EPA DOCKET NO. A-98-49, II-A4-88 

FINAL REPORT 

WASTE CHARACTERIZATION INSPECTION REPORT 

EPA BASELINE INSPECTION NO. LANL-CCP-05.06-8 

OF THE CENTRAL CHARACTERIZATION PROJECT 

WASTE CHARACTERIZATION PROGRAM 

AT THE LOS ALAMOS NATIONAL LABORATORY 

May 23–25, 2006 

WITH FOLLOW UP INSPECTIONS ON 

August 22, 2006 and 

March 6, 2007 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center of Federal Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

June 2007
i

TABLE OF CONTENTS 

Section Page

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

2.0 Purpose of Inspections ........................................................................................................ 7 

3.0 Purpose of This Report........................................................................................................ 8 

4.0 Scope of Inspection ............................................................................................................. 9 

5.0 Inspection-Related Definitions.......................................................................................... 10 

6.0 Personnel ........................................................................................................................... 10 

6.1 EPA Inspection Team............................................................................................ 10 

6.2 Personnel Contacted.............................................................................................. 11 

7.0 Performance of the Inspection........................................................................................... 12 

7.1 Site Background and History ................................................................................ 12 

7.2 Inspection Process Overview ................................................................................ 12 

8.0 Technical Waste Characterization Areas .......................................................................... 13 

8.1 Acceptable Knowledge and Load Management.................................................... 13 

8.2 Nondestructive Assay............................................................................................ 37 

8.3 Real-Time Radiography ........................................................................................ 56 

8.4 Visual Examination............................................................................................... 61 

8.5 Sealed-Source Visual Examination Technique..................................................... 67 

8.6 WIPP Waste Information System ......................................................................... 70 

9.0 Response to Comments ..................................................................................................... 73 

10.0 Summary of Results .......................................................................................................... 73 

10.1 Findings and Concerns.......................................................................................... 73 

10.2 Conclusions ........................................................................................................... 73 

11.0 References ......................................................................................................................... 78 
ii

ATTACHMENTS 

Attachment A.1 Acceptable Knowledge (AK) & Load Management Checklist 

Attachment A.2 Nondestructive Assay (NDA) Checklist, LANL HENC #1 

Attachment A.3 Nondestructive Assay (NDA) Checklist, LANL HENC #2 

Attachment A.4 Nondestructive Assay (NDA) Checklist, PTGS 

Attachment A.5 Real-Time Radiography (RTR) Checklist 

Attachment A.6 Visual Examination (VE) Checklist 

Attachment A.7 Visual Examination Technique (VET) for OSRP Checklist 

Attachment A.8 WIPP Waste Information System (WWIS) Checklist 

Attachment B.1 Replicate Testing Data for Container 52331, HENC #1 System 

Attachment B.2 Replicate Testing Results for Container 52331, HENC #1 System 

Attachment B.3 Replicate Testing Data for Container 52476, HENC #1 System 

Attachment B.4 Replicate Testing Results for Container 52476, HENC #1 System 

Attachment B.5 Replicate Testing Data for Container 53093, HENC #1 System 

Attachment B.6 Replicate Testing Results for Container 53093, HENC #1 System 

Attachment B.7 Replicate Testing Data for Container D52277, HENC #2 System 

Attachment B.8 Replicate Testing Results for Container D52277, HENC #2 System 

Attachment B.9 Replicate Testing Data for Container D53991, HENC #2 System 

Attachment B.10 Replicate Testing Results for Container D53991, HENC #2 System 

Attachment B.11 Replicate Testing Data for Container D55700, HENC #2 System 

Attachment B.12 Replicate Testing Results for Container D55700, HENC #2 System 

Attachment B.13 Replicate Testing Results for Container 52338, PTGS System 

Attachment B.14 Replicate Testing Data for Container 52338, PTGS System 

Attachment B.15 Replicate Testing Results for Container 53551, PTGS System 

Attachment B.16 Replicate Testing Data for Container 53551, PTGS System 

Attachment B.17 Replicate Testing Data for Container 54857, PTGS System 

Attachment B.18 Replicate Testing Results for Container 54857, PTGS System 

Attachment B.19 Replicate Testing Data for Container S817309, HENC #2 System 

Attachment B.20 Replicate Testing Results for Container S817309, HENC #2 System 

Attachment B.21 Replicate Testing Data for Container 61209, HENC #2 System 

Attachment B.22 Replicate Testing Results for Container 61209, HENC #2 System 

Attachment C.1 EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-AK-06-001CR

Attachment C.2 EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-AK-06-002C 

Attachment C.3 EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-AK-06-003CR 

Attachment C.4 EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-VE-06-004F, 

Revision 1 

Attachment C.5 EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-VE-06-005CR 

Attachment C.6 EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-VE-06-006CR 

Attachment C.7 EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-VE-06-007CR 

Attachment C.8 EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-RTR-06-008C 

Attachment D Public Comments and EPA’s Responses
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1.0 EXECUTIVE SUMMARY 

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

Agency) conducted Baseline Inspection No. LANL-CCP-05.06-8 of the Central Characterization 

Project (CCP) waste characterization (WC) program at the U.S. Department of Energy (DOE) 

Los Alamos National Laboratory (LANL) in Los Alamos, New Mexico. This inspection 

occurred on May 23–25, 2006, with a follow-up inspection of the visual examination (VE) 

process related to the sealed sources program on August 22, 2006. On March 6, 2007, EPA 

performed an on-site follow-up evaluation at LANL to verify the resolution of all open EPA 

issues. (See Sections 8.1 and 8.4 for the issues that were outstanding since the May 2006 

inspection). In accordance with the provisions of 40 CFR 194.8(b), as issued in a July 16, 2004, 

Federal Register (FR) notice (69 FR 42571–42583), EPA conducted a baseline inspection of the 

site’s program to characterize wastes proposed for disposal at the Waste Isolation Pilot Plant 

(WIPP). As a result of its baseline and follow-up inspections, EPA is approving the LANL-CCP 

contact handled (CH) waste characterization program based on a demonstration of the site’s 

capabilities, with conditions and limitations discussed in this report, in accordance with 40 CFR 

194.8(b). 

On April 18, 2007, EPA issued a Federal Register (FR) notice (72 FR 19494 - 19499, April 18, 

2007) announcing the proposed approval of the CH WC program implemented at LANL by 

CCP. The FR notice opened a 30-day comment period to solicit public comment on the 

proposed approval of LANL-CCP’s CH WC program and the LANL Baseline Inspection Report 

(EPA Air Docket A-98-49, II-A4-87). The comment period ended May 18, 2007 EPA received 

one set of public comments. (See EPA Docket ID Nos. EPA-HQ-OAR-2007-0326-0003 and 

EPA-HQ-OAR-2007-0326-0003.1). EPA evaluated and responded to the public comments (see 

Attachment D of this report), and made changes to the proposed approval decision, where 

appropriate. This report discusses EPA’s approval of the CH WC program implemented at 

LANL by CCP. 

EPA must verify compliance with 40 CFR 194.24 before waste may be disposed of at the WIPP, 

as specified in Condition 3 of the Agency’s certification of the WIPP’s compliance with disposal 

regulations for transuranic (TRU) radioactive waste (63 FR 27354, 27405, May 18, 1998). EPA 

previously evaluated and approved WC systems at LANL, most recently in April 2005 (EPA 

Docket No. A-98-49, II-A4-57). LANL received approval to dispose of debris (S5000), solids 

(S3000), and Offsite Sealed Source Recovery Program (OSRP)1

 wastes prior to this baseline 

inspection. The purpose of the LANL-CCP inspections was to evaluate the adequacy of the 

site’s WC programs for two TRU waste categories—debris and solids—to be disposed of at the 

WIPP; the debris included sealed sources from the OSRP. During the inspections, the Agency 

examined the following activities: 

• Acceptable knowledge (AK) and load management for contact-handled (CH) retrievablystored TRU debris waste (S5000) and solid waste (S3000) and AK for CH newlygenerated, repackaged debris waste from the OSRP 

• Visual examination (VE) as a quality control (QC) check of real-time radiography (RTR) 

and in lieu of RTR for CH retrievably-stored TRU debris waste (S5000) and solid waste 

 

1

 The OSRP is described in EPA Docket No. A-98-49, II-A4-57. 
2

(S3000) and Visual Examination Technique (VET) for CH newly-generated, repackaged 

debris waste from the OSRP 

• RTR for CH retrievably-stored TRU debris waste (S5000) and solid waste (S3000) 

• Nondestructive assay (NDA), specifically, three NDA systems—LANL HENC #1 and 

LANL HENC #2 for characterizing debris (S5000) and solid (S3000) waste, respectively, 

and the portable tomographic gamma scanner (PTGS) for characterizing debris waste 

(S5000)2

 only 

• WIPP Waste Information System (WWIS) for CH retrievably-stored TRU debris waste 

(S5000) and solid waste (S3000). 

The EPA inspection team identified one finding and seven concerns. The one finding in the area 

of VE and five of the concerns that required a response from DOE, while two concerns did not 

require a response. EPA Inspection Issue Tracking Forms (see Attachments C.1 through C.8 to 

this report) document the finding and seven concerns. Personnel from LANL, the Carlsbad Field 

Office (CBFO), and CCP provided information to resolve the finding and concerns to the EPA 

inspection team prior to the closeout of the onsite inspection and subsequent to the inspection. 

The information provided by CBFO addressed the one finding and the five concerns that 

required a response, as well as the two concerns that did not require a response. Between May 

2006 and March 2007, CCP provided satisfactory resolution addressing three concerns while one 

finding and three concerns remained unresolved. At a follow-up inspection on March 6, 2007, 

CCP discussed with the EPA inspection team their responses for the four outstanding issues that 

EPA evaluated for completeness and adequacy, and concluded that each had been resolved 

satisfactorily. EPA considers the one finding and all concerns to be resolved, and there are no 

open issues resulting from this inspection. 

The EPA inspection team determined that the LANL-CCP CH WC program activities were 

technically adequate. EPA is approving the LANL-CCP CH WC program in the configuration 

observed during this inspection and described in this report and the attached checklists 

(Attachments A.1 through A.8). This approval includes the following: 

(1) The AK and load management process for CH retrievably-stored TRU debris and solid 

wastes and for newly-generated debris wastes from the OSRP 

(2) The LANL HENC #1 and LANL HENC #2 NDA systems for assaying CH solid and debris 

wastes 

(3) The PTGS NDA system for assaying CH debris waste 

(4) VE as a QC check of the RTR process3

 and in lieu of the RTR process for retrievablystored solid and debris wastes and VET of newly-generated debris wastes from the OSRP 

(5) The nondestructive examination process of RTR for CH retrievably-stored solid and debris 

wastes 

 

2

 NDA systems are typically not matrix-specific in the same manner as other characterization techniques and 

their approval is not tied to specific waste matrix categories (i.e., S3000 or S5000). Specifically, virtually any 

material within the system’s matrix calibration range may be assayed. 

 

3

 However DOE is not required to maintain the ability to perform VE as a QC check of RTR (see EPA letter of 

December 6, 2006). 
3

(6) The WWIS process for tracking of waste contents of solid and debris wastes, including 

debris from the OSRP 

LANL-CCP must report and receive EPA approval of any Tier 1 (T1) changes to the LANLCCP WC activities from the date of the baseline inspection, and must notify EPA regarding 

Tier 2 (T2) changes according to Table 1, below. It is worth noting that Table 1 in this report is 

not identical to those included in previous baseline inspection reports and EPA site approval 

letters in several ways. The most important of these involve presentation of the T2 elements. 

In previous reports there were two T2 columns that have been merged into a single T2 column 

for LANL-CCP. The T2 column entries have also been modified to better reflect the 

40 CFR 194.24(h) requirements. When T2 changes are made the site must notify EPA of the 

changes and provide a brief description of the specific T2 changes, whereas the tiering tables in 

the previous inspection reports stated that the site must actually provide the information specific 

T2 elements (document or procedure revisions, etc.). This notification with summary of each T2 

change is similar to the tiering tables used in EPA reports for sites characterizing remote-handled 

TRU waste. Additionally, there are other minor word changes to the table for the sake of 

legibility. 

The 40 CFR 194.8 regulatory changes gave EPA flexibility whereby EPA now is able to evaluate 

targeted WC program items (namely T1 and T2 changes) based on submission of T1 and T2 

information. This allows EPA to be well informed about changes at the sites on a regular basis. 

The slight variation in tiers among the sites reflects EPA’s site inspection experience and site 

specific conditions where inspectors are able to compare what they observed at the previouslyapproved CCP sites verses what they notice as they evaluate sites for approval. 

There are changes to specific WC areas as well. For AK, the AK Reassessment Memoranda 

(reflecting resolution to concern LANL-CCP-AK-06-001CR) and the AK-VE Memoranda 

related to VE cited under T2 changes (reflecting resolution to finding LANL-CCP-VE-06-004F) 

and do not appear in the tiering tables in previous baseline inspection reports. The reason being 

that each provides different type of information. For example, the reassessment memoranda 

address differences in information put together using historical information versus actual 

characaterization data from NDA and NDE. The AK-VE memorandum documents the selection 

of VE for non-debris waste. Using AK information, site personnel determine the appropriate 

NDE technique for a waste stream. Because this document begins with the AK information, it 

resides under the AK section in the tiering table. 

Similarly, requesting revisions to CCP-AK-008 or notification regarding the combination of 

waste streams that were distinct at the time of inspection are specific to the LANL OSRP or the 

result of information identified during this inspection. Accordingly, these are absent from the 

tiering tables in previous baseline inspection reports. For WWIS, changes to specific process 

elements (e.g., spreadsheets and data fields) are cited as T2 changes and these did not appear in 

previous tiering tables. These were added to provide a greater degree of specificity in an attempt 

to identify and focus on the key elements relevant to waste isolation. 

The ***footnote in Table 1 specifies that substantive changes means changes with the potential 

to impact the site’s waste characterization activities under 40 CFR 194.24 or documentation 

thereof, excluding changes that are solely related to Environmental Safety &Health (ES&H), 

nuclear safety, the Resource Conservation and Recovery Act (RCRA) or editorial in nature.
4

EPA will notify the public of the results of its evaluations of T1 and T2 changes through postings 

to the EPA Web site and by sending e-mails to the WIPPNEWS list (see Section 2.0 of this 

report for a brief discussion of tiering). All T1 changes must be submitted for evaluation and 

approval by EPA before their implementation. Upon approval, EPA will post the results of the 

evaluations through the EPA Web site and the WIPPNEWS list, as described above. Upon 

completion of its review of the T2 changes submitted at the end of each fiscal year quarter, EPA 

will post the T2 changes. EPA expects the first report of LANL-CCP’s T2 changes at the end of 

the fourth quarter FY2007. Consistent with EPA’s authority under 194.24(h), EPA may request 

information relative to these changes if EPA deems the information is necessary to ensure 

continued compliance with EPA regulations. 

The scope of the site baseline compliance decision is based on EPA’s inspections completed on 

May 25, 2006, and August 22, 2006, and the follow-up evaluation conducted on March 6, 2007.
5

Table 1. Tiering of TRU WC Processes Implemented by LANL-CCP 

Based on May 23–25, 2006 On Site Baseline Inspection, August 22, 2006 OSRP Inspection and March 6, 

WC Process Elements LANL-CCP WC T1 Changes LANL-CCP WC T2 

Acceptable Knowledge (AK) and Load Management 

Any new waste category, or new OSRP wastes addressed in AK Summaries separate from CCP-AK-008; AK (3), AK (6), AK (16) and (AK) 17 Implementation of Load Management for waste streams other than AK-009; AK (5) 

Notification to EPA upon completion of AK A

Notification to EPA upon completion of updat

modifications*** of the following: - AK Reassessment Memoranda and co

were distinct at the time of this inspec

- AK-VE Memoranda related to VE an

- AK-NDA Memoranda; AK (2 and 3) - AK Accuracy Reports; AK (2) - Site procedures requiring CBFO appr- AK Summary CCP-AK-008, if chang

and/or following the addition of new 

- Change Notices used to modify and u

to waste stream(s) within an approved 

Nondestructive Assay (NDA) New equipment or physical modifications to approved 

equipment**; NDA (1-1, 2-1, 3-1) Extension or changes to approved calibration range for 

approved equipment; NDA (1-2, 2-2, 3-2) 

Notification to EPA upon completion of chang

equipment, operating range(s) and site procedu

NDA (1-2, 2-2, 3-2) 

Real-Time Radiography (RTR) N/A Notification to EPA upon the following: - Implementation of new equipment or 

approved equipment; RTR (1) - Completion of changes to site proced

RTR (2) 

Visual Examination (VE) and Visual Examination Technique (VET), including OSRP Wastes (Sealed Source VET or SSVET) 

N/A Notification to EPA upon the following: - Completion of changes to site VE and 

approvals, including OSRP VET proc

WIPP Waste Information System (WWIS) 

N/A Notification to EPA upon the following: - Completion of changes to WWIS pro

approvals; WWIS (1) and WWIS (2) - Changes to the Excel spreadsheet, W

characterization and certification*** WWIS (1) and WWIS (2)

 * Upon receiving EPA approval, LANL-CCP will report all T2 changes to EPA at the end of each fiscal year quarter. 

 ** Modifications to approved equipment include all changes with the potential to affect NDA data relative to waste isolation and exclude minor 

of safety-related equipment. 
6

***Substantive changes means changes with the potential to impact the site’s waste characterization activities or documentation thereof, excludin

related to Environmental Safety & Health (ES&H), nuclear safety, the Resource Conservation and Recovery Act (RCRA) or are editorial in natur
7

2.0 PURPOSE OF INSPECTIONS 

On May 18, 1998, the U.S. Environmental Protection Agency (EPA or the Agency) certified that 

the Waste Isolation Pilot Plant (WIPP) will comply with the radioactive waste disposal 

regulations at 40 CFR Part 191. In this certification, EPA also included Condition 3, which 

states that “the Secretary shall not allow shipment of any waste from...any waste generator site 

other than LANL [Los Alamos National Laboratory] for disposal at the WIPP until the Agency 

has approved the processes for characterizing those waste streams for shipment using the process 

set forth in §194.8.” The approval process described at 40 CFR 194.8 requires the U.S. 

Department of Energy (DOE) to (1) provide EPA with information on acceptable knowledge 

(AK)4

 for waste streams proposed for disposal at the WIPP, and (2) implement a system of 

controls used to confirm that the total amount of each waste component that will be emplaced in 

the WIPP will not exceed limits identified in the WIPP Compliance Certification Application 

(DOE/CAO 1996-2184, 40 CFR Part 191, Compliance Certification Application for the Waste 

Isolation Pilot Plant, 1996). 

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, FR notice, EPA must 

perform a single baseline inspection of a TRU waste generator site’s WC program. The purpose 

of the baseline inspection is to approve the site’s WC program based on a demonstration that the 

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

TRU wastes and comply with the regulatory requirements imposed on TRU wastes destined for 

disposal at the WIPP. An EPA team conducts an onsite inspection to verify that the site’s system 

of controls is technically adequate and properly implemented. Specifically, the EPA inspection 

team verifies compliance with 40 CFR 194.24I(4), which states the following: 

Any compliance application shall: . . . Provide information which demonstrates 

that a system of controls has been and will continue to be implemented to confirm 

that the total amount of each waste component that will be emplaced in the 

disposal system will not exceed the upper limiting value or fall below the lower 

limiting value described in the introductory text of paragraph I of this section.5

 

The system of controls shall include, but shall not be limited to: measurement; 

sampling; chain of custody records; record keeping systems; waste loading 

schemes used; and other documentation. 

In other words, the purpose of the baseline inspection is to assess whether DOE sites that 

characterize TRU waste prior to disposal at the WIPP are capable of characterizing and tracking 

the waste in such a manner that EPA is confident that the waste will not exceed the approved 

limits. Before proposing the approval of CCP WC systems and processes at LANL, EPA 

evaluated the capabilities of systems and processes to (1) identify and measure waste 

 

4

 As of the Federal Register notice of July 16, 2004 (69 FR 42571–42583), EPA has replaced the term “process 

knowledge” with “acceptable knowledge.” Acceptable knowledge refers to any information about the process used 

to generate waste, material inputs to the process, and the time period during which the wastes were generated, as 

well as data resulting from the analysis of waste conducted prior to or separate from the waste certification process 

authorized by an EPA certification decision to show compliance with Condition 3 of the certification decision. 

5

 The introductory text of 40 CFR 194.24(c) states, “For each waste component identified and assessed pursuant 

to [40 CFR 194.24(b)], the Department shall specify the limiting value (expressed as an upper or lower limit of 

mass, volume, curies, concentration, etc.), and the associated uncertainty (i.e., margin of error) for each limiting 

value, of the total inventory of such waste proposed for disposal in the disposal system.” 
8

components (such as plutonium) that must be tracked for compliance,6 and (2) confirm that the 

waste in any given container has been properly identified as belonging to the group of approved 

waste streams. 

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

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

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

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

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

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

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

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

inspection or approval under 40 CFR 194.24. EPA will accomplish this by assigning a tier level 

to each aspect of the characterization program. T1 activities have more stringent reporting 

requirements and require DOE to notify EPA and receive the Agency’s approval prior to 

implementing the change. DOE will report T2 activities to EPA based on the frequency 

established in the inspection report. DOE may choose to characterize and dispose of materials at 

its own risk while EPA considers the proposed T2 changes. If LANL-CCP contemplates a 

change that is not identified in this report, EPA recommends that the site, in consultation with the 

Carlsbad Field Office (CBFO), discuss the nature of the change with EPA. This would minimize 

the possibility of EPA not approving the site-assigned tiers. The rule applying to this baseline 

inspection can be found in the FR (Vol. 69, No. 136, pp. 42571–42583, July 16, 2004). 

3.0 PURPOSE OF THIS REPORT 

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

Baseline Inspection No. LANL-CCP-05.06-8 in terms of findings and concerns. Specifically, 

this report does the following: 

• Describes the characterization systems approved during the inspection 

• Provides objective evidence of the approval basis for all WC systems 

• Identifies all relevant system limitations and/or conditions for each WC system 

• Identifies the applicable T1 and T2 elements 

• Provides objective evidence of outstanding findings or concerns in the form of 

documentation, as applicable 

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

their relevance to EPA’s approval decision 

 

6 The potential contents of a waste stream or group of waste streams determine which processes can adequately 

characterize the waste. For example, if AK information suggests that the waste form is heterogeneous, the site 

should select a nondestructive assay (NDA) technique that suits such waste to ensure adequate measurements. 

Radiography and visual examination (VE) help both to confirm and quantify waste components, such as cellulosics, 

rubbers, plastics, and metals. Once the nature of the waste has been confirmed, the assay techniques then quantify 

selected radionuclides in the waste. In some cases, a TRU waste generator site may be able to characterize a wide 

range of heterogeneous waste streams or only a few. A site’s stated limits on the applicability of proposed WC 

processes govern EPA’s inspection scope.
9

The completed checklists (Attachments A.1 through A.7 to this report) reference the documents 

that the EPA inspection team reviewed in support of the technical determination. To see or 

obtain copies of any items identified in the attached checklists, write to the following address: 

Quality Assurance Manager 

USDOE/Carlsbad Field Office 

P.O. Box 3090 

Carlsbad, NM 88221 

EPA’s final approval decision on the LANL-CCP WC program is conveyed to DOE separately 

by letter. More information is also on EPA’s Web site at 

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

4.0 SCOPE OF INSPECTION 

The scope of EPA Baseline Inspection No. LANL-CCP-05.06-8 included the technical adequacy 

of the WC systems in use at LANL-CCP to characterize TRU wastes. The EPA inspection team 

evaluated these systems with respect to their ability to perform the following functions: 

• Identify and quantify the activities of the 10 WIPP-tracked radionuclides (241Am, 137Cs, 

238Pu, 239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U, and 238U) using a combination of AK and NDA 

systems 

• Assign waste material parameters (WMPs) correctly using real-time radiography (RTR) 

and VE for contact-handled (CH) retrievably-stored solid and debris waste, and visual 

examination technique (VET) for newly-generated debris wastes from the OSRP 

• Perform effective waste information (data) transfer using the WIPP Waste Information 

System (WWIS) 

Specifically, these systems consisted of the following components: 

• AK and load management processes that support retrievably-stored S3000 solid and 

S5000 debris wastes, and OSRP (sealed sources) newly generated S5000 wastes. 

• Two NDA systems—LANL High-Efficiency Neutron Counter (HENC) #1 and LANL 

HENC #2, as described in the attachments to this report—for the analysis of CH 

retrievably-stored S3000 solid and S5000 debris wastes, and one NDA system—portable 

tomographic gamma scanner (PTGS), as described in the attachments to this report—for 

the analysis of CH retrievably-stored S5000 debris wastes 

• VE as a quality control (QC) check of RTR and in lieu of RTR for retrievably-stored 

S3000 solid wastes and S5000 debris wastes 

• VET of newly-generated S5000 debris waste from the OSRP 

• RTR for retrievably-stored S5000 debris and S3000 solid wastes 

• The WWIS for the purpose of data transfer for waste containers of all waste matrices 

destined for WIPP emplacement 
10

During an inspection, EPA does not approve characterization data; that function is the sole 

responsibility of the site being evaluated—in this case, LANL-CCP. EPA evaluated the site’s 

WC processes to characterize CH retrievably-stored debris and newly-generated debris wastes. 

The evaluation consisted of interviewing personnel, observing equipment operations that 

comport with the site procedures, and inspecting records related to each of the WC processes 

within the inspection’s scope. An important aspect of this evaluation was the objective evidence 

documenting the effectiveness of the WC processes. Objective evidence typically takes the form 

of batch data reports (BDRs); Radioassay Data Sheets; AK accuracy reports; VE and RTR tapes; 

VET records from two-person examinations; and, WWIS printouts for specific TRU containers. 

During this inspection, EPA selected samples of each of these items, based on the number and 

variety of items each WC process produced, consistent with standard auditing techniques. For 

example, the sample of NDA BDRs that EPA inspectors evaluated to verify compliance included 

a contribution from all three operating systems, were representative of all pertinent waste 

matrices and spanned each system’s operating range to the extent possible. Based on the 

evaluation of the WC processes in conjunction with the sample of objective evidence, EPA 

determined the technical adequacy of the WC processes within the inspection’s scope. 

5.0 INSPECTION-RELATED DEFINITIONS 

During an inspection, EPA inspectors may encounter items or activities that require further 

inquiry for their potential to adversely affect WC and/or isolation within the repository. The two 

main categories relevant to WC inspections are identified below: 

Finding: A determination that a specific item or activity does not conform to 

40 CFR 194.24I(4). A finding requires a response from CBFO. 

Concern: A judgment that a specific item or activity may or may not have a negative effect on 

compliance and, depending on the magnitude of the issue, may or may not require a 

response. 

Note that DOE does not need to address concerns not requiring a response prior to program 

approval. However, EPA recommends that when DOE accepts the site’s response to an EPA 

concern, it should inform EPA at the same time that the site implements the corresponding 

corrective action. This process is similar to what is used for a T2 issue. 

6.0 PERSONNEL 

6.1 EPA Inspection Team 

Table 2 identifies the members of the EPA WC inspection team. 

Table 2. EPA Inspection Team Members 

Inspection Team Member Position Affiliation

Ed Feltcorn Inspection Team Leader U.S. EPA ORIA 

Rajani Joglekar Inspector U.S. EPA ORIA 

Connie Walker Inspector S. Cohen & Associates, Inc.

Dorothy Gill Inspector S. Cohen & Associates, Inc. 

Patrick Kelly Inspector S. Cohen & Associates, Inc.
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6.2 Personnel Contacted 

EPA and its support personnel conducted interviews with LANL-CCP personnel in several 

disciplines. The personnel contacted represented only a sample of the CH TRU WC staff, and 

they are listed in the Table 3, along with their affiliations and areas of expertise. 

Table 3. Personnel Contacted During Inspection

Personnel Affiliation Area of Expertise/Function 

Mark Pearcy CCP AK – SPM, WWIS – SPM 

Steve Schafer CCP AK – AKE 

Julia Whitworth CCP AK – AKE 

Kevin Peters CCP AK – AKE 

Randy Fitzgerald CCP AK – SPQAO 

David Dreher CCP NDA – HENC 

Joe Wachter MCS NDA – PTGS 

Joe Harvill WTS/CCP NDA – HENC 

John Veilleux LANL NDA – HENC 

Harald Poths LANL NDA – PTGS/FRAM 

Doug Cramer MCS NDA – PTGS 

Sean Stanfield MCS NDA – HENC 

Willie Salazar LANL NDA – PTGS/FRAM 

Colleen Monk CCP 

RTR – ITS/TS/FQAO & 

Operator 

William Mussman CCP 

RTR – SME/OJT, 

Operator/ITR/TS/FQAO 

Steve Ewing CCP 

VE – SME/OJT, 

Operator/ITR/TS/FQAO 

M. Romero LANL 

VE – SME/OJT, 

Operator/ITR/TS/FQAO 

J. Lopez LANL VE – Operator/ITR/TS/FQAO 

Ricky Baros LANL VE – VEE 

Genevieve Fernandez LANL VE – VEE 

Israel Aragon CCP 

VE – SME/OJT, 

Operator/ITR/TS/FQAO 

Buddy Fussell CCP VE & RTR – VPM 

Sue Peterman CCP VE & RTR – SPM 

Davis Christenson LANL VE – Operator 

John Guadagnoli CCP VE – Operator 

J.R. Stroble CCP WWIS – WCO 

Larry Porter CCP Program Manager 

Courtland Fesmire CBFO Observer 

Charlie Riggs 

CBFO QA 

Contractor (CTAC) Observer 

Annabelle Axinn 

CBFO QA 

Contractor (CTAC) Observer 
12

During the baseline inspection, LANL-CCP provided a list of TRU WC personnel from which 

EPA selected a few individuals to be interviewed. The EPA inspectors reviewed the 

qualifications (including WC experience) and training records of these individuals to assess their 

WC capabilities. Based on this evaluation, EPA determined that LANL-CCP WC personnel 

responsible for characterizing TRU waste and certifying it as TRU waste were qualified and had 

received adequate training to perform their assigned function. When personnel changes occur, 

EPA may request qualification and training records of any new individuals identified as key WC 

personnel. EPA will review these records and may interview the personnel to determine their 

ability to produce quality data. This personnel qualification evaluation and review of training 

records is similar to the EPA’s evaluation during each inspection. 

7.0 PERFORMANCE OF THE INSPECTION 

7.1 Site Background and History 

LANL is located approximately 25 miles northwest of Santa Fe, New Mexico, and encompasses 

an area of 43 square miles. The primary mission of LANL since its creation in the 1940s has 

been nuclear weapons research and development. Its current mission supports civilian defense 

and includes large waste management and stockpile stewardship components. In 1998, LANL 

was the first DOE site authorized by EPA to ship waste to the WIPP. In 2003, CCP assumed 

responsibilities for CH TRU waste certification activities at the site, and the purpose of this 

inspection was to determine if the CCP WC program complies with 40 CFR 194.24. 

7.2 Inspection Process Overview 

EPA Baseline Inspection No. LANL-CCP-05.06-8 took place on May 23–25, 2006. EPA 

conducted two follow-up inspections on August 22, 2006, and March 6, 2007. The purpose of 

the August 2006 follow-up inspection was to evaluate the use of VE for sealed sources under the 

OSRP. During the March 2007 evaluation, EPA inspectors formalized the results of previous 

discussion with CBFO and CCP personnel regarding open issues from the initial LANL 

inspection in 2006. EPA inspectors also verified changes made to the HENC #2 NDA system 

between May 2006 and March 2007, and evaluated the system’s performance history over that 

time, including the evaluation of replicate analyses for two waste containers measured on the 

HENC #2. EPA performed the inspection in accordance with the scope described in Section 4.0 

of this report and for the purpose of determining the site’s compliance with 40 CFR 194.24. The 

inspection involved the following steps: 

(1) Preparing draft checklists specific to each technical area before the inspection 

(2) Reviewing the results of EPA’s and CBFO’s previous inspections and audits of the 

LANL-CCP WC program, including findings and concerns previously identified by EPA 

and/or CBFO and corrective actions 

(3) Obtaining and reviewing site procedures, reports, and other technical information related 

to WC activities at LANL-CCP in advance of the inspection 

(4) Interacting with CBFO and LANL-CCP personnel to arrange inspection logistics 
13

(5) Verifying onsite the technical adequacy or qualifications of WC personnel, procedures, 

processes, and equipment by means of interviews, observation, and demonstrations, and 

recording the results on checklists 

(6) Recording all concerns on EPA Inspection Issue Tracking Forms and providing 

completed forms to CBFO and site personnel as they were generated 

(7) Communicating all pertinent information to CBFO and LANL-CCP personnel onsite, as 

appropriate 

(8) Pursuing resolution of all identified issues before completion of the inspection by 

discussions with CBFO and LANL-CCP personnel 

(9) Conducting entrance, exit, and daily briefings for CBFO and LANL-CCP management 

personnel, as appropriate 

8.0 TECHNICAL WASTE CHARACTERIZATION AREAS 

Sections 8.1 through 8.6 of this report detail the four technical areas assessed during this 

inspection—AK and load management; NDA; nondestructive examination, consisting of RTR, 

VE and VET; and, the WWIS. 

8.1 Acceptable Knowledge and Load Management 

EPA examined the AK process and load management and associated information to determine 

whether LANL-CCP demonstrated compliance with 40 CFR 194.8 requirements for CH 

retrievably-stored solid and debris wastes and newly-generated OSRP debris wastes. 

WC Element Description 

As part of the inspection, EPA reviewed the following elements of the AK process: 

• Overall procedural technical sufficiency and scope and ability to follow the AK WC 

process for containers and waste stream 

• Waste-generating procedures, processes, and documentation 

• Characterization of required waste material parameters (WMPs) and radionuclides 

• AK information assembly and compilation 

• AK confirmation and associated discrepancy resolution 

• Sufficiency of AK characterization results 

• Assembly of required information and use of supplemental information 

• AK summary preparation 

• Reassignment of waste stream due to AK and discrepancy analysis 

• AK accuracy 

• Load management 
14

Attachment A.1 to this report identifies objective evidence reviewed by the EPA inspection 

team. AK provides information on several aspects of TRU wastes at LANL-CCP, including but 

not limited to the following: 

• Defense waste status 

• Material parameters 

• Waste stream 

• Radionuclide composition 

• Waste matrix codes (WMCs) 

Documents Reviewed

During the inspection, EPA inspectors examined or accepted a variety of procedures and 

documents related to AK. Documents were provided as paper copies and in electronic format. 

The list of all documents reviewed is considerable. The list of general documents provided as 

paper copies is presented first, and most of these were provided as paper copies. These are 

followed by documents that were provided in conjunction with specific AK reports, i.e., AK-004, 

AK-006, AK-008 and AK-009, most of which were provided in electronic (PDF) format. 

General Reference Documents

• NCR-LANL-0537-05, Revision 0, BDR LA04-HGSAS-LS-012, Drum S845363, 

Unvented Rigid Liners, July 18, 2005 

• E-mail from Dean Mooney to Sheila Pearcy, RE: NCR-LANL-0005-06, Waste Stream 

Identification Summary Layers of Confinement, May 10, 2006 

• LANL-007 NDA memorandum from Steve Shafer to CCP Central Records, Revision 1, 

Evaluation of the Radiological Characterization of LANL Waste Stream LA-MHD02.01, 

March 2, 2006 

• Interoffice Correspondence, from C. Simmons to CCP Records, RE: Transmittal of 

Characterization Information Summary for Lot 17 LA-MIN03-NC.001 Waste Stream 

[LANL-004], March 8, 2006 

• Interoffice Correspondence from M. Pearcy to CCP Records, Transmittal of Solids 

Summary Report for Lot 1 LA-MIN03-NC-001 [LANL-007], August 1, 2005 

• Interoffice Correspondence from C. Simmons to CCP Records [LANL-004], March 8, 

2006 

• NCR-LANL-0742-06, Nonconformance Report (NCR), Container S845150 and CBR 

LA-RTR2-06-0063, Residual Liquids in Containers, February 23, 2006 

• NCR-LANL-0803-05, LA-RTR2-05-0190, Sealed Containers with Greater Than 4 Liters 

of Liquid, November 15, 2005 

• Los Alamos Radioactive Solid Waste Disposal Record for Container S850312 (solid), 

March 18, 1985 

• AK Accuracy Report, LANL Waste Stream LA-MHD01.01, Lots 1-26 (LANL-06), 

December 20, 2005 
15

• CCP AK Confirmation Checklist, LANL LA-MIN03-NC.001, Homogenous Solid 

[LANL-04], January 25, 2006 

• Project Tracking System (PTS)/Container Tracking System (CTS) Printouts for 

Containers S831785, S870375, S814218, S814218 (PTS only), printed May 18, 2006 

• AK Accuracy Report, LANL Waste Stream LA-MIN03-NC.001, Lots 1–15 [LANL004], March 27, 2006 

• Set of Freeze Changes to LANL-004, -007, and –009 based on March 15–18 EPA 

inspection 

• Waste Stream Profile Forms (WSPFs) for Waste Streams LA-MHD01.001, LA-MIN03-

NC.001, LA-OS-00-01.001, LA-MHD02.001 [LANL –004, -008, -007]; note that only 

LANL-007 was actually included, May 11, 2006 

• CCP-AK-LANL-008, Revision 3, Central Characterization Project Acceptable 

Knowledge Summary Report for Los Alamos National Laboratory Off-Site Source 

Recovery Project Sealed Sources, September 22, 2005

• CCP-AK-LANL-009 AK/NDA Memorandum, Revision 0, Evaluation of the 

Radiological Characterization for LANL Waste Stream LA-MHD03.001, April 20, 2006 

• CCP-AK-LANL-009, Central Characterization Project Acceptable Knowledge Summary 

Report for Los Alamos National Laboratory, Chemistry and Metallurgy Research (CMR) 

Facility, March 9, 2006 

• CCP-AK-LANL-004, Central Characterization Project Acceptable Knowledge Summary 

Report for Los Alamos National Laboratory, TA-5- Radioactive Liquid Waste Treatment 

Facility Homogenous Inorganic Non-Cemented Waste, March 9, 2006 

• AK Accuracy Report, LANL Waste Stream LA-0S-00-01, Lots 1–5 

• CCP-TP-005, Revision 16, CCP Acceptable Knowledge Documentation, April 2006 

• DR003, RCRA EPA Hazardous Waste Code Assignment Discrepancy Report for LAMHD02.001, LANL-007, April 27, 2006 

• LANL Radioactive Solid Waste Disposal Record Form, S831785, July 14, 1983 

• LA-MHD02.001, DR002, Radiological Discrepancy Report, RE: Variation in MT 83, 

February 27, 2006 

• CCP-TP-005, Attachment 5, Hazardous Constituents, CMR Debris Waste Stream LAMHD03.001, May 18, 2006 

• CCP-T-005, Attachment 7, Radionuclides, LA-MHD02.001, Mixed 238Pu Heterogeneous 

Debris, Including the NDA-AK Memorandum, April 12, 2005 

• CCP-AK-LANL-007, Revision 2, Los Alamos National Laboratory 238Pu Contaminated 

Mixed Heterogeneous Debris, Waste Stream LA-MHD02.001, April 13, 2006 

• CCP-AK-LANL-007, Attachment 2, CCP Records Transmittal Form C041, Detailed 

238Pu Operations Process Flow Diagrams, May 10, 2006 

• LA-MHD02.001, CCP AK Confirmation Checklist, 238Pu Contaminated Mixed 

Heterogeneous Debris, Lot Evaluation—Lot 01, April 3, 2006 
16

• NDA-AK Memorandum for LANL-004, included in CCP-TP-005, Attachment 7, 

Radionuclides, LA-MIN03-NC.001, R0, TA-50 Homogenous Solids, Non-Cemented, 

April 29, 2004 

• TRU Waste Defense Determination Approval Form for Waste Stream LA-OS-NA-02, 

241Americium, 238Plutonium, and 239Plutonium Originally Contained in DOE Sources 

That Were Recovered from a Foreign Country, February 17, 2006 

• TRU Waste Defense Determination Approval Form for Waste Stream LA-OS-NA-03, 

241Americium and 238Plutonium Sealed Sources Managed as Waste from DOE Sites, 

February 17, 2006 

• TRU Waste Defense Determination Approval Form for Waste Stream lA-OS-NA-01, 

241Americium and 238Plutonium Sealed Sources Recovered Domestically Containing 

Radioactive Material Originating from the DOE’s Weapons Program, February 17, 2006 

• Interoffice Correspondence from J.R. Franco to D.H. Haar, Transmittal of Management 

Assessment Report MA-CCP-0002-05, Maintenance of Acceptable Knowledge Data, 

July 20, 2005 

• NCR-LANL-0516-06, The Results of NDA Data Does Not Agree with AK with Regard 

to Isotopic Ratios, Waste Stream [stream unclear] 

• LANL Radioactive Solid Waste Disposal Record Form, S850419, February 12, 1985 

• LANL Radioactive Solid Waste Disposal Record Form, S854813, October 10, 1985 

• LANL Radioactive Solid Waste Disposal Record Form, S831784, July 14, 1983 

• LANL Radioactive Solid Waste Disposal Record Form, S834116, August 24, 1983 

Additional AK-004 Documents: TA-50 Homogenous Inorganic Solids

• CCP-TP-005, Attachments 1, 4, 5, 6, 7, 8, and 10 

• SWDS Form for container 14218 

• C007, Memorandum to J. Bratton re: Upgrading of Industrial Liquid Waste Treatment 

Plants, LASL, H. Roser, RLWT-11, April 20, 1978 

• C013, Memorandum to B. Garcia re: Re-characterization of Wastewater Treatment 

Sludge in Storage at Technical Area (TA) 54 – Request for Removal from Federal 

Facility Compliance Order (FFCO), J. Plum and M. Devaurs, January 12, 1996 

• C018, RCRA Evaluation, Steve Schafer, April 14, 2004 

• C028, Memorandum to P. Rogers re: Secondary Radionuclides and Toxic Metals in TA55 TRU Waste, C. Foxx, A. Montoya, NMT-7-WM/EC-97-156, TWCP-882, September 

5, 1997 

• C009, Memorandum to B. Jorgensen re: RCRA Metals in Filtered TA-50 Wastewaters, 

K. Bower, December 15, 1992 

• C017, Outstanding Questions on Vacuum Filter Sludge Waste, Julia Whitworth, 

November 13, 2003 
17

• C019, Radiological Evaluation, J. Whitworth, November 2003 

• C061, Interview with J. Foxx, TWCP-3547, Cl-25, September 23, 1999 

• D001, Process Acceptable Knowledge Report for Special Processing at TA-55, J. 

Musgrave, TWCP-AK-2.1-007, Revision 2, May 18, 2002

• D005, Los Alamos National Laboratory TA-50/21/63 Waste Management Operations 

Safety Analysis Report, TA-50 Radioactive Liquid Waste Treatment Facility 

• D025, Future Radioactive Liquid Waste Streams Study, Alfredo Rey, LA-12667-MS, 

November 1993 

• D033, A Survey of the Liquid Waste Discharge of NPDES Regulated Chemical Species 

in the Acid/Rad Lines of the CMR Building (TA-3, SM29), Robert Fuehrer, October 15, 

1993 

• D039, Waste Water Stream Characterization for TA-59, Santa Fe Engineering, Ltd., 

February 1994 and September 1992 

• D041, Wastewater Stream Characterization for TA-3-16, 65, 130, 208, 316, 477, 550, 

1228, 1229, 1522, 1538, 1612, 1730, 1731, 1734, 1762, 1898, 1944, 1945, 1946, 1949, 

2003, 2004, 2005, 2006, 2007, 2008, 2009, 2010, 2062, 2130, 2143, 2164, Santa Fe 

Engineering, Ltd., February 1994 through July 1992 

• D050, Decontamination and Size Reduction of Plutonium Contaminated Process Exhaust 

Ductwork and Gloveboxes, P. LaFrate et al, LA-UR-97-254, November 15, 1996 

• D054, Work Plan for Mortandad Canyon, ER Project LA-UR-97-3291, September 1997 

• D056, Los Alamos Transuranic Waste Size Reduction Facility, J. Harper and J. Warren, 

LA-UR-87-1916, 1987 

• D074, Final TRU Waste Inventory Work-Off Plan, J. Warren and A. Dross, LAR862932, Revised December 15, 1986, original date August 1986 

• D082, Final Safety Analysis Report for TA-55 NMTD, Gordon, TWCP-415, July 13, 

1995 

• D089, Wastes from Plutonium Conversion and Scrap Recovery Operations, LA-11069-

MS, TWCP-352, March 1988 

• D078, Acceptable Knowledge Information Summary for LANL Transuranic Waste 

Streams, AK-00-019, Revision 1, September 22, 2003 

• D051, Safety Assessment for TA-48 Radiochemical Operations, H&R Technical 

Associates, Inc., LA-SUB-95-225, August 1994 

• D044, Wastewater Stream Characterization for TA-3-39, 42, 102, 128, 149, 164, 356, 

357, 409, 422, 497, 531, 542, 551, 1635, 1636, 1814, 1847, 1994, 1995, 2012, 2029, 

2134, 2135, 2140, and 2141, Santa Fe Engineering, Ltd., March 1994-April 1993 

• D040, Wastewater Stream Characterization for TA-2-1, 4, 21, 27, 36, 44, 46, 49, 50, 51, 

57, 63, 69, and 70, Santa Fe Engineering, Ltd., May 1993 

• D035, Wastewater Stream Characterization for TA 3-29, 154, 503, 1196, 1610, 1614, 

1615, Santa Fe Engineering, Ltd., March 1994-October 1992 
18

• D029, Work Release #24, Study of Alternatives for Radioactive Wastewater Treatment 

Sludges, Ralph M. Parsons Company, August 1993 

• D018, Waste Management Site Plan, LA-UR-80-2836, October 1980 

• D006, Environmental Information Document, Radioactive Liquid Waste Treatment 

Facility, ICF Kaiser Engineers and ESH-8, Revision 0, February 27, 1994 

• D004, AK Summary Report for Waste Stream TA-50-19, Vacuum Filter Cake, S. 

Kosiewicz, LA-UR-02-6472, Draft, October 4, 2002 

• DR002, Discrepancy Resolution – Radiological Characterization, J. Whitworth, April 15, 

2004 

• DR004, Acceptable Knowledge Source Document Discrepancy Resolution – Debris 

Waste in Containers S841419 (LANL-0130-05), S825085 (LANL-0747-05), and 

S817006 (LANL-0822-05), Randy Fitzgerald, May 1, 2006 

• M007, Attachments Related to TA-50, Building 1, August 1994 

• M018, Spreadsheet Area G Rad Values from Opp, TWCP, October 6, 2003 

• M117, Annual/Monthly TA-50 Influent and Effluent Radiological Data Compiled from 

Facility Reports, J. Whitworth, D. Moss, December 17, 2003 

• M015, Procedure 420-MPP, TWCP-3542, PYRO-14, Revision 5 

• M025, Tables of Isotopic Composition for Various Material Types, October 1, 2003 

• M153, Procedure 212-MPP, TWCP-3543, SP-10, Revisions 1 through 6 

Additional AK-007 Documents: 238Pu Contaminated Mixed Heterogeneous Debris

• C002, Letter on Material Type Isotopic Composition Benchmark, AL-7193, May 2, 1997 

• C006, Memorandum to TWCP Records Center: Commingling of Defense and 

Nondefense TRU Waste, C.L. Foxx, August 21, 1997 

• C023, Interview with Jim Foxx; Segregation of non-defense wastes from defense wastes 

TWCP, October 12, 2000 

• C028, Email from SME: Sources of 137Cs, 231Pa and 244Cm in TA-55 TRU Waste, TWCP, 

April 11, 2001 

• C029, AK Personnel Interview of Lisa Pansoy-Hjelvik, Description of P/S Code ASP, 

TWCP, June 28, 2001 

• C032, Memorandum to Ed Wilmont, 238Pu Waste at TA-55, CBFO, CBFO:Oom: RPD: 

JGW:04-0435:UFC: 5822, May 20, 2004 

• C035, Email From Wayne Punjak to Pamela Rogers: 227Ac Drums, W. Punjak, July 10, 

2002 

• C040, Jim Foxx’s Review and Comments on Draft Process Flow Diagrams, Jim Foxx, 

February 21, 2006 
19

• C041, Detailed 238Pu Operations Process Flow Diagrams, J. M. Schoen and M. J. Papp, 

March 14, 2006 

• C042, Decay Corrected Values for LANL Heat Source Plutonium, Steve Schafer, April 

25, 2006 

• C144, Packaging of 238Pu Waste at TA-55, Interview of Dennis Wulff by Steve Shaffer, 

November 28, 2006 

• C145, Memorandum to CCP Central Records, Re: Evaluation of LANL 238Pu- Waste 

Management Practices, Kevin Peters, January 2, 2007 

• D004, Lightweight Radioisotope Heater Unit (LWRHU) Production for the Galileo 

Mission, G.H. Rinehart, LA-11166-MS, April 1988 

• D005, Lightweight Radioisotope Heater Unit (LWRHU) Production for the Cassinni 

Mission, G.H. Rinehart, LA-13143-MS, May 1996 

• D011, Process Acceptable Knowledge Report for Miscellaneous Operations at TA-55, J. 

Musgrave, TWCP-AK-2.1-004, Revision 2, May 17, 2001

• D014, Process Acceptable Knowledge Report for Special Processing at TA-55, TWCPAK-2.1-007, Revision 2, May 18, 2001 

• D015, Process Acceptable Knowledge Summary Report for 238Plutonium Operations at 

TA-55, J. Musgrave, TWCP-AK-2.1-009, Revision 0, August 7, 2001 

• D032, Acceptable Knowledge Information Summary for LANL Transuranic Waste 

Streams, C.H. Smith, AK-00-01-019, Revision 1, September 22, 2003 

• D033, Acceptable Knowledge Report for Debris Waste Streams Containing 239Pu, B.J. 

Humphrey, TWCP-AK-2.1-015, Revision 3, April 10, 2003 

• DR005, Acceptable Knowledge Source Document Discrepancy Resolution – Container 

Numbering Inconsistencies, Randy Fitzgerald, May 4, 2006 

• M002, Assembled Tables Taken from Milliwatt Generator Project Progress Reports, 

Various, LA-9170-PR, LA-9672-PR, LA-11217-PR, LA-11220-PR, LA-11346-PR, LA12236-PR, LA-13258-PR, December 1981 – July 1997 

• M025, Waste Profile Form Guidance LANL LIG 404-00-03.1, September 18, 1997 

• P003, TA-55 Generator Attachment to the Los Alamos TRU Waste Certification Plan, 

TWCP, TRU-MST12-CPA-03, Revision 0, March 1987 

• P014, Direct Oxide Reduction of 238PuO2, G. Rinehart, NMT9-SOP-0089, Revision 2, 

July 17, 2000 

• P016, Inspecting, Packaging, Rejecting, and Remediating Transuranic Waste for WIPP 

and for TA-54 Safe Storage, D. Wulff, NMT7-HCP-TA55-013, R1.1, December 2, 2002 
20

Additional AK-008 Documents: OSRP Sealed Sources Newly Generated Debris

• D008, Sealed Sources Peer Review Report, H. Evans, et al, TWCP-18562, December 5, 

2003 

• M024, Manufacturer’s Data for NUMEC Sources at Cornell College, 320C23, TWCP18917/P2010-0956, April19, 1953, Nuclear Materials and Equipment Corporation 

• DR001, Discrepancy Resolution, RE: Difference Between NMMSS and Shipping Data 

for Seven LLNLSS, Julia Whitworth, April 7, 2005 

• DR002, Discrepancy Resolution, MRC-PUBE-8-8, Total Pu Discrepancy, J. Whitworth, 

June 15, 2005 

• DR004, Source Pu8Be47-A-B from SRS, J. Whitworth, July 27, 2005 

• DR006, Discrepancy Resolution, Pu value on Sources M561, J. Whitworth, June 15, 

2005 

• DR007, Discrepancy Resolution, Sources MRPuBe346-348, Pu Quantity, J. Whitworth, 

June 20, 2005 

• DR008, Discrepancy Resolution, Sources in Container 60384, J. Whitworth, July 21, 

2005 

• DR009, Discrepancy Resolution, Discrepancy with Respect to Sources MRPu228-252, 

Pu Gram Values, J. Whitworth, July 19, 2005 

• DR010, Discrepancy Resolution, Certain Dates in NMMSS Database, J. Whitworth, 

August 8, 2005 

• C002, Memorandum: Approval to Generate OSRP Waste With No Disposal Path, R. 

Glass, DOE, TWCP-03760, February 10, 2000 

• P001, (TP-101), Visual Examination and Packaging of OSR Sealed Sources, Jerry 

McAlpin, OSR-OP-120 (P2010-0954), TWCP-04581 and TWCP-0059 (Multiple 

Revisions), last dated July 15, 2002 

• C010, Memorandum RE: Evaluating the Radiological Characterization of the OSRP 

Waste Stream, LA-05-00-01, A. Feldman and J. Whitworth, April 7, 2005 

• C011, Memoranda from T.J. Feske to J. McAlpin, RE: Pu-Be Sources 773-A, September 

12 and 16, 2002 

• M001, Summary of Waste Stream Containers/Spreadsheet of OSR Defense 

Relationships, J. McAlpin, J. Whitworth, M001/P201O-0919, September 24, 2004, 

January 18, 2005 and September 23, 2004 

• P004, Recovery, Transport and Storage of Off-Site Source Recovery Project Material, 

Jim Matzke, OSR-OP-100 (TWCP-24436)(P2010-0951), September 30, 2004 

• D007, Radiological Characterization of Actinide Sealed Sources Waste for Disposal at 

WIPP, J. Vance and M. Pearson, TWCP-19469, January, 2004 

• D012, Engineering Evaluation of New England Nuclear Model NER-478C Sealed Source 

as Special Form Radioactive Material, J. Tompkins, TWCP-05635, May 24, 2001 
21

• M055, Current Projection of OSR Waste Stream Volume, LA-04-00-01, J. McAlpin, 

April 13, 2005 

• M040, Specification for 238Plutonium, Beryllium Annular Pellets, Monsanto Research 

Corporation, TWCP-24599, NPD-STD-051, September, 1980 

• M037, OSR Plutonium Weight Percent Calculation, J. Whitworth, TWCP-24253, January 

10, 2005 

• M036, Calculation of Prevalent Radionuclides for the OSR Waste Stream, J. Whitworth, 

TWCP-23881, October 26, 2004 

• M026, Pu-239/Be Sealed Source Supporting Documentation, J. McAlpin, TWCP-05657, 

December 12, 1999 

• M011, Development of Radionuclide Distribution and Uncertainties in 241Am Sealed 

Source Material, J. Vance, TWCP-20712, OSR-TD-012, Revision 1, March 16, 2005 

• M010, Development of Radionuclide Distribution and Uncertainties in 239Pu Sealed 

Source Material, J. Vance, TWCP-20711, OSR-TP-011, Revision 1, March 18, 2005 

• M009, Calculation-Development of Radionuclide Distribution and Uncertainties in 238Pu 

Sealed Source Material, J. Whitworth, January 27, 2004 (two data packages) 

• CCP-QP-005, Revision 13, CCP TRU Nonconforming Item and Control, Effective Date 

November 11, 2006 

Additional AK-009 Documents: CMR Facility Debris Waste References

• C015, Interview: Adrian Lovell, Stan Kosiewicz-CMR Waste Streams, Vivian ValenciaBeckamn, TWCP-20859, March 11, 2004 

• C022, Record of Communication – Interview with Robert Donohoe, Explosives 

Analyzed at CMR, Steve Schafer – CCP AKE, August 22, 2005 

• C005, Interview: Stanley Kosiewicz Discussing Waste Stream Documentation, 

Operational history and Hazardous Waste Codes, Jennifer Griffin/Vivian Valencia, 

TWCP-20848, January 6, 2004, Los Alamos National Laboratory 

• D001, Safety Analysis Report for the TA-3 Chemistry and Metallurgy Research Facility 

Tom Krause, TWCP-00464, February14, 1994, Los Alamos National Laboratory 

• D003, Waste Management Site Plan, LANL, December 1984, K. Balo, J. Warren, LAUR-85-336, December 1984, Los Alamos National Laboratory 

• D008, CMR Facility TWID (Transuranic Waste Interface Document), William Schueler, 

NMT7-AP-CMR-018, Draft, February 2, 2000, Los Alamos National Laboratory 

• D010, Los Alamos TRU Waste Certification Plan, Attachment 4: Analytical Chemistry 

TRU Waste Certification Plan, CLS-1, Joel Dahlby, ANC-QP-1-5, Revision 1, July 1, 

1988, Los Alamos National Laboratory 

• D011, Preparation of Certified TRU Waste for WIPP, ANC-DE-1-PA-31, Joel Dahlby, 

Revision 2, November 2, 1989, Los Alamos National Laboratory 
22

• D021, CMR Waste Management Plan, W. Atencio, CMR-PLA-001, Revision 0, 

December 6, 1994 

• D022, TA-3 Chemistry and Metallurgy Building Acceptable Knowledge Report, IT 

Corporation, TWCP-AK-2.1-016, Revision 0 (Draft), June 7, 2002 

• D028, Los Alamos National Laboratory Transuranic Waste Characterization Acceptable 

Knowledge Information Summary, LANL-Project 2010, TWCP-PLAN-0.2.7-001, 

Revision 7, February 28, 2003 

• D029, LANL Project 2010 Acceptable Knowledge Report-Acceptable Knowledge 

Operations Report for CMR, LANL-Project 2010, AK-00-022, Revision 0, Draft, June 

28, 2004 

• DR003, High Explosives in the CMR and Management at LANL, K.J. Peters, October 

22, 2005 

• M006, Description of Activities in Wing 4, Uranium Processing Laboratory, TWCP21140, December 1995, Los Alamos National Laboratory 

• M018, CMR Container List Database Query provided by Andy Montoya – NMT-7, 

December 19, 2003 

• M019, CMR Container Databases – Drum List, Radionuclides and EPA HWNs, Query 

provided by Andy Montoya – NMT-7, December 16, 2003 

• M017, MSDSs and Other Manufactures Information Various Sources 

• P001, Managing TRU Waste and TRU Mixed Waste at the CMR Facility, Lorenzo 

Trujillo, NMT7-WI1-HCP-CMR-008, Revision 2, April 16, 2003, Los Alamos National 

Laboratory 

• P009, Waste Handling Procedure, Georgia Ortiz, CLS-1-SOP-7, CLS-1, April 1992, Los 

Alamos National Laboratory 

• P015, Waste Handling Procedure, Adrian Lovell, CST-SOP-007/2, Revision 2, April 

1996, Los Alamos National Laboratory 

• P010, Procedure for Managing Wastes from Controlled Areas, CLS-1-OP-7, Joel Dahlby, 

August 1992, Los Alamos National Laboratory 

• P038, CMR Facility Transuranic Waste Interface Document, William Schueler – NMT-7, 

NMT7-AP-CMR-018, Final Draft, June 2000 

Waste Container and Batch Data Reports Reviewed

Waste containers (55-gallon drums) from BDRs for several WC technical areas (VE, RTR, 

NDA, Head Space Gas [HSG] and Solids) were examined during the inspection. They are listed 

in Table 4 by container number and the LANL-CCP BDR number and type. 
23

Table 4. BDRs Examined During the Inspection

Container 

Number 

VE 

BDR No. 

RTR 

BDR No. 

NDA 

BDR No. 

HSG 

BDR No. 

Solids 

BDR No. 

850312 (Solids) N/A N/A N/A N/A ALD030, 33S, 

33V, 25M, 25N 

S870375 (07) LAVE500066 LARTR2-05-0196 LANDA0278 LA06-HGASLA-018 N/A 

S814218 (solids) N/A LARTR2-05-0192 LANDA0257 LA-HGASLA/LS-003 N/A 

S834538 

(Pu-238 debris) 

LAVE500066 LARTR2-05-0194 LANDA0287 LA06-HSGLA/LS016 N/A 

S817225 (solids) LAVE540006 LA-RTR-04-0007 LANDA0072 LA06-HSGLA/LS006 N/A 

54631 HT 83 N/A LA-RTR-06-0130 2LANDA0004 None listed on 

PTS/CTS 

N/A 

55700 Pu-238 N/A LA-RTR-06-0130 2LANDA0004 LA06-HSGLS085 N/A 

LA00000061432 LA06-OSRVE-001 Not applicable for 

OSRP 

LA06-OSRCH-002 Not applicable 

for OSRP 

N/A 

LA00000062374 LA06-OSRVE-001 Not applicable for 

OSRP 

LA06-OSRCH-002 Not applicable 

for OSRP 

N/A 

Technical Evaluation

The EPA inspection team evaluated the adequacy of AK information specific to the CH TRU 

retrievably-stored debris and solid waste in the following areas: 

(1) Data management was evaluated. 

LANL-CCP uses the Container Tracking System (CTS) and the Program Tracking System (PTS) 

to track container status, including NCR status. CCP also uses an uncontrolled AK tracking 

spreadsheet to track container information that includes container-specific AK material type 

(MT)7

 data, as well as available isotopic AK information for containers. Numerous LANL 

databases that provide information to the AK experts (AKEs) for generating AK summaries and 

populating the AK tracking spreadsheet are available. These databases or log sheets include the 

following: 

• Container waste storage record (CWSR) (1971–87) 

• TWSR (1987) 

• Discardable waste log sheet (DWLS) 

• CONCERT database 

• Nuclear materials management and safeguards system (NMMSS) for OSRP 

Based on the information in the AK summaries, it is difficult to ascertain the specific databases 

and historic log sheets that are available to the AKEs, including ongoing databases that LANL 

 

7 Material Types (MTs) are addressed in detail in the Benchmark Environmental Corporation Memorandum 

dated May 2, 1997 to K. Dziewinska from K. Gruetzmacher. MTs are also relevant to NDA, see Section 8.2. 
24

may operate. For future reference, EPA recommends that LANL-CCP include a list of the site 

databases specific to that waste stream in Chapter 6 of forthcoming AK summaries so that 

relevant databases are easily identifiable. 

(2) AK accuracy was assessed. 

AK Accuracy is an important tool that tracks how well AK and characterization information 

coincide. It is important because it provides up-front information regarding waste stream 

assignment. Also, for example, if AK Accuracy with respect to radionuclide characterization 

shows large discrepancies, this may mean that AK-NDA communication and the use of AK by 

NDA should be reassessed, which directly impacts the quality of radionuclide characterization 

information that impacts performance assessment. LANL-CCP calculates AK accuracy on a lot 

basis and evaluates WMC changes. LANL-CCP also may discuss inconsistencies with respect to 

radionuclide data. EPA Checklist Elements 38, 42, and 48 are related to the reassessment of 

waste if the AK data and related confirmation consistently indicate discrepancies between AK 

information and measurement data. Up to this point, LANL-CCP had not formally reevaluated 

waste streams for which NDA data and AK-identified most prevalent nuclides do not agree 

because only a portion of the waste stream had been measured. Development of criteria for 

reassessment of AK accuracy based on radionuclide results is important, and EPA recommends 

that LANL-CCP develop these criteria. Using these criteria, CCP then can determine whether 

reassessment of or changes to the AK information using actual NDA measurements or 

information from VE and/or RTR activities is necessary. 

Also, LANL-CCP may assess AK accuracy for radionuclides by comparing the AK and NDAidentified weight percents of the two predominant nuclides. However, the accuracy assessment 

would be more meaningful if accuracy was also assessed by comparison of the AK and NDAidentified radionuclides based on activity. For example, the March 27, 2006, AK accuracy report 

for Waste Stream LA-MIN03-NC.001 states that the most prevalent isotopes identified by AK 

are 238U and 235U, based on weight percent. However, this assignment of 238U and 235U to this 

waste stream is the result of their presence in a small number of containers. Accordingly, if 

these few containers are not measured, the radionuclide mass values based on measurement 

would not match those predicted by AK. Therefore, AK accuracy reports should assess the 

NDA-AK agreement in identifying the two most prevalent radionuclides by activity as well as by 

mass. Providing notification to EPA that revised AK Accuracy Reports are available is a Tier 2 

change. (See Table 1, where this is included as a T2 change). 

The EPA inspection team identified two concerns related to AK-NDA communication. Both 

concerns were discussed with LANL-CCP AK personnel and EPA included them on EPA 

Inspection Issue Tracking Forms (See Attachments C.1 and C.2 of this report for copies of these 

forms) and they are discussed below. 

EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-AK-06-001CR: EPA AK 

Checklist Elements 38, 42 and 48 pertain to the reassessment of waste if the AK data and related 

confirmation consistently indicate discrepancies between AK and measurement (NDA) based 

radionuclide values. Up to this point, LANL-CCP has not formally reevaluated waste streams 

for which NDA data and AK-identified most prevalent radionuclides do not agree because only a 

portion of the waste stream had been measured. However, CCP should develop processes and 

criteria to establish when reassessment would occur and what this would entail. 
25

Resolution: In response to the discussions among EPA, CBFO and LANL-CCP personnel, 

CBFO proposed the following resolution during the follow-up March 6, 2007 inspection: 

In accordance with the requirements of CCP-QP-005, CCP TRU Nonconforming Item 

Reporting and Control and CCP-TP-005, CCP Acceptable Knowledge Documentation, 

CCP has implemented Trend Code L for identifying NCRs that potentially impact AK. 

NCRs that identify inconsistencies noted during the process of comparing AK information 

to characterization results and NCRs that identify potential changes to the AK of a waste 

stream are tracked as Trend Code L. These NCRs are evaluated by the AKE. The AKE 

evaluation and resolution of the NCR may include preparation of an AK Discrepancy 

Resolution report, an AK Re-Evaluation, and/or an update to the applicable AK report. 

Final disposition of Trend Code L NCRs is dependent upon the AKE’s evaluation and 

conclusions regarding actions necessary to close the NCR. 

Trending of NCRs identified as Trend Code L is performed and reported in the CCP 

Trend Report, which is prepared semi-annually in accordance with CCP-QP-014, CCP 

Data Analysis and Trending. If Trend Code L NCRs indicate consistent discrepancies 

between AK and measurement data, a re-evaluation of AK information will be 

conducted. CCP does not anticipate any re-evaluation of an entire approved waste 

stream. If an approved waste stream is eliminated or combined with another approved 

waste steam, a memorandum written to the AK record will be prepared in accordance to 

CCP-TP-005, Section 4.3.3, to document the issues, evaluations, and conclusions 

regarding the waste stream reassignment. In the event an entire waste stream is 

eliminated or combined with an existing approved waste stream in the future, CCP will 

provide and document training to characterization personnel regarding changes to the 

delineation of the waste stream and the content of the memorandum written to the AK 

record. 

Status of Concern: EPA expects to receive copies of the semi-annual CCP Trend Report that 

document the application of Trend Code L. This information will be provided as part of the 

Reassessment Memorandum. EPA accepts the proposed resolution and considers this concern 

closed. 

EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-AK-06-002C: AK accuracy for 

radionuclides is determined by comparing the AK- and NDA-identified weight percents of the 

two predominant radionuclides. However, this assessment would be more meaningful if 

accuracy was also expressed in terms of activity. For example, the March 27, 2006, AK 

accuracy report for Waste Stream LA-MIN03-NC.001 states that the most prevalent isotopes 

identified by AK are 238U and 235U, based on weight percent. However, the assignment of 235U 

and 238U as the most prevalent radionuclides is based on a small number of containers. If these 

containers are not among those that are measured, the measured versus AK-predicted prevalence 

by mass would not match. Future AK accuracy reports should also assess the NDA-AK 

agreement in identifying the two most prevalent radionuclides by activity as well as by mass. 

Resolution: This concern did not require a response. 

Status of Concern: EPA considers this concern closed. 
26

(3) NDA-AK communication was assessed. 

EPA examined the following four waste streams during the inspection, each of which offered 

different levels of NDA-AK communication. 

LA-MIN03-NC.001, TA-50 Homogenous Inorganic Solids Non-cemented Waste (AK-004)

The NDA-AK memorandum for this waste stream indicates that it is essentially a complex 

radiological mixture, with material input originating from a number of sources (CCP-TP-005, 

Attachment 7, Radionuclides, LA-MIN03-NC.001, R0, TA-50 Homogenous Solids, NonCemented, April 29, 2004). Individual waste container isotopic data derived through 

measurement of that container are not available, although general batch analysis was performed 

to glean an overall sense of stream contents. A specific isotopic composition or character for this 

waste was not readily assignable, so the AK memorandum specifically states that default 

isotopics are not available for this waste stream and only measured data will therefore be 

reported. Therefore, the NDA operator does not consult the AKE to obtain information beyond 

what is presented in the AK summary and NDA-AK memorandum. 

LA-MHD02.001, 238Pu Contaminated Mixed Heterogeneous Debris (AK-007)

The NDA-AK memorandum indicates that a specific MT—MT 83 (heat source plutonium)—

applies to this waste stream. The NDA operator examines the waste, and if there is indication 

that the isotopics do not match those in the NDA-AK memorandum, the waste is segregated to a 

different waste stream. Because of the strict definition of this waste stream based on radiological 

content, little NDA-AK communication is required at this time. 

LA-OS-00-01.001, OSRP Sealed Sources (AK-008)

Offsite sealed sources are characterized entirely using AK based on information from various 

sources, including the NMMSS, source certificates, shipping documents, and manufacturer’s 

shipping records. An AKE assembles all radionuclide information used by the site, which is not 

used or otherwise verified by NDA. Therefore, NDA-AK communication does not takes place 

since NDA is not performed. 

LA-MHD03.001, CMR Facility Debris (AK-009)

Waste generated from this facility originated from a number of different laboratory areas that 

managed several different plutonium and uranium MTs (primarily MT 52 and MT 54, followed 

by MT 83; MT 39 is the primary uranium MT). In addition, traces of other nuclides may be 

present in the waste. The generators, however, documented the specific MT in each waste 

container for more than 97% of the individual containers, unlike AK-004. In the case of this 

stream, operators compare individual assay data against the AK-derived isotopics for the specific 

container to determine each drum’s radiological content. In this case, the AKE-NDA 

communication is frequent and well documented, as the two disciplines work together to 

determine the radiological contents of the subject waste stream. 
27

As evidenced by the above, the NDA-AK memoranda for these streams indicate differing levels 

of NDA-AK interaction, ranging from none because only AK is used, to drum-by-drum 

coordination. The NDA-AK memoranda have various inconsistencies, as listed below: 

• The LANL-004 NDA-AK memorandum includes editorial issues with respect to 

appropriate units and inadequate referencing of support documents for specific statements 

or conclusions. 

• In the NDA memoranda for LANL-007 and –009, references for formulas or other 

calculations are lacking. 

• Tables in all NDA-AK memoranda are not matched against data in the AK summaries 

and attachments to ensure consistency; specifically, Table 3 in the LANL-009 NDA-AK 

memorandum is erroneous and should be revised to indicate expected (rather than 

suspected) radionuclides, as this affects how site personnel enter the radionuclide values 

into the WWIS. 

AK-NDA Memoranda are a key way to assess communication between these two important 

technical areas. Specifically, the AK-NDA memorandum documents the approved and agreed 

upon use of AK data so that information identified as having significant limitations by the AKE 

are not used inappropriately by NDA personnel, thus directly impacting the quality of 

characterization data obtained. Further, the memo documents how NDA uses AK, and provides 

the AKE with information needs identified by NDA personnel so that the best and most 

appropriate data are made available to NDA. Accordingly, providing notification to EPA 

regarding changes made to any AK-NDA document that detail how NDA personnel use AK to 

identify and quantify radionuclides is a Tier 2 change. (See Table 1, where this is included as a 

T2 change). 

During the inspection, the EPA inspection team noted inconsistencies with the AK- NDA 

memoranda. This was discussed with LANL-CCP AK personnel and EPA included this on an 

EPA Inspection Issue Tracking Form (See Attachment C.3 of this report for a copy of this form) 

and it is discussed below. 

EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-AK-06-003CR: The NDA-AK 

memoranda have various inconsistencies that require attention. The LANL-004 NDA-AK 

memorandum includes editorial issues with respect to appropriate units and inadequate 

referencing of support documents for specific statements or conclusions. The NDA memoranda 

for LANL-007 and –009 lack references for formulas and other calculations. Tables in all NDAAK memoranda should be checked against data in the AK summaries and attachments to ensure 

that the data presented therein are consistent. Specifically, Table 3 in the LANL-009 NDA-AK 

memorandum should be revised to indicated expected (rather than suspected) radionuclides, as 

this makes a difference in how site personnel enter the nuclides into the WWIS. 

Resolution: The NDA Memorandum is LANL-CCP’s method of addressing EPA-identified 

communication issues and originated when EPA identified these issues at a Hanford-CCP 

inspection. Some remedies implemented by sites related to TRU WC processes in response to 

EPA issues or concerns are self imposed, however, these at times may in fact provide assurance 

that EPA’s issues and/or concerns are appropriately identified and rectified. When such AKNDA memoranda are written they document AK-NDA communication for the purpose of 
28

ensuring that both NDA and AK personnel are aware of the use and limitations of AK as applied 

to NDA. CBFO has stated that, as with any process of improvement, inconsistencies should be 

corrected when they are found, and LANL-CCP has revised NDA memoranda for waste streams 

LANL-004, LANL-007 and LANL-009 to address the issues that were identified. EPA is 

convinced that when AK NDA communication occurs through the process of using an AK-NDA 

memorandum it avoids problems that could ultimately result in erroneous data use. 

Status of Concern: This concern is closed.

(4) AK procedural adequacy was assessed. 

CCP-TP-005, Revision 17, is the most recent AK procedure used by CCP. EPA evaluated this 

procedure and found it to be adequate. Providing notification to EPA regarding changes made to 

AK procedures that require CBFO approval is a Tier 2 change. (See Table 1, where this is 

included as a T2 change). 

(5) Load management was examined. 

Of the four waste streams EPA examined, CCP indicated that load management was being 

sought for only one, AK-009, Waste Stream LA-MHD03.001, CMR facility heterogeneous 

debris waste. The load management estimates showed that between 3–33% of the waste stream 

is expected to measure less than 100 nCi/g on a container basis. The AKE indicated that the 

range was assigned because data pertaining to the TRU status of individual drums were not 

available for about 30% of the containers, so it was assumed that these containers may not 

measure in the TRU waste range. In reality, site representatives expect that almost all drums 

from this stream will measure more than 100nCi/g TRU. 

LANL-CCP will not use load management for AK-004, AK-008, and AK-007 at this time. If 

CCP decides to use load management for these waste streams, it must meet the requirements of 

Appendix E to DOE/WIPP-02-3122, Contact-Handled Transuranic Waste Acceptance Criteria 

for the Waste Isolation Pilot Plant (CH-WAC), Revision 3, dated April 25, 2005, and notify 

EPA. Implementation of load management for waste streams other than AK-009 is a Tier 1 

change. (See Table 1, where this is included as a T1 change). 

(6) The definition of waste stream was evaluated. 

EPA assessed each of the four waste streams included in the inspection with respect to whether 

each was appropriately described and defined. AK-004, homogenous inorganic solids, had been 

evaluated previously on waste stream determination. AK-007, 238Pu contaminated 

heterogeneous debris waste, was originally two streams (combustible and noncombustible), 

which CCP combined because there was an approximately 20-percent error with respect to this 

WMP. However, note that during the inspection LANL-CCP representatives explicitly defined 

this waste stream as consisting only of 238Pu debris waste; if 239Pu was detected in drums 

assigned to this stream, the drums were segregated for inclusion in another waste stream. 

When asked whether the 239Pu containers could be placed in AK-006 in the May 2006 

inspection, site representatives indicated that this was not an option at that time, apparently due 

to how the waste streams were assigned. Therefore, at the time of the inspection, LANL-CCP 
29

had determined that AK-006 and AK-007 are different waste streams based on the definition of 

waste streams presented in the Waste Analysis Plan (WAP) (NM48901 139088-TSDF, Waste 

Isolation Pilot Plant Hazardous Waste Facility Permit, 1989) and WAC. EPA agreed that they 

are separate waste streams based on data available at the May 2006 inspection. Following the 

inspection, however, LANL-CCP representatives reevaluated these two waste streams and 

determined that AK-006 and AK-007 belonged to a single waste stream. 

LANL-CCP representatives stated that 238Pu bearing waste was not intentionally generated to

create a unique waste stream. Evidence they examined showed that wastes from both the 238Pu 

and 239Pu lines, which were separate process lines, were commingled at packaging without 

regard to the original process origin. LANL-CCP representatives stated that post generation, 

238Pu-bearing containers were singled out as a separate waste stream, but representatives 

explicitly stated that the waste generation process did not create two separate streams. Assuming 

that the information and sources reviewed by LANL-CCP are correct, this conclusion is 

considered as valid. However, if data sources show that the waste streams were in fact generated 

separately, combining the streams would not comport with the definition of waste stream. 

In the OSRP program, sealed sources are collected from various industries (e.g., universities, 

health care and pharmaceuticals, oil exploration), are expected to have different pedigree hence, 

different radiological contents. As additional sealed sources are recovered from various 

commercial and industrial applications, as CH TRU debris waste destined for WIPP disposal, 

they would be characterized using the peer-reviewed manufacturers’ information specific to the 

radiological contents of each sealed source. Sealed sources recovered from different commercial 

or industrial applications but with similar pedigree potentially could be combined in a single 

waste stream as a new waste stream or added to the existing approved waste stream. 

Considering that LANL’s OSRP program could actively recover sealed sources, their 

characterization and categorization into an approved or new waste stream is of interest to EPA 

due to their potential for having different radiological contents. Therefore, EPA has assigned a 

T1 tier when new OSRP wastes are added to the AK Summaries since the baseline inspection 

(CCP-AK-008). Also, EPA has assigned a T2 tier requiring notification, when characterization 

information in the AK Summaries for the approved waste streams (as part of the baseline 

inspection and T1 change evaluation) has been revised to accurately account for the changes in 

radiological contents. 

In other words, because waste stream combination can greatly impact the radionuclide content, 

any future combination of different waste streams that were distinct prior to the EPA baseline 

inspection and are suitable candidates for combining together as a single waste stream will be 

subject to EPA approval as a Tier 2 change. (See Table 1, where this is included as a T2 

change). Also, this change was made because AK data and related confirmation consistently 

indicated discrepancies that lead to reevaluation of the waste streams as defined. As indicated in 

EPA Inspection Issue No. LANL-CCP-AK-06-001CR discussed in (3), above, LANL-CCP 

agreed to prepare a memorandum to document this event whenever this condition occurred, 

particularly when waste streams previously defined as unique were combined or otherwise 

significantly modified. EPA requires notification of these memoranda preparation as a Tier 2 

change. (See Table 1, where this is included as a T2 change). 

Note that the approval of 239Pu and 241Am sealed sources as defense waste makes these wastes 

eligible for disposal at the WIPP. EPA does not know at this time whether CCP will attempt to 
30

include these in the current sealed sources stream, or whether new stream(s) will be defined, but 

EPA expects any AK summaries dealing with sealed sources to adequately justify the waste 

stream as defined. Providing AK summaries that include these sources is considered a Tier 2 

change. (See Table 1, where this is included as a T2 change). If irradiated OSRP sources are 

identified, these would most likely require a revised approach to characterization than the current 

approval for other sealed sources, and accordingly the addition of the OSRP waste is a Tier 1 

change. (See Table 1, where this is included as a T1 change). 

(7) The use of QuickScan was examined. 

LANL-CCP representatives did not specifically address whether RTR using QuickScan was 

being performed. If so, LANL-CCP should include QuickScan information in the appropriate 

AK record. 

(8) Staff training was examined. 

EPA reviewed training records for Julia Whitworth (AKE), Kevin Peters (AKE), Steve Schafer 

(AKE), Mark Pearcy (site project manager (SPM)), and Randy Fitzgerald (site project quality 

assurance officer (SPQAO)). These individuals had performed required reading pertinent to 

specific procedures and AK summaries associated with the site, as well as applicable WAP and 

WAC requirements and discrepancy resolution, and nonconformance reporting. However, 

training was lacking specific to Conditions 2 and 3 of the WIPP compliance certification 

decision, and there was no record of testing or participation in internal audits. While the 

individuals were clearly proficient as evidenced through interview, additional EPA-specific 

training would help ensure consistent understanding of EPA requirements. 

(9) Drum traceability was assessed, as well as the ability to follow the AK WC process for 

containers and waste streams that were evaluated. 

EPA examined traceability in whole or in part for several containers—S850312 (solids), 

S870375 (AK-007), S814218 (solids), S834538 (238Pu debris), S817225 (solids), 54631 MT 83, 

55700 238Pu, OSR LA00000061432, and OSR LA00000062374. Information for evaluated 

containers was traceable from original LANL radioactive solid waste disposal forms or similar 

forms through the current AK spreadsheet to BDRs generated through WIPP characterization 

and subsequent tracking in PTS/CTS. EPA did not assess input into the WWIS as part of AK. 

WSPFs and related documents were examined. LANL-CCP often uses Change Notices to 

modify WSPFs and these modifications can significantly alter a waste stream. Accordingly, 

EPA requires notification regarding the completion of all change notices and related 

documentation including modified WSPFs, full AK Summaries and AK-NDA communication 

documentation for each waste stream modified as a T2 change. (See Table 1, where this is 

included as a T2 change). For all new waste streams EPA requires the following documentation: 

• Complete data packages for every waste stream, including the WSPF, AK summaries; 

• Characterization Information Summaries relating EPA requirements and other forms; and 

• Summaries of radionuclide data for those containers included on the Characterization 

Information Summary drum list. 
31

(10) Limitations and exclusions associated with the AK record were assessed. 

CCP-TP-005, Attachment 3, presents AK data limitations. This form addresses each source 

document, and therefore each source document includes a data limitation assessment. 

LANL-CCP adequately assembles AK information and keys these data to specific AK 

requirements (CCP-TP-005, Attachments 1 and 4). Attachments 1 and 4 to CCP-TP-005 act as 

AK “roadmaps” in that they present specific supporting documents and detail the relevancy of 

those documents to required AK elements. 

(11) Discrepancy resolution (AK-AK) was examined. 

LANL-CCP provided several discrepancy resolutions for EPA’s examination. The discrepancy 

resolutions examined were comprehensive and complete (although this does not necessarily 

mean that EPA concurred with the resolution therein, for example, combining of waste streams, 

etc.). LANL-CCP had recently generated a number of discrepancy resolutions specific to the use 

of the NMMSS database, because the NMMSS database does not comport with other 

information with respect to sealed source radionuclide content. Tracking of such discrepancies 

between the NMMSS database and other sealed sources’ radiological content information will be 

helpful when reassessing the reliability of NMMSS as a primary data source for sealed source 

radionuclide information (239Pu). 

(12) Defense origin of waste was examined. 

Each of the four AK summaries examined by EPA presented defense waste information. Up to 

this point, the shippable portion of the AK-008 OSRP waste stream was limited to 239Pu-related 

sources that had a clear defense related pedigree. However, on May 1, 2006, CBFO and the 

Chief Counsel for the TRU waste site approved defense waste determinations for additional 

waste streams. The waste streams obtaining a defense waste determination were as follows: 

•

241Am and 238Pu sealed sources containing radioactive material that were recovered 

domestically and were stated to have originated from the DOE weapons program 

•

241Am, 238Pu, and 239Pu that were stated to be of DOE origin in sources recovered from a 

foreign country 

•

241Am and 238Pu sealed sources that were managed as waste from DOE sites 

All three streams are justified in the summaries as being defense waste based on the following 

argument: 

Radioactive materials in the sealed sources are [from] activation of decay products of 

defense materials production, resulting from materials separations during defense 

nuclear material byproduct management, and are now managed [as defense waste] for 

defense nuclear materials security and safeguards.

In essence, the material in the sealed sources is considered to be defense waste because it was 

created as part of “defense nuclear material byproduct management,” even if the sources had a 

non defense-related application (i.e., referred to as the “born on” justification). EPA did not 
32

assess the applicability of this approach. EPA relies on DOE to make the defense determination 

of such waste streams. These determinations added 560 containers to the pool of containers 

eligible for shipment to the WIPP and also helped relieve onsite storage and capacity issues at 

LANL. 

(13) AK information pertaining to radiological characteristics of waste was examined. 

EPA examined how CCP characterizes and quantifies radionuclides for each of the waste 

streams to better understand what is obtained through AK and how this information is used to 

determine the radiological components of the waste.

• LA-MIN03-NC.001, TA-50 Homogenous Inorganic Solids Non-Cemented Waste, 

AK-004: Default isotopics are not available for this waste stream due to the manner in 

which the stream was created. Therefore, comparison of measured and AK values to 

confirm plutonium isotopes cannot be performed. Similarly, while uranium information 

was tracked in waste from an AK perspective since 1985, the use of “valid AK” to 

confirm measurements is not appropriate. CCP identified 235U and 239Pu as the two 

prevalent isotopes by weight, but CCP did not indicate a specific point at which this 

assessment would be reconsidered to evaluate this initial determination. Determination 

of predominant radionuclides by activity rather than weight is more meaningful for the 

cumulative tracking of the total activity of each of the 10 WIPP-tracking radionuclides 

measured in the waste. 

• LA-MHD02.001, 238Pu Contaminated Mixed Heterogeneous Debris Waste, AK-007: At 

the time of the inspection, AK defined this waste stream as consisting entirely of MT 83, 

so the waste’s isotopic ratios are well defined. Because NDA personnel know that this 

waste stream consists of 238Pu, they use these values when determining the specific 

plutonium contents. It was assumed, therefore, that various measured values would 

reflect the associated MT 83 ratios. If the measured values did not comport with the 

known quantity in the waste based on AK, the drums were not part of this waste stream 

and were segregated for assignment to a new waste stream. Note that post inspection 

LANL-CCP combined this waste stream with AK-007 because an occasional 239Pubearing drum was found in the 238Pu stream, and because CCP believed that the two 

waste streams were not distinctly and intentionally generated. With respect to uranium, 

little 233U is anticipated, and it is therefore an “expected” rather than a “suspected” 

nuclide. 

• LA-OS-00-01.001, OSRP Sealed Sources, AK-008: AK is the exclusive means for 

determining the radionuclide content of sealed sources. For each source, site personnel 

assess NMMSS, source certificates, fabrication/shipping records, U.S. Nuclear 

Regulatory Commission registry information, and other data, to determine the 

radionuclide content of waste at the time of fabrication, which is then corrected for 

radiological decay and/or ingrowth, as appropriate. Following approval of the defense 

determinations for 241Pu and 241Am, CCP must update the AK summary to address these

sources, including modification to the anticipated prevalent nuclides and other documents 

(i.e., updating various AK attachments). Note that in addition to sealed sources for which 

AK has already been assessed, site representatives indicated that additional sources that 

have been irradiated are available, thus changing the initial composition assigned by the 

manufacturer. EPA has not examined these sources, nor has the site posed a 
33

characterization methodology for these sources. When these sources are brought on line, 

an updated AK summary, a revised WSPF and radiological characterization protocol 

using AK will be necessary. 

• LA-MHD03.001, CMR Facility Debris, AK-009: Upon waste generation, site personnel 

assigned each waste container an MT from those that are in the AK record. NDA 

personnel approach the AKE for specific information on waste containers to assist in 

NDA measurements. For example, NDA personnel need to know whether MT 83 is 

present based on AK, and MT 42 (242Pu) mixtures are also important to identify. 

Sometimes the AKE is required to evaluate information on a drum-by-drum basis and 

come up with a weighted average by material type(s) so that the NDA personnel 

understand the potential drum contents by weight percent. Confirmation of plutonium 

ratios with respect to weapons grade Pu versus heat source Pu (WG Pu versus HS Pu) as 

described in the WAP apparently does not take place. The CCP AKE indicated that 

verification might take place on an MT basis. The AKE also indicated that 241Pu was 

determined by AK as opposed to by calculation based on measured 241Am values, as 

indicated in the WAC; 241Pu is not a TRU radionuclide and is not one of the 10 WIPPtracked radionuclides. The Multi-Group Analysis (MGA) or Fixed-Energy Response 

Function Analysis with Multiple Efficiencies (FRAM) routines calculate 242Pu as part of 

the gamma measurement process (see Section 8.2) but site operators often use AK, 

particularly when AK identifies drums as containing high quantities of 242Pu. With 

respect to uranium, AK can help to some degree in determining the 234U content on a 

drum-by-drum basis, and a scaling factor is used to determine the 234U content based on 

the container’s observed 235U and/or 238U content. The AK memorandum states that 234U 

is quantified by calculation, and it provides the formula and assumptions for the HENCs 

(LANL HNEC #1 and LANL HENC #2, see Section 8.2) based on various factors, 

including AK identification of drums containing MT 83, etc. 

The EPA inspectors observed inconsistency in radionuclide presentation and reporting. For 

example, it is important to distinguish radionuclides that are “expected” because this directly 

impacts how site personnel enter the information for these radionuclides in the WWIS. 

Specifically, 233U is expected in waste stream LANL-007, and EPA recommends that it be 

indicated as such in the AK summary. 

(14) Resolution of EPA AK issues identified during previous inspections was examined. 

The following issue remained at the end of the previous LANL-CCP inspection, EPA-LANLCCP-04.05-8, conducted in April 2005 (see Docket No: A-98-49, II-A4-57): 

AK Concern No. 1. CCP did not revise the AK summary to address an original concern 

identified during the April 2005 LANL-CCP inspection. CCP must revise CCP-AKLANL-06 to “clearly support and justify why a [WMC] cannot be determined even if 

such a determination can be made on a drum level.” Also, the decision to assign the 

S5400 WMCG to the waste, rather than assign a WMC, is contrary to the requirement in 

the WAP and affects several aspects of WAP compliance. For example, Section B4-3e of 

the WAP states, “Accuracy is the degree of agreement between an observed sample result 

and the true value. The percentage of waste containers which require reassignment to a 

new Waste Matrix Code...based on the reevaluation of acceptable knowledge or on 

obtaining sampling and analysis data will be reported as a measure of acceptable 
34

knowledge accuracy.” The conscious decision to not assign a WMC code invalidates AK 

accuracy. 

LANL-CCP did not provide CCP-AK-LANL-006, so the EPA inspectors were unable to 

determine whether a WMC designation had been added. However, WMCs had been assigned to 

AK-004, AK-007 and AK-009. If these codes are too broadly assigned, the AK accuracy derived 

from the codes may be of questionable validity because it is unlikely that every drum would 

require reassignment. EPA recommends that in the future, if CCP seeks to validate reduction of 

characterization requirements, the specific details on how codes are assigned and whether the 

assignment(s) are accurate would be fully assessed.

(15) Identification of WMPs and prohibited items was assessed.

AK summaries include general information pertaining to the WMP content of the streams. CCP 

sometimes calculates WMP content based on individual drum data, if available. 

LANL-CCP elected to combine wastes distinguished as combustible and noncombustible debris 

(e.g., AK-007). Although LANL continues to differentiate wastes by these parameters, LANLCCP representatives believe that there is a margin of error in these assignments and that it is 

more appropriate to combine the streams. LANL-CCP typically combines distinguishable waste 

streams into larger pools to decrease the number of WSPFs needed. In this instance, EPA did 

not receive information why the sites separated or continue to separate the waste based on these 

constituents, i.e., why LANL distinguishes two separate waste streams while CCP does not. 

EPA believes that the LANL waste stream designation is more in line with the regulatory 

definition, and the combination of waste streams by CCP is mainly for convenience. This is not 

an issue so long as each container undergoes RTR or VE to determine the WMP content. If CCP 

relies on AK in the future to modify the characterization requirements for VE, RTR and NDA, a 

more precise differentiation of wastes based on AK would be required. Reassignment of wastes 

into separate streams would require consideration to ensure that the uncertainty associated with 

AK-only WMP assignment is minimized. 

AK documents also address some prohibited items, but do not provide specific information as to 

their specific location or other aspects of those wastes. For example, liquid derived through 

condensation or dewatering was identified in AK-004, but the anticipated location of this water 

in the containers was not specified. This turned out to be important, as liquid was identified in 

the wastes at the bottom and in containers within drums, not just at the top or along the sides of 

the containers as might be anticipated through condensation/dewatering. Future AK discussions 

would benefit from more precise statements about the location of prohibited items; if this cannot 

be ascertained, the AK summaries should state this so that the nondestructive examination staff 

is better informed. 

(16) AK summaries were assessed. 

EPA reviewed the following four AK summaries: 

• CCP-AK-LANL-004, Central Characterization Project Acceptable Knowledge Summary 

Report for Los Alamos National Laboratory, TA-50- Radioactive Liquid Waste 

Treatment Facility, Homogenous Inorganic Solids, Non-Cemented Waste, March 9, 2006 
35

• CCP-AK-LANL-007, Revision 2, Los Alamos National Laboratory Pu-238 

Contaminated Mixed Heterogeneous Debris, Waste Stream LA-MHD02.001, April 13, 

2006 

• CCP-AK-LANL-008, Revision 3, Central Characterization Project Acceptable 

Knowledge Summary Report for Los Alamos National Laboratory Off-Site Source 

Recovery Project Sealed Sources, September 22, 2005

• CCP-AK-LANL-009, Central Characterization Project Acceptable Knowledge Summary 

Report for Los Alamos National Laboratory, Chemical and Metallurgy Research (CMR) 

Facility, March 9, 2006 

The documents were comprehensive and addressed most of the important technical information. 

EPA requested and examined dozens of supplemental data sources from each of these documents 

to determine whether the information supported the specific facts referenced in the summaries. 

These references were sufficient for these purposes. However, to better document CCP’s 

compliance-related activities, additional modification to the text of some AK summaries is 

recommended. These modifications will help ensure that the documents are complete and 

technically accurate. Examples of the recommended changes include the following: 

• Remove Wing 1 discussion from Table 10 of LANL-009 and revise the text accordingly 

• Include waste stream generation dates in LANL-007 in an appropriate location(s) 

• Ensure that all discussion of 10 WIPP-tracked radionuclides as well as any other 

radionuclides expected are addressed as “expected” rather than “suspected,” because this 

impacts how site personnel enter the data into the WWIS 

• Examine WMP and prohibited item discussions to ensure that an accurate description of 

the wastes is presented. For example, for AK-004, the AK summary indicates that fluids 

may be present through dewatering and condensation, but it does not indicate specifically 

where the water may be in the containers 

• Clarify the language pertaining to heat source fabrication. AK-007 includes several 

different current and historic 238Pu waste generation processes, but it is hard to identify 

which of the processes are active versus those that are not, in large part because the 

language pertaining to heat source fabrication is confusing. 

• Always distinguish “expected” versus “suspected” radionuclides in radiological 

discussions; it is important to identify “expected” radionuclides as this impacts how site 

personnel enter radionuclide data into the WWIS (e.g., 

233U as presented in AK-007). 

This baseline inspection addressed retrievably-stored S3000 solid and S5000 debris wastes, as 

well as newly-generated S5000 debris wastes. The addition of any wastes(s) not included in this 

approval is a Tier 1 change. (See Table 1, where this is included as a T1 change). 

(17) The OSRP information was reassessed in light of the new defense determinations. 
36

Sealed sources containing 241Am and 238Pu have recently been given a defense determination. 

LANL-CCP intends to assess whether the creation of new waste streams is necessary. If not, 

LANL-CCP will update the current AK summary with respect to radionuclide content, 

predominant nuclides, etc. Similarly, LANL-CCP must update or create a new WSPF to reflect 

this change which requires EPA approval. Because EPA has not assessed the radiological 

characterization for new sealed sources, examination of this approach is required to ensure that 

the processes proposed are technically adequate. As discussed in section (13), above, the 

addition of sealed sources from new waste streams is a T1 change. (See Table 1, where this is 

included as a T1 change). 

Summary of AK Findings and Concerns

The EPA inspection team did not identify any findings related to AK and identified the concerns 

that are discussed above. Copies of the EPA Inspection Issue Tracking Forms on which these 

concerns were documented are provided in Attachments C.1 through C.3 of this report. EPA 

considers all concerns to have been adequately addressed and there are no open findings or 

concerns related to AK resulting from this inspection. 

Baseline Approval

EPA is approving the AK and load management systems evaluated during this baseline 

inspection for CH retrievably-stored debris and solid wastes and newly-generated debris wastes 

from the OSRP. 

AK Tiers

Based on the inspection and the results discussed above, EPA is assigning the following tiers: 

T1 AK changes will require EPA review and approval prior to implementation and will apply to 

any new waste category not evaluated during the baseline inspection. These include the 

following: 

• Any new waste category or new OSRP wastes addressed in AK Summaries separate from 

CCP-AK-008 

• Implementation of Load Management for waste streams other than AK-009 

LANL-CCP will report and submit documentation on T1 changes when it is ready for EPA 

review. Upon initial review, EPA will inform LANL-CCP and CBFO whether a site inspection 

is necessary. EPA may request additional information, choose to conduct a desktop review, 

and/or confer with LANL-CCP personnel. Upon AK evaluation with or without site inspection, 

EPA will issue a decision. Only upon receiving EPA written approval may LANL-CCP dispose 

of the new waste at the WIPP. 

T2 AK changes do not require prior EPA approval but require LANL-CCP to notify EPA upon 

implementation of such changes and submit a brief description of the changes. Notification to 

EPA must be made upon completion of updates to or substantive modifications of the following: 
37

• AK Reassessment Memoranda and combination of waste streams that were distinct at the 

time of this inspection 

• AK-VE Memoranda related to VE and/or RTR techniques (see Section 8.4 for specific 

details regarding the content of this memo and relationship to AK) 

• AK-NDA Memoranda 

• Site procedures requiring CBFO approval 

• AK Summary CCP-AK-008, if changed since the baseline inspection and/or following 

the addition of new sealed sources 

• Completion of AK Accuracy Reports 

• Change Notices used to modify and update WSPFs, including additions to waste 

stream(s) within an approved waste category 

The above changes to the WC activities from the date of the baseline inspection must be reported 

to and approved by EPA according to Table 1. Following EPA approval, LANL-CCP will notify 

EPA of T2 changes along with a summary of each T2 change at the end of each fiscal year 

quarter. EPA will evaluate the information and communicate with LANL-CCP as to whether 

EPA needs additional information for further evaluation, whether the changes raise any concerns 

requiring LANL-CCP response, or whether LANL-CCP can continue to implement the changes. 

Consistent with EPA’s authority under 194.24(h), EPA may request information relative to these 

changes if EPA deems the information is necessary to ensure continued compliance with EPA 

regulations. 

8.2 Nondestructive Assay 

WC Element Description 

EPA inspected three NDA systems that are used as part of the LANL-CCP WC activities. EPA 

had previously evaluated and approved two of these systems, LANL HENC #1 (previously 

called the MCS HENC) and the PTGS. The third system—LANL HENC #2, which LANL-CCP 

brought online in March 2006—is essentially equivalent to LANL HENC #1 with respect to 

design, hardware specifications, and assay modes. LANL HENC #1 and LANL HENC #2 

follow the same operating procedures, as described below, although the two systems have 

instrument-specific calibrations and EPA evaluated them as separate measurement systems using 

separate checklists. See Attachments A.2, A.3, and A.4 to this report for the LANL HENC #1, 

LANL HENC #2, and PTGS checklists, respectively. Note that the following paragraphs on 

LANL HENC #1 and the PTGS reference the previous EPA inspection in several places. This is 

because some elements of these two NDA systems are unchanged since EPA Inspection No. 

LANL-CCP-04.05-8, conducted in April 2005, and reported in EPA Docket No.A-98-49, 

II-A4-57. As part of this inspection, EPA reviewed the following elements of the NDA process 

related to all three systems: 

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

• Technical adequacy of the NDA documents and procedures 
38

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

Additionally, EPA reviewed the performance of the HENC #2 for the time period between the 

initial inspection in May 2006 and March 6, 2007, at the follow-up inspection, including the 

replicate measurements in accordance with the EPA Replicate Protocol. The results of this 

evaluation are presented in sections (5) and (6) of the LANL HENC #2 evaluation, below. 

Documents, BDRs, and Waste Containers Reviewed

Attachments A.2, A.3, and A.4 to this report identify the objective evidence that EPA examined 

for LANL HENC #1, LANL HENC #2, and the PTGS, respectively. The following documents 

were among those the EPA inspection team examined to assess whether NDA was adequately 

performed relative to all three measurement systems: 

• CCP-PO-002, Revision 11, CCP Waste Certification Plan, February 24, 2005 

• CCP-TP-063, Revision 7, CCP Operating the High-Efficiency Neutron Counter Using 

NDA 2000, March 31, 2006 

• CCP-TP-064, Revision 4, CCP Calibrating the High-Efficiency Neutron Counter Using 

NDA 2000, March 31, 2006 

• CCP-TP-103, Revision 6, CCP Data Reviewing, Validating and Reporting Procedure for 

the High-Efficiency Neutron Counter Using NDA 2000, February 28, 2006 

• CCP-TP-123, Revision 2, CCP Calibrating the Tomographic Gamma Scanning System, 

September 21, 2005 

• CCP-TP-124, Revision 2, CCP Determining Isotopic Ratios in Waste Containers Using 

the PC/FRAM Assay System, October 31, 2005 

• CCP-TP-125, Revision 2, Verification and Validation of FRAM and PTGS 

Nondestructive Assay Data Using a Manual Review Method, July 5, 2005 

• CCP-TP-126, Revision 4, CCP Waste Assay Using the Portable Tomographic Gamma 

Scanner, September 8, 2005 

• Canberra Report: Energy Calibration and Verification Report, Revision 0, S. Stanfield 

and B. Gillespie, October 2005 (HENC #1) 

• Canberra Report: Energy Calibration and Verification Report, Revision 1, S. Stanfield 

and J. Wachter, May 2006 (HENC #1) 

• MCS HENC#2 Calibration Verification, Revision 0, Sean Stanfield, July 21, 2006 

• MCS HENC#2 Calibration Verification, Revision 0, Sean Stanfield, September 12, 2006 

• LANL HENC (HENC#2) Calibration Verification, Revision 0, Sean Stanfield, 

December 14, 2006 

• MCS HENC#2 Calibration Verification, Revision 0, Sheri Chambers, January 25, 2007 

• MCS HENC#2 Calibration Verification, Revision 0, Sheri Chambers, January 29, 2007 

• MCS HENC#2 Calibration Verification, Revision 0, Sheri Chambers, January 29, 2007 
39

• HENC#2 Calibration Verification, Revision 0, Sheri Chambers, March 5, 2007 

• MCS-HENC1-NDA-1001, Revision 2, Calibration Report for the MCS HENC #1 

Including Passive Neutron Calibration Verification and Gamma Spectrometer Calibration 

and Conformation, April 28, 2004 

• MCS-HENC1-NDA-1002, Revision 2, Supplemental Calibration Report for the MCS 

HENC #1 Including Passive Neutron and Gamma Spectrometer Calibration and 

Conformation, April 4, 2005 

• MCS-HENC1-NDA-1002, Revision 3, Supplemental Calibration Report for the MCS 

HENC #1 Including Passive Neutron and Gamma Spectrometer Calibration and 

Conformation, April 13, 2005 

• MCS-HENC1-NDA-1002, Revision 4, Supplemental Calibration Report for the MCS 

HENC #1 Including Passive Neutron and Gamma Spectrometer Calibration and 

Conformation, December 14, 2005 

• HENC #2-NDA-1002, Revision 0, Calibration Report for the HENC #2 Including 

Passive Neutron and Gamma Spectrometer Calibration and Conformation, March 28, 

2006 

• CI-HENC-TMU-101, Revision 1, Total Measurement Uncertainty for the MCS HENC #1 

with Integral Gamma Spectrometer, March 23, 2005 

• LANL-HENC2-TMU-101, Revision 0, Total Measurement Uncertainty for the HENC #2 

with Integral Gamma Spectrometer, April 10, 2006 

• MCS HENC Calibration Verification, Sean Stanfield: September 14, 2005; April 22, 

2006; April 30, 2006; and Revision 1, May 3, 2006 

• RRES-CH:03-058, Lower Limit of Detection for the LANL Portable Tomographic 

Gamma Scanner (PTGS), March 15, 2005 

• NWIS-TP: 2005-01102, Revision to TWCP-23398, Total Measurement Uncertainty for 

the Portable Tomographic Gamma Scanner (PTGS), March 30, 2005 

• Weekly Interfering Matrix Check Results for the LANL PTGS and FRAM, October 1, 

2005, to March 31, 2006 

• Weekly Interfering Matrix Results, LANL MCS HENC #1, October 1, 2005, to March 

31, 2006 

• Weekly Interfering Matrix Results, LANL MSC HENC (HENC #1, April 1, 2005, to 

September 30, 2005 

• HENC #1BDR LANDA0361—10 containers 

• HENC #1 BDR LANDA0124—10 containers 

• HENC #1 BDR LANDA0227—11 containers 

• HENC #1BDR LANDA0390—11 containers 

• HENC #2 BDR 2LANDA0002—five containers 

• HENC #2 BDR 2LANDA0005—nine containers 
40

• HENC #2 BDR 2LANDA0006—five containers 

• HENC #2 BDR 2LANDA0010—seven containers 

• BDR LA05-PTGS-027—eight containers 

• BDR LA05-PTGS-042—nine containers 

• BDR LA05-PTGS-057—five containers 

• BDR LA05-PTGS-092—six containers 

Technical Evaluation: LANL HENC #1

(1-1) The design and operational history of LANL HENC #1 was assessed. 

LANL HENC #1 is located on Pad 10 in Area G of TA-54, in the same location as when EPA 

last inspected it in April 2005. The system incorporates two measurement modalities—a passive 

neutron counter and an integral gamma-ray spectrometer. The passive neutron counter uses 

multiple 3He proportional counters, along with a multiplicity shift register and an external 252Cf 

source for the Add-a-Source matrix correction function, to determine the spontaneously 

fissioning mass content of waste containers, referred to as the 240PuEffective (

240PuEff). The 240PuEff 

is defined as the amount of 240Pu that would produce the observed true coincidence rate, after 

correcting for the neutron moderation properties of the waste matrix. The quantities of 

individual radionuclides are related to the 240PuEff by applying the ratios of other TRU or target 

radionuclides, including all spontaneously fissioning radionuclides (i.e., 235U). In LANL 

HENC #1, these (isotopic) ratios are routinely determined by Multi Group Analysis (MGA) of 

the gamma-ray spectrum based on measurement data obtained with the integral gamma-ray 

spectrometer, as discussed below. 

The integral gamma-ray spectrometer is a high-purity germanium (HPGe) detector used to 

acquire the gamma-ray spectrum to be analyzed by MGA and to provide direct quantification of 

a number of radionuclides, including 238Pu, 239Pu, 241Pu, 241Am, 233U, 235U, 238U, 137Cs, and 

237Np. The spectrometer used a multicurve efficiency calibration based on the waste density to 

correct for photon attenuation inside the drum. 

The use of a different NDA system not observed during this inspection or physical modifications 

to the HENC#1 described above is a T1 change (see Table 1 where this is included as a T1 

change). 

(1-2) The passive neutron and gamma calibrations of LANL HENC #1 had been performed as 

required. 

The original calibration of LANL HENC #1 for its use in the WIPP program took place at 

Canberra Industries in Meriden, Connecticut. This calibration was initially verified when the 

system became operational at LANL in 2004 and both the initial calibration and subsequent 

verification were evaluated by EPA during Inspection No. LANL-CCP-04.05-8. An additional 

report, MCS-HENC1-NDA-1002, Supplemental Calibration Report for the MCS HENC #1

Including Passive Neutron and Gamma Spectrometer Calibration and Confirmation, Revision 2, 

dated April 4, 2005, addressed changes to gamma efficiency calibration that were indicated by 
41

the system’s performance in the CBFO-sponsored NDA performance demonstration program 

(PDP). The main change was the removal of the sludge drum calibration because the calibration 

sources extended above the matrix, resulting in an unacceptable bias, in addition to incorporating 

cadmium filters to reduce dead time originating from higher concentrations of 241Am normally 

associated with aged plutonium. The calibration was verified as documented in the supplemental 

calibration report from 2005. The calibration was applicable to S3000 homogenous solid wastes 

and S5000 debris wastes packaged in 55-gallon drums, with or without polyethylene liners. The 

passive neutron calibration performed originally in November 1997 was verified in March 2004 

and again in 2005 at LANL using combinations of plutonium oxide (PuO2) sources totaling 

approximately 0.599, 15.0, and 160 grams of total plutonium in a non-interfering matrix. The 

upper end of the passive neutron’s original calibrated range, which was the lower limit of 

detection (LLD) to 100 g plutonium (6.55 g 240PuEff), was extended to 177 g plutonium total 

(12.159 g 240PuEff) for both solid and debris wastes. LANL-CCP personnel stated that they will 

use this system to assay wastes containing weapons-grade plutonium (WG Pu) and heat source 

plutonium (HS Pu), which are predominantly 239Pu and 238Pu, respectively. Both WG Pu and HS 

Pu are correlated to a variety of MTs that were discussed in Section 8.1 of this report. The 

passive neutron calibration for LANL HENC # 1 was technically adequate and appropriately 

documented. 

The integral gamma-ray spectrometer was originally calibrated in March 2004 using six 

241Am/152Eu line sources in five surrogate waste drums with waste matrix densities of 0.018, 

0.49, 0.69, 1.24, and 1.64 g/cm3

. For each of the surrogate waste drums, the efficiency of the 

detector was measured as a function of gamma-ray energy between 59 and 1,408 keV. Note that 

the energy calibration for LANL HENC #1 differs slightly from what was established for LANL 

HENC #2, discussed later in this section. The calibration of the integral gamma-ray 

spectrometer was confirmed using the same WG Pu sources used to verify the passive neutron 

calibration. This is still the calibration of record, although the efficiency calibration was changed

and verified as required (as documented in MCS-HENC1-NDA-1002, Revision 2, dated April 4, 

2005). The gamma calibration is not a mass calibration in the strict sense, although the 

calibration/qualification summary in the supplemental calibration report states an operating range 

of LLD to 175 g plutonium, which is more representative of the passive neutron component. 

Like other gamma systems, there is no strict upper mass limit, provided all operational 

parameters, such as dead time and resolution (peak shape), are met. The gamma calibration for 

LANL HENC #1 was technically adequate and appropriately documented. 

The extension of or changes to the stated calibration neutron and/or gamma range(s) for the 

HENC#1 is a Tier 1 change (see Table 1 where this is included as a T1 change). 

Changes to the software or operating range(s) of the HENC#1, and to the site procedures that 

govern its use that require CBFO approval are T2 changes (see Table 1 that includes these as T2 

changes). 

(1-3) The total measurement uncertainty (TMU) of assays performed on LANL HENC #1 had 

been determined and documented. 

CI-HENC-TMU-101, Total Measurement Uncertainty for the MCS HENC #1 with Integral 

Gamma Spectrometer, Revision 2, dated April 28, 2004, documents the original determination of 

the TMU for LANL HENC #1. This had been modified by changing the second paragraph of 
42

Section 4.1.4, on page 17, regarding a previously identified issue related to drum fill height that 

CI-HENC-TMU-101 (Revision 1, dated March 23, 2005) also documented. Among the 

components of uncertainty included in the TMU determination for the passive neutron 

measurement were contributions from the calibration uncertainty; calibration counting statistics; 

matrix and source distribution effects; background effects for high atomic number waste 

matrices; and uncertainties due to isotopics, chemical forms, and neutron multiplication. The 

TMU determination for the passive neutron component of this system was unchanged since the 

last EPA inspection in April 2005. For the integral gamma-ray spectrometer, the TMU 

evaluation included counting statistics, background fluctuations, interferences from other 

gamma-emitting radionuclides, calibration uncertainties, matrix non-homogeneities, non-uniform 

source distributions, isotopic measurement uncertainties, and effects from self-absorption. The 

TMU determination for the gamma component of this system was unchanged since the last EPA 

inspection in April 2005. LANL-CCP adequately determined and documented the TMU for both 

operational modes for LANL HENC #1. 

(1-4) The LLD, including the minimum detectable concentration (MDC) of LANL HENC #1, 

had been determined and documented. 

CCP-PO-002, CCP Transuranic Waste Certification Plan, Revision 11, defined LLD as: 

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

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

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

The LLD of any given NDA measurement depends on the type of measurement (passive neutron 

or gamma), the properties of the waste matrix being assayed, the data acquisition (measurement) 

time, and the environmental background. For this reason, the LLD is expected to vary from 

drum to drum and also may vary between measurements of the same drum. The NDA 2000 

software estimated and reported the LLD of each of the 10 WIPP-tracked radionuclides for each 

measurement. Only values that exceeded the reported LLD for that measurement were to be 

reported and were used in calculations of derived quantities, such as total TRU alpha activity and 

TRU alpha activity concentration. LANL-HENC1-NDA-1002, Revision 2, included the average 

LLD for each of the WIPP-tracked radionuclides estimated for two surrogate drums containing 

38.3 kg of debris waste and 227 kg of homogenous waste. These values were typical of the 

waste drums to be assayed on LANL HENC #1. The LLD of LANL HENC #1 was technically 

adequate and appropriately documented. 
43

(1-5) EPA coordinated and evaluated replicate testing of LANL HENC #1. 

The purpose of the replicate testing during this inspection was to provide EPA with an 

independent means to verify that LANL HENC #1 could provide consistent, reproducible results 

for determining the quantity of 10 WIPP-tracked radionuclides (241Am, 137Cs, 238Pu, 239Pu, 240Pu, 

242Pu, 90Sr, 233U, 234U, and 238U) and the TRU alpha concentration. This was accomplished by 

reassaying drums previously characterized on the same system or instrument in order to evaluate 

its ability to do the following: 

• Produce results consistent with the reported TMU (as judged by comparing the sample 

standard deviation for a number of replicate measurements taken over several hours or 

days to the reported TMU) 

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

judged by comparing the results of the replicate measurement(s) to the original reported 

values) 

As part of the inspection to certify LANL HENC #1, EPA requested that LANL reassay a group 

of waste drums that EPA randomly selected from a list of drums previously assayed on the 

HENC that was provided by LANL-CCP. The three drums selected were Containers 52331, 

52476, and 53093. At EPA’s request, site personnel reassayed each of these drums five times for 

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

) test and a t test, were performed for the 

replicate analyses on each container. Attachments B.1 through B.6 to this report include 

analytical data for each assay event and the results of the statistical analysis. 

For all three drums the t test showed no statistically significant differences between the original 

measurement assay values and the average of the five replicate measurements for all measured 

parameters. The χ2

 tests for these same three containers showed a highly significant flag only for 

242Pu. This indicates that the variances in the replicate measurements for 242Pu were greater than 

the reported uncertainties for all values relative to the limits of the test. For all three containers 

this appears to be an artifact of the statistical evaluation. Specifically, the spread of values is so 

tight that the test effectively places an inordinate emphasis on small variations, resulting in a 

penalty for high precision. EPA has previously observed and reported this phenomenon during 

inspections at other TRU WC sites. An evaluation of the 242Pu data outside of the χ2

 test 

indicates that there is no real measurement issue. Although the software identified these 

variances as “highly significant,” this does not indicate a measurement issue that warrants 

additional attention at this time. There is no technical issue relative to the highly significant 

flags for the 242Pu values on the χ2

 test for the LANL HENC #1 replicates. 

The t test for all three containers showed only statistically significant differences between the 

original measurement assay values and the average of the five replicate measurements for the 

activities of all measurement parameters. There is no technical issue relative to the t test values 

for the LANL HENC #1 replicates. 

Technical Evaluation: LANL HENC #2

(2-1) The design and operational history of LANL HENC #2 was assessed. 
44

LANL HENC #2 is located on Pad 10 in Area G of TA-54, in building TA-54-B498, adjacent to 

the location of LANL HENC #1, discussed above. The system functions in the same manner as 

LANL HENC #1 in that it incorporates two measurement modalities—a passive neutron counter 

and an integral gamma-ray spectrometer. The passive neutron counter uses 113 3He proportional 

counters arranged in a 4Β geometry, in conjunction with a multiplicity shift register and an 

external 252Cf source for the Add-a-Source matrix correction. This combination quantifies the 

spontaneously fissioning content of waste containers, referred to as the 240PuEff, described above 

As was observed for the LANL HENC#1, the quantities of individual radionuclides are related to 

the 240PuEff by applying the ratios of other TRU or target radionuclides, including all 

spontaneously fissioning radionuclides (i.e., 235U). In the LANL HENC #2, the isotopic ratios 

are routinely determined by MGA of the gamma-ray spectrum based on data obtained with the 

integral gamma-ray spectrometer, as discussed below. 

The integral gamma-ray spectrometer is an HPGe detector used to acquire the gamma-ray 

spectrum to be analyzed by MGA and to provide direct quantification of a number of 

radionuclides, including 238Pu, 239Pu, 241Pu, 241Am, 233U, 235U, 238U, 137Cs and 237Np. The 

spectrometer used a multicurve efficiency calibration based on the waste density to correct for 

photon attenuation inside the drum. 

The use of a different NDA system not observed during this inspection or physical modifications 

to the HENC#2 described above is a T1 change (see Table 1 where this is included as a T1 

change). 

Changes to the software or operating range(s) of the HENC#2, and to the site procedures that 

govern its use that require CBFO approval are T2 changes (see Table 1 that includes these as T2 

changes). 

(2-2) The passive neutron and gamma calibrations of the LANL HENC #2 had been performed 

and confirmed as required. 

The original calibration of the LANL HENC #2 was performed in 1999; however, the system 

was recalibrated at LANL for use in the WIPP program beginning in February 2006. HENC#2-

NDA-1002 (also numbered as P2010-1516), Calibration Report for the HENC#2 Including 

Passive Neutron and Gamma Spectrometer Calibration and Confirmation, Revision 0, 

documents the calibration. The calibration is applicable to S3000 homogenous solid wastes and 

S5000 debris wastes packaged in 55-gallon drums, with or without polyethylene liners. The 

calibration range of the passive neutron system is stated as the LLD to 16.29g 240PuEff, and 

HENC#2-NDA-1002 includes documentation of a calibration confirmation using predominantly 

238Pu material. 

The integral gamma-ray spectrometer was originally calibrated in February 2006 using six 

241Am/152Eu line sources in five surrogate waste drums with waste matrix densities of 0.018, 

0.49, 0.69, 1.24, and 1.64 g/cm3

. For each of the surrogate waste drums, the efficiency of the 

detector was measured as a function of gamma-ray energy between 50 and 1,228 keV. This 

energy range differs slightly from the range stated for LANL HENC #1, which is listed as 59 to 

1408 keV. According to LANL-CCP personnel, the functional range of the gamma component’s 

operational range for LANL HENC #2 is slightly greater than 100 keV due to attenuation of the 

Sn/Cu filters that were installed to prevent excessive dead-time corrections from high 
45

concentrations of 241Am. The calibration of the integral gamma-ray spectrometer was confirmed 

using the same WG Pu sources that were used to verify the passive neutron calibration. The 

gamma calibration is not a mass calibration in the strict sense, although the calibration and 

qualification summary in HENC#2-NDA-1002 states a gamma operating range of LLD to 217 g 

total plutonium, which is limited by dead time. Like other gamma systems, there is no strict 

upper mass limit, provided all operational parameters, such as dead time and resolution (peak 

shape), are met. EPA found that the passive neutron and gamma calibrations for LANL HENC 

#2 were technically adequate and appropriately documented. 

The extension of or changes to the stated calibration neutron and/or gamma range(s) for the 

HENC#2 is a Tier 1 change (see Table 1 where this is included as a T1 change.) 

(2-3) The TMU of assays performed on LANL HENC#2 had been determined and 

documented. 

LANL-HENC2-TMU-101, Total Measurement Uncertainty for the HENC #2 with Integral 

Gamma Spectrometer, Revision 0, dated April 10, 2006, documents the original determination of 

the TMU for LANL HENC #2. Among the components of uncertainty included in the TMU 

determination for the passive neutron measurement were contributions from the calibration 

uncertainty; calibration counting statistics; matrix and source distribution effects; background 

effects for high atomic number waste matrices; and uncertainties due to isotopics, chemical 

forms, and neutron multiplication. For the integral gamma-ray spectrometer, the TMU 

evaluation included counting statistics, background fluctuations, interferences from other 

gamma-emitting radionuclides, calibration uncertainties, matrix non-homogeneities, non-uniform 

source distributions, isotopic measurement uncertainties, and effects from self-absorption. The 

approaches to TMU determination for the passive neutron and gamma components are 

essentially the same as those used for the LANL HENC #1, discussed above. The TMU 

determination for both operational modes was technically adequate and appropriately 

documented for the LANL HENC #2. 

(2-4) The LLD, including the MDC of the LANL HENC #2, had been determined and 

documented. 

CCP-PO-002, CCP Transuranic Waste Certification Plan, Revision 11, defined LLD as: 

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

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

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

The LLD of any given NDA measurement depends on the type of measurement (passive neutron 

or gamma), the properties of the waste matrix being assayed, the data acquisition (measurement) 

time, and the environmental background. For this reason, the LLD is expected to vary from 

drum to drum and also may vary between measurements of the same drum. The NDA 2000 

software estimated and reported the LLD of each of the 10 WIPP-tracked radionuclides for each 

measurement. Only measured values that exceeded the reported LLD for that measurement were 

to be reported and were used in calculations of derived quantities, such as total TRU alpha 

activity and TRU alpha activity concentration. The average passive neutron and gamma LLDs 

for each of the WIPP-tracked radionuclides estimated for two surrogate drums containing 38.3 
46

kg of debris waste and 191.7 kg of homogenous waste were included in HENC#2-NDA-1002, 

Revision 0, page 12, Tables 8a and 8b, respectively. These values are representative of waste 

drums to be assayed on LANL HENC #2. EPA found the LLD determination for LANL HENC 

#2 to be technically adequate and appropriately documented. 

(2-5) EPA evaluated the performance of the LANL HENC #2 for the time period between May 

25, 2006, and March 6, 2007. 

There were 7calibration verifications performed between May 25, 2006, and March 6, 2007, and 

each was documented. The verifications were required for the typical types of measurement 

issues expected during routine operations, e.g., exceeding a 3 σ Control Limit on the daily 152Eu 

source check. The complete list of the documentation for each verification that was reviewed on 

March 6, 2007 is provided above. All calibration verifications were acceptable. The dates on 

which the verifications were documented8

 and a summary of each are as provided below: 

• July 21, 2006 – 3 σ failure on the 152Eu source 

• September 12, 2006 – 3 σ failure on the K normalization 

• December 14, 2006 – 3 σ failure on the Full-Width-at-Half-Maximum (FWHM) on the 

152Eu 122 keV line 

• January 25, 2007 – computer failure 

• January 28, 2007 – 3 σ failure on the 152Eu source 

• January 29, 2007 – 3 σ failure on the 152Eu source 

• March 5, 2007 – 3 σ failure on the FWHM on the 152Eu 122 keV line 

A source check was performed using a combination of PDP-type Pu sources configured in a 

matrix drum and each source check was evaluated for accuracy (Relative Percent Accuracy or 

RPA) and precision (Relative Standard Deviation or RSD) using the criteria in DOE-WIPP-02-

3122. All checks were acceptable and were documented appropriately. The EPA inspection 

team observed the assay of the Weekly Interfering Matrix using PDP Matrix Drum No. 003 that 

was loaded with the RANT 50-1, RANT 50-2, RANT 50-3 and NTP-0164 WG Pu sources in 

specified positions (height and distance from drum center), as required. The total Pu loading of 

the drum was approximately 215 g. The LANL HENC#2 operational logbook (logbook No. 

LANL-NDA-HENC-02-003) that was observed in use in the LANL HENC #2 trailer had been 

appropriately completed and contained documentation of the activities observed during this 

inspection. 

It was noted that containers assayed on the LANL HENC #2 were marked with a blue adhesive 

label that stated VPM ADMINISTRATIVE HOLD, EQUPIMENT NOT CERTIFIED, reflecting 

the system’s regulatory status, i.e., uncertified at the time of this inspection. A sample of this 

label was provided and the EPA inspection team observed actual waste drums that had been 

assayed on the LANL HENC #2. 

Following the May 2006 inspection, LANL-CCP initiated a Corrective Action Plan (CAP) in 

response to the CBFO Corrective Action Report CAR-LANL-0007-06, Revision 0 related to a 

 

8

 The actual date of the measurement event that prompted the calibration verification is not necessarily the same 

as the date of the calibration verification report. The actual date of the measurement event is documented in the 

calibration report in all cases. 
47

measurement failure during Cycle 13A of the CBFO sponsored NDA Performance 

Demonstration Program (PDP). Specifically, the LANL HENC #1, LANL HENC #2, and the 

PTGS had failed the accuracy criterion on the NDA PDP Glass Matrix Drum containing HS Pu. 

The CAP proposed changing the analysis routine such that it operated in the count-to-precision 

mode as opposed to operating for a preset time. This allowed the NDA systems to continue the 

assay until sufficient counts were obtained irrespective of the measurement time as opposed to 

assaying for a preset time. This approach was successful for both LANL HENC units but was 

not successful for the PTGS. As of January 2007, the following CBFO approvals are in effect: 

• LANL HENC #1 – approved for WG Pu and HS Pu in all matrices 

• LANL HENC #2 – approved for WG Pu and HS Pu in all matrices 

• PTGS – approved for WG Pu in matrices as described below, and not approved for HS 

Pu in any matrix 

There are no open issues related to the LANL-CCP CAP. 

(2-6) EPA coordinated and evaluated replicate testing of LANL HENC #2. 

The purpose of the replicate testing during this inspection was to provide EPA with an 

independent means to verify that LANL HENC #1 could provide consistent, reproducible results 

for determining the quantity of 10 WIPP-tracked radionuclides (241Am, 137Cs, 238Pu, 239Pu, 240Pu, 

242Pu, 90Sr, 233U, 234U, and 238U) and the TRU alpha concentration. To accomplish this, LANLCCP reassayed drums previously characterized on the same system or instrument in order to 

evaluate its ability to do the following: 

• Produce results consistent with the reported TMU (as judged by comparing the sample 

standard deviation for a number of replicate measurements taken over several hours or 

days to the reported TMU) 

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

judged by comparing the results of the replicate measurement(s) to the original reported 

values) 

As part of the inspection to certify LANL HENC #2, EPA requested that LANL reassay a group 

of waste drums that EPA randomly selected from a list of drums previously assayed on LANL 

HENC #2 that was provided by LANL-CCP. The drums selected were identified as Containers 

555700, 52277, and 53991. At EPA’s request, site personnel reassayed each of these drums five 

times for this inspection. Two statistical tests, a χ

2

 test and a t test, were performed for the 

replicate analyses on each container. Attachments B.7 through B.12 to this report include 

analytical data for each assay event and results of the statistical analysis. 

The χ2

 test for all measured parameters for all three containers showed that the observed 

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

all values within the statistical limits of the test. 

For Containers 55700 and 52277, the t test showed no statistically significant differences 

between the original measurement assay values and the average of the five replicate 
48

measurements for all measured parameters. For Container 53991, the t test showed a “highly 

significant” flag for only 242Pu, indicating that the variances in the replicate measurements for 

242Pu were greater than the reported uncertainties for all values relative to the limits of the test. 

A close examination of the data reveals that the original measurement differs slightly from the 

mean of the five replicates, although the difference is minimal. There are several possible 

reasons for this—actual changes in the physical configuration of the drums’ contents due to 

movement or settling; fluctuations in the measurement system’s background; or actual changes 

in the measurement system, the very aspect that this test is designed to query. Although the 

software identified these variances as “highly significant,” this does not necessarily indicate a 

measurement issue that warrants additional attention at this time. EPA may, however, request 

additional replicate analyses for the LANL HENC #2 at a later date. There is no technical issue 

at this time relative to the highly significant flags for the 242Pu values on the χ2

 test for the LANL 

HENC #2 replicates. 

As part of the follow-up inspection in March 2007, EPA requested that LANL-CCP reassay two 

waste drums that EPA randomly selected from a list of drums previously assayed on the LANL 

HENC #2 that was provided by LANL-CCP. EPA selected Container No. S817309 (S3000 

sludge matrix) and Container No. 61209 (S5000 debris matrix). At EPA’s request, site personnel 

reassayed both drums five times for this inspection. The EPA inspection team observed the 

loading and the initiation of the assay sequence for Container No. S817309. Two statistical tests, 

a χ

2

 test and a t test, were performed for the replicate analyses on both containers. Attachments 

B.19 through B.22 to this report include analytical data for each assay event and results of the 

statistical analysis. Analysis of the results is presented below. 

Container No.61209, showed no statistically differences between the original measurement assay 

values and the average of the five replicate measurements for all measured parameters using the t

test and a “highly significant” flag for 239Pu, 240Pu, 242Pu and 241Am using the χ2

 test. Container 

No. 61209 was a very low signal drum with a total TRU alpha concentration of approximately 

230 nCi/g, and the original measurement differs slightly from the mean of the five replicates, 

although the difference is minimal. There are several possible reasons for this: 

• Changes in the physical configuration of a drum’s contents due to settling or shifting 

resulting from drum movement/staging or related waste management activities on site 

over the time period between the initial and replicate measurements 

• Fluctuations in the measurement system’s background due to normal fluctuations or 

placement of higher radionuclide-bearing containers in proximity to the measurement 

system 

• Actual changes in the measurement system, the very aspect that this test is designed to 

query. 

For a low signal drum where the reported values are close to the system’s detection limit, small 

changes in background or the expected variability associated with nuclear transitions can 

produce effects that appear large using these statistical metrics. Irrespective of the assignment of 

a “highly significant” flag to these differences, their magnitude is small. Additionally, the 

container’s total TRU alpha activity concentration agreed well between the original measurement 

and the replicates. Accordingly, there is no technical issue at this time relative to the “highly 

significant” flags for the 239Pu, 240Pu, 242Pu and 241Am values using the χ2

 test. 
49

Container No. S817309 showed a “highly significant” flag for a single radionuclide, 242Pu, using 

the t test and a “highly significant” flag for 238Pu, 240Pu, 242Pu and 241Am as well as 137Cs and 90Sr 

using the χ2

 test. The magnitude of the differences for the χ2 test are small, and the 238Pu values 

for the original measurement and the mean of the five replicates are virtually identical, i.e., 

1.53E-01 and 1.51E-01. With the exception of 242Pu, the differences between the original and 

mean of the five replicates for the other TRU radionuclides are similarly small and do not 

represent a technical concern regarding precision of the LANL HENC #2. Regarding the 137Cs 

and 90Sr results, although the χ2

 test identified these results as “highly significant”, this does not 

necessarily represent a measurement concern for the LANL HENC #2. It is important to note 

that 137Cs is quantified based on a disproportionate response at the 662 keV line of 241Am 

relative to that peak’s 722 keV line, which is then attributed to 137Cs based on predetermined 

statistical spectral criteria. This results in a highly variable quantity as a function of the 

technique used to indirectly determine the quantity of 137Cs independent of the true 

measurement-related attributes of the photon measurement system, i.e., amplifier gain or detector 

reliability. Examination of the results reveals that the replicate measurements were all very close 

with a small standard deviation. Because the 137Cs value is in turn used to derive the container’s 

90Sr content by applying a scaling factor, any statistical anomaly for 137Cs will by definition also 

apply to 90Sr. 

There are no technical issues relative to the additional replicate testing for the LANL HENC #2. 

 

Technical Evaluation: PTGS

(3-1) The design and operational history of the PTGS was assessed. 

EPA found that the PTGS, which is located in Building B54-438 on Pad G in TA-54, was 

essentially unchanged since the last EPA evaluation performed in April 2005. The PTGS is an 

automated NDA system that is designed to quantify the amount of 239Pu in a 55-gallon waste 

drum and that uses a single HPGe detector to detect gamma rays emitted by 239Pu. A tungsten 

shield and collimator limit the detector view and provide shielding. In addition to measuring the 

emission rate of 239Pu, the HPGe detector also measures the attenuation of gamma rays emitted 

by a 75Se transmission source located on the opposite side of the drum from the detector. 

Detector signals were processed by an EG&G DSPECTM signal processor, and the assay was 

controlled by ANTECH’s MasterScan software package. The PTGS used a 109Cd source to 

correct for the dead time of the system. During the assay, the drum was rotated and translated 

vertically and horizontally. By viewing the drum from many positions, the operators calculate 

239Pu emission and matrix attenuation properties for each volume element (voxel) of the drum. 

Each voxel was approximately the size of 2 in.3

 (approximately 5 cm3). By summing the 

quantity of 239Pu in each voxel, the total quantity of 239Pu in the drum is calculated. During the 

inspection it was observed that the PTGS had been assigned standby operational status for 

reasons not related to performance (i.e., it was idle due to logistical factors or drum availability).

Two separate HPGe detector systems are located in Building B54-439 on Pad G in TA-54, and 

they are referred to as FRAM 1 and FRAM 3 (currently there is not a FRAM 2). FRAM 1 

consists of HPGe Detector No. 137-P407961, Nomad Analyzer SN 95 7378, and Dell Computer 

No. 1138460. FRAM 2 consists of HPGe Detector No. 40P21213B, Nomad Analyzer SN 

917943, and Dell Computer No. 1138459. Each FRAM unit has a corresponding logbook that 
50

site personnel use to record pertinent assay-related information and the system’s operational 

status. During the inspection, it was observed that both FRAM systems were on standby for 

reasons not related to performance (i.e., they were idle due to logistical factors or drum 

availability). These two systems measure the ratios of gamma-ray emitting radionuclides to 

239Pu using the FRAM software. By combining the isotopic data from one of the FRAM systems 

with the 239Pu data determined by the PTGS, site personnel calculate the total quantity of 

individual radionuclides along with other derived quantities, such as the total TRU alpha activity, 

TRU alpha activity concentration, decay heat, and plutonium equivalent curies. EPA found that 

all aspects of the PTGS and FRAM units were technically adequate and appropriately 

documented. 

The use of a different NDA system not observed during this inspection or physical modifications 

to the PTGS described above is a T1 change (see Table 1 where this is included as a T1 change). 

Changes to the software or operating range(s) of the PTGS, and to the site procedures that 

govern its use that require CBFO approval are T2 changes (see Table 1 that includes these as T2 

changes). 

(3-2) System calibration of the PTGS had been performed as required. 

NWIS-TP:05-0141, Portable TGS Mass Calibration and Calibration Confirmation for Pu-239, 

dated August 3, 2005, documents the calibration of record for the PTGS, and lists Joe Wachter as 

the originator. This was a complete recalibration that was performed in August 2005 in 

accordance with CCP-TP-123 and NWIS-TP: 2005-0131, Recalibration and Confirmation 

Plan—June 2005. The recalibration was prompted by a low bias in the weekly control check 

measurements observed beginning on June 6, 2005. The recalibration was performed using 

PDP-style encapsulated weapons-grade PuO2 sources with masses of 0 g, 0.6 g, 3 g, 10 g, 100 g, 

and 189 g in a combustible matrix. This provides an operational range of 0.565 g 239Pu (0.6 g 

total plutonium) and 176.75 g 239Pu (189 g total plutonium) that LANL-CCP states is identical to 

the system’s calibrated range. The calibration protocol and its execution were technically 

adequate and appropriately documented. In July 2005, LANL-CCP confirmed the calibration as 

required by assaying different 239PuO2 sources in a series of combinations that resulted in assay 

totals of 0.9 g, 9 g, and 160 g in the same combustible (non-interfering) matrix. The calibration 

confirmation passed the WAC-stipulated measurement criteria for precision and accuracy—

percent relative standard deviation and relative percent accuracy, respectively—and was 

technically acceptable in other aspects and adequately documented. LANL-CCP personnel 

stated that no actual waste drums for WIPP were affected by the PTGS low bias problem in 

June 2005. The EPA inspection team confirmed this by evaluating the LANL-PTGS 2006 

Operational Logbook, Control No. LANL-NDA-PTGS-003, that was located in TA-54-B438, the 

PTGS trailer. 

The FRAM units are not calibrated in the same manner as the PTGS. The FRAM software 

contains a series of internal performance checks that are executed with each and every assay 

event. These performance checks take the place of the energy versus channel and peak 

resolution calibrations (full-width-at-half maximum) that are typical of photon spectrometers. 

EPA had previously evaluated and approved the LANL FRAM operation on several occasions 

(see EPA Docket No. A-98-49, II-A4-43). 
51

The extension of or changes to the stated calibration range for the PTGS is a Tier 1 change (see 

Table 1 where this is included as a T1 change.) 

(3-3) The TMU of the PTGS had been determined and documented. 

The determination of the TMU for the PTGS was documented in two places—TWCP-09491, 

Method for Computing Total Measurement Uncertainty for the Portable TGS System, dated 

August 29, 2002, that lists David Miko as the author (also listed as Document No. P2010-0516) 

and Revision to TWCP-23398, Total Measurement Uncertainty for the Portable Tomographic 

Gamma Scanner (PTGS), dated March 30, 2005, which lists Joe Wachter as the author. The 

TMU determination included contributions from self-shielding (lumps of plutonium), source 

position/distribution, matrix properties, and system calibration. LANL-CCP personnel referred 

to these combined components as the system uncertainty. The system uncertainty, estimated to 

be 11.7%, was combined with uncertainties from counting statistics and the FRAM isotopic 

analysis, and was calculated for each individual assay to determine the TMU of the reported 

values. EPA found that the TMU for the PTGS was technically adequate and appropriately 

documented. 

(3-4) The LLD, including the MDC of the PTGS, had been determined and documented. 

CCP-PO-002, CCP Transuranic Waste Certification Plan, Revision 11, defined LLD as: 

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

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

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

The LLD of any given NDA measurement is predominantly a function of both the properties of 

the waste matrix being assayed and the environmental background. For this reason, the LLD is 

expected to vary from drum to drum and even between measurements of the same drum. NWISTP: 05-0094, Lower Limit of Detection for LANL Portable Tomographic Gamma Scanner 

(PTGS), dated March 15, 2005, documented the determination of the LLD of the PTGS. 

Although the LLD was not determined for each assay, the LLD estimated for a typical 

measurement is approximately 0.28 g 239Pu, which is considerably less than the lower end of the 

PTGS operating range of 0.565 g 239Pu. EPA found that the LLD for the PTGS was technically 

adequate and appropriately documented. 

(3-5) EPA coordinated and evaluated replicate testing of the PTGS. 

The purpose of the replicate testing during this inspection was to provide EPA with an 

independent means to verify that the PTGS could provide consistent, reproducible results for the 

determination of the quantity of 10 WIPP-tracked radionuclides (241Am, 137Cs, 238Pu, 239Pu, 

240Pu, 242Pu, 90Sr, 233U, 234U and 238U) and the TRU alpha concentration. This was accomplished 

by reassaying drums previously characterized on the same system or instrument in order to 

evaluate its ability to do the following: 

• Produce results consistent with the reported TMU (as judged by comparing the sample 

standard deviation for a number of replicate measurements taken over several hours or 

days to the reported TMU) 
52

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

judged by comparing the results of the replicate measurement(s) to the original reported 

values) 

 

As part of the inspection to certify the PTGS, EPA requested that LANL reassay a group of 

waste drums that EPA randomly selected from a list of drums previously assayed on the PTGS 

that was provided by LANL-CCP. The three were Container Nos. 52338, 53551, and 54857. At 

EPA’s request, LANL-CCP reassayed each of these previously assayed drums five times for this 

inspection. Two statistical tests, a χ2

 test and t test, were performed on the replicate data for each 

container. Attachments B.13 through B.18 to this report include analytical data for each assay 

event and results of the statistical analysis. 

The t test for Container No. 52338 showed no statistically significant differences between the 

original measurement assay values and the average of the five replicate measurements for all 

measured parameters. The t test for Container Nos. 53551 and 54857 showed “highly 

significant” flags for 238Pu, 239Pu, 242Pu and 241Am, as well as for TRU alpha activity, indicating 

statistically significant differences between the original measurement assay values and the 

average of the five replicate measurements for these radionuclides. The “highly significant” flag 

for 238Pu, 239Pu, 242Pu and 241Am, as well as for TRU alpha activity, indicates that the variances 

in the replicate measurements for these items were greater than the reported uncertainties for all 

values relative to the limits of the test. The TRU alpha activity reflects the contributions of these

and other TRU radioisotopes, and since 238Pu and 239Pu are the major contributors to this, this 

flag is expected for TRU alpha activity. Close examination of the data shows that while the 

agreement among the replicates is good, the “highly significant” flag does not appear to be an 

artifact. Specifically, the original measured values for these radionuclides for both drums clearly 

differ from the mean of the five replicates. There are several possible reasons for this—actual 

changes in the physical configuration of the drums’ contents due to movement or settling, 

discussed below; fluctuations in the measurement system’s background; or, actual changes in the 

measurement system, the aspect that this test is designed to query. Although the software 

identified these variances as “highly significant,” this does not necessarily indicate a 

measurement issue that warrants additional attention at this time. It does, however, point out one 

of the test’s limitations particularly for the PTGS which keys all radionuclide values off a single 

measured radionuclide, 239Pu. The source material (239Pu) within the drum may in fact be quite 

small in physical size and could have shifted through drum movement. The new configuration of 

239Pu within the container may represent an essentially new measurement geometry for the 

container, in violation of a test assumption that the original and replicate measurements are 

performed on the same container. Unfortunately, this is difficult to avoid since containers must 

be moved for purposes of storage, staging and analysis. There is no technical issue at this time 

relative to these highly significant flags on the χ2

 test for the PTGS. 

The χ2

 test for all three containers showed that the observed variances in the replicate 

measurements are less than or equal to the reported uncertainties for all parameters within the 

statistical limits of the test. 

Summary of NDA Findings and Concerns

The EPA inspection team did not identify any findings or concerns related to the LANL HENC 

#1, LANL HENC #2 or PTGS NDA systems during this inspection. 
53

Baseline Approval

The baseline conditions that the EPA inspection team evaluated during this inspection consist of 

the following NDA systems, as described in this report: 

• LANL HENC #1 for passive neutron- and gamma-based quantitative assays and isotopic 

determinations as described above and detailed in the LANL HENC #1 checklist 

(Attachment A.2 to this report) over the system’s calibrated mass range of LLD to 177 g 

total plutonium (12.159 g 240PuEFF) for passive neutron assays and calibrated range for 

energy and efficiency of photon emissions from 59 keV to 1,408 keV at sample densities 

between 0.018 and 1.649 g/cm3

• LANL HENC #2 for passive neutron- and gamma-based quantitative assays and isotopic 

determinations as described above and detailed in the LANL HENC #2 checklist 

(Attachment A.3 to this report) over the system’s calibrated mass range of LLD to 

16.29 g 240PuEff for passive neutron assays and calibrated range for energy and efficiency 

of photon emission from 50 keV to 1,228 keV at sample densities between 0.018 and 

1.649 g/cm3

• PTGS system for gamma-based assays of 239Pu using measured isotopic distributions 

from the FRAM 1 and/or FRAM 3 gamma systems as described above and detailed in the 

PTGS checklist (Attachment A.4 to this report) over the system’s calibrated/operational 

range of 0.565 g 239Pu to 176.75 g 239Pu 

EPA has approved each system, along with its range of applicability for disintegration rate 

(activity) and matrix and any limitations, as described in this report and detailed in the NDA 

checklists (Attachments A.2, A.3, and A.4 to this report). The LANL HENC #1 and LANL 

HENC #2 systems are currently configured to assay CH retrievably-stored debris (S5000) wastes 

and heterogeneous solid (S3000) wastes. The PTGS is currently configured to assay CH 

retrievably-stored debris (S5000) wastes. The use of NDA equipment other than these three 

systems as described in this report, or physical modifications to these systems is a T1 change 

(see Table 1 where this is included as a T1 change). This is discussed in the following section. 

NDA Tiers

Based on the inspection and the results discussed above, EPA assigns the following tiers: 

T1 NDA changes require EPA review and approval prior to implementation. They include the 

following: 

• New NDA equipment9

 

9

 New NDA equipment refers to a system or component not previously evaluated by EPA. Specifically, this is 

defined as a physically distinct or different system or apparatus; an assay system that is reported to be the equivalent 

of or identical to a previously approved system, but which has not been formally inspected and approved by EPA, is 

a new system and must be approved by EPA prior to implementation to characterize WIPP wastes. 
54

• Physical modifications to approved equipment10 

• Extension or changes of an approved calibration range(s) for approved equipment 

The last bulleted item above refers to the extension of a system’s approved calibration range with 

respect to determination of the disintegration rate (activity) or physical characteristics (matrix) of

any of the two NDA systems approved as a result of this inspection. An EPA technical 

inspection involves the evaluation of several characteristics of a measurement system. A key 

characteristic is the range of conditions for which the instrument is capable of producing 

technically defensible data with respect to the following two aspects: 

• Activity—the nuclear disintegration rate of specific radiation types (neutron or gamma), 

typically special nuclear material or TRU radionuclides; units of activity and mass are 

interchangeable 

• Physical characteristics—the physical attributes of waste matrices as they relate to a 

radiometric system (i.e., how the matrix’s physical properties interact with the radiations 

that originate within the sample and affect the system’s ability to detect them); examples 

include attenuation of photons (gamma) and moderation and absorption of neutrons 

During the inspection, the system’s technical capabilities being evaluated represent the 

conditions observed, and they define the operational envelope in which WIPP measurements will 

occur. Changes to a system’s calibrated range with respect to disintegration rate and/or matrix 

may represent an essentially different set of conditions from those evaluated during the 

inspection. For this reason, a change to a system’s calibrated range is considered a T1 change. 

A system’s operating range is generally, but not always, a subset of a calibration range; that is, 

systems that are calibrated to make valid measurements from 0 to 200 g of WG Pu or total 

plutonium typically operate in a smaller range, the system’s LLD to 177 g for WIPP. In the case 

of the LANL PTGS, the calibrated and operational ranges are identical (i.e., 0.56 to 176.79 g 

239Pu). Provided the system’s calibrated range is valid, a site can designate a different operating 

range(s) within the calibrated range as a T2 change (i.e., a subset of the calibrated range). 

Similarly, for physical characteristics NDA systems are often calibrated with respect to a range 

of sample attributes—for example, a matrix density range upper limit of 1.649 g/cm3 for the 

LANL HENC systems discussed earlier in this report. This range may include materials that are 

commonly referred to using terms such as “debris (S5000)” and “solids (S3000),” both of which 

are within the calibrated density range. Actual waste assays may be restricted to a portion or 

subset of this range (i.e., debris only, for a variety of technical and/or administrative reasons). 

Changing the calibrated range by extending it beyond 1.649 g/cm3

 for either of the LANL HENC 

systems would constitute a T1 change. Provided the original density range is valid, changing the 

operational range(s) of an approved NDA system—that is, decreasing it relative to the originally 

approved density range—is a T2 change, as discussed below. 

LANL-CCP will report and submit documentation for T1 changes when it is ready for EPA 

review. In the case of the first two T1 NDA changes listed above, DOE should assume that an 

 

10 Changes to existing NDA equipment include all changes and/or modifications to approved equipment that

have the potential to affect the quality of NDA data used for the purposes of WC and/or waste isolation. This does 

not include minor changes or safety-related changes (e.g., addition of handrails) that do not have the potential to 

affect WC data. 
55

EPA inspection is likely. In the case of the last T1 NDA change, EPA will inform LANL-CCP 

and CBFO whether a site inspection is necessary. EPA may request additional information, 

choose to conduct a desktop review, and/or confer with LANL-CCP NDA personnel. Upon 

evaluation (with or without site inspection), EPA will issue an approval letter and only upon 

receiving the EPA approval can LANL-CCP continue to use the equipment affected by the 

change. 

T2 NDA changes do not require prior EPA approval but do require LANL-CCP to notify EPA 

upon implementation of such changes and submit a brief description of the changes. These 

include the following: 

• Changes to software for approved equipment 

• Changes to the approved operating range(s) of approved NDA systems upon CBFO 

approval (see discussion above) 

• Changes to procedures that require CBFO approval 

Examples of the first bulleted item above would include the following: 

• Changing a system’s operating system (e.g., first use of Canberra NDA 2000) 

• Identification of a systematic problem with a software package and subsequent 

modifications to address the problem, (e.g., use of an incorrect value for a radionuclide’s 

transition probability (branching ratio) in NDA 2000) 

• Introduction of a new version of an existing software package beyond what is in current 

use 

Regarding the second bulleted item above, reducing a system’s operating range because of 

performance-related problems or equipment failure would be a T2 change. For example, if the 

PTGS failed to pass a PDP cycle for a specific matrix or activity range and its use for those were 

formally restricted by the site or CBFO, this would be a T2 change. 

The above T2 changes to the WC activities from the date of the baseline inspection must be 

reported to and approved by EPA according to Table 1. Following EPA approval, LANL-CCP 

will notify EPA of T2 changes along with a summary of each T2 change at the end of each fiscal 

year quarter. EPA will evaluate the information and communicate with LANL-CCP as to 

whether EPA needs additional information for further evaluation, whether the changes raise any 

concerns requiring LANL-CCP response, or whether LANL-CCP can continue to implement the 

changes. Consistent with EPA’s authority under 194.24(h), EPA may request information 

relative to these changes if EPA deems the information is necessary to ensure continued 

compliance with EPA regulations. 
56

8.3 Real-Time Radiography 

WC Element Description

As part of the inspection of the RTR activities, the EPA inspection team focused on overall 

procedural technical adequacy and implementation, as well as the identification of WMPs and 

prohibited items, in reviewing the following RTR elements: 

• Documentation of RTR activities through use of an approved procedure 

• Proper execution of RTR activities 

• Management oversight and independent review of RTR activities 

• Training of RTR personnel 

The RTR facility uses radiography to help determine the following aspects of TRU WC: 

• Types and amounts of WMPs 

• Presence or absence of prohibited items 

• Testing for new operators on the RTR system using specifically placed items 

Documents, BDRs, and Objective Evidence Reviewed

The following documents were among those the EPA inspection team examined to assess 

whether all RTR operations follow the appropriate approved procedures: 

• CCP-TP-053, Revision 4, CCP Standard Real-Time Radiography (RTR) Inspection 

Procedure, December 22, 2005 

• CCP-TP-028, Revision 3, Radiography Test and Training Drum Requirements, 

January 19, 2006 

• CCP-QP-002, Revision 20, Training and Qualification Plan, May 3, 2006 

• CCP-TP-001, Revision 11, Project Level Data Validation and Verification, March 23, 

2005 

• CCP-QP-008, Revision 11, Records Management, August 22, 2005 

• CCP-TP-003, Revision 14, Sampling Design and Data Analysis for RCRA 

Characterization, September 3, 2003 

• RTR BDRs LA-RTR2-05-0103, LA-RTR2-05-0111, LA-RTR2-05-0112, LA-RTR2-05-

0194, LA-RTR2-04-0007, LA-RTR2-05-0123, LA-RTR2-05-0152, LA-RTR2-05-0175, 

LA-RTR1-06-0001, LA-RTR1-06-0002, LA-RTR1-06-0003 
57

The following is a complete listing of all objective evidence the EPA team evaluated during the 

inspection: 

• RTR BDRs LA-RTR2-05-0103, LA-RTR2-05-0111, LA-RTR2-05-0112, LA-RTR2-05-

0194, LA-RTR2-04-0007, LA-RTR2-05-0123, LA-RTR2-05-0152, LA-RTR2-05-0175, 

LA-RTR1-06-0001, LA-RTR1-06-0002, LA-RTR1-06-0003 

• Audio/visual recording of RTR events for BDRs LA-RTR1-06-0001, LA-RTR1-06-0002, 

LA-RTR1-06-0003, LA-RTR2-05-0103, LA-RTR2-05-0111, LA-RTR2-05-0112, LARTR2-05-0194 

• Waste Content Codes, Revision 12 

• PowerPoint presentation for operational training for waste stream LA-MHD02.001

• LANL-NDE-TEST-001-CL, Latest capability demonstration drum audio/visual recording 

for RTR subject matter expert (SME), May 3, 2006 

• Latest capability demonstration drum audio/visual recording for RTR operator, July 21, 

2005 (no longer qualified) 

• List of currently qualified RTR personnel 

• CCP-AK-LANL-007 

Technical Evaluation

During the inspection, the EPA team investigated the following technical elements of the RTR 

process (see also Attachment A.5 to this report): 

(1) Overall procedural technical adequacy and implementation were considered. 

The RTR procedure, documented in CCP-TP-053, Revision 4, Standard Real-Time Radiography 

(RTR) Inspection Procedure, contained specific information on performing non-intrusive 

radiography, including operational setup and checkout, identification of prohibited items, 

assignment of WMPs and estimation of weights and volumes, confirmation of WMCs, input of 

data, issuance of NCRs, and technical review of radiography results. 

(2) Characterization of WMPs and prohibited items was assessed. 

Procedure CCP-TP-053, Revision 4, required that radiography audio/visual recording equipment 

verification be conducted at the beginning of every shift in which drums are subject to 

examination. EPA inspectors confirmed adherence to verification requirements through 

interviews with RTR operators, observation of the RTR events for containers S852566 (RTR 

Unit 1, S5000) and 58959 (RTR Unit 2, S5000), and review of audio/video tapes for Batches 

LA-RTR1-06-0001, LA-RTR1-06-0002, LA-RTR1-06-0003, LA-RTR2-05-0103, LA-RTR2-05-

0111, LA-RTR2-05-0112, and LA-RTR2-05-0194. 

At the beginning of a shift and before examining any waste containers, the operator runs a scan 

on the lines-pair resolution test gauge to determine that images are clearly visible. On the day of 

the inspection, the operator had performed this check before EPA arrived at the facility, but the 
58

inspectors reviewed the image quality checks for Batches LA-RTR2-05-0103 and LA-RTR1-06-

0003. Operators for both RTR units did not have a copy of the waste stream description 

available for review and could not explain how they answered questions on the RTR data sheet 

with regard to waste stream description. EPA generated Concern LANL-CCP-VE-06-005CR to 

address this issue (see Attachment C.5 to this report for a copy of this form) that is discussed in 

Section 8.4. 

For each container undergoing examination, the operator makes an audio/video recording of the 

RTR event. The first notations that the operator makes on the audio/video recording are the 

drum number and the date and time on the audio/video recording before beginning the 

radiography process. The examination of the drum begins at the top drum lid, where the operator 

identifies the seal and vent. The drum rotates through at least 360 degrees, so that objects are 

visible from all sides. The operator can zoom both in and out and increase or decrease the scan 

energy in order to compensate for varying densities in the material being examined. During 

examination, the operator also “rocks” the drum to determine the presence of free liquids. 

The RTR operator identifies WMPs, and a second staff member enters the data electronically 

into the RTR Data Sheet. This second person is not a qualified RTR operator and performs only 

data entry. There is a standardized weight table (Table 3) in the procedure that provides weights 

for commonly encountered waste items. RTR personnel record the weight of leaded rubber 

gloves as rubber only. However, VE personnel record the weights of leaded rubber gloves as 

60% rubber and 40% other metals. EPA generated concern LANL-CCP-VE-06-006CR to 

address this discrepancy in WMP weight assignment (see Attachment C.6 to this report for a 

copy of this form) that is discussed in Section 8.3. 

As part of the inspection, the EPA team observed the examination of two waste containers—

Container S852566 on RTR Unit 1 and Container 58959 on RTR Unit 2. Both of these drums 

contained S5000 waste. The EPA inspectors also reviewed the audio/visual recordings of 

Containers S834121 and S831784 (LA-RTR2-05-0103), S834131 and S831722 (LA-RTR2-05-

0111), S834116 (LA-RTR2-05-0112), S845058 (LA-RTR2-05-0194), S851999 (LA-RTR1-06-

0003), 52473 (LA-RTR1-06-0001), and S846186 (LA-RTR1-06-0002), and their associated data 

forms. In all cases the information on the audio/visual recording matched the written RTR 

record (BDR). 

(3) Documentation of radiography activities was examined. 

Simultaneous audio and video recordings are made as the waste is examined. The EPA 

inspectors observed this during the examination of two waste containers and further verified it by 

review of RTR audio/visual recordings for the above-referenced waste containers. Site 

personnel enter the data into an electronic radiography data sheet during the RTR event. 

(4) EPA ascertained that documentation of radiography procedures was adequate. 

Radiography procedures are well defined and the documents are controlled. During the 

inspection, the EPA team reviewed the adequacy and implementation of all radiography-related 

procedures. QC examinations were performed as required by the procedure. In Batch LARTR1-06-0002, an independent observation was performed on Container 54374 and a replicate 

scan was performed on Container 55434. In Batch LANL-RTR2-05-0123, an independent 
59

observation was performed on Container 59316 and a replicate scan was performed on 

Container 57776. For the QC replicate, different operators performed the original and the 

replicate scan. 

Site personnel generate NCRs as needed. For example, NCR-LANL-0786-06 was initiated for 

Drum S833213 because of a sealed container greater than 4 liters, and NCR-LANL-0727-06 was 

initiated because of the presence of polychlorinated biphenyls. NCR-LANL-0125-05 was 

initiated for Drum S834116 because it contained greater than 1 inch of liquid at the 30-inch mark 

and a liquid volume that exceeded 1-percent of the drum’s volume. 

The BDRs the EPA examined had been reviewed at the data generation level (ITR, TS, FQAO) 

and project level (SPM and SPQAO) as required. 

(5) Training of radiography personnel was adequate. 

During the inspection, the EPA team reviewed documentation of the capability demonstration for 

selected radiography personnel. The inspectors viewed the audio/visual recording for the latest 

capability demonstration drum for an RTR SME and RTR operator during the inspection. 

Training records reviewed indicate that only trained personnel were operating the RTR 

equipment and that the technical supervisor is responsible for the verification of qualification for 

RTR operators. RTR operators must review the results of the RTR/VE comparison 

examinations, but they had not received “lessons learned” training for the last two annual 

VE/RTR comparison reports. EPA presented this on an EPA Inspection Issue Tracking Form 

(see Attachments C.8 of this report for a copy of this form) and it is discussed below. 

EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-RTR-06-008C. LANL-CCP 

has generated two annual VE/RTR comparison reports, but at the time of this inspection, RTR 

operators had not received any “lessons learned” training on the discrepancies between the RTR 

and VE results. 

Resolution: This concern did not require a response. 

Status of Concern: This concern is closed. 

Training documentation was complete and was filed correctly for purposes of viewing and 

reference. The documents reviewed include the following: 

• List of currently qualified RTR personnel 

• PowerPoint presentation for operational training for Waste Stream LA0MHD02.001 

EPA inspectors also viewed the following RTR test drum audio/visual recording and verified 

that the operator identified all prohibited items: 

• Requalification checklist and audio/visual recording for RTR SME and RTR operator 
60

Summary of RTR Findings and Concerns

The EPA inspection team did not identify any findings related to RTR and identified the one 

concern that is discussed above. A copy of the EPA Inspection Issue Tracking Form on which 

this concern is documented is provided in Attachment C.8 of this report. EPA considers this 

concern to have been adequately addressed and there are no open findings or concerns related to 

RTR resulting from this inspection. 

Baseline Approval

The baseline conditions that the EPA inspection team evaluated during this inspection consisted 

of the following: 

• Trained personnel—operator/ITR/TS/FQAO and SME 

• Approved and controlled operating procedures—CCP-TP-053, Revision 4; CCP-TP-028, 

Revision 3; CCP-TP-003, Revision 14; CCP-TP-001, Revision 11; CCP-QP-002, 

Revision 20 

• RTR Units 1 and 2 

• RTR records and supporting data—RTR electronic data recording forms, CCP-TP-053 

review checklists, CCP-TP-001 review checklists, and RTR BDRs 

This system is suitable for RTR of S5000 (debris) and S3000 (solid) wastes. 

RTR Tiers 

Based on the inspection and the results discussed above, EPA assigns the following tiers: 

T1 RTR changes: None. 

T2 RTR changes do not require prior EPA approval but do require LANL-CCP to notify EPA 

upon implementation of such changes and submit a brief description of the changes. These 

include the following: 

• New RTR equipment or modifications to approved equipment 

• Changes made to RTR procedure(s) that require CBFO approval 

The above T2 changes to the WC activities from the date of the baseline inspection must be 

reported to and approved by EPA according to Table 1. Following EPA approval, LANL-CCP 

will notify EPA of T2 changes along with a summary of each T2 change at the end of each fiscal 

year quarter. EPA will evaluate the information and communicate with LANL-CCP as to 

whether EPA needs additional information for further evaluation, whether the changes raise any 

concerns requiring LANL-CCP response, or whether LANL-CCP can continue to implement the 

changes. Consistent with EPA’s authority under 194.24(h), EPA may request information 

relative to these changes if EPA deems the information is necessary to ensure continued 

compliance with EPA regulations. 
61

8.4 Visual Examination 

WC Element Description

The VE process for retrievably-stored waste uses manual examination to determine the following 

aspects of TRU WC: 

• Confirmation of WMP and WMC 

• Confirmation of presence or absence of prohibited items 

• Confirmation of RTR analysis 

• Generation of data for calculation of miscertification rates

Procedure CCP-TP-113 is used to perform VE as a QC check of RTR and VE in lieu of RTR. 

Documents, BDRs, and Objective Evidence Reviewed

The following documents were among those the EPA reviewed to assess whether VE operations 

follow the appropriate approved procedures and meet VE requirements: 

• CCP-TP-113, Revision 4, CCP Standard Waste Visual Examination, December 22, 2005 

• CCP-QP-002, Revision 20, Training and Qualification Plan, May 3, 2006 

• CCP-TP-001, Revision 11, Project Level Data Validation and Verification, March 23, 

2005 

• CCP-QP-008, Revision 11, Records Management, August 22, 2005 

• CCP-TP-003, Revision 14, Sampling Design and Data Analysis for RCRA 

Characterization, September 3, 2003 

• VE in lieu of RTR BDRs LAVE540025, LAVE500081 (unvalidated BDR for 

demonstration drum) 

• VE as a QC check of RTR BDRs LAVE540027, LAVE500060, LAVE500061 

Following is a complete list of all objective evidence that the EPA inspection team evaluated 

during the inspection: 

• VE BDRs LAVE540025, LAVE500081, LAVE540027, LAVE500060, LAVE500061 

• Audio/visual recording for BDRs LAVE540025, LAVE540027, LAVE500060, 

LAVE500061 

• List of currently qualified VE personnel 

• Qualification cards for two VEEs 

• List of rejected containers for VE as a QC check of RTR 

• Letter, 2006 Selection of Visual Examination Drums from S3000 and S5000 Category 

Groups, March 23, 2006 
62

• Memorandum, Initial Summary Category Group-Specific S3120 Miscertification Rate, 

April 26, 2005 

• Memorandum, Los Alamos National Laboratory Annual Assessment of the Site Specific 

Annual Miscertification Rate (S3000 and S5000), February 10, 2006 

• Memorandum, 2005 Selection of Visual Examination Drums from S3000 Summary 

Category Group, March 30, 2005 

• Memorandum, 2005 Selection of Visual Examination Drums from S3000 Summary 

Category Group, June 27, 2005 

• Memorandum, Initial Summary Category Group-Specific S5000 Miscertification Rate, 

March 29, 2005 

• Memorandum, Waste Material Parameter Weight Comparison Report for Los Alamos 

National Laboratory April 2004 Through March 2005 (Relative Percent Difference 

Comparison Report for Radiography and Visual Examination), April 12, 2005 

• Memorandum, Waste Material Parameter Weight Comparison Report for Los Alamos 

National Laboratory June 2004 Through April 2005 (Relative Percent Difference 

Comparison Report for Radiography and Visual Examination): Waste Stream LAMIN03-NC.001, May 26, 2005 

• Memorandum, Waste Material Parameter Weight Comparison Report for Los Alamos 

National Laboratory April 2005 Through December 2005 (Relative Percent Difference 

Comparison Report for Radiography and Visual Examination), February 7, 2006

Technical Evaluation

During the inspection, the EPA team evaluated the technical elements of the VE process using 

the checklist included as Attachment A.6 to this report. These areas are summarized as follows: 

(1) Overall procedural technical adequacy and implementation were assessed. 

The VE procedure, documented in CCP-TP-113, Revision 4, contained specific information on 

performing VE, including operational setup and checkout, identification of prohibited items, 

assignment of WMPs and estimation of weights and volumes, confirmation of WMCs, input of 

data, issuance of NCRs, and technical review of VE results. 

(2) Characterization of WMPs and prohibited items was evaluated. 

During the inspection, EPA observed VE in lieu of RTR for a debris (S5000) drum (Drum 

601142), and the VE event took place in a glove box in Room 102 of Building 69 at TA-50. The 

operators had already successfully performed the audio/visual check for the day of the 

demonstration before the EPA inspection team arrived. The EPA inspectors did, however, verify 

that audio/visual checks were successfully completed by reviewing tapes for BDR Nos. 

LAVE540025, LAVE540027, LAVE500060, LAVE500061, as well as the unvalidated batch 

from the demonstration for LAVE500081. The inspectors reviewed audio/visual tapes in 

conjunction with the written record (BDR) to ensure consistency of the visual and written 

records. The EPA inspection team did not identify any discrepancies for the BDRs reviewed. 
63

For the demonstration, the drum contents were emptied, sorted by WMP, and weighed. The 

EPA inspectors observed the scale calibration performed for this batch. These personnel record 

the weights for leaded rubber gloves as 60% rubber and 40% other metals. However, the RTR 

process assigns the entire weight of the leaded rubber glove weights to rubber. In order to 

address the discrepancy between RTR and VE data recording, the EPA inspectors initiated an 

EPA Inspection Issue Tracking Form (see Attachment C.6 to this report for a copy of this form), 

and it is discussed in Section 8.3 and below. 

EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-VE-06-006CR. Site personnel 

inconsistently recorded WMP weights for leaded rubber gloves. RTR personnel record leaded 

gloves only under the rubber WMP, but VE personnel assign 60% of the weight of the gloves to 

rubber and 40% to other metals. VE personnel were unable to provide the rationale for assigning 

the material weights in this manner. This concern required a response. 

Resolution: The LANL-CCP VPM and SPM gave verbal directions to stop this practice and 

provided training on June 22, 2006. CCP will assign the weight of leaded rubber gloves as 100% 

rubber. 

Status of Concern: This concern is closed. 

When reviewing the BDRs for four data packages, EPA reviewed the audio/visual recording 

concurrently with the BDR to ensure that the data contained in both were the same. By review 

of the audio/visual recordings, EPA also verified that image quality checks were performed as 

required. The EPA inspectors reviewed the BDRs listed below: 

• BDR LAVE540025 (VE in lieu of RTR, S3000) 

• Audio/visual recording for BDRs LAVE540025 

• BDR LAVE500081 (unvalidated BDR for demonstration drum, VE in lieu of RTR, 

S5000) 

• BDR LAVE540027 (VE as a QC check of RTR, S3000) 

• Audio/visual recording for BDRs LAVE540027 

• BDR LAVE500060 (VE as a QC check of RTR, S5000) 

• Audio/visual recording for BDRs LAVE500060 

• BDR LAVE500061 (VE as a QC check of RTR, S5000) 

• Audio/visual recording for BDRs LAVE500061 

The EPA inspectors found that all data packages reviewed were correctly completed and had 

been reviewed at both the data generation and project level. 

It is the policy of LANL-CCP to open all bags during VE, although the VEE is permitted to 

document decisions with regard to opening bags in the BDR. The drums from BDR 

LAVE500061, reviewed by the EPA inspectors, contained numerous small cans. The VE 

operators did not completely empty the cans before weighing, and it was unclear how the 

operators provided a complete inventory of the items inside the cans and how they were able to 

verify the absence of prohibited items. The VE data forms did not include any justification for 
64

not emptying the cans. EPA presented this as a Finding on an EPA Inspection Issue Tracking 

Form (see Attachment C.4 to this report for a copy of this form) and it is discussed below. 

EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-VE-004F: AK Summary 

CCP-AK-LANL-004 did not predict the quantity and location of prohibited liquid encountered in 

the RTR examinations of containers performed prior to May 2005 from waste stream 

LA-MIN03-NC.001. Although characterization personnel initiated NCRs to address the 

presence of prohibited liquids, this information was not communicated to AK personnel to 

enable updating of the AK record. CCP personnel used VE in lieu of RTR to characterize wastes 

from this same waste stream from May 4, 2005, through June 23, 2005. However, the presence 

of liquids made the use of this technique unsuitable for containers of solid (S3000) wastes. Until 

corrective action is taken, the use of this technique to characterize WIPP wastes, in particular 

dewatered sludge, at CCP sites is unacceptable. 

Resolution: CBFO Interpreted this finding as a prohibition of the use of VE for all solid 

(S3000) waste streams throughout the DOE complex. This was not EPA’s intention and EPA 

provided verbal clarification to CBFO regarding this on multiple occasions. EPA did intend this 

finding to prohibit the use VE for de-watered sludge containers at LANL-CCP and to prompt 

CBFO to reexamine the use of VE for similar wastes throughout the complex. During the 

follow-up March 6, 2007 inspection LANL-CCP committed to conducting additional training for 

the SPMs and AKEs to develop and issue, as necessary, a memorandum that will be included in 

the AK record to document special characterization requirements for S3000/S4000 summary 

category group wastes. The purpose of this memorandum is primarily to document the technical 

basis for the decision to use VE in lieu of RTR. 

Status of Concern: This concern is closed. 

There was another concern identified relative to the documentation of WMPs during the 

inspection. EPA presented this as a Concern on an EPA Inspection Issue Tracking Form (see 

Attachment C.7 of this report for a copy of this form) and it is discussed below. 

EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-VE-06-007CR: The containers 

examined by VE in BDR LAVE500061 (VE as a QC check of RTR) contained numerous small 

cans that were opened but not emptied during the VE event. LANL-CCP personnel were unable 

to demonstrate that all of the WMPs contained in the cans were inventoried, and the VE 

procedure does not address this circumstance. 

Resolution: During the follow-up March 6, 2007 inspection LANL-CCP committed to 

conducting additional training for the VE operators and VE experts to emphasize the importance 

of including a greater amount of audible content (verbal) on the recordings made during the VE 

events to allow an independent person to reach the same conclusion as the VE operator or VE 

expert. 

Status of Concern: EPA expects to receive objective evidence during the public comment 

period documenting the completion of the VE training performed in response to this concern. 

This concern is closed. 
65

(3) Documentation of VE activities was examined. 

EPA inspectors reviewed data packages listed in paragraph (2) above to verify that the VE data 

were documented correctly and completely. Site personnel use a VE data form for data entry 

(CCP-TP-113, Attachment 1). Except for LAVE500081, all the data packages reviewed 

included completed data generation and project-level review checklists. Site personnel make 

audio/visual recordings of the VE events, and the EPA inspection team viewed the recordings for 

the BDRs listed above to ensure consistency of the recorded data. Site personnel entered the 

data that were generated during the VE event observed by the EPA inspectors into electronic 

data forms. Table 4 in the procedure, “Waste Item Weights and Weighing Codes,” contains 

standardized weights for items commonly found in the waste streams examined. 

EPA identified an issue with the documentation of VE activities during this inspection. This was 

presented as a Concern on an EPA Inspection Issue Tracking Form (see Attachment C.5 to this 

report for a copy of this form) and it is discussed in Section 8.3 and below. 

EPA Inspection Issue Tracking Form, Issue No. LANL-CCP-VE-06-005CR. Attachments 

used for data entry for both RTR and VE include a line item that requires operators to verify that 

the waste examined matches the waste stream’s description. The VEE for the VE demonstration 

and the operators of RTR units 1 and 2 who were observed by the EPA inspectors on May 24, 

2006, could not explain how to complete this line item. These personnel did not have a copy of 

the waste stream descriptions (e.g., CCP-LANL-AK-9) in their respective work areas, nor were 

they able to describe the items included in the waste stream descriptions provided in the AK 

summary report for the waste stream they were currently examining. 

Resolution: Prior to the March 6, 2007, follow-up inspection, EPA reviewed a copy of the 

LANL-CCP RTR and VE Training Module (PowerPoint presentation) and the Non Destructive 

Examination (NDE) RTR Comprehensive Examination. During the March 2007 follow-up 

inspection, EPA interviewed RTR operators who were able to correctly answer questions with 

the regard to the items on the data form that are detailed above. The operators also demonstrated 

to EPA that they had access to both paper and electronic copies of the applicable AK waste 

stream descriptions. 

Status of Concern: This concern is closed. 

(4) Calculation of miscertification rates was examined.

At the time of the inspection, LANL-CCP had calculated a miscertification rate for summary 

category group (SCG) S5000 (debris) and S3000 (solids). Various interoffice memoranda 

establish the miscertification rate for S5000 and S3000 waste. LANL-CCP correctly established 

the number of containers to be examined by VE, and container numbers were randomly selected. 

LANL-CCP selected extra containers to ensure that replacement containers were identified if 

they were required. Site personnel documented the reason for rejecting any container. The 

algorithm used for the calculation was appropriate.

EPA examined the following miscertification rate objective evidence: 
66

• Memorandum, Los Alamos National Laboratory Annual Assessment of the Site Specific 

Annual Miscertification Rate (S3000 and S5000), February 10, 2006 

• Memorandum, 2005 Selection of Visual Examination Drums from S3000 Summary 

Category Group, March 30, 2005 

• Memorandum, 2005 Selection of Visual Examination Drums from S3000 Summary 

Category Group, June 27, 2005 

• Memorandum, Initial Summary Category Group-Specific S5000 Miscertification Rate, 

March 29, 2005 

• Memorandum, Waste Material Parameter Weight Comparison Report for Los Alamos 

National Laboratory April 2004 Through March 2005 (Relative Percent Difference 

Comparison Report for Radiography and Visual Examination), April 12, 2005 

• Memorandum, Waste Material Parameter Weight Comparison Report for Los Alamos 

National Laboratory June 2004 Through April 2005 (Relative Percent Difference 

Comparison Report for Radiography and Visual Examination): Waste Stream LAMIN03-NC.001, May 26, 2005 

• Memorandum, Waste Material Parameter Weight Comparison Report for Los Alamos 

National Laboratory April 2005 Through December 2005 (Relative Percent Difference 

Comparison Report for Radiography and Visual Examination), February 7, 2006

• List of rejected containers for VE as a QC check of RTR

(5) Training for VE personnel was examined. 

The site maintains a list of qualified individuals, which it uses to ensure that all training is 

current. The site documents the personnel who are trained for VE, which includes VET because 

both VE and VET are performed by personnel from the same pool of qualified individuals. 

During the inspection, the EPA team reviewed the qualification packages for both 

characterization and facility VE personnel and found that they require comprehensive and 

adequate training for VE personnel. 

The EPA inspectors reviewed the following records: 

• VE operator/ITR/TS/FQAO qualification card for two VEEs 

• List of qualified VE personnel 

Summary of VE Findings and Concerns

The EPA inspection team identified the one finding and three concerns related to VE that are 

discussed above. Copies of the EPA Inspection Issue Tracking Forms are provided in 

Attachments C.4 through C.7 of this report. EPA considers all findings and concerns to have 

been adequately addressed and there are no open findings or concerns related to VE resulting 

from this inspection. 
67

Baseline Approval

The VE system for retrievably-stored waste that the EPA inspection team evaluated during this 

baseline inspection consisted of the following elements: 

• Trained personnel—VE operators, VEEs, SPM, and SPQAO 

• Approved and controlled operating procedures—CCP-TP-113, Revision 4; CCP-TP-028, 

Revision 3; CCP-TP-003, Revision 14; CCP-TP-001, Revision 11; CCP-QP-002, 

Revision 20 

• VE records and supporting data—electronic VE data form, CCP-TP-053 review 

checklists, CCP-TP-001 review checklists, and VE BDRs 

VE as a QC check of RTR and VE in lieu of RTR are suitable for S5000 debris and S3000 solid 

waste. 

However DOE is not required to maintain the ability to perform VE as a QC check of RTR (see 

EPA letter of December 6, 2006). 

VE Tiers 

Based on the inspection and the results discussed above, EPA assigns the following tiers: 

T1 VE changes: None. 

T2 VE changes do not require prior EPA approval but do require LANL-CCP to notify EPA 

upon implementation of such changes and submit a brief description of the changes. These 

include the following: 

• Changes made to site VE procedure(s) that require CBFO approval

Item below is listed as a T2 item under the AK section but is based on a VE concern: 

• AK-VE Memoranda related to VE and/or RTR techniques

The above T2 changes to the WC activities from the date of the baseline inspection must be 

reported to and approved by EPA according to Table 1. Following EPA approval, LANL-CCP 

will notify EPA of T2 changes along with a summary of each T2 change at the end of each fiscal 

year quarter. EPA will evaluate the information and communicate with LANL-CCP as to 

whether EPA needs additional information for further evaluation, whether the changes raise any 

concerns requiring LANL-CCP response, or whether LANL-CCP can continue to implement the 

changes. Consistent with EPA’s authority under 194.24(h), EPA may request information 

relative to these changes if EPA deems the information is necessary to ensure continued 

compliance with EPA regulations. 

8.5 Sealed-Source Visual Examination Technique 

WC Element Description
68

The VET process for sealed sources uses manual examination to determine the following aspects 

of TRU WC: 

• Confirmation of WMP and WMC 

• Confirmation of the presence or absence of prohibited items 

Procedure CCP-TP-069, CCP Sealed Source Visual Examination and Packaging, Revision 3, 

dated December 7, 2005, is used for VET of sealed sources. 

Documents, BDRs, and Objective Evidence Reviewed

The following documents were among those reviewed to assess whether VET operations follow 

the appropriate approved procedures and meet VE requirements: 

• CCP-TP-069, Revision 3, CCP Sealed Source Visual Examination and Packaging, 

December 7, 2005 

• OSR-OP-180, Revision 0, Assembly Procedure for LANL Special Form Capsule, 

Model II, May 10, 2005 

• CCP-QP-002, Revision 21, Training and Qualification Plan, June 13, 2006 

The following is a complete listing of all objective evidence that was evaluated during the 

inspection: 

• BDR LA06-OSR-VE-002 

• Attachment 4 from CCP-TP-069 for sources processed during EPA’s observation of a 

VET event, performed at an offsite location 

• Qualification cards for VET operator/ITR/TS/FQAO and VE SME 

Technical Evaluation

During the inspection, the technical elements of the sealed source VET process were evaluated 

using the checklist contained in Attachment A.7 and are summarized below. 

(1) Overall procedural technical adequacy and implementation was evaluated. 

The VET procedure, documented in CCP-TP-069, Revision 3, contains specific information on 

performing VET of sealed sources, including the identification of prohibited items, assignment 

of WMPs, and estimation of weights. The procedure also contains instructions for closing of 

POC, if used, and drum. The special form capsule, used to receive sources and, when closed, to 

form the sealed source, is tested before use in accordance with LANL Procedure OSR-OP-180, 

Assembly Procedure for LANL Special Form Capsule, Model II, Revision 0, dated May 10, 

2005. Attachment 4 of procedure CCP-TP-069 is used to record all the VE data generated. 

(2) Characterization of WMPs and prohibited items was evaluated. 
69

EPA observed the packaging of four 241Am (80 mCi each) sources at Radiation Technology, Inc., 

located at 8407 Skyline Avenue, Odessa, Texas. The LANL personnel who performed this VET 

event were a VET operator, a VET packager, and a Radiological Control Technician (RCT). 

Prior to arriving at the site, the LANL personnel compiled a work plan that included information 

on the source’s radionuclides, expected activity, AK Summary, and waste stream description, as 

available. The special form capsule was inspected for usability at the start of the process in 

accordance with LANL procedures. The VET operator inspected the sources to locate any 

identification or other markings but found none on the sources to be packaged. Prior to loading, 

the special form capsule is etched with information about the sealed sources to be placed in it, a 

step that is not required by CCP-TP-069 but is required in Section 7.3c of OSR-OP-170. As part 

of the VET event, the operators verify that no prohibited items are present and that the WMC is 

correct. These data are entered into Attachment 4, Container Packaging and VE Data Record, to 

Procedure CCP-TP-069. These sealed sources are designated as WMC S5100 (debris). 

(3) Documentation of VET activities was examined. 

The VET operator completed Attachment 4 to Procedure CCP-TP-069 electronically as 

information became available. The data recorded included the presence/absence of prohibited 

items, WMC, POC, and drum closure. Other information included the following: 

• Drum LA00000062745 

• Filter NucFil-013, Serial No. LC-734, December 2002 

• POC Filter UT9400, Serial No. 025194, January 2003, S100 (6-inch pipe component) 

• Capsule Model II-1-0268 

• Outside TID No. LANL 001416 

EPA reviewed BDR LA06-OSR-VE-002 to verify that the data sheets were complete. Both 

data-generation level and project-level review checklists were completed and attached to the 

BDR. 

(4) Training for VET personnel was examined. 

The site maintains a list of qualified individuals, which is used to ensure that only qualified 

individuals conduct operations. Personnel who perform sealed source VET are listed under the 

“Off-site Source Recovery Project, Visual Examination” section of the list of qualified 

individuals. This list included the two VET operators who performed the offsite VET event 

observed by EPA. As part of the inspection, the EPA team reviewed the qualification cards for 

two VET operators, one of whom was a designated SME. The qualification cards demonstrated 

that training for these personnel was current and complete for VET of sealed sources. 

The inspectors reviewed the following records: 

• VET operator/ITR/TS/FQAO qualification card 

• VETSME qualification card 
70

• List of qualified VET personnel 

Summary of Sealed Source VE Findings and Concerns

There were no findings or concerns related to VET and packaging of sealed sources identified 

during this inspection. 

Baseline Approval

The VE system for sealed source examination and packaging that the EPA inspection team 

evaluated during this baseline inspection consisted of the following: 

• Trained personnel—operator/ITR/TS/FQAO and SME 

• Approved and controlled operating procedures—CCP-TP-069, Revision 3; CCP-QP-002, 

Revision 21 

• OSRP records and supporting data—VET electronic data recording forms, CCP-TP-069 

review checklists, CCP-TP-001 review checklists, and OSRP VE BDRs 

This system is suitable for VET of S5000 (debris) waste from the LANL OSRP. 

Sealed Source VET Tiers 

Based on the inspection and the results discussed above, EPA assigns the following tiers: 

T1 VET changes: None. 

T2 VET changes do not require prior EPA approval but do require LANL-CCP to notify EPA 

upon implementation of such changes and submit a brief description of the changes. These 

include the following: 

• Changes made to the VET procedure for OSRP wastes that require CBFO approval 

The above T2 changes to the WC activities from the date of the baseline inspection must be 

reported to and approved by EPA according to Table 1. Following EPA approval, LANL-CCP 

will notify EPA of T2 changes along with a summary of each T2 change at the end of each fiscal 

year quarter. EPA will evaluate the information and communicate with LANL-CCP as to 

whether EPA needs additional information for further evaluation, whether the changes raise any 

concerns requiring LANL-CCP response, or whether LANL-CCP can continue to implement the 

changes. Consistent with EPA’s authority under 194.24(h), EPA may request information 

relative to these changes if EPA deems the information is necessary to ensure continued 

compliance with EPA regulations. 

 

8.6 WIPP Waste Information System 

WC Element Description
71

LANL-CCP has successfully submitted WC data for TRU waste containers to the WWIS in the 

past (see EPA Inspection No. LANL-CCP-04.05-8, conducted in April 2005 and reported in EPA 

Docket No. A-98-49, II-A4-57). The CCP procedures, practices, and personnel who process 

container data that the EPA inspectors observed at LANL-CCP are the same as those used at 

other TRU generator sites currently approved for CH WC by EPA. Procedure CCP-TP-030 is 

used for submittal of both characterization and certification data to the WWIS. 

Documents, BDRs, and Objective Evidence Reviewed

The following documents were among those the EPA inspectors reviewed to assess whether 

WWIS operations follow the appropriate approved procedures and meet WWIS requirements: 

• CCP-TP-030, Revision 8, TRU Waste Certification and WWIS Data Entry, May 1, 2006 

• CCP-QP-002, Revision 20, Training and Qualification Plan, May 3, 2006 

The EPA inspectors evaluated the following objective evidence during the inspection: 

• Waste Container Data Report for Containers LA00000052034 and LA00000061956 

• WWIS data entry summary—characterization and certification for Containers S811270 

and LA00000059179 

• Correlation of container identification, May 4, 2006 

• WWIS data entry personnel qualification card 

• WWIS shipment summary report 

• List of NCR/corrective action report (CAR) status for selected containers 

• CCP-WCO data entry activities, data checklist for containers to be shipped, Container 

S811270 

• E-mail, Transmitting NCR/CAR Dispositions for Lot LANL 701, May 11, 2006 

• LA-MHD02.001, CCP WSPF 

Technical Evaluation

(1) Overall procedural technical adequacy was evaluated. 

The WWIS procedure, documented in CCP-TP-030, TRU Waste Certification and WWIS Data 

Entry, Revision 8, dated May 1, 2006, is well defined and controlled and contains complete 

instructions for entering, reviewing, and transmitting data. The WWIS data entry procedure 

incorporates adequate reviews to minimize the transmittal of noncompliant or incorrect data. 

The Microsoft Excel spreadsheet, used for data entry, was also adequate and controlled. The 

EPA inspectors identified no adequacy issues for the procedure or spreadsheet. Changes made to 

the WWIS procedure(s) that require CBFO approval is a T2 change. (See Table 1, where this is 

included as a T2 change). 

(2) Implementation and documentation of WWIS activities were examined. 
72

Personnel entering data into the WWIS can only do so after being granted access by the WWIS 

administrator, and access is password-protected. After the data have been through every level of 

review and approval, they are compiled into a drum file and entered into a controlled Excel 

spreadsheet by the waste certification assistant (WCA). The waste certification official (WCO) 

reviews the data to ensure that they are WIPP-compliant and signs the spreadsheet to accept the 

data. At this point, site personnel convert the data into ASCII format files and transmit them to 

the WWIS. The information contained in the drum file is subsequently used for transportation 

activities. The EPA inspectors viewed demonstrations of data storage and retrieval. LANL-CCP 

personnel were able to retrieve and print requested records, including WWIS access requests and 

waste container data reports for Containers LA00000059179 and S811270. Changes made to the 

WWIS data entry summary (e.g., Excel characterization and certification spreadsheets) that 

require CBFO approval is a T2 change. (See Table 1, where this is included as a T2 change). 

(3) Training of WWIS personnel was reviewed. 

The EPA inspectors observed the actual job performance of a WCO to verify training and 

qualification. Inspectors also reviewed the training and qualification package for a WCA (data 

entry personnel). Required training included use of the WWIS user’s manual, and the required 

reading list included the WIPP WAP and DOE/CBFO quality assurance program document 

(DOE/CBFO-94-1012, Quality Assurance Program Description (QAPD), Revision 7, dated July 

2005). Training documentation was complete and filed correctly for viewing and reference. 

Summary of WWIS Findings and Concerns

There were no findings or concerns related to WWIS identified during this inspection. 

Baseline Approval

The container certification system that the EPA evaluated during this baseline inspection 

consisted of the following: 

• Trained WWIS WCA (formerly, data entry personnel) and WCO 

• Approved and controlled operating procedures—CCP-TP-030, Revision 18; and CCPQP-002, Revision 20 

• Approved and controlled Excel spreadsheet, WWIS data entry summary—

characterization and certification 

WWIS Tiers 

Based on the inspection and the results discussed above, EPA proposes assigning the following 

tiers: 

T1 WWIS changes: None. 

T2 WWIS changes do not require prior EPA approval but do require LANL-CCP to notify EPA 

upon implementation of such changes and submit a brief description of the changes. These 
73

changes were added to provide a greater specificity in an attempt to identify and focus on the key 

elements relevant to waste isolation and include the following: 

• Changes to WWIS procedure(s) that require CBFO approval 

• Changes to the Excel spreadsheet, WWIS data entry summary—characterization and 

certification 

The above T2 changes to the WC activities from the date of the baseline inspection must be 

reported to and approved by EPA according to Table 1. Following EPA approval, LANL-CCP 

will notify EPA of T2 changes along with a summary of each T2 change at the end of each fiscal 

year quarter. EPA will evaluate the information and communicate with LANL-CCP as to 

whether EPA needs additional information for further evaluation, whether the changes raise any 

concerns requiring LANL-CCP response, or whether LANL-CCP can continue to implement the 

changes. Consistent with EPA’s authority under 194.24(h), EPA may request information 

relative to these changes if EPA deems the information is necessary to ensure continued 

compliance with EPA regulations. 

9.0 RESPONSE TO COMMENTS 

On April 18, 2007, EPA issued a Federal Register (FR) notice (72 FR 19494 - 19499, April 18, 

2007) announcing the proposed approval of the CH waste characterization (WC) program 

implemented at LANL by CCP. The FR notice opened a 30-day comment period to solicit 

public comment on the proposed approval of LANL-CCP’s CH WC program and the LANL 

Baseline Inspection Report (EPA Air Docket A-98-49, II-A4-87). The comment period ended 

May 18, 2007. EPA received one set of public comments. EPA evaluated those comments and 

revised the report accordingly. Attachment D provides the public comments and EPA’s 

response. 

10.0 SUMMARY OF RESULTS 

10.1 Findings and Concerns 

The findings and concerns issues identified during the inspection as well as LANL-CCP’s 

responses are discussed in the preceding sections of this report. Copies of the EPA Inspection 

Issue Tracking Forms that capture these issues are included in Attachment C. 

LANL-CCP responded to all EPA findings and concerns that required a response prior to the 

inspection closeout on site as well subsequent to the inspection. The EPA inspection team 

members evaluated all responses for completeness and adequacy, and concluded that each EPA 

issue requiring a response had been resolved satisfactorily. No EPA issues related to this 

inspection remain open at this time. 

10.2 Conclusions 

The EPA inspection team determined that the LANL-CCP WC program activities were 

technically adequate. EPA is approving the LANL-CCP WC program in the configuration 
74

observed during this inspection and described in this report and the attached checklists 

(Attachments A.1 through A.8). This approval includes the following: 

(1) The AK and load management process for CH retrievably-stored TRU debris and solid 

wastes and for newly-generated debris wastes from the OSRP 

(2) The LANL HENC #1 and LANL HENC #2 NDA systems for assaying solid and debris 

wastes 

(3) The PTGS NDA system for assaying debris waste 

(4) VE as a QC check of the RTR process11 and in lieu of the RTR process for retrievablystored solid and debris wastes and VET of newly-generated debris wastes from the OSRP 

(5) The nondestructive examination process of RTR for retrievably-stored solid and debris 

wastes 

(6) The WWIS process for tracking of waste contents of solid and debris wastes, including 

debris from the OSRP 

LANL-CCP must report and receive EPA approval of any T1 changes to the LANL-CCP WC 

activities from the date of the baseline inspection, and must notify EPA regarding Tier 2 (T2) 

changes according to Table 5, below. It is worth noting that Table 5 in this report is not 

identical to those included in previous baseline inspection reports and EPA site approval letters 

in several ways. The most important of these involve presentation of the Tier 2 (T2) elements. 

In previous reports there were two Tier 2 (T2) columns that have been merged into a single T2 

column for LANL-CCP. The T2 column entries have also been modified to better reflect the 40 

CFR 194.24 (h) requirements that the site provide notification regarding the completion or 

availability of specific T2 elements, whereas the previous tables stated that the site must actually 

provide the T2 elements (document or procedure revisions, etc.). This approach is similar to the 

tiering tables used in EPA inspection reports for sites characterizing remote handled TRU waste. 

Additionally, there are other minor word changes to the table for the sake of legibility. 

There are changes to specific WC areas as well. For AK, the AK Reassessment Memoranda 

(reflecting resolution to concern LANL-CCP-AK-06-001CR) and the AK-VE Memoranda 

related to VE cited under T2 changes (reflecting resolution to finding LANL-CCP-VE-06-004F) 

and do not appear in the tiering tables in previous baseline inspection reports. Similarly, 

requesting revisions to CCP-AK-008 or notification regarding the combination of waste streams 

that were distinct at the time of inspection are specific to the LANL OSRP or the result of 

information identified during this inspection. Accordingly, these are absent from the tiering 

tables in previous baseline inspection reports. For WWIS, changes to specific process elements 

(e.g., spreadsheets and data fields) are cited as T2 changes and these did not appear in previous 

tiering tables. These were added to provide a greater degree of specificity in an attempt to 

identify and focus on the key elements relevant to waste isolation. The ***footnote in Table 1 

specifies that substantive changes means changes with the potential to impact the site’s waste 

characterization activities under 40 CFR 194.24 or documentation thereof, excluding changes 

 

 

11 However DOE is not required to maintain the ability to perform VE as a QC check of RTR (see EPA letter of 

December 6, 2006). 
75

that are solely related to Environmental Safety &Health (ES&H), nuclear safety, the Resource 

Conservation and Recovery Act (RCRA) or editorial in nature.

 

The scope of the site baseline compliance decision is based on EPA’s inspections completed on 

May 25, 2006, and August 22, 2006, and the follow-up evaluation conducted on March 6, 2007 
76

Table 1. Tiering of TRU WC Processes Implemented by LANL-CCP 

Based on May 23–25, 2006 On Site Baseline Inspection, August 22, 2006 OSRP Inspection and March 6

WC Process Elements LANL-CCP WC T1 Changes LANL-CCP WC T2 

Acceptable Knowledge (AK) and Load Management 

Any new waste category, or new OSRP wastes addressed in AK Summaries separate from CCP-AK-008; AK (3), AK (6), AK (16) and (AK) 17 Implementation of Load Management for waste streams other than AK-009; AK (5) 

Notification to EPA upon completion of AK A

Notification to EPA upon completion of upda

modifications*** of the following: - AK Reassessment Memoranda and c

were distinct at the time of this inspe

- AK-VE Memoranda related to VE a

- AK-NDA Memoranda; AK (2 and 3- AK Accuracy Reports; AK (2) - Site procedures requiring CBFO app- AK Summary CCP-AK-008, if chan

and/or following the addition of new 

- Change Notices used to modify and 

to waste stream(s) within an approve

Nondestructive Assay (NDA) New equipment or physical modifications to approved 

equipment**; NDA (1-1, 2-1, 3-1) Extension or changes to approved calibration range for 

approved equipment; NDA (1-2, 2-2, 3-2) 

Notification to EPA upon completion of chan

equipment, operating range(s) and site proced

NDA (1-2, 2-2, 3-2) 

Real-Time Radiography (RTR) N/A Notification to EPA upon the following: - Implementation of new equipment o

approved equipment; RTR (1) - Completion of changes to site proced

RTR (2) 

Visual Examination (VE) and Visual Examination Technique (VET), including OSRP Wastes (Sealed Source VET or SSVET) 

N/A Notification to EPA upon the following: - Completion of changes to site VE an

approvals, including OSRP VET pro

WIPP Waste Information System (WWIS) 

N/A Notification to EPA upon the following: - Completion of changes to WWIS pro

approvals; WWIS (1) and WWIS (2) - Changes to the Excel spreadsheet, W

characterization and certification*** WWIS (1) and WWIS (2)

 * Upon receiving EPA approval, LANL-CCP will report all T2 changes to EPA at the end of each fiscal year quarter. 

 ** Modifications to approved equipment include all changes with the potential to affect NDA data relative to waste isolation and exclude mino

addition of safety-related equipment. 
77

***Substantive changes means changes with the potential to impact the site’s waste characterization activities or documentation thereof, exclud

related to Environmental Safety & Health (ES&H), nuclear safety, the Resource Conservation and Recovery Act (RCRA) or are editorial in nat
78 

11.0 REFERENCES 

New Mexico Environment Department, Waste Isolation Pilot Plant Hazardous Waste Facility 

Permit (WAP), NM48901 139088-TSDF, Santa Fe, New Mexico, 1989. 

U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 191, 

“Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear 

Fuel, High-Level and Transuranic Radioactive Wastes.” 

U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 194, “Criteria for 

the Certification and Re-Certification of the Waste Isolation Pilot Plant’s Compliance with the 

40 CFR Part 191 Disposal Regulations.” 

U.S. Department of Energy, “40 CFR Part 191, Compliance Certification Application for the 

Waste Isolation Pilot Plant,” DOE/CAO 1996-2184, Carlsbad, New Mexico, 1996. 

U.S. Department of Energy, “40 CFR Part 191, Subparts C and D, Compliance Recertification 

Application 2004,” DOE/WIPP/2004-3231. 

U.S. Department of Energy, Carlsbad Field Office, “Contact-Handled Transuranic Waste 

Acceptance Criteria for the Waste Isolation Pilot Plant (CH-WAC),” Rev. 3, DOE/WIPP-02-

3122, Carlsbad, New Mexico, April 25, 2005. 

U.S. Department of Energy, Carlsbad Field Office, “Quality Assurance Program Description 

(QAPD)”, DOE/CBFO-94-1012, Rev. 7, Carlsbad, New Mexico, July 2005. 

U.S. Environmental Protection Agency, “Criteria for the Certification and Recertification of the 

Waste Isolation Pilot Plant’s Compliance with the Disposal Regulations: Certification Decision; 

Final Rule,” Federal Register, Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405. 

U.S. Environmental Protection Agency, “EPA Replicate Testing for WIPP Nondestructive Assay 

(NDA) Systems,” Rev. 2, June 2002. 

U.S. Nuclear Regulatory Commission, “Contact-Handled Transuranic Waste Authorized 

Methods for Payload Control” (CH-TRAMPAC). 
Attachments A.1 through A.8 
Revision No.: 2.0 AK-1 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

GENERAL 

AK-1: Is the waste TRU by definition as presented in the 

LWA? (P.L.102-579) 

CCP-TP-005, Revision 16; CH WAC Revision 3; P.L. 102-579 

Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). Load management to 

only. 

AK-2: Do the presented volumes comport with LWA capacity restrictions? (P.L.102-579) 

CCP-TP-005, Revision 16; CH WAC Revision 3; P.L. 102-579 

Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 

3, (September 22, 2005); CC2006). Data examined identiwaste volume. 

AK-3: Are any wastes considered (or previously considered HLW? HLW are prohibited. (P.L.102-579) 

CCP-TP-005, Revision 16; CH WAC Revision 3; P.L. 102-579 

Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 

3, (September 22, 2005); CC2006). CCP representatives 

examined contained HLW. 

AK-4: Are any wastes considered (or previously considered) Spent Nuclear Fuel? (P.L.102-579) 

CCP-TP-005, Revision 16; CH WAC Revision 3; P.L. 102-579 

Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). CCP personnel stated contained SNF. 

AK-5: Are these defense-related wastes? (P.L.102-579) 

CCP-TP-005, Revision 16; CH WAC Revision 3; P.L. 102-579 

Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). Three waste streams 

241Am and 238Pu have recent

determination by CBFO and three streams are justified in waste based on the followinmaterials in the sealed sourc

products of defense material

materials separations during 
Revision No.: 2.0 AK-2 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

byproduct management, and 

waste] for defense nuclear msafeguards.” In essence, the considered to be defense wa

of “defense nuclear material if the sources had a nondefedoes not make defense deter

AK-6: What is the scope of authorization sought (i.e., SCG, newly generated vs. retrievably stored, other sitespecific breakdowns) 

CCP-TP-005, Revision 16; CRA 2002 

Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). Audit scope is retrie

S3000 solid TRU waste. OSconsidered newly- generated 

AK-7: Is AK being used that was assembled prior to an EPA approved QA program (retrievably stored). If so, what qualification process is used? Is this waste undergoing confirmation as per the CCA/CRA (100% sampling) [194.24(c)(2)-(5), 194.22(a)] 

CCP-TP-005, Revision 16; CH WAC Revision 3; P.L. 102-579 

Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). BDRs for waste cont

(07), S814218 (solids), S834

(solids), 54631 HT 83, 5570LA00000062374. Waste und

AK-8: Is AK being assembled as waste is generated after

EPA approval of the QA program (newly-generated)? Is this waste undergoing confirmation as per the CCA/CRA (100% sampling)? [194.24(c)(2)-(5)] 

CCP-TP-005, Revision 16; CH WAC Revision 3; P.L. 102-579 

Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). Waste streams LANLwaste generation into the futgenerated debris component 

(LANL-008) is considered n

100% NDA and NDE is bein

PERSONNEL TRAINING REQUIREMENTS AK-9: Procedures require staff to be qualified to assemble, compile, and confirm AK data, including but not limited to: 

CCP-TP-005, Revision 16; CCP-QP-002 

Partial Verification, see Objective Evidence 

Training records for Julia W(AKE), Steve Schafer (AKERandy Fitzgerald (SPQAO)
Revision No.: 2.0 AK-3 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

a.Identification of required reading list and successful 

completion of all required reading including, but not limited to: • Applicable portions of the WIPP WAP and TSDF 

WAC 

• WIPP Compliance Certification Decision Conditions 

2 and 3 

• State and Federal RCRA regulations associated with 

solid and hazardous waste characterization 

• Discrepancy resolution and reporting processes 

• Site-specific procedures associated with waste 

characterization using acceptable knowledge 

b. Successful completion of testing to demonstrate 

understanding of required reading list 

c. Completion of internal and/or external training 

programs pertinent to AK 

d.Participation in internal audits to assess AK program 

e. Other methodologies for demonstrating AK proficiency 

as developed on a site-specific basis 

(WAP B4, B4-3a) 

evidenced through interviewtraining would help ensure c

requirements. 

PROCEDURE SCOPE 

AK-10: a. Are procedures adequate to encompass the spectrum of 

wastes for which authorization is sought? 

b. Are there different procedures for newly-generated vs. 

retrievably-stored waste? Are there different 

procedures for solid, debris, or soil waste? Should 

there be? 

CCP-TP-005, Revision 16; CCP-TP-101 

Partial Verification; see Objective Evidence 

CCP-AK-LANL-004 (MarcRevision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). Procedure CCP-TP-0retrievably-stored waste; OSusing AK as well as CCP-TPentirely characterized prior t
Revision No.: 2.0 AK-4 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

c. For newly-generated waste, have adequate procedures 

been developed and implemented to characterize waste 

using acceptable knowledge prior to packaging? 

(WAP B4, B4-3b) 

ASSEMBLING AK INFORMATION AND COMPILING AK DOCUMENTATION INTO AN AUDITABLE RECORD AK-11: What is the breakdown of the types and quantities of TRU waste generated/stored at the site? (WAP B4, B4-2a) 

CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006), D041, D039, D074, DD032 (007); M055 (008); D

in the above references inclu

types and quantities of waste

AK-12: Do procedures call for AK information to be collected for: a. 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, 

137Cs plus any unexpected radionuclides 

b. ferrous metals (in containers) 

c. cellulosics, plastics, rubber d. nonferrous metals (in containers) (CRA/CCA Ch 4 and Attachments/Appendices) 

CCP-TP-005, Revision 16; Manual IS Revision 5 

Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006), C028, C019, D01, D0

D004, M018, M117 (004); C

D015 (007); C010, C011, DM009 (008); D011, D021, Dcomponents are identified in 

Note that the identification operformed; detailed breakdo

quantities not included in AK 

AK-13: Do procedures require documentation of radionuclide process origin? Are the facility and TRU waste management operations correlated to specific waste stream information? (Attachment B4; CH WAC Appendix A.2.2) 

CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006), C028, C019, D01, D0

D004, M018, M117 (004); C

D015 (007); C010, C011, DM009 (008); D011, D021, Dorigin discussed. Note that 

LANL-007 (MT 83) is a dis
Revision No.: 2.0 AK-5 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

239Pu (006) stream; this was 

appeared to contain an occas

contrary to the process definof LANL-004 is tied to numis associated with MT83 pronewly-generated OSRP waswith various activities in CM

AK-14: Are correlations between waste streams, with regard to time of generation, waste-generating processes, and site-specific facilities clearly described? For newlygenerated wastes, the rate and quantity of waste to be generated shall be defined. (Attachment B4, B4-3c; CH WAC Appendix A, Section A.2) 

CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). Four separate waste summaries for each addresserequirements. 

AK-15: a. Are wastes streams appropriately identified and are

wastes characterized on a waste stream basis? 

b.Are wastes grouped on a waste stream basis using 

Acceptable Knowledge and are they characterized in 

the same manner (i.e., by visual examination) as a newly-generated waste if a waste does not have all mandatory AK documentation requirements? 

(Attachment B4, Section B-1a) 

CCP-TP-005, Revision 16 Partial 

Verification, see Objective Evidence 

CCP-AK-LANL-004 (MarcRevision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). Three waste streams 

241Am and 238Pu have recent

determination by CBFO and intends to assess whether newarranted based on both the the presence of irradiated sewill update the current AK sradionuclide content, predomwill update or create a new Wapproval. Because EPA has characterization for new seaapproach is required to ensuare technically adequate.Also, CCP has consistently udemonstrate similar materiaspecifically LANL-007 and 
Revision No.: 2.0 AK-6 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

streams in contradiction with 

practices requires prior EPA 

AK-16: Do procedures demonstrate a logical progression from general facility information to more detailed waste stream-specific information? 

CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). Data were available tstream information. 

AK-17: Does the process include review of AK information to evaluate and document AK-AK information discrepancies? (CH WAC Section A.2.2.3, Attachment B4, Section B4-3) 

CCP-TP-005, Revision 16 Partial 

Verification, See Objective Evidence 

CCP-AK-LANL-004 (MarcRevision 2 (April 13, 2006), 

3, (September 22, 2005); CC2006). DR004 (004), DR005 010 (008), DR003 (009). Thexamined were complete (almean that EPA concurred w

example, combining of wastrecently generated a number 

specific to the use of the NM

sealed sources, because the Ncomport with other informat

radionuclide content. Track

NMMSS database and other 

content information is impor

NMMSS is still a reliable so

important because OSR relie

characterization. 

AK-18: Do procedures require collection of information regarding how waste is tracked and managed at the generator site (including historical and current operations)? (CH WAC Section A.2; Attachment B4 Section B4-2a) 

CCP-TP-005, Revision 16 Yes, in part CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 

3, (September 22, 2005); CC2006). CTS/PTS CCP print 

record database discardable examples), CONCERT datatracks data on an uncontrolle

includes container, MT, and status). CTS/PTS track data 
Revision No.: 2.0 AK-7 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

to follow the specific databacould include this listing. Dexamined. 

AK-19: Is AK information compiled in an auditable record, including a road map for all applicable information? 

CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). Attachments 1 and 4 each waste stream). Attachm

program and waste stream in

support the determination; Areference list for each stream

AK-20: Has a reference list been provided that identifies documents, databases, Quality Assurance protocols, and other sources of information that support AK information? (Attachment B4, Section B4-3c) 

CCP-TP-005, Revision 16 Partial 

Verification, See Objective Evidence 

CCP-AK-LANL-004 (MarcRevision 2 (April 13, 2006), 

3, (September 22, 2005); CC2006). Attachment 4 (CCP-and is prepared for each streto track source documents bcommon identifiers (e.g., the

LANL-004 and D011 for LA

different). It is recommendeidentifier be added to each r

stream it applies to, as the saused in different reports to i

which can lead to confusion

AK-21: Have the following mandatory information requirements been identified? • Map of the site that identifies the areas and facilities 

involved in TRU waste generation, treatment, and storage 

• Facility mission description related to TRU waste 

generation and management 

CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). C028, C019, D01, D0

D004, M018, M117 (004); C

D015 (007); C010, C011, DM009 (008); D011, D021, Dinformation is also summari
Revision No.: 2.0 AK-8 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

• Description of the operations that generate TRU waste 

at the site and process information, including: 

 - Area(s) or building(s) from which the waste stream 

was or is generated 

 - Estimated waste stream volume and time period of 

generation 

 - Waste generating process description for each 

building or area 

 - Process flow diagrams, if appropriate  - Generalized material inputs or other information that 

identifies the radionuclide content of the waste stream and the physical waste form 

 - Types and quantities of TRU waste generated, 

including historical generation through future 

projections 

• Physical/chemical waste composition that could affect 

isotopic distribution (i.e., processes to remove ingrown 

241Am) 

• Statement of all numerical adjustments applied to 

derive the material’s isotopic distribution, e.g., scaling 

factors, decay/ingrowth corrections and secular equilibrium considerations 

• Specification of isotopic ratios for the 10 WIPP-tracked 

radionuclides and, if applicable, the radionuclides that comprise 95% of the hazard 

(CH WAC Section A.2.2; Attachment B4, B4-2a, B4-2b)

CCP-AK-LANL-004, 007, amemorandum prepared for 0

identified the specific progra

information required in this 

physical/chemical informati

distribution should be addre

Isotopic ratios could not be 

LANL-004; isotopic data ar

basis for containers in stream

isotopics are assigned to LA

AK-22: Does the site have procedures for the collection of supplemental information? Examples of supplemental information, from CH WAC, include: 

CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). C028, C019, C061, D
Revision No.: 2.0 AK-9 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

• Safeguards and security and other material control 

systems/programs 

• Reports of nuclear safety or criticality 

• Accidents involving SNM waste packaging and waste 

disposal 

• Building or nuclear material management area logs or 

inventory records 

• Site databases that provide SNM or nuclear material

information test plans 

• Research project reports, or laboratory notebooks that 

describe the radionuclide content of materials used in experiments 

• Information from site personnel 

• Historical analytical data relevant to isotopic 

distribution in the waste stream 

(CH WAC Section A.2.2.2; Attachment B4 Section B4-2c) 

D082, D051, D044, D035, D

C041, D011, D014, D015, DD007, M040, M036, M026 D028, M018, M019 (009). 

available for many of the ex

AK-23: Is all necessary supplemental information assembled and has it been appropriately used? (Section B4-2c) 

CCP-TP-005, Revision 16 Partial 

Verification, see Objective Evidence 

CCP-AK-LANL-004 (MarcRevision 2 (April 13, 2006), 

3, (September 22, 2005); CC2006). Supplemental informappropriately used at this po

combustible/non combustiblto be based on the desire to 

is unclear whether the justifi

streams will hold true throug

AK-24: a. Are waste categorization schemes presented and are 

they appropriate? 

CCP-TP-005, Revision 16; CH WAC Revision 3 

Partial Verification, see Objective Evidence 

CCP-AK-LANL-004 (MarcRevision 2 (April 13, 2006), 3, (September 22, 2005); CC2006), M025 (004); D015, D
Revision No.: 2.0 AK-10 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

b. Are waste identification/categorization schemes 

relevant to the isotopic composition of waste? 

(Attachment B4 Section B1, CH WAC page ix, Appendix

A.2) 

CCP explicitly defined CCPonly of 238Pu debris waste; if 

drums assigned to this streamdrums would be segregated stream. When asked whethe

placed in AK-006, CCP pers

option, apparently due to hoassigned. However, the AK considering broadening the dallow the inclusion of an occrepresented by MT 83, but ahad not been accomplished. 006 and AK-007 are differendefinition of waste streams pPlan (WAP) and WAC. EPA waste streams, and post-inspcombinations of waste streaminspection would require revAlso, approval of 239Pu and 

waste makes these wastes elcorrect waste stream determ

AK-25: Have data uses and limitations been assembled and are they technically adequate? (CRA/CCA; CH WAC Appendix A, Section A.2.2.3) 

CCP-TP-005, Revision 16 Yes All Source Documents exam

Attachment 3 Acceptable KnSummary. This attachment 

each reference; the attachme

source document limitations 

GENERATING AN AK SUMMARY/AK DOCUMENT AK-26: Site documents/procedures require the facility 

prepare an AK summary document that summarizes all 

information collected, including the basis for all waste 

stream designations. Is the AK Summary of sufficient scope and detail? 

CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). AK Summaries exam

addressed most technical inf
Revision No.: 2.0 AK-11 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

(CH WAC Appendix A Section A.2.2; Attachment B4 Section B4-2b) 

supporting references were s

they were reviewed to asses

identified: Remove Wing 1 discussion revise the text accordingly; Include waste stream genera

appropriate location(s); Ensure that all discussion of 

as well as any other radionu“expected” rather than “susp

how site personnel enter the Examine WMP and prohibitthat an accurate description example, for AK-004, the Amay be present through dewdoes not indicate where, spethe containers; Clarify the language pertainAK-007 includes several dif

waste generation processes, the processes are active vers

part because the language pe

fabrication is confusing; Always distinguish “expecteradionuclides in radiologicaidentify “expected” radionuc

personnel enter radionuclide 

as presented in AK-007); AK documents address somspecify where in the waste thexample, liquid from condenidentified in AK-004, but thwater in the containers was n
Revision No.: 2.0 AK-12 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

be important, as liquid was ibottom and in containers wi

along the sides of the contaithrough condensation/dewatspecific, if possible, as to thCCP-TP-005, Attachment 3Attachment 3 is included on documents. This form addretherefore each source documdata limitation assessment. 005 act as AK “roadmaps” isupporting documents and sdocuments to required AK e

AK-27: Are conclusions and interpretations presented in the AK Summary technically sound and supported by referenced mandatory and supplemental information? 

CCP-TP-005, Revision 16 Partial 

Verification, see Objective Evidence 

See reference lists and discu23, AK-25, and AK-26. 

AK-28: If AK data discrepancy is identified, site will evaluate the source of the discrepancy to determine if discrepant information is credible. Information that is not credible will be identified as such and reasons fordismissing will be justified in writing. Limitations concerning information will be documented in the AKrecord and summarized in the AK report. If a discrepancy cannot be resolved, the site will perform direct measurements for the impacted population. (CH WAC Appendix A.2, Section A.2.2.3) 

CCP-TP-005, Revision 16 Partial 

Verification, see Objective Evidence 

See references and discussio

this AK item, several discrep

to question the reliability of 

encouraged to examine thesOSR relies solely on AK for data. 

AK-29 : Is load management proposed? Does the AK Summary include the following from the CH WAC, Revision 3, Appendix E? • Each TRU waste stream selected for payload 

management must include in its acceptable knowledge

summary report an estimate of the total waste volume and the percentage of the waste volume that is above 

CCP-TP-005, Revision 16 Partial 

Verification, see Objective Evidence 

CCP-AK-LANL-004 (MarcRevision 2 (April 13, 2006), 

3, (September 22, 2005); CC2006). Load management is Waste Stream LA-MHD03.0

debris waste. Between 3–33

expected to be less than 100 
Revision No.: 2.0 AK-13 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

and below 100 nCi/g. (It should be noted that thisinformation, although based on the best available AK information, is preliminary and subject to the 

performance of WIPP-certified NDA measurements 

and cannot and will not be used as a measure of AK accuracy.) (Reference E3) 

(CH WAC, Appendix E) 

will not use load manageme

AK-007 at this time. If CCP management for these waste requirements of Appendix E 

IDENTIFYING MANAGEMENT CONTROLS FOR DISCREPANT ITEMS/CONTAINERS/WASTE STREAMS AND DATA MANAK-30: Are nonconforming wastes segregated? Are 

NCRs disposition in an appropriate and technically 

defensible manner? (Attachment B4, Section B4-3b, Attachment B3, Section 

B3-13) 

CCP-TP-005, Revision 16 Yes NCR-LANL-0537-05, NCR

0803-05, NCR-LANL-0516show that CCP is capable of 

items; the specific stream as06 should be identified, as thmismatches. 

AK-31: Do site procedures require that additional information be collected before waste may be shipped if the required AK information is not available for a waste stream or if available AK is poor or unacceptable? (Attachment B4, Section B1) 

CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). See AK 28 and 10. 

been available so far. 

CONFIRMING AK INFORMATION WITH OTHER ANALYTICAL RESULTS AK-32: Do these procedures facilitate the mandatory traceability analysis performed for each Summary Waste Category Group examined during the audit, noting that EPA will determine whether the available waste streams adequately demonstrate the full characterization process for the proposed scope? (Attachment B4, Section B4-2) 

CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (Marc

007, Revision 2 (April 13, 2Revision 3, (September 22, (March 9, 2006). EPA exam

part for several containers—

(stream 238Pu debris), S8142

debris), S817225 (solids), 54

LA00000061432, and OSR for evaluated containers was radioactive solid waste dispowaste disposal records, or si
Revision No.: 2.0 AK-14 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

AK spreadsheet to BDRs gecharacterization and subsequdid not assess input into the 

AK-33: If AK was used (i.e., data collected prior to QA 

program), what method was employed to qualify the 

information? Approved methods or peer review, corroborating data, confirmatory testing, and QA program 

equivalency? If confirmatory testing is used, has the following been considered (from CH WAC) • At a minimum, to confirm existing AK data, it is 

necessary to compare ratios of the two most prevalent 

radionuclides in the isotopic mix 

a. For 238 Pu, 239Pu, 240Pu, 241Pu, 242 Pu and 241Am:

• Confirmation can be accomplished via comparison of 

measured and AK values for 239 Pu/ 240 Pu for 

weapons grade plutonium; 238Pu/ 239Pu for heat 

source 

• Measured 241Am can be used to calculate 241Pu (for 

subsequent AK comparison) if time of chemical separation is known (no 241Am at time of separation 

assumed) 

• 241Pu can be compared (by ratio) to confirm AK of 

any Pu isotope associated with WG/RG (i.e., 239Pu or 

240 Pu) 

• 238Pu from AK for wg/rg Pu is assumed to be valid if 

the AK values of 239Pu and 240Pu have been 

confirmed by measurement 

• 242Pu calculated by correlation techniques, since it 

can’t be measured 

CCP-TP-005, Revision 16, CH WAC, Revision 3 

Partial Verification, see Objective Evidence 

CCP-AK-LANL-004 (MarcRevision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). AK-NDA Memoran

LA-MIN03-NC.001, TA-50 

Noncemented Waste (AK-0

available for this waste streathe stream was created. Theand AK values to confirm an

performed. Similarly, while 

tracked from an AK perspecof “valid AK” to confirm U CCP identified 235U and 239P

by weight. CCP did not ind

this assessment would be recthis initial determination. Fu

predominant radionuclides b

more meaningful for the cumactivity of each of the 10 Wmeasured in the waste. LA-MHD02.001, 238Pu Con

Debris Waste (AK-007). AK 

consisting entirely of MT 83are well defined. Because Nwaste stream consists of 238P

ratios for MT83 to determinvalues don’t match MT83, Cthe drums are not part of thisegregated for assignment to respect to uranium, little 233U 

therefore an “expected” rath
Revision No.: 2.0 AK-15 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

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Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

b. For 235U, 233U, 238U, 234U:

• Were they tracked or measured in AK information? 

• If no valid AK exists, data generated can only be 

used to detect or calculate, or confirm absence ratios for 234U calculated from 235U enrichment 

• If valid AK exists, can confirm with certified systems 

• 234U calculated by 235U enrichment, because 234U 

can’t be measured 

c. For 137 Cs and 90 Sr:

• Confirmed by WIPP-certified system via comparison 

of 241Am peak at 662 keV to 722 241Am peak, i.e., a 

disproportionate response at 662 keV could mean 

presence of 137Cs) 

• 90Sr calculated from 137Cs using scaling factors 

Other radionuclides – must identify via NDA and should identify via AK (40 CFR 149.22(b), CH WAC, Appendix A, Section A.2.1) 

LA-OS-00-01.001, OSRP S

the exclusive means for deteof sealed sources. Thereforeassess NMMSS, source certrecords, U.S. Nuclear Regulinformation, and other data, radionuclide content of wastwhich is then corrected for ringrowth, as appropriate. In which AK has already been stated additional irradiated stherefore have an initial comassigned by the manufacturenew OSRP waste streams bawaste and irradiated sources LA-MHD03.001, CMR Fac

personnel assigned MTs to e

generation. NDA personnel each container to assist in Nexample, NDA personnel mis present based on AK; MT 

important to identify. AKE 

by material type(s) for use b

Confirmation with respect to described in the WAP apparinstead, the AKE indicated ton an MT basis. The AKE i

determined by AK, as opposmeasured 241Am values, as i

not a TRU radionuclide or oradionuclides. MGA or FRA

NDA process, but site opera

when AK identifies drums a

242Pu. AK used to help dete

by-drum basis; a scaling fac

content based on the observe
Revision No.: 2.0 AK-16 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

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Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

states that 234U is quantified 

the formula and assumptionobserved inconsistency in rareporting. For example, it is radionuclides that are “expeimpacts how site personnel eradionuclides in the WWIS. 

in waste stream LANL-007. assumptions must take into aCRA. 

AK-34: If waste is generated after an EPA-approved QA 

program, are radioassay and NDE results compared to the 

data assembly process as a cross reference to verify implementation of the as-generated characterization

program? 

(194.24 (c)(3); 194.22(b)) 

CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). See Item AK-6, abov

AK-35: This procedure requires a reevaluation of AK if 

NDE identifies it to be a different waste matrix code. 

This procedure describes how the waste must be reassigned, based on the AK reevaluation. (Attachment B4, Section B4-3d) 

CCP-TP-005, Revision 16 Yes AK Re-Evaluation Checklis

Checklists are prepared whe

based on NDE results. It is 

indicated that Fastscan or Q

If so, data must be in the AK 

AK-36: Does the generator site have written procedures for newly generated waste to document the confirmation of acceptable knowledge information with visual examination prior to or during waste packaging? Dothese procedures address the required elements in 3.4-3d? 

 (Attachment B4, Section B4-3d) 

CCP-TP-005, Revision 16 Yes See VE checklists for evalua

technique analysis. 

AK-37: Procedures require the following steps to be followed if wastes are reassigned to a different waste matrix code based on NDE: 

CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (Marc

Revision 2 (April 13, 2006), 3, (September 22, 2005); CC2006). Attachment 10 of CC
Revision No.: 2.0 AK-17 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

• Review existing information based on the container 

identification number and document all differences 

• Reassess and document all analytical data associated 

with the waste 

• Reevaluate waste material parameter determinations 

and document any changes 

• Reevaluate the radionuclide content and document any 

changes 

• Verify and document that the reassigned waste matrix 

code was generated within the specified time period, area and buildings, waste generating process, and that the process material inputs are consistent with the waste material parameters identified during radiography or visual examination 

• Record all changes to acceptable knowledge records 

• If discrepancies exist in the acceptable knowledge 

information for the reassigned waste matrix code, complete a nonconformance report, document the segregation of this container, and define the corrective actions necessary to fully characterize the waste. 

(Attachment B4, Section B4-3d) 

process were provided; see i

AK-38: Has the acceptable knowledge expert calculated the percent changes in matrix parameter categories (MPCs) based on AK and NDE/VE? Were accuracy evaluations assigned? Are these acceptable? (Attachment B4, Section B4-3e; CH WAC Appendix A, Section A.6.5) 

CCP-TP-005, Revision 16 Partial 

Verification, see Objective Evidence 

AKE did not calculate the Msummaries include general i

WMP content of the streamsWMP content based on indi

CCP elected to combine com

debris from two streams into 

LANL continues to differen

or noncombustible, CCP repconfidence in these values a
Revision No.: 2.0 AK-18 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

appropriate to combine the tcombines distinguishable wato decrease the number of WEPA received no informatiocontinue to separate the was(i.e., why LANL distinguishwhile CCP does not). 

NDA-AK DATA SHARING AND COMMUNICATION/PROCEDURALIZATION AK-39: Are the following bullets addressed with respect to AK-NDA communication and use of AK data by NDA 

personnel? 

• Do procedures require the identification of AK data

limitations? 

• Are AK data and associated limitations communicated

to NDA personnel and is this required by procedure?

• How is AK used by NDA? • Do AK and NDA personnel communicate and agree 

about the use of AK? 

• Is this agreement proceduralized? (CH WAC, Appendix A) 

CCP-TP-005, Revision 16, Section 4.4.20 

Partial Verification, see Objective Evidence 

AK-NDA memoranda for LTA-50 Homogenous Inorgan(AK-004); LA-MHD02.001

Heterogeneous Debris (AK-CMR Facility Debris (AK-0identified on all source docuC). The AK-NDA memoranand limitations to the NDA pfor each waste stream (discuAK-NDA memorandum sho

personnel are aware of its co

LA-MIN03-NC.001, TA-50 

Non-cemented Waste (AK-0

composition highly complex isotopics—determination of measurement only. LA-MHD02.001, 238Pu Con

Debris (AK-007). This is on

controlled by process, so NDwith little consultation with LA-OS-00-01.001, OSRP S

characterized entirely using various sources, including thshipping documents, and ma

No NDA used so there is no 
Revision No.: 2.0 AK-19 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

LA-MHD03.001, CMR Fac

generated from this facility odifferent laboratory areas anThe generators documented container for more than 97% (unlike AK-004), so NDA pwith AK personnel to obtain assignments. The NDA-AK memoranda h

below: 

1. The LANL-004 NDA-AK editorial issues with respect inadequate referencing of sustatements or conclusions. 2LANL-007 and -009, referencalculations are lacking. 3. memoranda are not matched summaries and attachments specifically, Table 3 in the Lmemorandum is erroneous aexpected (rather than suspechow site personnel enter the 

AUDITING OF AK RECORDS AND AK DISCREPANCY IDENTIFICATION/RESOLUTION AK-40: Have internal audits been performed? (Attachment B4, Section B4-3e) 

CCP-TP-005, Revision 16 Yes Management Assessment Re

Maintenance of Acceptable 

AK-41: Has a waste stream been revoked based either on AK information or reassessment as part of reconfirmation? If so, was the procedure(s) followed? (Attachment B4, Section B4-4) 

CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004. Whil

presence of liquid was ident

for water within already-shipchecklist for additional infor

AK-42: If data consistently indicate discrepancies with acceptable knowledge information, the site increases 

CCP-TP-005, Revision 16 Partial 

Verification, see 

 No example available to da

establish general criteria for 
Revision No.: 2.0 AK-20 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

sampling, reassesses the materials and processes that generate the waste, and resubmits waste stream profile information. (CH WAC Section A.2.2.3; Attachment B4, Sections B4-3b, B4-3d) 

Objective Evidence address this requirement, no

relatively mature with respe

QA OBJECTIVES FOR AK AND OTHER ELEMENTS AK-43: Are acceptable knowledge processes consistently applied among all generator sites, and does each generator site comply with the following data quality requirements for acceptable knowledge documentation: a. Precision – Precision is not applicable to AK (see 

Attachment B4) 

b. Accuracy – Accuracy is the degree of agreement 

between an observed sample result and the true value. 

The percentage of waste containers which require reassignment to a new waste matrix code based on the reevaluation of acceptable knowledge and sampling and analysis data will be reported as a measure of acceptable knowledge accuracy. Accuracy based on radionuclide content is typically assessed by comparing measured results with AK data. 

c. Completeness – Completeness is an assessment of the 

number of waste streams or number of samples collected to the number of samples determined to beuseable through the data validation process. The acceptable knowledge record must contain 100 percent of the information specified in Section B4-2. The usability of the acceptable knowledge information will 

be assessed for completeness during audits. 

d. Comparability – Data are considered comparable when 

one set of data can be compared to another set of data. Comparability is ensured through sites meeting the 

CCP-TP-005, Revision 16 Partial 

Verification, see Objective Evidence 

Acceptable Knowledge Acc00-01, Lots 1-5, AK Accura

Laboratory Waste Stream LA(LANL-06), December 20, 2Accuracy Report: LANL W

NC.001, Lots 1-15, dated M

Development of criteria for 

based on radionuclide result

recommends that CCP devedetermination of most preva

activity should be considere

does not specify which, and meaningful comparison. Se. 
Revision No.: 2.0 AK-21 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

training requirements and complying with the minimum standards outlined for procedures that are used to implement the acceptable knowledge process. CH WAC Section A.6.5: Additionally, comparison of measured data with AK-derived or -based values, as applicable, provides a means to assess comparability on a waste stream basis. 

e. Representativeness – Representativeness expresses the 

degree to which sample data accurately and precisely represent characteristics of a population. Representativeness is a qualitative parameter that will 

be satisfied by ensuring that the process of obtaining, 

evaluating, and documenting acceptable knowledge information is performed in accordance with the minimum standards established in Section B3. Sitesalso must assess and document the limitations of the acceptable knowledge information used to assign waste 

parameters. 

(Attachment B4, Section B4-3e) 

AK-44: Does the generator site address quality control 

by tracking its performance with regard to the use of 

acceptable knowledge by: 1) assessing the frequency of inconsistencies among information, and 2) documenting the results of acceptable knowledge confirmation through radiography or visual examination? In addition, the acceptable knowledge process and waste stream documentation must be evaluated through internal assessments by quality assurance organizations and assessments by auditors or observers external to the organization (i.e., CBFO, NMED, EPA). (Section B4-3e) 

CCP-TP-005, Revision 16 Yes CCP-TP-005 Attachment 13

(Attachment 13). CCP docu

this checklist. Internal assesAK-40, above). 

AK-45: Did the generator site implement, or does it currently implement, process controls to 

CCP-TP-005, Revision 16 Partial 

Verification, see 

NCR-LANL-0537-05, NCR

0803-05, NCR-LANL-0516
Revision No.: 2.0 AK-22 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

ensure that prohibited items are documented and managed in accordance with site-specific certification plans and that the following minimum site specific controls: • Identify the organization(s) responsible for 

compliance with administrative controls 

• Identify the oversight procedures and 

frequency of actions to verify compliance with administrative controls 

• Develop on-the-job training specific to 

administrative control procedures 

• Ensure that personnel may stop work if 

noncompliance with administrative controls is identified 

• Develop a nonconformance process that 

complies with the requirements in Section B3-13 of the WAP to document and establish corrective actions 

• Address controlled changes to WAP-related 

plans or procedures as part of the 

nonconformance and corrective action process 

• As part of the corrective action process, assess 

the potential time frame of the noncompliance, the potentially affected waste population(s), and the reassessment and recertification of those wastes 

 (Attachment B4, Section B4-3b) 

Objective Evidence unclear whether Quick or Fa

process control; should inclu

noted that CCP AK personnsite process controls to elimwater, and have couched thi

by making relatively noncomprohibited item occurrence. 
Revision No.: 2.0 AK-23 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Required Technical Elements Procedure Location/Adequacy Verification of Activity Examples of O

AK-46: Does the generator site document, justify, and consistently delineate waste streams... based on site- specific permit requirements or state-enforced agreements? How do these agreements impact waste characterization? (Section B4-4) 

CCP-TP-005, Revision 16 Yes The TWBIR delineates Was

used as a starting point for astreams. No state-enforced requirements were identified impact waste stream determ
Revision No.: 1.0 HENC#1-1 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)

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

SYSTEM DESCRIPTION Identify the NDA system by name, location, and number, as appropriate. 

NA NA The system is the LANL-HENC #1, previously known as 

the MCS HENC. It is housed in Building No.,54506 (trailer) located in Technical Area 54 (TA 54), Area G, Pad 10 at LANL. The system has not been moved since the last EPA inspection. 

Y Vis

HEof T

Describe the system’s operational history including deployment at other DOE sites. NA NA The LANL-HENC #1 was initially deployed at LLNL and was first evaluated during EPA-LLNL-CCP-04.08.8, 

August 2004, and more recently during EPA-LANL-CCP04.05-8 in April 2005. 

Y EPA 

EPA CCCC

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

NA NA The LANL-HENC #1 has been modified as follows: 

addition of a Cd filter; removal of sludge drum data from 

the system calibration in response to PDP related problems; and, recalculation of the efficiency to address gamma attenuation in the calibration sources. 

Y Vis

Supthe 

Neu

CaRev

SYSTEM PERFORMANCE Identify the period of performance relevant to this inspection and if this NDA system has 

prior EPA approval(s). 

NA NA The period of performance relevant to this inspection is 

April 15, 2005 to March 31, 2006, and March 31, 2006 to 

March 6, 2007. 

Y EPA 

ApLA200insp

Identify the number of waste containers this system assayed during the period of 

performance. Of these, indicate how many 

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

NA NA During the time period of interest, 3589 assays of 55-gallon 

(208 liter) drums have been conducted, including PDP 

drums and EPA replicates. These results have been compiled in a total of 351 BDRs. 

Y Info

dur
Revision No.: 1.0 HENC#1-2 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)

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

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Quantitative values and uncertainties for 

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

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Containers assayed for WIPP are TRU waste, i.e., they contain >100 nCi/g of transuranic alpha activity. 

Y 

NDA instruments and procedures are 

appropriate for the waste streams being assayed. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The LANL HENC #1 and supporting 

procedures are appropriate for the wastes 

currently being assayed. 

Y 

NDA instruments and procedures result in 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The radionuclide values produced by the LANL HENC #1 are appropriate for supporting the cumulative activity of the WIPP radionuclide inventory. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

234U, 242Pu, and 90Sr are derived by the 

application of scaling and/or correlation factors. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The scaling and/or correlation factors cited in the preceding checklist item are technically adequate and appropriately documented. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The procedure that governs the application of scaling factors is identified and the results of these calculations are documented. 

Y 
Revision No.: 1.0 HENC#1-3 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)

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

ACCEPTABLE KNOWLEDGE (AK) If isotopic ratios based on AK are used, the values are qualified by confirmatory testing. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

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

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

NDA personnel using AK derived isotopic 

values to calculate radionuclide values do so according to a formal procedure, the technical adequacy of which is adequate. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The procedure for AK calculations is identified and results of these calculations are documented in the LANL HENC #1 BDRs. 

Y 

ISOTOPIC DETERMINATION Identify the radionuclides that are measured directly and the specific radiation type (gamma, AN, or PN) that is measured. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

240PuEFF is directly measured based on 

passive neutron emission. Other 

radionuclides (238Pu, 239Pu, 241Am, etc.) are 

derived from 240PuEFF based on isotopics 

determined by gamma-based MGA or by a direct gamma determination, as appropriate. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

MGA is used to derive the isotopic contribution for unmeasured radionuclides. All containers (100%) are subject to routine gamma assay, although useable data may not 

be available for each container. AK-based 

isotopic values are used in the absence of useable MGA values when data to support AK are documented in AK/NDA Memoranda. 

Y 
Revision No.: 1.0 HENC#1-4 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)

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

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The LLD for the LANL HENC#1 has been determined for the passive neutron and gamma mode. 

Y 

Site-specific environmental backgrounds and container-specific interferences must be accounted for in LLD determinations. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Site-specific environmental backgrounds and container specific interferences are accounted for in LLD determinations. 

Y 

NDA instruments performing TRU/NonTRU waste discrimination measurements are 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Both the passive neutron and gamma modes have LLDs less than 100 nCi/g for debris and solid matrices. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The technical bases and derivation for the 

passive neutron and gamma modes are 

technically adequate and appropriately documented. 

Y 

For radionuclides that are not determined 

primarily by measurement, an LLD analog, 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

A reporting threshold (LLD analog) has 

been determined for 90Sr, 234U, and 242Pu. 

These are technically adequate and appropriately documented. 

Y 

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

provided basis on a lack of technical 

feasibility. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

There are no instances where an LLD value for a non-measured radionuclide is not 

provided based on a lack of technical 

feasibility are documented. 

NA 
Revision No.: 1.0 HENC#1-5 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)

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

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The LLD values listed in MCS-HENC#1-

NDA-1002, Revision 4, Tables 7a, 7b, 7c, 

and 7d are typical values that demonstrate the LANL HENC #1’s sensitivity with the understanding that these values listed may not be obtained for every assay event. 

Y 

TOTAL MEASUREMENT UNCERTAINTY (TMU) The method used to calculate the TMU for all required quantities must be documented and technically justified. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The method used to calculate the TMU for the LANL HENC #1 is documented and technically justified. 

Y 

TMU determination accounts for all sources of uncertainty, specifically: 

• Random errors 

• Calibration 

• Isotopic determination 

• Matrix inhomogeneity 

• Difference between calibration 

assumptions and actual waste 

• Non uniform source distribution 

• End effects 

• Self absorption 

• Transmission source 

• Self shielding 

• Neutron multiplication 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The TMU determined and documented for the LANL HENC #1 includes all required elements. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

CBFO Technical Specialist D. Stuenkel confirmed that the TMU report had been reviewed and approved. 

Y 
Revision No.: 1.0 HENC#1-6 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)

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

SYSTEM CALIBRATION Each NDA instrument must be calibrated 

before its initial use. Determine the date of 

the system’s calibration of record and where this is documented. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The LANL HENC #1 was originally calibrated in 2004. There have been four revisions to the calibration report and each was available. The system’s current calibration is documented in Revision 4. The passive neutron and gamma calibrations are technically adequate. 

Y 

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

procedures or other formal documentation. 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The operating range is the system LLD to 16.278 g 240PuEFF for passive neutron; LLD 

to 217 g Pu total for gamma, but gamma range is best expressed as 122 to 1408 keV, limited by dead time. Matrix density range for gamma is 0.018 to 1.64 g/cc and is suitable to S3000 and S5000 wastes. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Matrix/source waste combinations are representative of routine samples currently measured by the LANL HENC #1. The system is calibrated to 100% recovery. 

Y 

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

by CBFO. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Consensus standards have been used for calibrating the LANL HENC #1, see checklist item below. 

Y 
Revision No.: 1.0 HENC#1-7 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)

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

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The specific consensus standards used for calibration are: ASTM-C1030-95, ASTM C-1133-96, ASTM C-1207 and ASTM C1500. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Primary gamma standards have been obtained a commercial supplier; Pu sources for passive neutron calibration were obtained from R. Marshall’s group in the LANL CMR. Both organizations maintain a nationally accredited measurement program. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The calibration standards are listed and the 

pedigree of each has been verified. 

Y 

CALIBRATION VERIFICATION & CONFIRMATION Verification of an NDA instrument’s calibration must be performed after any of the following occurrences: major system repairs and/or modifications, replacement of the system’s components, significant changes to the system’s software, and relocation of the system. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The LANL HENC #1 has been recalibrated several times since the system’s initial calibration at LANL in 2004. Each recalibration has been confirmed and documented appropriately as discussed above in this checklist. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Recalibration of the system has been 

performed if the calibration verification 

demonstrated that the system’s response has significantly changed and the recalibration 

Y 
Revision No.: 1.0 HENC#1-8 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)

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

has been documented. 

The system calibration must be confirmed by 

performing replicate measurements of a noninterfering matrix. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The LANL HENC #1’s calibration has been confirmed and documented appropriately following each calibration. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Replicate measurements have been 

performed with 55-gallon (208 liter) drums 

and the operating and data review 

procedures that are used for routine waste 

assays. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Replicate measurements have been 

performed with appropriate standards that 

span the operational range of use of the LANL HENC #1 with respect to activity and matrix. All standards that were used for confirmation have been identified in the calibration report. See next checklist item, 

below. 

Y 

Identify the nationally accredited measurement program. List the standards used for verification/confirmation and verify the pedigree of each standard. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Standards are listed in the calibration report. The LANL program’s standards are derived from nationally recognized NIST standards. 

Y 

The standards used for calibration confirmation must not be the same sources as 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,

The standards used for calibration confirmation are different from those used 

Y 
Revision No.: 1.0 HENC#1-9 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)

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

those used for the system’s calibration of record. 

Revision 11 for the system’s calibration of record. 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Requirements for accuracy and precision have been met as specified in DOE/WIPP02-3122, Appendix A, Table A-3.2 for 

precision and ∀30% for accuracy. 

Y 
Revision No.: 1.0 HENC#1-10 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)

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

QUALITY CONTROL All radioassay functions and data validation must be performed by appropriately trained and qualified personnel. 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

All radioassay functions and data validation have been performed by personnel who are appropriately trained and qualified. 

Y 

Identify the name, title, and function of all 

personnel performing NDA data validation. 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

The name, title and function of all NDA 

personnel performing data validation for the 

LANL HENC#1 are documented. 

Y 

Requalification of personnel must be based on evidence of continued satisfactory 

performance and must be performed at least 

every two years. 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Requalification of personnel be based on evidence of continued satisfactory 

performance has been performed at least 

every two years. 

Y 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

The site has participated successfully in Cycle 13A of the CBFO sponsored NDA PDP. The conditional approval of the LANL HENC #1 effective in July 2006 was made permanent upon successful implementation of the LANL Corrective Action Plan that addressed the Cycle 13A PDP failures for the glass matrix container with HS Pu. 

Y 

BACKGROUND AND PERFORMANCE CHECKS Assay system background measurements must be taken daily, unless otherwise approved by CBFO. Determine the form of CBFO approval documentation of the alternate approach to backgrounds, if applicable. Contributions to backgrounds from nearby radiation sources must be 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Daily background are taken and recorded. Contributions to backgrounds from high activity containers that are stored or staged in proximity to the LANL HENC #1 Trailer do affect the background but NDA personnel control this. 

Y 
Revision No.: 1.0 HENC#1-11 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)

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

carefully controlled, or more frequent 

backgrounds must be measured. 

Assess how often background radiation was 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Background control charts are used to document the system’s performance over time. 

Y 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Backgrounds are evaluated against 

predetermined upper and lower boundaries 

and are non-statistical in nature. Initial control limits are based on the system’s first month of operations, and each day’s measurements are automatically compared to the established limits. 

Y 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Initial control limits for all performance measurements were based on six measurements. Limits will be recalculated as more data are acquired or the system is recalibrated. 

Y 

System performance checks must be 

performed at least once per operational day. 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Performance checks have been performed at least once per operational day and all checks have been documented. 

Y 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Performance checks include: 121 keV peak centroid and FWHM, 964 peak centroid and FWHM and weighted average of 152Eu 

activity. 

Y 
Revision No.: 1.0 HENC#1-12 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)

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

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Two matrix drums are available, a debris and homogeneous solid. They are used with a variety of PDP-type Pu sources that span a range of activity. The acceptance criteria for the Weekly Interfering Matrix checks were not apparent during this inspection. 

Y 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Interfering surrogate waste matrices have 

been constructed such that the salient matrix 

characteristics do not change over time. 

Y 

The radionuclide sources used for 

performance checks must be long-lived and 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

The 241Am, 152Eu, and Pu sources used for 

performance checks are of sufficient activity 

to provide statistically sufficient results over a short measurement time. 

Y 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

The 241Am and 152Eu sources are decay 

corrected as a function of their physical halflife. Decay correction is not applicable to 

239Pu sources. 

Y 

Performance checks must be quantitative and 

based on 2 and 3 sigma limits. 

 CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Limits are based on Student t-test for 95% 

(warning limit) and 99% (control limit) confidence intervals. 

Y 
Revision No.: 1.0 HENC#1-13 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)

Required Technical Elements Y/N Location Verification of Activity Y/N 
Revision No.: 1.0 HENC#1-14 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)

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

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

Individual Radioassay Data Sheets (RDS) were reviewed, as indicated. All were acceptable. 

Y L

L1

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

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

Y L

L1

Radioassay BDRs must consist of the following elements: 

• Testing facility name, testing batch 

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

• Table of Contents 

• Background and performance check data 

or control charts for the relevant time 

period 

• Data validation per the QAPD and site 

procedures 

• Separate testing report sheets for each 

container. 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

The LANL HENC #1 BRDs reviewed during this inspection contained all required elements. 

Y L

L1
Revision No.: 1.0 HENC#1-15 

ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)

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

Radioassay data sheets 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 signature 

• Reviewer signature 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

The LANL HENC #1 RDSs evaluated during this inspection included all required elements. 

Y R

H

LL1

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

• Testing batch reports 

• All raw data, including instrument 

readouts, calculation records, and radioassay QC results 

• All applicable instrument calibration 

reports 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

Nonpermanent records are maintained 

in the LANL HENC #1 trailer in TA-54, Area G, and all raw data are included on two compact discs that are submitted with each BDR to the CCP office. 

Y I

o

N
Revision No.: 1.0 HENC#2-1 

ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)

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

SYSTEM DESCRIPTION Identify the NDA system by name, location, and number, as appropriate. 

NA NA The system is the LANL-HENC #2 and is located at 

Technical Area 54 (TA 54), Building 498, Area G, Pad 10 at LANL. This is the first EPA inspection of this system. 

Y V

HG 

Describe the system’s operational history, including deployment at other DOE sites. NA NA The LANL-HENC #2 was initially deployed at LANL and was previously operated under the LANL WIPP program. Y C

I

Ga

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

NA NA This is the initial EPA inspection of the LANL HENC #2. Y V

##Ga

SYSTEM PERFORMANCE Identify the period of performance relevant to this inspection and if this NDA system has 

prior EPA approval(s). 

NA NA The period of performance relevant to this inspection is the 

system’s initial calibration to March 31, 2006, and March 31, 2006 to March 6, 2007 

Y E

MsFoC

Identify the number of waste containers this system assayed during the period of 

performance. Of these, indicate how many 

BDRs were assembled. Of the assembled BDRs, indicate how many have been 

promoted through Project Level Review and 

are available for evaluation during this inspection. 

NA NA During the time period of interest 218 assays of 55-gallon 

(208 liter) drums have been conducted, including PDP drums and EPA replicates. These results have been compiled in a total of 20 BDRs. 

Y I

S
Revision No.: 1.0 HENC#2-2 

ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)

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

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

Y CCP-PO-001 ,CCP Transuranic 

Waste Certification Plan,Revision 11 

Quantitative values and uncertainties for 

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

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Containers assayed for WIPP are TRU waste, i.e., they contain >100 nCi/g of transuranic alpha activity. 

Y 

NDA instruments and procedures are 

appropriate for the waste streams being assayed. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The LANL HENC #2 and supporting procedures are appropriate for the wastes currently being assayed. 

Y 

NDA instruments and procedures result in 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The radionuclide values produced by the LANL HENC #2 are appropriate for supporting the cumulative activity of the WIPP radionuclide inventory. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

234U, 242Pu, and 90Sr are derived by the 

application of scaling and/or correlation factors. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The scaling and/or correlation factors cited in the preceding checklist item are technically adequate and appropriately documented. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The procedure that governs the application of scaling factors is identified and the results of these calculations are documented. 

Y 
Revision No.: 1.0 HENC#2-3 

ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)

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

ACCEPTABLE KNOWLEDGE (AK) If isotopic ratios based on AK are used, the values are qualified by confirmatory testing. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

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

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

NDA personnel using AK-derived isotopic 

values to calculate radionuclide values do so according to a formal procedure, the technical adequacy of which is adequate. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The procedure for AK calculations is identified and results of these calculations are documented in the LANL HENC #2 BDRs. 

Y 

ISOTOPIC DETERMINATION Identify the radionuclides that are measured directly and the specific radiation type (gamma, AN or PN) that is measured. 

Y CCP-PO-001 CCP Transuranic 

Waste Certification Plan,Revision 11 

240PuEFF is directly measured based on 

passive neutron emission. Other 

radionuclides (238Pu, 239, Pu242, Am241, etc.) 

are derived from 240PuEFF based on isotopics 

determined by gamma-based MGA or by a direct gamma determination, as appropriate. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

MGA is used to derive the isotopic contribution for unmeasured radionuclides. All containers (100%) are subject to routine gamma assay, although useable data may not 

be available for each container. AK-based 

isotopic values are used in the absence of useable MGA values when data to support AK are documented in AK/NDA Memoranda. 

Y 
Revision No.: 1.0 HENC#2-4 

ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)

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

LOWER LEVEL OF DETECTION (LLD) The LLD for each NDA system must be determined. For multimodal systems this may require a separate determination for each mode, i.e., active neutron, passive neutron, and gamma. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The LLD for the LANL HENC#1 has been determined for the passive neutron and gamma mode. 

Y 

Site-specific environmental backgrounds and container-specific interferences must be accounted for in LLD determinations. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Site-specific environmental backgrounds and container specific interferences are accounted for in LLD determinations. 

Y 

NDA instruments performing TRU/NonTRU waste discrimination measurements are 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Both the passive neutron and gamma modes have LLDs less than 100 nCi/g for debris and solid matrices. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The technical bases and derivation for the 

passive neutron and gamma modes are 

technically adequate and appropriately documented. 

Y 

For radionuclides that are not determined 

primarily by measurement, an LLD analog, 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

A reporting threshold (LLD analog) has 

been determined for 90Sr, 234U, and 242Pu. 

These are technically adequate and appropriately documented. 

Y 

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

provided basis on a lack of technical 

feasibility. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

There are no instances where an LLD value for a non-measured radionuclide is not 

provided based on a lack of technical 

feasibility are documented. 

NA 
Revision No.: 1.0 HENC#2-5 

ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)

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

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The LLD values listed in MCS-HENC#2-

NDA-1002, Revision 0, Tables 8a, 8b, 8c, 

and 8d are typical values that demonstrate the LANL HENC #2’s sensitivity with the understanding that these values listed may not be obtained for every assay event. 

Y 

TOTAL MEASUREMENT UNCERTAINTY (TMU) The method used to calculate the TMU for all required quantities must be documented and technically justified. 

 CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The method used to calculate the TMU for the LANL HENC #2 is documented and technically justified. 

Y 

TMU determination accounts for all sources of uncertainty, specifically: 

• Random errors 

• Calibration 

• Isotopic determination 

• Matrix inhomogeneity 

• Difference between calibration 

assumptions and actual waste 

• Non-uniform source distribution 

• End effects 

• Self absorption 

• Transmission source 

• Self shielding 

• Neutron multiplication

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The LANL HENC #2 TMU addresses all required elements. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

CBFO Technical Specialist D. Stuenkel confirmed that the TMU report had been reviewed and approved. 

Y 
Revision No.: 1.0 HENC#2-6 

ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)

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

SYSTEM CALIBRATION Each NDA instrument must be calibrated 

before its initial use. Determine the date of 

the system’s calibration of record and where this is documented. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The LANL HENC #2 was originally for both gamma and passive neutron in February 2006. The passive neutron and gamma calibrations are technically adequate. 

Y 

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

procedures or other formal documentation. 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The operating range is the system LLD to 16.29 g 240PuEFF for passive neutron; LLD to 

217 g Pu total for gamma, but gamma range is best expressed as ~50 to 1228 keV, limited by dead time. Matrix density range for gamma is 0.018 to 1.64 g/cc and is suitable to S3000 and S5000 wastes. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Matrix/source waste combinations are representative of routine samples currently measured by the LANL HENC #2. The system is calibrated to 100% recovery. 

Y 

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

by CBFO. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Consensus standards have been used for calibrating the LANL HENC #2, see checklist item below. 

Y 
Revision No.: 1.0 HENC#2-7 

ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)

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

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The specific consensus standards used for calibration are: ASTM-C1030-95, ASTM C-1133-96, ASTM C-1207 and ASTM C1500. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Primary gamma standards have been obtained from a commercial supplier; Pu sources for passive neutron calibration were obtained from R. Marshall’s group in the LANL CMR. Both organizations maintain a nationally accredited measurement program. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The gamma and neutron calibration standards are listed and the pedigree of each has been verified. 

Y 

CALIBRATION VERIFICATION & CONFIRMATION Verification of an NDA instrument’s calibration must be performed after any of the following occurrences: major system repairs and/or modifications, replacement of the system’s components, significant changes to the system’s software, and relocation of the system. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The LANL HENC #2 has not been recalibrated since the system’s initial calibration at LANL in 2006. 

Y 
Revision No.: 1.0 HENC#2-8 

ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)

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

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The system has not been recalibrated. There have been 7 calibration verifications for 

performance-related reasons between 6-21-

06 and 3-5-07, see Section 8.2, LANL HENC#2, (5). 

Y 

The system calibration must be confirmed by 

performing replicate measurements of a noninterfering matrix. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The LANL HENC #2’s calibration has been confirmed and documented appropriately following each calibration. 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Replicate measurements have been 

performed with 55-gallon (208 liter) drums 

and the operating and data review 

procedures that are used for routine waste 

assays. 

Y 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Replicate measurements have been 

performed using nationally recognized 

standards or standards derived from nationally recognized standards that span the range of use of the instrument with respect to disintegration rate and/or matrix effects. All standards that were used have been identified and their application documented. 

Y 
Revision No.: 1.0 HENC#2-9 

ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)

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

Identify the nationally accredited measurement program. List the standards used for verification/confirmation and verify the pedigree of each standard. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Standards are listed in the calibration report. The LANL program’s standards are derived from nationally recognized NIST standards 

Y 

The standards used for calibration confirmation must not be the same sources as those used for the system’s calibration of record. 

 CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The standards used for calibration confirmation are different from those used for the system’s calibration of record. 

Y 

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

 CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Requirements for accuracy and precision have been met as specified in DOE/WIPP02-3122, Appendix A, Table A-3.2 for 

precision and ∀30% for accuracy. 

Y 
Revision No.: 1.0 HENC#2-10 

ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)

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

QUALITY CONTROL All radioassay and data validation must be 

performed by appropriately trained and 

qualified personnel. 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

All radioassay functions and data validation have been performed by appropriately trained and qualified personnel. 

Y 

Identify the name, title, and function of all 

personnel performing NDA data validation. 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

The name, title, and function of all NDA 

personnel performing data validation for the 

LANL HENC#1 are documented. 

Y 

Requalification of personnel must be based on evidence of continued satisfactory 

performance and must be performed at least 

every two years. 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Requalification of personnel based on evidence of continued satisfactory 

performance has been performed at least 

every two years. 

Y 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

The site has participated successfully in Cycle 13A of the CBFO-sponsored NDA PDP. The conditional approval of the LANL HENC #2 effective in July 2006 was made permanent upon successful implementation of the LANL Corrective Action Plan that addressed the Cycle 13A PDP failures for the glass matrix container with HS Pu. 

Y 

BACKGROUND AND PERFORMANCE CHECKS Assay system background measurements must be taken daily, unless otherwise approved by CBFO. Determine the form of CBFO approval documentation of the alternate approach to backgrounds, if applicable. Contributions to backgrounds from nearby radiation sources must be 

Y CCP-PO-001 ,CCP 

Transuranic Waste Certification Plan, Revision 11 

Daily background measurements are taken and recorded. Contributions to backgrounds from high activity containers that are stored or staged in proximity to the LANL HENC #2 Trailer do affect the background, but 

NDA personnel control this. 

Y 
Revision No.: 1.0 HENC#2-11 

ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)

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

carefully controlled, or more frequent 

backgrounds must be measured. 

Assess how often background radiation was 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Background control charts are used to document the system’s performance over time. 

Y 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Backgrounds are evaluated against 

predetermined upper and lower boundaries 

and are non-statistical in nature. Initial control limits are based on the system’s first month of operations and each day’s measurements are automatically compared to the established limits. 

Y 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Initial control limits for all performance measurements were based on six measurements. Limits will be recalculated as more data are acquired or the system is recalibrated. 

Y 

System performance checks must be 

performed at least once per operational day. 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Performance checks have been performed at least once per operational day and all checks have been documented. 

Y 

System performance checks must include, as applicable, efficiency, matrix correction 

Y CCP-PO-001, CCP 

Transuranic Waste 

Performance checks include: 121 keV peak centroid and FWHM, 964 kev peak centroid 

Y 
Revision No.: 1.0 HENC#2-12 

ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)

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

checks, and systems peak position and resolution for spectrometric systems. 

Certification Plan, Revision 11 and FWHM and weighted average of 152Eu 

activity. 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Two matrix drums are available, a debris and homogeneous solid. They are used with a variety of PDP-type Pu sources that span a range of activity. The acceptance criteria for the Weekly Interfering Matrix checks were not apparent during this inspection. 

Y 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Interfering surrogate waste matrices have 

been constructed such that the salient matrix 

characteristics do not change over time. 

Y 

The radionuclide sources used for 

performance checks must be long-lived and 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

The 241Am, 152Eu, and Pu sources used for 

performance checks are of sufficient activity 

to provide statistically sufficient results over a short measurement time. 

Y 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

The 241Am and 152Eu sources are decay 

corrected as a function of their physical halflife. Decay correction is not applicable to 

239Pu sources. 

Y 

Performance checks must be quantitative and 

based on 2 and 3 sigma limits. 

 CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Limits are based on Student t-test for 95% 

(warning limit) and 99% (control limit) confidence intervals. 

Y 
Revision No.: 1.0 HENC#2-13 

ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)

Required Technical Elements Y/N Location Verification of Activity Y/N 
Revision No.: 1.0 HENC#2-14 

ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)

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

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

Individual Radioassay Data Sheets (RDS) were reviewed, as indicated. All were acceptable. 

Y H

22

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

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

Y H

22

Radioassay BDRs must consist of the following elements: 

• Testing facility name, testing batch 

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

• Table of Contents 

• Background and performance check data 

or control charts for the relevant time 

period. 

• Data validation per the QAPD and site 

procedures 

• Separate testing report sheets for each 

container. 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

The LANL HENC #2 BRDs reviewed during this inspection contained all required elements. 

Y H

22
Revision No.: 1.0 HENC#2-15 

ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)

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

Radioassay data sheets 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 signature 

• Reviewer signature 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

The LANL HENC #2 RDSs evaluated during this inspection included all required elements. 

Y R

H

2   

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

• Testing batch reports 

• All raw data, including instrument 

readouts, calculation records, and radioassay QC results 

• All applicable instrument calibration 

reports 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

Nonpermanent records are maintained 

in the LANL HENC #2 trailer in TA-54, Area G, and all raw data are included on two compact discs that are submitted with each BDR to the CCP office. 

Y I

o

N
Revision No.: 1.0 PTGS-1 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

SYSTEM DESCRIPTION Identify the NDA system by name, location, and number, as appropriate. 

NA NA The system is the LANL P-TGS (LANL Property No. 

959314) and is housed in Trailer No. TA-54-B438 in Technical Area 54 (TA-54), Area G, Pad 10. 

Y V

s5

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

NA NA This is the same PTGS unit that was evaluated by EPA 

previously during EPA-LANL-CCP-04.08.8 in August 

2004 and EPA-LANL-CCP-04.05-8 in April 2005. It isused in conjunction with two (2) PC-FRAM Units No. 1 (Detector No. 137P40796A and No .3 (Detector No. 40P21213B). The FRAM units are housed in Trailer 

No.TA-54-B439 in TA-54, Area G. 

Y V

aA

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

NA NA The system has been refurbished since its initial 

deployment, including software upgrades (Master Analysis, Master Scan and Maestro), repair of the DSPEC+ spectrometer and modifications to secure the

109Cd rate-loss correction source to the detector face. 

These have been appropriately documented. 

Y E

REA0

SYSTEM PERFORMANCE Identify the period of performance relevant to this inspection and if this NDA system has 

prior EPA approval(s). 

NA NA The period of performance relevant to this inspection is 

April 15, 2005 to March 31, 2006, and March 31, 2006 to 

March 6, 2007. 

Y E

Ms8sL

Identify the number of waste containers this system assayed during the period of 

performance. Of these, indicate how many 

BDRs were assembled and how many have 

been promoted through Project Level 

Review. 

NA NA During the time period of interest, 951 55-gallon drums 

have been assayed, and these results have been compiled in a total of 136 BDRs. 

Y S

MP

1MW
Revision No.: 1.0 PTGS-2 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

Quantitative values and uncertainties for 238Pu, 

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

Y Radioassay Data 

092, LA05-PTGPTGS-057 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

Only payload containers that contain TRU radionuclides concentrations greater than 100 nCi/g are eligible for disposal at WIPP. 

Y BDR Nos. LA05

LA05-PTGS-04

NDA instruments and procedures are 

appropriate for the waste streams 

being assayed. 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

PTGS and associated FRAM procedures are appropriate for S5000 debris waste. In this checklist, the term PTGS refers to the combination of the PTGS for quantitative 

239Pu determination in conjunction with an 

isotopic distribution from one of the two FRAM units. 

Y Calibration Repo

Calibration and 239, NWIS-TP: 

Portable TGS M

Confirmation foAugust 1, 2005 

NDA instruments and procedures 

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

Y CCP-PO-001 CCP 

Transuranic Waste Certification Plan,Revision 11 

The radionuclide values produced by the PTGS are appropriate for supporting the cumulative activity of the WIPP radionuclide inventory. 

Y Portable TGS M

Confirmation fo

March 31, 2005 

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

All measurements are scaled to the measured 

239Pu value, using FRAM or AK-based 

isotopic values. 234U is scaled to measured 

values of 235U and 238Pu; 242Pu and 90Sr are 

scaled to the measured value of 137Cs; and 

242Pu is correlated to 239Pu, 240Pu and 241Pu. 

Y LANL Reports: 

NDA Reporting, 

2003; CCP-TP-1Waste ContainerSystem, May 17
Revision No.: 1.0 PTGS-3 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

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

Y CCP-PO-001 ,CCP 

Transuranic Waste Certification Plan, 

Revision 11 

The calculations used to apply scaling factors to determine 235U, 242Pu, and 90Sr are 

technically adequate and appropriately documented. 

Y CCP Technical P

Revision 2; CCP

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

The procedures controlling the application of scaling factors to determine 235U, 242Pu, and 

90Sr are identified. The results are 

documented in radioassay BDRs. 

Y CCP-TP-124, R

2, Appendix A; PTGS-092, LA0LA05-PTGS-05

ACCEPTABLE KNOWLEDGE (AK) If isotopic ratios based on AK are used, the values are qualified by confirmatory testing. 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

Isotopic ratios are determined using samplespecific gamma data and PC-FRAM. AK indicates that debris waste is primarily WG Pu. If default isotopic ratios are unavailable, only radionuclides that are directly measured will be reported. 

Y CCP Technical P

Revision 2; CCP

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

AK derived isotopic values are documented in CCP-AK/NDA Memoranda. This activity is technically adequate and is executed in accordance with CCP procedures. 

Y CCP-AK-LANL

Revision 0; MemEstill regarding CCP-TP-124, R

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

The results of these calculations are documented in PTGS BDRs. 

Y BDR Nos. LA05

LA05-PTGS-04

ISOTOPIC DETERMINATION Identify the radionuclides that are measured directly and the specific radiation type (gamma, AN, or PN) that is measured. 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

The PTGS measures the gamma emission of the 414 keV line of 239Pu. All other 

radionuclides that are reported are based on this measurement. 

Y CCP-TP-126, R
Revision No.: 1.0 PTGS-4 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan,Revision 11 

FRAM is used for the isotopic determination. AK isotopics (default) are used when required. 

Y CCP Technical P

Revision 2; CCP
Revision No.: 1.0 PTGS-5 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

LOWER LEVEL OF DETECTION (LLD) The LLD for each NDA system must be determined. For multimodal systems this may require a separate determination for each mode, i.e., active neutron, passive neutron, and gamma. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification PlanRevision 11 

The LLD for the PTGS has been determined and is technically adequate and appropriately documented. 

Y L

L

GT

Site-specific environmental backgrounds and container-specific interferences must 

be accounted for in LLD determinations. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

LLD determinations are containerspecific. TA-54 Area G backgrounds are addressed in all LLD determinations. 

Y L

L

GT

NDA instruments performing TRU/NonTRU waste discrimination measurements 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The PTGS is not used to distinguish TRU and Non-TRU wastes. The LLD is approximately 0.09 g 239Pu, which is 

well below the system’s operational range of 0.565 – 176.76 g of 239Pu. 

Y L

L

GT

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Only assay values above the LLD and system’s operational range of 0.565 – 176.76 g of 239Pu will be reported. 

Assays that are below the system’s LLD are flagged as failed assays, in 

accordance with CCP-TP-125, and an NCR is initiated for each. 

Y L

L

GT

For radionuclides that are not determined 

primarily by measurement, an LLD analog, 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

LLDs for all radionuclides except 239Pu 

are determined relative to the 239Pu 

LLD, and all could be considered a technically based reporting threshold. 

Y L

L

GT
Revision No.: 1.0 PTGS-6 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

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

not provided based on a lack of technical feasibility. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

There are no instances where an LLD value for a non-measured radionuclide 

is not provided based on a lack of technical feasibility. 

NA 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

LLDs are measurement-event specific, 

based on the system’s response to the 

414 keV 239Pu line. 

Y L

L

GT

TOTAL MEASUREMENT UNCERTAINTY (TMU) The method used to calculate the TMU for all required quantities must be documented and technically justified. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The TMU determination for the PTGS is documented and technically adequate. 

Y R

MR

T(M

TMU determination accounts for all sources of uncertainty, as appropriate, specifically: 

• Random errors 

• Calibration 

• Isotopic determination 

• Matrix inhomogeneity 

• Difference between calibration 

assumptions and actual waste 

• Non-uniform source distribution 

• End effects 

• Self absorption 

• Transmission source

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

The TMU determination accounts for all sources of uncertainty applicable to the PTGS. 

Y R

MR

T(M
Revision No.: 1.0 PTGS-7 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

• Self shielding

• Neutron multiplication

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

CBFO Technical Specialist D. Stuenkel confirmed that the TMU report had 

been reviewed and approved 

Y O

Sc
Revision No.: 1.0 PTGS-8 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

SYSTEM CALIBRATION Each NDA instrument must be calibrated 

before its initial use. Determine the date of 

the system’s calibration of record and where this is documented. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The PTGS was initially calibrated in December 2003. It was recalibrated in December 2004, and again in August 2005. All calibrations are appropriately documented. 

Y C

C

P

a

P

M

M

2

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

procedures or other formal documentation. 

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

The calibration range of the PTGS is from 0.565 – 176.76 g of 239Pu. The 

PTGS assays only debris (S5000) wastes. The PTGS is prohibited from assaying HS Pu in any matrix due to a 

NDA PDP failure of Cycle 13A. 

Y P

a

P

AMCoC

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The calibration was performed in a 55-gallon (208 liter) drum using a combustibles matrix similar to the routine waste matrix. The PTGS is calibrated to 100% recovery. 

Y P

a

P

A

The use of consensus standards for calibration is required, when such 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,

Consensus standard for calibration have not been identified. CBFO has 

Y C

R
Revision No.: 1.0 PTGS-9 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

standards exist. If consensus standards do not exist, the calibration technique must be approved by CBFO. 

Revision 11 approved Recalibration and 

Confirmation Plan for the Portable Tomographic Gamma Scanner – June 2005.

PJ

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

See previous checklist item. Y 

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

program. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Certificates for the PuO2 sources used 

for calibration were reviewed and found to be acceptable. All are PDP-style sources traceable to NIST. 

Y L

M9

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

Standards used for calibration included combinations of PuO2 sources totaling 

0, 0.6, 3, 10, 100, and 189 g total Pu and were obtained by combining the specific 

239Pu sources listed to the right. Each 

source has an acceptable pedigree. 

Y L

M

0R

CALIBRATION VERIFICATION & CONFIRMATION Verification of an NDA instrument’s calibration must be performed after any of the following occurrences: major system repairs and/or modifications, replacement of the system’s components, significant changes to the system’s software, and relocation of the system. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

Initial verification of the PTGS calibration was performed and documented. Two subsequent verifications were performed on August 1-2, 2005, and October 3-4, 2005. These were required due to replacement of the system’s spectrometer and a 

Y C

P

S0

P
Revision No.: 1.0 PTGS-10 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

shutter problem, respectively. Both verifications were performed and documented appropriately. 

S0

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

The PTGS was recalibrated in August 2005, see previous checklist entry. 

Y P

a

P

A

The system calibration must be confirmed 

by performing replicate measurements of a 

non-interfering matrix. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

Calibration confirmation has been 

performed by making six (6) replicate 

measurements for each of three (3) drums containing 0.9, 9, and 160 g total Pu in a non-interfering matrix, as documented in NWIS-TP: 2005-0105. 

Y P

a

P

A

Replicate measurements must be 

performed with containers of the same 

nominal size and according to the same 

procedures used for actual waste assays. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

Replicate measurements have been 

performed with containers of the same 

nominal size and according to the same 

procedures as those used for actual 

waste assays. Replicate measurements were made using 55-gallon drums of the same size and shape as those to be assayed. 

Y R

mT

P

S

p

a

Replicate measurements must be 

performed using nationally recognized 

standards or standards derived from nationally recognized standards that span the range of use of the instrument with respect to disintegration rate and/or matrix 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

Replicate measurements have been 

performed using PuO2 sources of the 

same type as those discussed above for calibration. Sources span the range of use of the PTGS with respect to activity and matrix. All standards have been 

Y P

a

P

A

N

0
Revision No.: 1.0 PTGS-11 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

effects. Identify all standards that were used and indicate their application (verification or confirmation). 

identified and are listed in the column to the right. 

N

0

Identify the nationally accredited measurement program. List the standards used for verification/confirmation and verify the pedigree of each standard. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

The LANL program that fabricated the PuO2 sources is a nationally accredited 

measurement program. All PuO2

sources used for verification and/or confirmation are traceable to NIST. 

Y 

cas

The standards used for calibration confirmation must not be the same sources as those used for the system’s calibration of record. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

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

Y P

a

P

A

Requirements for accuracy, expressed as %R, and precision, expressed as %RSD, must be met as specified in DOE/WIPP02-3122, Appendix A, Table A-3.2 for 

precision and ∀30% for accuracy. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

Requirements for accuracy and 

precision have been met as specified in 

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

accuracy. 

Y P

(

pb

m
Revision No.: 1.0 PTGS-12 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

QUALITY CONTROL All radioassay data validation must be 

performed by appropriately trained and 

qualified personnel. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

All radioassay data validation and review personnel have been trained and are currently listed as qualified 

personnel. 

Y C

IA

p

Identify the name, title, and function of all 

personnel performing NDA data 

validation. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

Expert Analysts: Doug Cramer, Harald Poths, and Joseph Wachter Independent Technical Reviewers 

Y C

IA

p

Requalification of personnel must be based on evidence of continued satisfactory 

performance and must be performed at 

least every two years. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

Requalification of personnel based on evidence of continued satisfactory 

performance has been performed at least 

every two years. 

Y C

IA

p

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

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

Y 

AV

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

The site has participated successfully in the CBFO-sponsored NDA PDP Primary Cycle 13A. PTGS is prohibited from assaying HS Pu. 

Y J

M

RN

Jfuo
Revision No.: 1.0 PTGS-13 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

BACKGROUND AND PERFORMANCE CHECKS Assay system background measurements must be taken daily, unless otherwise approved by CBFO. Determine the form of CBFO approval documentation of the alternate approach to backgrounds, if applicable. Contributions to backgrounds from nearby radiation sources must be carefully controlled, or more frequent 

backgrounds must be measured. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

The PTGS background is measured daily for each assay event using the 414 keV emission line of 239Pu, and 

backgrounds are recorded in PTGS 

BDRs. Contributions to backgrounds from nearby radiation sources (high activity staged drums) have the potential to affect PTGS backgrounds and these are controlled. 

Y P

0P

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Background records in the PTGS BRDs reviewed for this inspection do not indicate a serious background problem. 

Y P

0P

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Backgrounds have been evaluated against an acceptance criterion derived 

by dividing the net counts by the 

uncertainty. 

Y P

0P

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

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

Y L

L

T

System performance checks must be 

performed at least once per operational 

day. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Performance checks have been 

performed at least once per operational 

day and all checks have been documented. 

Y R

N

PL

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Checks include: Efficiency using TGS# for133Ba at 356 keV; FWHM for 109Cd 

and 133Ba; energy calibration control at 

88 and 356 keV using 75Se 

Y R

N

PL
Revision No.: 1.0 PTGS-14 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Combustibles (debris) matrix is used with PuO2 sources of 2.8, 25.0, 93.0, 

135.5, and 164.5 g total Pu for weekly interfering matrix checks. 

Y I

R

S

N

M

IfLFA

a30

Interfering surrogate waste matrices must 

be constructed in such a way that the 

salient matrix characteristics do not change over time. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

Matrix containers are the same as those used for the CBFO sponsored NDA PDP and are adequately constructed. 

Y V

dCe

The radionuclide sources used for 

performance checks must be long-lived 

and of sufficient strength (activity) to 

provide statistically sufficient results over 

a short measurement time. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan, Revision 11 

133Ba, 109Cd, 75Se, and 239Pu sources are 

of adequate intensity for their intended 

purposes. 

Y I

N

PP

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

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

133Ba, 109Cd, and 75Se sources are decay 

corrected as appropriate. Decay correction is not applicable to 239Pu 

sources. 

Y I

N

PP

Performance checks must be quantitative and based on 2 and 3 sigma limits. 

Y CCP-PO-001, CCP Transuranic 

Waste Certification Plan,Revision 11 

Limits are based on Student t-test for 

95% (warning limit) and 99% (control limit) confidence intervals. 

Y C

BL0
Revision No.: 1.0 PTGS-15 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

DATA MANAGEMENT All radioassay data must be reviewed and approved by qualified personnel before 

being reported to WWIS. 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Individual Radioassay Data Sheets (RDS) were reviewed, as indicated. All were acceptable. 

Y Rev

PTG

LALALA LA

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

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

The name, title, and function of all 

personnel performing review and 

approval of BRDs are documented. All 

personnel are appropriately qualified. 

Y PTG

LALA

Radioassay BDRs must consist of the following elements: 

• Testing facility name, testing batch 

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

• Table of Contents 

• Background and performance check 

data or control charts for the relevant time period. 

• Data validation per the QAPD and site 

procedures 

• Separate testing report sheets for each 

container. 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

The PTGS BRDs reviewed during this inspection contained all required elements. 

Y PTG

LALA
Revision No.: 1.0 PTGS-16 

ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 

Inspection Date: May 23 – 25, 2006

NDA System: Portable Tomographic Gamma Scanner (PTGS)

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

Radioassay data sheets 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 signature 

• Reviewer signature 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

The PTGS RDSs evaluated during this inspection included all required elements. 

Y Rev

PTG

LALALA LAS84

The following nonpermanent records must 

be maintained at the radioassay-testing 

facility or forwarded to the site project office: 

• Testing batch reports 

• All raw data, including instrument 

readouts, calculation records, and radioassay QC results 

• All applicable instrument calibration 

reports 

Y CCP-PO-001, CCP 

Transuranic Waste Certification Plan, Revision 11 

Nonpermanent records are maintained in 

the PTGS trailer in TA-54, Area G, and all raw data are included on two compact discs that are submitted with each BDR to the CCP office. 

Y Inte

oth
Revision No.: 1.0 RTR-1 

ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspecti

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objectiv

Co

RTR-1: Site procedures identify required training and qualifications for RTR 

personnel 

Y 

CCP-QP-002, Rev. 20 CCP-TP-028, Rev. 3 

• Operator training was consistent with 

applicable procedures 

• Operator certification is current • OJT was documented for each operator 

• Operators are re-qualified every two years • RTR operators passed a training drum test that 

includes items common to the waste streams examined at the site (biannually) 

• Training drum contains all required items 

• RTR operators receive training on the waste 

matrix parameters and typical packaging configurations expected to be found in each waste stream. 

Y CCP uses Qualification C

record training received bProject Manager appointExperts (SME,) and this 

by a letter included in the 

The site maintains a List which is used to ensure athe inspection, EPA reviedemonstration tape and devery six months) for an 

performed on May 3, 200

LANL-NDE-TEST-001-

problems identified durin

Training on specific wastypical packaging configexpected to be found in e

provided to the RTR per

training is provided only update to the AK record. 

Objective evidence revie

1. Competency demon

and associated docum

2. List of Qualified Ind3. RTR demonstration: 

S852566. RTR unit 

RTR-2: Site procedure(s) provide complete instructions for operators to perform the RTR examination and completion of the associated documentation. 

Y 

CCP-TP-002, Rev. 20 CCP-TP-053, Rev. 4, s. 4.0, Attachments 1 & 2 

• RTR operator adequately explained the process 

followed for examining a drum and entering data into data forms (whether hard copy or electronic data entry is used). 

Y During the on-site inspec

RTR event for a debris (SS852566, on RTR unit #RTR event for a debris (S58959, on RTR unit #2. the applicable procedure the RTR operations area event in accordance with 
Revision No.: 1.0 RTR-2 

ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspecti

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objectiv

Co

RTR data are electronicaform (Attachment 2 of prsecond person who acts aare not qualified RTR opPair Resolution check fo

prior to EPA’s arrival, th

of the audio/visual recordEPA. EPA reviewed audio/visugenerated from both RTR complete, but one issue wgeneration of the RTR daParameter weights (WMrecorded for leaded rubbVE. In RTR the weight osolely to Rubber but in V

between Rubber and Oth

checklist). EPA generateaddress this issue. LANL-CCP-VE-06-006C

1. Waste Material Para

inconsistently recordIn RTR, leaded glovunder the rubber waVE the weight of the following way: 60% metals. 

2. VE personnel were u

rationale for assigninmanner. 

Objective evidence revie

1. Batch Data Report a

for batches LA-RTRRTR2-05-0111 (S30
Revision No.: 1.0 RTR-3 

ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspecti

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objectiv

Co

05-0112 (S3000), LALA-RTR1-06-0003 RTR1-06-0002 (S50(S5000) 

2. BDRs LA-RTR2-05

04-0007, LA-RTR2-RTR2-05-0175 (S30

3. RTR demonstration: 

S852566; RTR unit 

RTR-3: The RTR procedure(s) require an image quality check to be 

performed. 

Y 

CCP-TP-053, Rev. 4, s. 4.3, Attachment 1 

• Operator adequately explained how the 

acceptability of an image is determined 

• Image quality check is performed once per day • Performance of the image quality check is 

documented and recorded 

Y EPA observed the RTR e

on both RTR units #1and 58959). The operator vathe examination to accomWMPs present. The oper

present and this informat

second person (not a qua

conclusion of the examin

WMP weights based on tAttachment 2 of the procIn each of the BDRs revicheck was documented o

procedure CCP-TP-053 (

Report). EPA also reviewon selected audio/visual examinations. 

Objective evidence revie

1. Batch Data Report a

for batches LA-RTRRTR2-05-0111 (S3005-0112 (S3000), LALA-RTR1-06-0003 RTR1-06-0002 (S50(S5000) 
Revision No.: 1.0 RTR-4 

ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspecti

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objectiv

Co

2. BDRs LA-RTR2-05

04-0007, LA-RTR2-RTR2-05-0175 (S30

3. RTR demonstration: 

S852566; RTR unit 

RTR-4: The procedure allows the operator to adjust the RTR to accommodate the physical 

properties of the waste and 

waste containers likely to be encountered at the site. 

Y 

CCP-TP-053, Rev. 4, s. 4.3, 4.4 

• Operator could identify applicable policies and 

procedures governing the operation of RTR 

equipment 

• The RTR system could be adjusted • High-density material was examined with the 

x-ray device set on the maximum voltage and low density material at a lower voltage 

• Operator adequately explained what is done if 

an image is unacceptable (e.g., the waste is solidified or the container is lead-lined) 

Y EPA observed the RTR e

on both RTR units #1and 58959). The operator vathe examination to accomWMPs present. The ope

present and this informat

second person (not a quaconclusion of the examinWMP weights based on tAttachment 2 of the procThe operator was able to would be written. Some ocontained NCRs for prohLA-RTR1-06-0003, contand S815002, all had linevented and NCR-LANL-address this issue. Also, S822352, contained liquiLANL-0187-05 was writ

prohibited item. 

In each of the BDRs revicheck was documented o

procedure CCP-TP-053 (

Report). EPA also review

on selected audio/visual examinations. 

Objective evidence revie

1. Batch Data Report a

for batches LA-RTR
Revision No.: 1.0 RTR-5 

ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspecti

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objectiv

Co

RTR2-05-0111 (S3005-0112 (S3000), LALA-RTR1-06-0003 RTR1-06-0002 (S50(S5000) 

2. BDRs LA-RTR2-05

04-0007, LA-RTR2-RTR2-05-0175 (S30

3. RTR demonstration: 

S852566; RTR unit 

RTR-5: Y 

CCP-TP-053, Rev. 4, s. 4.0, Attachment 1 

• RTR tape is high quality, the sound track is 

audible, and the required information is contained on the audible portion of the tape 

• The RTR tape is consistent with the data 

package for the same drum 

Y As part of the inspection

selected drums in batche(S5000), LA-RTR2-05-0LA-RTR2-05-0112 (S30(S5000), LA-RTR1-06-0LA-RTR1-06-0002 (S50(S5000) were reviewed. audio/visual tapes and BDwere consistent. The audand of good quality. 

Objective evidence revie

1. Batch Data Report a

for batches LA-RTRRTR2-05-0111 (S3005-0112 (S3000), LALA-RTR1-06-0003 RTR1-06-0002 (S50(S5000) 

RTR-6: There is a procedure for determining whether the waste matches the waste stream description and Waste Matrix 

Y 

CCP-TP-053, Rev. 4, s. 4.4.3 [D]-[F], [H], 

• The procedure is adequately implemented • Operators verify that the waste matches the 

waste stream description 

• Waste Matrix Code is verified. If not, 

Y Procedure CCP-TP-053 c

table, Table 3, which wa

observed by EPA. Howeconsistently when estima(see EPA Concern LANL
Revision No.: 1.0 RTR-6 

ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspecti

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objectiv

Co

Code, and for determining Waste Material Parameters and weights 

Attachment 2, Table 3 

corrective action is taken 

• WMP weights are estimated by compiling an 

inventory of waste items and residual/packaging materials 

• Does the RTR operator use a standard weight 

lookup table to provide an estimate of WMP weights? If so, has the table been updated to reflect additional information gained through 

previous RTR/VE exams or updated AK 

information? 

RTR-2 above). Attachment 2, CCP-TP-0Sheet, documents that thmatches the waste stream matrix code. During the observed by EPA, neitheinterviewed (RTR units # explain how they verified matched the waste stream did not have a hard copy waste stream description trailers, and they were noexpected WMPs in the wexamining (see also the Vgenerated the following C

(see also VE-6). LANL-CCP-VE-06-005C

Attachments used for datVE include a line item thverify that the waste examStream description. The demonstration and the op2, observed by EPA on Mexplain how they were abThese personnel did not descriptions, for example respective work areas nothe items included in the 

provided in the AK Sum

stream they were current

March 6, 2007 meeting, CCP RTR and VE Traini

presentation) and the ND

Examination. During the interviewed RTR operatocorrectly answer question
Revision No.: 1.0 RTR-7 

ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspecti

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objectiv

Co

form items detailed abovdemonstrated that they helectronic copies of the adescription. EPA consid

Objective evidence revie

1. Batch Data Report a

for batches LA-RTRRTR2-05-0111 (S3005-0112 (S3000), LALA-RTR1-06-0003 RTR1-06-0002 (S50(S5000) 

2. BDRs LA-RTR2-05

04-0007, LA-RTR2-RTR2-05-0175 (S30

3. RTR demonstration: 

S852566; RTR unit 

4. Visual Examination 

Training Module 

5. LANL – NDE RTR 

Examination 

RTR-7: The RTR procedure provides instructions for identifying 

prohibited items and for processing drums containing prohibited items. 

Y 

CCP-TP-053, Rev. 4, s. 4.4.3, Note following [F], [G], Attachment 1, Table 1 

• Operator could name prohibited items 

• Operator adequately explained how the 

presence of free liquids is determined 

• Operator’s explanation of required actions if 

prohibited items were encountered was 

consistent with procedure 

• Corrective actions are taken when necessary 

Y The operator demonstrat

liquids is determined (ro

Numerous NCRs had bee

reviewed for the presencFinding LANL-CCP-VEchecklist) and other proh

NCR-LANL-0786-06 wa

S833213 because of a se

liters and NCR-LANL-0

presence of PCBs. NCR

initiated for drum S8341of liquid at the 30” mark 
Revision No.: 1.0 RTR-8 

ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspecti

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objectiv

Co

of liquid in the drum. Prohibited items are liste

Objective evidence revie

1. Batch Data Report a

for batches LA-RTRRTR2-05-0111 (S3005-0112 (S3000), LALA-RTR1-06-0003 RTR1-06-0002 (S50(S5000) 

2. BDRs LA-RTR2-05

04-0007, LA-RTR2-RTR2-05-0175 (S30

RTR-8: RTR procedures include the required QC examinations, evaluation accuracy and reproducibility of the RTR 

process. 

Y 

CCP-TP-053, Rev. 4, s. 4.5, 4.6 

• An independent replicate scan is performed on 

one waste container per day or on one container per testing batch (whichever is less frequent) 

• An independent observation of one scan (not 

the replicate) is performed, by a qualified RTR operator (anyone but the initial RTR operator) 

Y In batch LA-RTR1-06-00

observation was performreplicate scan was perfor

batch LANL-RTR2-05-0

observation was performreplicate scan was perforBoth of the QC samples different operator to the o

Objective evidence revie

1. Batch Data Report a

for batchs LA-RTR2RTR2-05-0111 (S3005-0112 (S3000), LALA-RTR1-06-0003 RTR1-06-0002 (S50(S5000) 

2. BDRs LA-RTR2-05

04-0007, LA-RTR2-RTR2-05-0175 (S30
Revision No.: 1.0 RTR-9 

ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspecti

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objectiv

Co

RTR-9: Procedure(s) contain standardized forms for recording RTR data. 

Y 

CCP-TP-053, Rev. 4, Attachments 1 & 2 

• RTR operator adequately explained the process 

followed for examining a drum and entering data into data forms (whether hard copy or electronic data entry is used). 

• Direct data entry into an electronic form is 

done by the RTR operator using a computer while the operator is still in the RTR booth 

• The electronic data file undergoes the same 

quality control (QC) checks used for handwritten data entries 

Y During the on-site inspec

RTR event for a debris (Sand RTR unit #2. The opapplicable procedure (CCRTR operations area and accordance with the instr

procedure. RTR data are 

the data form (Attachmen053) by an individual whrecord the RTR data genqualified RTR operator). standard weight table (Ta

both data generation and 

checklists for the BDRs rsigned, and dated. 

Objective evidence revie

1. Batch Data Report a

for batches LA-RTRRTR2-05-0111 (S3005-0112 (S3000), LALA-RTR1-06-0003 RTR1-06-0002 (S50(S5000) 

2. BDRs LA-RTR2-05

04-0007, LA-RTR2-RTR2-05-0175 (S30

RTR-10: Site procedures require review of BDRs at the data generation and project level. 

Y 

CCP-TP-053, Rev. 4, s. 4.10-4.12, Attachments 3-5 CCP-TP-001, 

• Data generation level reviews are performed 

and documented 

• Project level reviews are performed and 

documented

Y All BDRs reviewed durin

contained complete and sreview checklists (IndepeTechnical Supervisor, anOfficer). The BDRs also signed Site Project Qualichecklist and a complete Validation Summary che
Revision No.: 1.0 RTR-10 

ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspecti

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objectiv

Co

Rev. 11 Objective evidence revie

1. Batch Data Report a

for batches LA-RTRRTR2-05-0111 (S3005-0112 (S3000), LALA-RTR1-06-0003 RTR1-06-0002 (S50(S5000) 

2. BDRs LA-RTR2-05

04-0007, LA-RTR2-RTR2-05-0175 (S30

RTR-11: Procedures require that RTR operators receive the results of the VE/RTR comparison. 

Y 

CCP-TP-053, Rev. 4 

• RTR operators receive the results of the 

VE/RTR comparison 

• RTR operators receive lessons learned 

information based on the comparison of RTR and VE data 

• Identify corrective action steps (additional 

training) taken to address lessons learned 

Y Although CCP at LANL 

VE/RTR comparison repnot received any “lessongenerated the following Cissue. LANL-CCP-RTR-06-00

CCP at LANL has generComparison Reports, but inspection RTR operator“lessons learned” trainin

between the RTR and VE 
Revision No.: 1.0 RTR-11 

Information Included in Batch Data Reports 

Required Testing Batch Content Present Y or N Required Testing Batch Content Present Y or N Required Testing Batc

Batch Date Y Description of liners Y Estimated weights for Wa

Material Parameters 

Report date Y Layers of confinement Y Verification of Waste Ma

Code 

Waste container number Y Indication of vented rigid

liners 

Y Reference to or copies of 

NCRs 

Waste Matrix Code Y Description of container 

contents 

Y Operator signature and te

date 

Implementing procedure name or # 

Y Indication of sealed 

containers >4L 

Y Data generation checklist

Videotape reference Y Amount of free liquid Y Data generation checklistQC documentation Y Container gross weight Y Project level checklists Verification that waste matches waste stream description 

Y Y 
Revision No.: 1.0 VE-1 Dat

ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

VE-1: Site procedures identify required training and qualifications for VE 

personnel. 

Y 

CCP-TP-002, Revision 20 

Visual Examination Expert’s (VEE) explanation of job duties was consistent with applicable procedures. VE personnel’s training was consistent with applicable procedures. VE personnel’s certification is current. 

VE personnel are re-qualified every two years. 

VE personnel received training on specific waste generating processes, typical 

packaging configurations, and WMPs 

expected to be found in each Waste Matrix Code. 

Y CCP uses Qualification Cards 

received by CCP personnel. TExamination Experts (VEE) aletter that is included in the Vinspection, the Qualification Creviewed and found to be comTraining on specific waste-ge

packaging configurations, and 

each waste stream is provided However, this training is prov

update to the AK record. The site maintains a List of Qto ensure training is current. 

Objective evidence:

1. Visual Examination Operat

Card for two VEEs 

2. List of Qualified Individual

VE-2: Procedures and technical guidance documents provide complete instructions for 

performing VE. 

Y 

CCP-TP-113, Revision 4, s. 4.0, Tables 1-4 

The site uses AK to identify the matrix 

parameter category and to estimate waste 

material parameters present. 

Procedures are sufficiently detailed to enable the operator to determine if a waste container meets the criteria of 40 CFR 194.24 with regard to identifying applicable 

parameters with waste limits. 

Establish standard nomenclature, based on current site practice, so that all staff recognize waste by the same descriptors. 

Y Two types of VE were assesse

LANL-CCP, namely VE in liecheck of RTR. Procedure CCP-TP-113 containstructions for performing Vin lieu of RTR. These two typexactly the same manner and of the procedure. The proced

prohibited items, a description 

description of Waste Material table for waste item weights, aused to record some of the VE 
Revision No.: 1.0 VE-2 Dat

ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

When a new AK summary bereceive documented training wand packaging configurations 

VE-3 Y 

CCP-TP-113, Revision 4, s. 3.2.3 

Prior to starting the VE, the VEE reviews all documented data related to the waste container and its contents to ensure that there are no safety hazards for the VE operators. 

Y Objective evidence:

1. Audio/visual recording an

 LAVE540025 (VE in Lie LAVE540027 (VE as a Q LAVE500060 (VE as a Q LAVE500061 (VE as a Q
Revision No.: 1.0 VE-3 Dat

ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

VE-4: Procedure requires an audio/visual recording of the VE event to be recorded. 

Y 

CCP-TP-113, Revision 4, s. 4.1.2 

VEE/operator’s explanation of how to operate the data recording system was consistent with applicable procedures. The video camera was focused prior to the start of VE. An audio/videotape is made of the waste container exam and maintained as a nonpermanent record. Data on the audio/visual recording is consistent with documentation. 

Y During the inspection, EPA ob

debris (S5000) drum. The druevent took place in a glovebox TA-50. The audio/visual checdemonstration had already beto EPA’s arrival. EPA did, hochecks were successfully comBDRs LAVE540025, LAVE5LAVE500061, as well as the udemonstration LAVE500081. reviewed in conjunction with of the visual and written recoridentified for the BDRs reviewFor the demonstration, the drusorted by WMP and weighed. calibration performed for this for leaded rubber gloves, were 40% other metals. However, iweights are assigned totally to following Concern for this dis(see also RTR checklist). LANL-CCP-VE-06-006CR:

1. Waste Material Paramete

recorded for leaded rubbgloves are recorded as onmaterial parameter, but in assigned in the following other metals. 

2. VE personnel were unabl

assigning the weights (60

Objective evidence:

1. Audio/visual recording an

 LAVE540025 (VE in 
Revision No.: 1.0 VE-4 Dat

ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

 LAVE540027 (VE a LAVE500060 (VE a LAVE500061 (VE a LAVE500081 (VE in 

VE-5: There is a procedure for handling instances when the VE Expert is unable to see through the inner 

plastic bags/packages/containers 

of waste. 

Y 

CCP-TP-113, Revision 4, s. 4.1.4, [D], [F.3](b) 

The VEE has decision-making criteria for assessing the need to open the 

bags/packages in order to identify all of 

their contents. If the bags are not opened, a brief written description of the contents of the bags is 

prepared with estimates of the amount of 

each waste type in the bags.

Y It is CCP’s policy to open all 

VEE is permitted to documenopening bags in the BDR. Thcontained in the drums from BEPA. The VE operators did n

prior to weighing and it was uprovided a complete inventory 

how they were able to verify tThe VE data forms did not incemptying the cans. EPA geneaddress this issue. LANL-CCP-VE-06-007CR:

The containers examined by Vas a QC Check of RTR) contawere opened but not emptied 

personnel were unable to dem

contained in the cans were invdoes not address this circumstObjective evidence:

1. Audio/visual recording an

 LAVE540025 (VE in Lie LAVE540027 (VE as a Q LAVE500060 (VE as a Q LAVE500061 (VE as a Q LAVE500081 (VE in Lie

VE-6: The VE procedure requires 

Y 

CCP-TP-113, 

If an automated data entry system is used, data entry VE personnel could navigate 

Y CCP uses the WTS to enter da

demonstration observed by EPexplain how VE personnel ve
Revision No.: 1.0 VE-5 Dat

ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

verification of Waste Matrix Code and WMP weights. 

Revision 4, s. 4.1.4, Table 4, Attachment 1 

through the various screens. A VE data form is used to document the matrix parameter category and estimated WMP weights of the waste. VE staff have access to standardized charts or tables to aid in the consistent estimation or assignment of weights, waste material 

parameters, and waste matrix codes. 

The estimated or weighed WMP weights are determined by compiling an inventory of waste items, residual materials, and 

packaging materials. 

The items on the inventory list are sorted by WMP and combined with a standard weight look-up table to provide an estimate of WMP weights. References tables are updated as site gains information from VE. VEE verifies Waste Matrix Code and recommends changes as needed.

matched the waste stream desnot have a hard copy or electrdescription available in the VE was not able to describe the exstream they were examining. following Concern (see RTR-LANL-CCP-VE-06-005CR:

Attachments used for data enta line item that requires operaexamined matches the Waste for the VE demonstration and and 2, observed by EPA on Mhow they were able to answer did not have a copy of Waste LANL-AK-9, in their respectiable to describe the items incldescriptions provided in the Astream they were currently ex2007 meeting, EPA reviewed Training Module (PowerPoint RTR Comprehensive Examinmeeting, EPA interviewed RTcorrectly answer questions widetailed above. The operators access to both paper and electwaste stream description. EPA closed. Objective evidence:

1. Audio/visual recording an

 LAVE540025 (VE in Lie LAVE540027 (VE as a Q LAVE500060 (VE as a Q LAVE500061 (VE as a Q LAVE500081 (VE in Lie
Revision No.: 1.0 VE-6 Dat

ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

2. Visual Examination and R3. LANL – NDE RTR Com

VE-7: Procedure provides instructions for processing of containers with 

prohibited items. 

Y 

CCP-TP-113, Revision 4, s. 4.3, Table 1, Attachment 1, section 5 

VE expert could name prohibited items. VE expert’s explanation of required actions if prohibited items were encountered was consistent with procedure. The VEE describes any liquids found, including a description of their location in the container and estimated volume. Other prohibited items, including sealed containers, are identified and segregated. 

Y The data form used lists prohi

VEE/operators are required to The default answers in the for

The quantity and location of pthe RTR examinations of contwaste stream number LA-MINin the AK summary CCP-AKcharacterization personnel ini

presence of prohibited liquids

communicated to AK personnrecord. CCP personnel used Vcharacterize wastes from this 

through June 23, 2005. Howemade the use of this technique S3000 wastes. Until correctivtechnique at CCP sites is unacfinding LANL-CCP-VE-06-0

NCRs were initiated as requir

0911-05 was initiated for drumS814194 (BDR LAVE540025>1% of the container volume. initiated for container 55598 bfrom Kg to lbs in the middle oObjective evidence:

1. Audio/visual recording an

 LAVE540025 (VE in Lie LAVE540027 (VE as a Q LAVE500060 (VE as a Q LAVE500061 (VE as a Q LAVE500081 (VE in Lie
Revision No.: 1.0 VE-7 Dat

ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

VE-8: Y 

CCP-TP-113, Revision 4, s. 4.1.4, [C1] (a), [C8], Attachment 1, section 2 

The gross weight of the waste container (container plus contents) is recorded on the VE data form. Volume utilization of the container is documented. 

Y The gross weight of container

container are recorded in sectiCCP Waste Visual ExaminatiObjective evidence:

1. Audio/visual recording an

 LAVE540025 (VE in Lie LAVE540027 (VE as a Q

LAVE500060 (VE as a QLAVE500061 (VE as a Q

 LAVE500081 (VE in Lie

VE-9: Y 

CCP-TP-113, Revision 4, s. 4.1.4 [C.1] (a), [C.4] (d), [H.3] (a), 4.3.2, 4.3.6, Attachment 1, section 1, Attachment 4, #8 

The procedure is adequately implemented and corrective actions are taken when necessary. 

Y During the inspection, EPA ob

debris (S5000) drum. The dru

event took place in a glovebox 

TA-50. The audio/visual checdemonstration had already be

to EPA’s arrival. EPA did, hochecks were successfully comBDRs LAVE540025, LAVE5LAVE500061, and the un-valdemonstration LAVE500081. reviewed in conjunction with of the visual and written recoridentified for the BDRs reviewwas recorded. For the demonemptied, sorted by WMP and scale calibration performed fo

NCRs were initiated as requir

0911-05 was initiated for drum

S814194 (BDR LAVE540025

>1% of the container volume. initiated for container 55598 b

from Kg to lbs in the middle o
Revision No.: 1.0 VE-8 Dat

ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

Objective evidence:

1. Audio/visual recording an

 LAVE540025 (VE in Lie LAVE540027 (VE as a Q LAVE500060 (VE as a Q LAVE500061 (VE as a Q LAVE500081 (VE in Lie

VE-10: Site procedure(s) require data generation and project level reviews of BDRs. 

Y 

CCP-TP-113, Revision 4, s. 4.6-4.8, Attachment 2-4 CCP-TP-001, Rev. 11 

BDRs contain all required information (see table below). Data generation and project level reviews are complete. 

Y The BDRs listed below contai

and project level review check

required information. Objective evidence:

1. Audio/visual recording an

 LAVE540025 (VE in Lie LAVE540027 (VE as a Q LAVE500060 (VE as a Q LAVE500061 (VE as a Q

VE-11: The site has a procedure for using the data obtained from VE as a QC check of RTR to calculate the percentage of miscertified waste containers. The facility has a procedure for randomly selecting waste containers. 

Y 

CCP-TP-113, Rev. 4, s. 4.1 CCP-TP-003, Rev. 14, s. 4.7, A13, Rev. 0 CCP-TP-003, Rev. 14, A13, Rev. 0 

The number of waste containers to undergo VE is appropriately calculated. The site uses an initial miscertification rate of 11%. Miscertification rate is calculated for each applicable Summary Category Group after 6 months or 50% of the SCG have undergone RTR. Site uses 1% miscertification rate if calculated value is <1%. Rate is reassessed annually using a drumweighted average. 

Y The table used for determinin

requiring VE is a duplicate of TP-003, Table 1). Memoranda: March 30, 2005

Examination Drums from S30

June 27, 2005, 2005 Selection from S3000 Summary Categoto undergo VE and a list of re

Letter: March 23, 2006, Selec

Drums from S3000 and S5000 document the random selectio

calculation of the miscertificareplacement drums. 
Revision No.: 1.0 VE-9 Dat

ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

EPA also reviewed memorandSummary Category Group-SpRate; and March 29, 2005, IniSpecific S5000 Miscertificatioinitial rates calculated for thesSection 4.11 requires that a cohistoric site-specific miscertifwas evidenced by review of a included the container weightObjective evidence:

1. Memorandum dated Mar

Visual Examination DrumCategory Group and mem2005 Selection of Visual Summary Category Grou

2. Letter dated March 23, 20

Examination Drums from Groups 

3. Memorandum dated Febr

Reassessment of the Site 

(S3000 and S5000) 

4. Memorandum dated Mar

Category Group-Specific 

5. Memorandum dated Apri

Category Group-Specific 

VE-12: The site has a documented stratagem for selecting replacement waste containers. 

Y 

CCP-TP-003, Revision 14, s. 4.12 & 4.13 

If fewer containers were visually examined than were sampled, the reason for excluding the containers is documented. The replacement stratagem is restricted to containers from the same waste stream. 

Y When CCP selects the contain

RTR, extra containers are ranreplacement containers are avfor excluding containers in the documented. EPA reviewed tand reasons for rejection on a 
Revision No.: 1.0 VE-10 Dat

ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

VE is performed on the replacement containers. 

Objective evidence:

1. Status report for containe

miscertification rate, inclrejection. 

VE-13: The calculation used for the miscertification rate is documented. 

Y 

CCP-TP-003, Revision 14, s. 4.9-4.11 

After the required number of containers have been visually examined, the UCL90 for 

the proportion miscertified is calculated. The site has used the appropriate distribution for the UCL90 calculation to 

determine N. 

Y The table used for determinin

requiring VE is a duplicate of 

The calculations used were apObjective evidence:

1. Memorandum dated Mar

Category Group-Specific 

2. Memorandum dated Mar

Category Group-Specific 

3. Memorandum dated Febr

National Laboratory Ann

Specific Annual Miscerti

VE-14: Site procedure requires that results of VE as a QC check of RTR are forwarded to the radiography facility. 

RTR operators receive results of RTR/VE comparison. 

Y Memoranda: April 12, 2005, 

Weight Comparison Report foLaboratory April 2004 ThrougDifference Comparison ReporExamination); May 26, 2005, Weight Comparison Report foLaboratory June 2004 Throug

Difference Comparison Repor

Examination): Waste Stream 7, 2006, Waste Material ParamReport for Los Alamos NationThrough December 2005 (RelComparison Report for Radiodocument the RTR/VE compa
Revision No.: 1.0 VE-11 Dat

ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

calculate the miscertification rAt the time of the inspection, not been provided to the RTR following concern to address t

LANL-CCP-RTR-06-008C:

CCP at LANL has generated tComparison Reports but at the operators had not received any the discrepancies between the Objective evidence:

1. Memorandum dated Apri

Parameter Weight Compa

National laboratory April 

(Relative Percent DiffereRadiography and Visual E

2. Memorandum dated May 

Parameter Weight CompaNational laboratory June (Relative Percent DiffereRadiography and Visual ELA-MIN03-NC.001 

3. Memorandum dated Febr

Parameter Weight Compa

National laboratory April 

(Relative Percent DiffereRadiography and Visual ERTR/VE comparisons pemiscertification rates. 
Revision No.: 1.0 VE-12 Dat

Information Included in BDR

Required Testing Batch Content Present Y or N Required Testing Batch Content Present Y or N Required Testing Batc

Batch Date Y Description of liners Y Verification of Waste MaReport date Y Layers of confinement Y Reference to or copies of 

NCRs 

Waste container number Y Indication of vented rigid

liners 

Y VEE decisions 

Waste Matrix Code Y Description of container 

contents 

Y Operator signature and te

date 

Implementing procedure name or # 

Y Indication of sealed 

containers >4L 

Y VEE signature and test da

Videotape reference Y Amount of free liquid Y Completed data generatio

checklists 

QC documentation Y Container gross weight Y Completed project level 

checklists 

Verification that waste matches waste stream description 

Y Waste Material Parameters 

weights 

Y 
Revision No.: 1.0 VET-OSRP-1 Dat

ATTACHMENT A.7: VISUAL EXAMINATION TECHNIQUE (VET) 

FOR OFF-SITE SOURCE RECOVERY PROGRAM (OSRP) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Insp

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

OSRP-1: Procedures identify required training and qualifications for VE personnel. 

CCP-TP-069, Revision 3, s. 2.2.1 CCP-QP-002, R. 21 

• VE personnel’s training was consistent with 

applicable procedures 

• VE personnel’s certification is current 

• VE personnel are re-qualified every two years 

 CCP-QP-002, R. 21 

requirements for VE CH waste. 

OSRP-2: Equipment required 

CCP-TP-069, Revision 3, s.2.4.1 

Calibrated torque wrench Y EPA observed the co

torque wrench during ID # 026327, calibra2006. The wrench halbs. Prior to arriving at ea

personnel ship the re

facilitate operations. 

OSRP-3: Procedures and technical guidance documents provide complete instructions for performing VE. 

CCP-TP-069, Revision 3, s. 4.0 

• VE operator and VE packager required (both 

VE operators) 

• Attachment 4 

Y EPA observed the pa

mCi each) sources at located at 8407 SkyliThe LANL personnewere a VE operator, Prior to arriving at thcompile a work plan isotopes, activity, AK description, as availawas inspected for usa

process in accordanc

VE operator inspecteidentification markinfound on the sources loaded, the special foinformation about the it (this is not required 
Revision No.: 1.0 VET-OSRP-2 Dat

ATTACHMENT A.7: VISUAL EXAMINATION TECHNIQUE (VET) 

FOR OFF-SITE SOURCE RECOVERY PROGRAM (OSRP) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Insp

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

OSR-OP-170, SectioAttachment 4 of procelectronically compleinformation became include the presence/WMC, POC, and druincluded: Drum # LA00000062Filter # NucFil-013, POC filter UT9400, S100 (6” pipe compoCapsule model # II-1Outside TID # LANL 

OSRP-4: VE operator verifies: 

CCP-TP-069, Revision 3, s. 4.1.5 

• Source meets applicable regulatory 

definitions 

• Outer casing made of non volatile organic 

material 

• Source is or is contained in rigid sealed 

container ≤ 4 liters 

• Items match the waste stream description, 

WMC, and physical form/SCG provided by AK 

• No non-packaging items placed in the 

container other than sources 

• No more than 2 layers of confinement 

• Source loaded using tongs or special tool 

Y The VE operator elec

information into Atta

Initially the VE operstream description fosummary Report AKto obtain this informacourse of the VE eveFor packaging of theone layer of confinem
Revision No.: 1.0 VET-OSRP-3 Dat

ATTACHMENT A.7: VISUAL EXAMINATION TECHNIQUE (VET) 

FOR OFF-SITE SOURCE RECOVERY PROGRAM (OSRP) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Insp

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

OSRP-5: CCP-TP-069, 

Revision 3, s. 4.0 

Attachment 4 completed: 

• Sealed source description and identifier 

• WMP category from Attachment 1 

• Estimated weight 

• Item information verified during VE 

• Absence/presence of prohibited items 

 Attachment 4 was co

verified and signed bVE packager. Weights for items cosealed source packagAttachment 2 of procWMP assigned, from metals). The absencis recorded in the ProConditions section o

OSRP-6: Closing POC 

CCP-TP-069, Revision 3, s. 4.1.14 – 4.1.20 

• Ensure serial #s on POC and lid match 

• Insert bolts 

• Tighten bolts using criss-cross pattern 

• Torque the 12” POC to 65 ft-lb (± 5 ft-lbs) 

• Torque the 6” POC to 40 ft-lb (± 4 ft-lbs) 

• Retorque the bolts going clockwise 

• Record torque value, wrench ID #, cal due 

date 

Y EPA observed the VE 

The closure procedurwere observed and waccordance with the rTP-069. 

OSRP-7: Closing drum 

CCP-TP-069, Revision 3, s. 4.1.21 

• Plastic bag closed with horsetail (if present) 

• Install closure ring 

• Torque bolt to 40 ft-lb (± 4 ft-lbs) 

• Record torque value, wrench ID #, cal due 

date 

• Apply TID to drum 

Y The VE operator atta

after closure. This seLANL but is not requCCP procedure requiclosure bolt of the drobserved by EPA. 

OSRP-8: BDR assembled by VE operator 

CCP-TP-069, Revision 3, s. 4.2.1 

• Cover page (Attachment 5) 

• Table of Contents (Attachment 6) 
Revision No.: 1.0 VET-OSRP-4 Dat

ATTACHMENT A.7: VISUAL EXAMINATION TECHNIQUE (VET) 

FOR OFF-SITE SOURCE RECOVERY PROGRAM (OSRP) CHECKLIST

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Insp

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

• ITR checklist (Attachment 7) 

• TS checklist (Attachment 8) 

• FQAO checklist (Attachment 9) 

• Container Packaging and VE data record 

(Attachment 4) 

• NCRs if applicable 

• AK documentation identifier 

• Sources in Special Form Capsules 

• Radiological Contamination Surveys 

• Special Form Documentation 

• Source Markings 

OSRP-9: BDR 

• Assign a unique BDR #, e.g. LAyy-OSR-VEnnn, and record on Attachment 5 

• Record waste stream name and number and 

container type on Attachment 5 

• Record container ID # for each container 

included in the BDR on Attachment 5 

OSRP-10: Data generation level review 

• ITR, Attachment 7 

• TS, Attachment 8 

• FQAO, Attachment 9 

 LANL personnel (IT

generation level revie

OSRP-11: Project level review

• SPM 

• SQAO 

 CCP personnel perfo
Revision No.: 1.0 WWIS-1 

ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

WWIS-1: WWIS and Data Entry Personnel must 

be trained to assess data and properly 

enter data into the WWIS. 

Y 

CCP-QP-002, R. 20, CCPTP-030, R. 18, s. 2.2.1 

• WCO and Data Entry Personnel are trained to 

assess data and properly enter and transfer all data in the WWIS. 

• Training for Data Entry Personnel and data 

reviewers/verifiers include the WIPP Waste Information System User’s Manual and the applicable site procedures. 

• Training records are available for review and 

are complete. 

Y Training for data en

Waste Certification Waste Information Sapplicable site proceAdministrator proviorientation to WWISdocumented. WCO/WCAs are ba

but a WCO was ava

the WWIS processeinto WWIS takes plarecord, contained in card, for a WCA wainspection. The traiWCO interviewed hduring baseline inspThe training was comthese positions. 

The WCO and/or WCcharacterization/certito be entered into WWaccess BDR informathe PTS (Project Offadministrative system 

that are fully charactentry. Objective evidence r

1. Qualification Ca

Assistant (WCA

WWIS-2: Security measures for ensuring data integrity and accessing WWIS are 

Y 

CCP-TP-030, 

Access to WWIS is controlled. WWIS access requests are recorded in an access log, however named, that is available for review. 

Y Access to WWIS is c

Administrator. CCP and the approval and 
Revision No.: 1.0 WWIS-2 

ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

sufficient. R. 18, s. 4.1 CCP via e-mail. WW

by the WWIS Data A

Mexico. Objective evidence r

1. E-mail, dated Ju

access to WCA 

WWIS-3: There are adequate procedures for entering data into the WWIS and transmitting data to WIPP. 

Y 

CCP-TP-030, Revision 18, s. 3.0, 4.0 

Employee’s explanation of job duties was consistent with applicable procedures. WWIS and Data Entry Personnel adequately explained how data are assessed, input, and transferred into WWIS. 

Y Data entry for all CC

New Mexico. For th

WCO was present at The WWIS Data EntCharacterization and Excel spreadsheet, is characterization/certicompletion, the spreareviewed. By signinaccepts the data for sthe spreadsheet data WCO, ASCII, tab-deand then submitted to spreadsheet is contro

NCRs must be closed 

Mooney verifies NCR WCO of containers tinto WWIS. After acinformation can be aContainer Data Repo Objective evidence r

1. WWIS Data Entr

and Certification 

2. WWIS Data Entr

and Certification 

3. Waste Container 

LA00000052034 
Revision No.: 1.0 WWIS-3 

ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

4. Waste Container 

LA00000061956 

5. E-mail, dated Ma

Mooney with regfor Lot LANL 70

6. List of NCR/CAR 

7. WCO Data Entry 

Containers to be LAS811270 

WWIS-4: Procedures require that only verified and validated data are entered into WWIS. 

Y 

CCP-TP-030, Revision 18, s. 4.3, 4.4 

Data generation and project level reviews of container data for WWIS entry have been 

performed and review checklists are complete. 

Y When all reviews hav

Project Manager (SPthat a lot evaluation i(container informatioadministrative controonly containers that hof review are availabAs part of this inspecreviewed RTR and Vcontained complete rObjective evidence r

1. Correlation of C

Numbers to Batc

2. BDRs LAVE540

LAVE500060, L0194, LA-RTR20152, LA-RTR20002, LA-RTR10003 

WWIS-5: Procedures include instructions for submission of data into the 

Y 

CCP-TP-030, Revision 18, 

• To enable Waste Stream Profile Form 

approval Data are entered into the Characterization module of WWIS on a 

Y Characterization data 

Characterization MoStream Profile Form data fields in the Cha
Revision No.: 1.0 WWIS-4 

ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

Characterization and the Certification module of WWIS. 

s. 4.4, 4.5 container basis. 

• To obtain shipping certification of a 

container, data are entered into the Certification module of WWIS. 

subset of those in the characterization data transferred into the Cchecks of electronica

but 100% of manuall

accuracy. The checkand the WCO/WCA the data. Any changBDR. The WCO is permitteconcentration from thmethane is flagged “UAn Excel spreadshee–Characterization anensure that all data ar

to uploading to WWImany of the same daWWIS submission th

by signing the Excel 

Objective evidence r

1. WWIS Data Ent

Characterization LA00000059179 

2. WWIS Data Ent

Characterization LAS811270 

3. Waste Container 

LA00000052034 

4. Waste Container 

LA00000061956 

5. Waste Stream Pr
Revision No.: 1.0 WWIS-5 

ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

WWIS-6: Procedures include a requirement for review of data prior to submission to WWIS. 

Y 

CCP-TP-030, Revision 18, s. 4.3, 4.4 

• There is an independent review of data prior 

to submission to WIPP via the WWIS. 

• Procedures for resolution/correction of 

nonconforming data are adequately implemented. 

Y Characterization data 

Characterization MoStream Profile Form data fields in the Chasubset of those in the characterization data transferred into the Cchecks of electronica

but 100% of manuall

accuracy. The checkand the WCO/WCA the data. Any changBDRs. The WCO accsubmission by signinWWIS contains checor unusable data to bto identify containers 

and eligible for WWObjective evidence r

1. WWIS Data Ent

Characterization LA00000059179 

2. WWIS Data Ent

Characterization LAS811270 

3. Waste Container 

LA00000052034 

4. Waste Container 

LA00000061956 

5. E-mail, dated M

Mooney with regfor Lot LANL 7

6. List of NCR/CA
Revision No.: 1.0 WWIS-6 

ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

containers 

7. WCO Data Entry 

Containers to be LAS811270 

WWIS-7: There are adequate procedures for entering data into the WWIS and transmitting the data to WIPP. 

Y 

CCP-TP-030, Revision 18, s. 4.3, 4.4, 4.5 

The site has successfully submitted characterization and certification data to WIPP via WWIS. 

Y CCP at LANL has su

characterization and containers to WIPP vdisposed and 298 prewas able to access m

demonstrate CCP’s pidentification numbeObjective evidence r

1. WWIS Data Ent

Characterization LA00000059179 

2. WWIS Data Ent

Characterization LAS811270 

3. Waste Container 

LA00000052034 

4. Waste Container 

LA00000061956 

WWIS-8: Procedures provide instructions for data correction if data are rejected by WWIS. 

Y 

CCP-TP-030, Revision 18, s. 4.5.17, 4.5.18 

• E-mail notifications from WWIS 

(acceptance/modification/rejection of data) 

• If data are rejected by the WWIS Data 

Administrator, processes for data reconciliation/correction are implemented 

Y WWIS contains chec

or unusable data to bdata is detected by Wred to indicate which WCO/WCA is then awith the data and corused to compile the dmany of the same chaccepted by WWIS, informing the WCO/
Revision No.: 1.0 WWIS-7 

ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

accepted. WWIS constatus of entered dataObjective evidence r

1. WWIS Data Ent

Characterization LA00000059179 

2. WWIS Data Ent

Characterization LAS811270 

3. Waste Container 

LA00000052034 

4. Waste Container 

LA00000061956 

WWIS-9: Procedures for waste container characterization/certification data submittal to WWIS require the appropriate records to be retained. 

Y 

CCP-TP-030, Revision 18, s. 5.0 

• WWIS access requests 

• WWIS access logs 

• Waste container data input reports

Y The WCO demonstra

was able to retrieve aData access logs are Administrator in CarWWIS is requested b

by the WWIS Data A

Objective evidence r

1. E-mail, dated Ju

access to WCA 

2. WWIS Data Ent

Characterization LA00000059179 

3. WWIS Data Ent

Characterization LAS811270 

4. Waste Container 

LA00000052034 
Revision No.: 1.0 WWIS-8 

ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLIST 

EPA Inspection No.: EPA-LANL-CCP-05.06-8 Inspec

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

5. Waste Container 

LA00000061956 

WWIS-10: NA • Plans and procedures for payload 

management have been approved by CBFO. 

• CBFO informed EPA prior to approving the 

site to use payload management for containers. 

• TRU alpha activity concentration is > 100 

nCi/g for the entire waste stream. 

• Only waste containers from the same waste 

stream are payload managed in the same 

payload container. 

• Each waste container selected for payload 

management contains at least one TRU isotope. 

• TRU alpha activity concentration of the 

payload container is determined and reported. 

NA CCP at LANL does n

containers. 
Revision No.: 1 WWIS-9 Date of Revision: 10/20/05

WWIS Data Requirements 

Characterization Module Data Fields 

(not a complete list) 

Container ID - present Pu 239 equivalent activity - present 

Generator EPA ID - present Pu 239 fissile gram equivalent - present 

Site ID - present Pu 239 FGE uncertainty - present 

Waste Stream Profile Number - present Radionuclide name – present 

Waste Matrix Code - present Radionuclide activity - present 

Waste Matrix Code Group - present Radionuclide activity uncertainty - present 

Waste Material Weight - present Radionuclide mass – present 

Waste Material Parameter - present Radionuclide mass uncertainty - present 

Hazardous Code - present Radioassay method – present 

Layers of packaging - present Assay date – present 

Liner exists - present Characterization method - present 

Filter model - present Characterization method date - present 

Number of filters installed - present Alpha surface concentration - present 

TRUCON code - present Dose rate – present 

Decay heat - present Sample ID – present 

Decay heat uncertainty - present Sample type – present 

TRU alpha activity - present Sample date – present

TRU alpha activity uncertainty - present Analyte – present 

TRU alpha activity concentration - present Analyte concentration - present 

TRU alpha activity concentration uncertainty - present Analyte detection method - present 

Waste type code - present Analyte detection method - present 

Certification Module Data Fields 

Container ID - present Container Certification date - present 

Container Type - present Container Closure date - present 

Container weight - present Handling Code - present 

Contact Dose Rate - present 
Attachments B.1 through B.22 
B-1 

ATTACHMENT B.1 REPLICATE TESTING DATA FOR CONTAINER 52331, HENC #1 S

Instrument: HENC#1

Container: 52331

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238Pu Activity (Ci) 6.77E-01 1.14E-01 1.68E-01 8.06E-01 1.60E-01 1.99E-01 4.51E-0239Pu Activity (Ci) 9.71E+00 2.34E+01 2.41E+00 9.64E+00 2.29E+01 2.38E+00 9.69E+0240Pu Activity (Ci) 2.63E+00 1.71E+00 6.52E-01 2.71E+00 1.81E+00 6.68E-01 2.77E+0242Pu Activity (Ci) 2.66E-04 1.75E-08 6.59E-05 2.73E-04 1.84E-08 6.75E-05 2.80E-0241Am Activity (Ci) 3.87E+00 3.72E+00 9.60E-01 0.00E+00 N/A 0.00E+00 0.00E+090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0TRU Alpha Conc. (nCi/g) 4.25E+05 2.87E+10 6.75E+04 4.30E+05 2.88E+10 6.70E+04 4.27E+0

Replicate #3 Replicate #4 

Quantity of Interest 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238Pu Activity (Ci) 7.41E-01 1.34E-01 1.81E-01 9.34E-01 2.14E-01 2.29E-01 4.97E-0239Pu Activity (Ci) 9.55E+00 2.23E+01 2.34E+00 9.58E+00 2.25E+01 2.35E+00 9.67E+0240Pu Activity (Ci) 2.80E+00 1.92E+00 6.86E-01 2.71E+00 1.80E+00 6.65E-01 2.74E+0242Pu Activity (Ci) 2.83E-04 1.96E-08 6.92E-05 2.74E-04 1.84E-08 6.72E-05 2.82E-0241Am Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0TRU Alpha Conc. (nCi/g) 4.28E+05 2.83E+10 6.61E+04 4.30E+05 2.85E+10 6.62E+04 4.25E+0
B-2 

ATTACHMENT B.2 REPLICATE TESTING RESULTS FOR CONTAINER 52331, HENC #1 

Instrument: HENC#1

Container: 52331

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ2 Pr(x <|χ2233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU238Pu Activity (Ci) 6.77E-01 1.14E-01 6.86E-01 2.06E-01 3.00E-01 1.31E+01 1.06E-239Pu Activity (Ci) 9.71E+00 2.34E+01 9.63E+00 5.94E-02 6.17E-03 2.58E-05 1.00E+240Pu Activity (Ci) 2.63E+00 1.71E+00 2.75E+00 3.91E-02 1.42E-02 2.08E-03 1.00E+242Pu Activity (Ci) 2.66E-04 1.75E-08 2.78E-04 4.62E-06 1.66E-02 2.77E+05 0.00E+241Am Activity (Ci) 3.87E+00 3.72E+00 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUTRU Alpha Conc. (nCi/g) 4.25E+05 2.87E+10 4.28E+05 2.12E+03 4.96E-03 2.19E-14 1.00E+

Quantity of Interest χ2 Test t Test233U Activity (Ci) #VALUE! Not Applicable 234U Activity (Ci) #VALUE! Not Applicable 238U Activity (Ci) #VALUE! Not Applicable 238Pu Activity (Ci) Significant Not Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Highly Significant Not Significant 241Am Activity (Ci) Not Significant Not Applicable 90Sr Activity (Ci) #VALUE! Not Applicable 137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
B-3 

ATTACHMENT B.3 REPLICATE TESTING DATA FOR CONTAINER 52476, HENC #1 S

Instrument: HENC#1 Container: 52476 

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reporte

Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238Pu Activity (Ci) 1.34E+00 5.13E-01 3.83E-01 1.46E+00 6.25E-01 4.28E-01 1.41E+239Pu Activity (Ci) 9.75E+00 1.43E+01 1.47E+00 1.04E+01 1.87E+01 1.80E+00 1.00E+240Pu Activity (Ci) 8.98E+00 1.26E+01 1.40E+00 9.61E+00 1.63E+01 1.70E+00 9.26E+242Pu Activity (Ci) 4.43E-03 4.32E-06 9.76E-04 4.75E-03 5.32E-06 1.12E-03 4.58E241Am Activity (Ci) 2.12E+01 1.30E+02 6.12E+00 1.54E+01 1.26E+02 8.18E+00 0.00E+90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+TRU Alpha Conc. (nCi/g) 4.51E+05 1.77E+10 3.93E+04 4.94E+05 5.73E+10 1.16E+05 4.84E+

Replicate #3 Replicate #4 

Quantity of Interest 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238Pu Activity (Ci) 1.41E+00 5.84E-01 4.14E-01 1.40E+00 5.74E-01 4.10E-01 1.47E+239Pu Activity (Ci) 1.01E+01 1.75E+01 1.73E+00 1.00E+01 1.72E+01 1.72E+00 1.05E+240Pu Activity (Ci) 9.30E+00 1.52E+01 1.63E+00 9.22E+00 1.49E+01 1.62E+00 9.66E+242Pu Activity (Ci) 4.60E-03 4.97E-06 1.08E-03 4.55E-03 4.87E-06 1.07E-03 4.77E-241Am Activity (Ci) 1.37E+01 3.27E+01 2.39E+00 0.00E+00 N/A 0.00E+00 0.00E+90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+TRU Alpha Conc. (nCi/g) 4.67E+05 2.14E+10 4.59E+04 4.82E+05 5.40E+10 1.12E+05 4.95E+
B-4 

ATTACHMENT B.4 REPLICATE TESTING RESULTS FOR CONTAINER 52476, HENC #1 

Instrument: HENC#1

Container: 52476

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ2 Pr(x <|χ2|233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU238Pu Activity (Ci) 1.34E+00 5.13E-01 1.43E+00 3.24E-02 2.27E-02 1.59E-02 1.00E+239Pu Activity (Ci) 9.75E+00 1.43E+01 1.02E+01 2.35E-01 2.30E-02 1.07E-03 1.00E+240Pu Activity (Ci) 8.98E+00 1.26E+01 9.41E+00 2.08E-01 2.21E-02 1.10E-03 1.00E+242Pu Activity (Ci) 4.43E-03 4.32E-06 4.65E-03 1.02E-04 2.20E-02 2.24E+03 0.00E+241Am Activity (Ci) 2.12E+01 1.30E+02 5.82E+00 7.99E+00 1.37E+00 1.52E-02 1.00E+90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUTRU Alpha Conc. (nCi/g) 4.51E+05 1.77E+10 4.84E+05 1.13E+04 2.34E-02 1.63E-12 1.00E+

Quantity of Interest χ2 Test t Test233U Activity (Ci) #VALUE! Not Applicable 234U Activity (Ci) #VALUE! Not Applicable 238U Activity (Ci) #VALUE! Not Applicable 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Highly Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable 137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
B-5 

ATTACHMENT B.5 REPLICATE TESTING DATA FOR CONTAINER 53093, HENC #1 S

Instrument: HENC#1 Container: 53093 

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reporte

Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E238Pu Activity (Ci) 5.14E-01 5.91E-02 1.15E-01 5.66E-01 7.87E-02 1.39E-01 4.42E239Pu Activity (Ci) 8.84E+00 1.75E+01 1.98E+00 9.67E+00 2.30E+01 2.38E+00 9.17E240Pu Activity (Ci) 2.59E+00 1.50E+00 5.81E-01 2.55E+00 1.60E+00 6.29E-01 2.54E242Pu Activity (Ci) 2.57E-04 1.48E-08 5.77E-05 2.61E-04 1.68E-08 6.44E-05 2.61E241Am Activity (Ci) 4.00E+00 3.95E+00 9.87E-01 0.00E+00 N/A 0.00E+00 3.91E90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00ETRU Alpha Conc. (nCi/g) 4.59E+05 3.01E+10 6.55E+04 4.95E+05 3.89E+10 7.85E+04 4.74E

Replicate #3 Replicate #4 

Quantity of Interest

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238Pu Activity (Ci) 5.50E-01 7.32E-02 1.33E-01 4.51E-01 4.87E-02 1.08E-01 4.61E-239Pu Activity (Ci) 9.50E+00 2.18E+01 2.29E+00 9.42E+00 2.12E+01 2.25E+00 9.23E+240Pu Activity (Ci) 2.51E+00 1.52E+00 6.06E-01 2.59E+00 1.60E+00 6.18E-01 2.65E+242Pu Activity (Ci) 2.58E-04 1.60E-08 6.22E-05 2.62E-04 1.64E-08 6.27E-05 2.67E-241Am Activity (Ci) 4.02E+00 3.90E+00 9.69E-01 3.95E+00 3.72E+00 9.43E-01 3.87E+90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+TRU Alpha Conc. (nCi/g) 4.89E+05 3.70E+10 7.57E+04 4.84E+05 3.60E+10 7.44E+04 4.78E+
B-6 

ATTACHMENT B.6 REPLICATE TESTING RESULTS FOR CONTAINER 53093, HENC #1 

Instrument: HENC#1

Container: 53093

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ2 Pr(x <|χ2233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU238Pu Activity (Ci) 5.14E-01 5.91E-02 4.94E-01 5.91E-02 1.20E-01 4.00E+00 4.07E-239Pu Activity (Ci) 8.84E+00 1.75E+01 9.40E+00 2.03E-01 2.16E-02 5.39E-04 1.00E+240Pu Activity (Ci) 2.59E+00 1.50E+00 2.57E+00 5.40E-02 2.10E-02 5.16E-03 1.00E+242Pu Activity (Ci) 2.57E-04 1.48E-08 2.62E-04 3.27E-06 1.25E-02 1.95E+05 0.00E+241Am Activity (Ci) 4.00E+00 3.95E+00 3.15E+00 1.76E+00 5.59E-01 7.97E-01 9.39E-90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUTRU Alpha Conc. (nCi/g) 4.59E+05 3.01E+10 4.84E+05 8.40E+03 1.73E-02 3.12E-13 1.00E+

Quantity of Interest χ2 Test t Test233U Activity (Ci) #VALUE! Not Applicable 234U Activity (Ci) #VALUE! Not Applicable 238U Activity (Ci) #VALUE! Not Applicable 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Highly Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable 137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
B-7 

ATTACHMENT B.7 REPLICATE TESTING DATA FOR CONTAINER D52277, HENC #2 

Instrument: HENC#2 Container: D52277 

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reporte

Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E234U Activity (Ci) 9.94E-04 5.38E-05 5.41E-02 1.05E-03 5.68E-05 5.41E-02 1.01E238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E238Pu Activity (Ci) 6.37E+00 9.39E-01 1.47E-01 6.76E+00 9.99E-01 1.48E-01 6.46E239Pu Activity (Ci) 1.38E-01 2.04E-02 1.48E-01 1.42E-01 2.11E-02 1.49E-01 1.40E240Pu Activity (Ci) 3.28E-02 4.84E-03 1.48E-01 3.38E-02 5.00E-03 1.48E-01 3.34E242Pu Activity (Ci) 2.17E-06 3.19E-07 1.47E-01 2.23E-06 3.30E-07 1.48E-01 2.20E241Am Activity (Ci) 1.82E-02 2.69E-03 1.48E-01 1.71E-02 3.08E-03 1.80E-01 1.81E90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00ETRU Alpha Conc. (nCi/g) 4.15E+05 5.94E+04 1.43E-01 4.40E+05 6.33E+04 1.44E-01 4.22E

Replicate #3 Replicate #4 

Quantity of Interest

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+234U Activity (Ci) 1.02E-03 5.73E-05 5.62E-02 1.05E-03 5.87E-05 5.59E-02 1.02E-238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238Pu Activity (Ci) 6.54E+00 9.67E-01 1.48E-01 6.70E+00 9.86E-01 1.47E-01 6.54E+239Pu Activity (Ci) 1.42E-01 2.10E-02 1.48E-01 1.46E-01 2.14E-02 1.47E-01 1.42E-240Pu Activity (Ci) 3.37E-02 4.99E-03 1.48E-01 3.46E-02 5.09E-03 1.47E-01 3.37E-242Pu Activity (Ci) 2.22E-06 3.29E-07 1.48E-01 2.28E-06 3.35E-07 1.47E-01 2.22E-241Am Activity (Ci) 1.71E-02 3.22E-03 1.88E-01 1.74E-02 3.06E-03 1.76E-01 1.69E-90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+TRU Alpha Conc. (nCi/g) 4.27E+05 6.12E+04 1.43E-01 4.37E+05 6.24E+04 1.43E-01 4.26E+
B-8 

ATTACHMENT B.8 REPLICATE TESTING RESULTS FOR CONTAINER D52277, HENC #

Instrument: HENC#2

Container: D52277

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ2 Pr(x <|χ2233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU234U Activity (Ci) 9.94E-04 5.38E-05 1.03E-03 1.87E-05 1.82E-02 4.84E-01 9.75E-238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU238Pu Activity (Ci) 6.37E+00 9.39E-01 6.60E+00 1.25E-01 1.89E-02 7.08E-02 9.99E-239Pu Activity (Ci) 1.38E-01 2.04E-02 1.42E-01 2.19E-03 1.54E-02 4.61E-02 1.00E+240Pu Activity (Ci) 3.28E-02 4.84E-03 3.38E-02 4.51E-04 1.33E-02 3.47E-02 1.00E+242Pu Activity (Ci) 2.17E-06 3.19E-07 2.23E-06 3.00E-08 1.35E-02 3.54E-02 1.00E+241Am Activity (Ci) 1.82E-02 2.69E-03 1.73E-02 4.71E-04 2.72E-02 1.23E-01 9.98E-90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUTRU Alpha Conc. (nCi/g) 4.15E+05 5.94E+04 4.30E+05 7.70E+03 1.79E-02 6.72E-02 9.99E-

Quantity of Interest χ2 Test t Test233U Activity (Ci) #VALUE! Not Applicable 234U Activity (Ci) Not Significant Not Significant 238U Activity (Ci) #VALUE! Not Applicable 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Not Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable 137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
B-9 

ATTACHMENT B.9 REPLICATE TESTING DATA FOR CONTAINER D53991, HENC #2 

Instrument: HENC#2 Container: D53991 

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reporte

Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E238Pu Activity (Ci) 8.12E-02 1.08E-03 1.33E-02 6.20E-02 8.30E-03 1.34E-01 5.51E239Pu Activity (Ci) 8.04E-01 1.07E-01 1.33E-01 7.79E-01 1.04E-01 1.34E-01 7.14E240Pu Activity (Ci) 1.58E-01 2.11E-02 1.34E-01 1.58E-01 2.12E-02 1.34E-01 1.56E242Pu Activity (Ci) 1.73E-05 2.31E-06 1.34E-01 1.51E-05 2.02E-06 1.34E-01 1.57E241Am Activity (Ci) 2.73E-01 3.63E-02 1.33E-01 2.42E-01 3.24E-02 1.34E-01 2.29E90Sr Activity (Ci) 7.34E-08 4.16E-08 5.67E-01 0.00E+00 N/A 0.00E+00 0.00E137Cs Activity (Ci) 7.34E-08 4.16E-08 5.67E-01 0.00E+00 N/A 0.00E+00 0.00ETRU Alpha Conc. (nCi/g) 2.26E+04 1.98E+03 8.76E-02 2.13E+04 1.91E+03 8.97E-02 1.98E

Replicate #3 Replicate #4 

Quantity of Interest

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238Pu Activity (Ci) 5.60E-02 7.38E-03 1.32E-01 5.00E-02 6.64E-03 1.33E-01 3.38E-239Pu Activity (Ci) 8.40E-01 1.11E-01 1.32E-01 7.90E-01 1.05E-01 1.33E-01 8.44E-240Pu Activity (Ci) 1.59E-01 2.10E-02 1.32E-01 1.60E-01 2.13E-02 1.33E-01 1.61E-242Pu Activity (Ci) 1.52E-05 2.00E-06 1.32E-01 1.47E-05 1.95E-06 1.33E-01 1.52E-241Am Activity (Ci) 2.55E-01 3.36E-02 1.32E-01 2.26E-01 3.00E-02 1.33E-01 2.43E-90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+TRU Alpha Conc. (nCi/g) 2.25E+04 2.02E+03 8.98E-02 2.10E+04 1.91E+03 9.10E-02 2.20E+
B-10 

ATTACHMENT B.10 REPLICATE TESTING RESULTS FOR CONTAINER D53991, HENC #

Instrument: HENC#2

Container: D53991

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ2 Pr(x <|χ2233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU238Pu Activity (Ci) 8.12E-02 1.08E-03 5.14E-02 1.07E-02 2.08E-01 3.93E+02 7.21E-239Pu Activity (Ci) 8.04E-01 1.07E-01 7.93E-01 5.30E-02 6.69E-02 9.83E-01 9.12E-240Pu Activity (Ci) 1.58E-01 2.11E-02 1.59E-01 1.92E-03 1.21E-02 3.32E-02 1.00E+242Pu Activity (Ci) 1.73E-05 2.31E-06 1.52E-05 3.56E-07 2.35E-02 9.52E-02 9.99E-241Am Activity (Ci) 2.73E-01 3.63E-02 2.39E-01 1.17E-02 4.91E-02 4.17E-01 9.81E-90Sr Activity (Ci) 7.34E-08 4.16E-08 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+137Cs Activity (Ci) 7.34E-08 4.16E-08 0.00E+00 0.00E+00 N/A 0.00E+00 1.00E+TRU Alpha Conc. (nCi/g) 2.26E+04 1.98E+03 2.13E+04 1.03E+03 4.85E-02 1.09E+00 8.96E-

Quantity of Interest χ2 Test t Test233U Activity (Ci) #VALUE! Not Applicable 234U Activity (Ci) #VALUE! Not Applicable 238U Activity (Ci) #VALUE! Not Applicable 238Pu Activity (Ci) Highly Significant Not Significant239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Not Significant Highly Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) Not Significant Not Applicable 137Cs Activity (Ci) Not Significant Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
B-11 

ATTACHMENT B.11 REPLICATE TESTING DATA FOR CONTAINER D55700, HENC #2 

Instrument: HENC#2 Container: D55700 

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reporte

Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E234U Activity (Ci) 4.10E-03 4.16E-04 1.01E-01 4.32E-03 4.20E-04 9.72E-02 4.02E238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E238Pu Activity (Ci) 2.63E+01 4.26E+00 1.62E-01 2.77E+01 4.42E+00 1.60E-01 2.58E239Pu Activity (Ci) 8.06E-02 1.31E-02 1.63E-01 8.51E-02 1.36E-02 1.60E-01 7.92E240Pu Activity (Ci) 1.89E-02 3.06E-03 1.62E-01 1.99E-02 3.18E-03 1.60E-01 1.85E242Pu Activity (Ci) 6.88E-06 1.12E-06 1.63E-01 7.26E-06 1.16E-06 1.60E-01 6.76E241Am Activity (Ci) 1.82E-02 3.06E-03 1.68E-01 2.20E-02 4.58E-03 2.08E-01 2.46E90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00ETRU Alpha Conc. (nCi/g) 2.96E+06 4.78E+05 1.61E-01 3.15E+06 4.96E+05 1.57E-01 2.91E

Replicate #3 Replicate #4 

Quantity of Interest

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+234U Activity (Ci) 4.06E-03 4.16E-04 1.02E-01 4.41E-03 4.05E-04 9.18E-02 3.96E-238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238Pu Activity (Ci) 2.60E+01 4.19E+00 1.61E-01 2.83E+01 4.53E+00 1.60E-01 2.54E+239Pu Activity (Ci) 7.98E-02 1.29E-02 1.62E-01 8.68E-02 1.39E-02 1.60E-01 7.80E-240Pu Activity (Ci) 1.87E-02 3.01E-03 1.61E-01 2.03E-02 3.26E-03 1.61E-01 1.83E-242Pu Activity (Ci) 6.81E-06 1.10E-06 1.62E-01 7.41E-06 1.19E-06 1.61E-01 6.66E-241Am Activity (Ci) 2.38E-02 4.53E-03 1.90E-01 1.92E-02 2.11E-03 1.10E-01 1.94E-90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+TRU Alpha Conc. (nCi/g) 2.93E+06 4.70E+05 1.60E-01 3.19E+06 5.09E+05 1.60E-01 2.86E+
B-12 

ATTACHMENT B.12 REPLICATE TESTING RESULTS FOR CONTAINER D55700, HENC #

Instrument: HENC#2

Container: D55700

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ2 Pr(x <|χ2233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU234U Activity (Ci) 4.10E-03 4.16E-04 4.15E-03 1.98E-04 4.78E-02 9.10E-01 9.23E-238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU238Pu Activity (Ci) 2.63E+01 4.26E+00 2.66E+01 1.28E+00 4.80E-02 3.60E-01 9.86E-239Pu Activity (Ci) 8.06E-02 1.31E-02 8.18E-02 3.91E-03 4.78E-02 3.56E-01 9.86E-240Pu Activity (Ci) 1.89E-02 3.06E-03 1.91E-02 8.99E-04 4.70E-02 3.45E-01 9.87E-242Pu Activity (Ci) 6.88E-06 1.12E-06 6.98E-06 3.33E-07 4.77E-02 3.53E-01 9.86E-241Am Activity (Ci) 1.82E-02 3.06E-03 2.18E-02 2.47E-03 1.13E-01 2.61E+00 6.26E-90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUTRU Alpha Conc. (nCi/g) 2.96E+06 4.78E+05 3.01E+06 1.51E+05 5.01E-02 3.98E-01 9.83E-

Quantity of Interest χ2 Test t Test233U Activity (Ci) #VALUE! Not Applicable 234U Activity (Ci) Not Significant Not Significant 238U Activity (Ci) #VALUE! Not Applicable 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Not Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable 137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
B-13 

ATTACHMENT B.13 REPLICATE TESTING DATA FOR CONTAINER 52338, PTGS SY

Instrument: PTGS Container: 52338 

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reporte

Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) <LLD #VALUE! #DIV/0! <LLD #VALUE! #DIV/0! <LLD 234U Activity (Ci) 1.10E-05 2.37E-06 2.15E-01 2.06E-05 2.78E-06 1.35E-01 1.88E238U Activity (Ci) <LLD #VALUE! #DIV/0! <LLD #VALUE! #DIV/0! <LLD 238Pu Activity (Ci) 7.07E-02 1.52E-02 2.15E-01 1.32E-01 1.78E-02 1.35E-01 1.20E239Pu Activity (Ci) 1.76E+00 2.11E-01 1.20E-01 1.73E+00 2.06E-01 1.19E-01 1.70E240Pu Activity (Ci) 4.41E-01 5.89E-02 1.34E-01 4.10E-01 5.19E-02 1.27E-01 4.03E242Pu Activity (Ci) 1.24E-05 3.45E-06 2.77E-01 1.08E-05 3.00E-06 2.78E-01 1.07E241Am Activity (Ci) 6.51E-01 7.82E-02 1.20E-01 5.73E-01 6.83E-02 1.19E-01 5.37E90Sr Activity (Ci) 2.83E-06 3.43E-07 1.21E-01 2.47E-06 2.97E-07 1.20E-01 2.54E137Cs Activity (Ci) 2.84E-06 3.44E-07 1.21E-01 2.48E-06 2.97E-07 1.20E-01 2.55ETRU Alpha Conc. (nCi/g) 2.14E+04 1.71E+03 7.99E-02 2.08E+04 1.64E+03 7.88E-02 2.02E

Replicate #3 Replicate #4 

Quantity of Interest

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) <LLD #VALUE! #DIV/0! <LLD #VALUE! #DIV/0! <LLD 234U Activity (Ci) 2.03E-05 2.76E-06 1.36E-01 2.09E-05 2.86E-06 1.37E-01 2.03E-238U Activity (Ci) <LLD #VALUE! #DIV/0! <LLD #VALUE! #DIV/0! <LLD 238Pu Activity (Ci) 1.30E-01 1.77E-02 1.36E-01 1.34E-01 1.83E-02 1.37E-01 1.30E-239Pu Activity (Ci) 1.70E+00 2.02E-01 1.19E-01 1.75E+00 2.11E-01 1.21E-01 1.75E+240Pu Activity (Ci) 4.36E-01 5.47E-02 1.25E-01 4.04E-01 5.17E-02 1.28E-01 4.16E-242Pu Activity (Ci) 1.15E-05 3.19E-06 2.77E-01 1.04E-05 2.90E-06 2.79E-01 1.09E-241Am Activity (Ci) 5.61E-01 6.67E-02 1.19E-01 5.58E-01 6.74E-02 1.21E-01 5.90E-90Sr Activity (Ci) 2.56E-06 3.06E-07 1.20E-01 2.67E-06 3.24E-07 1.21E-01 2.74E-137Cs Activity (Ci) 2.57E-06 3.07E-07 1.20E-01 2.68E-06 3.25E-07 1.21E-01 2.75E-TRU Alpha Conc. (nCi/g) 2.07E+04 1.61E+03 7.78E-02 2.09E+04 1.67E+03 7.99E-02 2.11E+
B-14 

ATTACHMENT B.14 REPLICATE TESTING RESULTS FOR CONTAINER 52338, PTGS 

Instrument: PTGS 

Container: 52338 

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ2 Pr(x <|χ2233U Activity (Ci) <LLD #VALUE! N/A N/A N/A N/A N234U Activity (Ci) 1.10E-05 2.37E-06 2.02E-05 8.11E-07 4.02E-02 4.68E-01 9.77E-238U Activity (Ci) <LLD #VALUE! N/A N/A N/A N/A N238Pu Activity (Ci) 7.07E-02 1.52E-02 1.29E-01 5.40E-03 4.18E-02 5.06E-01 9.73E-239Pu Activity (Ci) 1.76E+00 2.11E-01 1.73E+00 2.51E-02 1.45E-02 5.66E-02 1.00E+240Pu Activity (Ci) 4.41E-01 5.89E-02 4.14E-01 1.35E-02 3.25E-02 2.09E-01 9.95E-242Pu Activity (Ci) 1.24E-05 3.45E-06 1.09E-05 4.04E-07 3.72E-02 5.49E-02 1.00E+241Am Activity (Ci) 6.51E-01 7.82E-02 5.64E-01 1.96E-02 3.47E-02 2.50E-01 9.93E-90Sr Activity (Ci) 2.83E-06 3.43E-07 2.60E-06 1.08E-07 4.15E-02 3.95E-01 9.83E-137Cs Activity (Ci) 2.84E-06 3.44E-07 2.61E-06 1.08E-07 4.14E-02 3.93E-01 9.83E-TRU Alpha Conc. (nCi/g) 2.14E+04 1.71E+03 2.07E+04 3.36E+02 1.62E-02 1.55E-01 9.97E-

Quantity of Interest χ2 Test t Test233U Activity (Ci) Not Applicable Not Applicable 234U Activity (Ci) Not Significant Highly Significant 238U Activity (Ci) Not Applicable Not Applicable 238Pu Activity (Ci) Not Significant Highly Significant239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Not Significant Significant 241Am Activity (Ci) Not Significant Significant 90Sr Activity (Ci) Not Significant Not Significant 137Cs Activity (Ci) Not Significant Not Significant TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
B-15 

ATTACHMENT B.15 REPLICATE TESTING DATA FOR CONTAINER 53551, PTGS SY

Instrument: PTGS Container: 53551 

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reporte

Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) <LLD #VALUE! #DIV/0! <LLD #VALUE! #DIV/0! <L234U Activity (Ci) 2.45E-05 3.51E-06 1.43E-01 1.98E-05 2.89E-06 1.46E-01 2.56E238U Activity (Ci) <LLD #VALUE! #DIV/0! <LLD #VALUE! #DIV/0! <L238Pu Activity (Ci) 1.57E-01 2.25E-02 1.43E-01 1.27E-01 1.85E-02 1.46E-01 1.64E239Pu Activity (Ci) 5.83E+00 6.92E-01 1.19E-01 4.99E+00 5.95E-01 1.19E-01 5.13E240Pu Activity (Ci) 1.31E+00 1.59E-01 1.21E-01 1.13E+00 1.37E-01 1.21E-01 1.14E242Pu Activity (Ci) 3.08E-05 8.52E-06 2.77E-01 2.64E-05 7.32E-06 2.77E-01 2.59E241Am Activity (Ci) 3.98E+00 4.73E-01 1.19E-01 3.25E+00 3.87E-01 1.19E-01 3.40E90Sr Activity (Ci) 7.13E-07 8.96E-08 1.26E-01 4.48E-07 5.82E-08 1.30E-01 3.90E137Cs Activity (Ci) 7.15E-07 8.98E-08 1.26E-01 4.49E-07 5.84E-08 1.30E-01 3.91ETRU Alpha Conc. (nCi/g) 2.86E+05 2.16E+04 7.55E-02 2.41E+05 1.84E+04 7.63E-02 2.50E

Replicate #3 Replicate #4 

Quantity of Interest

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) <LLD #VALUE! #DIV/0! <LLD #VALUE! #DIV/0! <LL234U Activity (Ci) 2.64E-05 3.59E-06 1.36E-01 2.08E-05 3.03E-06 1.46E-01 2.26E-238U Activity (Ci) <LLD #VALUE! #DIV/0! <LLD #VALUE! #DIV/0! <LL238Pu Activity (Ci) 1.70E-01 2.30E-02 1.35E-01 1.33E-01 1.94E-02 1.46E-01 1.45E-239Pu Activity (Ci) 5.15E+00 6.15E-01 1.19E-01 5.16E+00 6.15E-01 1.19E-01 5.33E+240Pu Activity (Ci) 1.11E+00 1.36E-01 1.23E-01 1.15E+00 1.40E-01 1.22E-01 1.13E+242Pu Activity (Ci) 2.58E-05 7.14E-06 2.77E-01 2.67E-05 7.38E-06 2.76E-01 2.60E-241Am Activity (Ci) 3.35E+00 4.01E-01 1.20E-01 3.29E+00 9.32E-01 2.83E-01 3.45E+90Sr Activity (Ci) 2.75E-07 3.92E-08 1.43E-01 4.08E-07 5.39E-08 1.32E-01 6.00E-137Cs Activity (Ci) 2.76E-07 3.93E-08 1.42E-01 4.09E-07 5.41E-08 1.32E-01 6.02E-TRU Alpha Conc. (nCi/g) 2.48E+05 1.90E+04 7.66E-02 2.47E+05 1.89E+04 7.65E-02 2.55E+
B-16 

ATTACHMENT B.16 REPLICATE TESTING RESULTS FOR CONTAINER 53551, PTGS 

Instrument: PTGS 

Container: 53551 

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ2 Pr(x <|χ2233U Activity (Ci) <LLD #VALUE! N/A N/A N/A N/A N234U Activity (Ci) 2.45E-05 3.51E-06 2.30E-05 2.90E-06 1.26E-01 2.72E+00 6.05E-238U Activity (Ci) <LLD #VALUE! N/A N/A N/A N/A N238Pu Activity (Ci) 1.57E-01 2.25E-02 1.48E-01 1.88E-02 1.27E-01 2.79E+00 5.93E-239Pu Activity (Ci) 5.83E+00 6.92E-01 5.15E+00 1.21E-01 2.35E-02 1.22E-01 9.98E-240Pu Activity (Ci) 1.31E+00 1.59E-01 1.13E+00 1.48E-02 1.31E-02 3.48E-02 1.00E+242Pu Activity (Ci) 3.08E-05 8.52E-06 2.62E-05 3.78E-07 1.45E-02 7.88E-03 1.00E+241Am Activity (Ci) 3.98E+00 4.73E-01 3.35E+00 8.07E-02 2.41E-02 1.17E-01 9.98E-90Sr Activity (Ci) 7.13E-07 8.96E-08 4.24E-07 1.17E-07 2.77E-01 6.87E+00 1.43E-137Cs Activity (Ci) 7.15E-07 8.98E-08 4.25E-07 1.18E-07 2.77E-01 6.88E+00 1.42E-TRU Alpha Conc. (nCi/g) 2.86E+05 2.16E+04 2.48E+05 5.07E+03 2.04E-02 2.20E-01 9.94E-

Quantity of Interest χ2 Test t Test233U Activity (Ci) Not Applicable Not Applicable 234U Activity (Ci) Not Significant Not Significant 238U Activity (Ci) Not Applicable Not Applicable 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Highly Significant 240Pu Activity (Ci) Not Significant Highly Significant 242Pu Activity (Ci) Not Significant Highly Significant 241Am Activity (Ci) Not Significant Highly Significant 90Sr Activity (Ci) Not Significant Not Significant 137Cs Activity (Ci) Not Significant Not Significant TRU Alpha Conc. (nCi/g) Not Significant Highly Significant 
B-17 

ATTACHMENT B.17 REPLICATE TESTING DATA FOR CONTAINER 54857, PTGS SY

Instrument: PTGS Container: 54857 

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reporte

Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) <LLD #VALUE! #DIV/0! <LLD #VALUE! #DIV/0! <L234U Activity (Ci) 3.27E-05 4.54E-06 1.39E-01 2.24E-05 3.29E-06 1.47E-01 2.26E238U Activity (Ci) <LLD #VALUE! #DIV/0! <LLD #VALUE! #DIV/0! <L238Pu Activity (Ci) 2.10E-01 2.91E-02 1.39E-01 1.44E-01 2.11E-02 1.47E-01 1.45E239Pu Activity (Ci) 4.82E+00 5.78E-01 1.20E-01 4.00E+00 4.74E-01 1.19E-01 4.02E240Pu Activity (Ci) 1.18E+00 1.45E-01 1.23E-01 9.96E-01 1.21E-01 1.21E-01 9.38E242Pu Activity (Ci) 2.98E-05 8.26E-06 2.77E-01 2.46E-05 6.80E-06 2.76E-01 2.30E241Am Activity (Ci) 1.89E+00 2.27E-01 1.20E-01 1.79E+00 2.13E-01 1.19E-01 1.78E90Sr Activity (Ci) 2.37E-07 3.22E-08 1.36E-01 2.44E-07 3.19E-08 1.31E-01 1.90E137Cs Activity (Ci) 2.38E-07 3.23E-08 1.36E-01 2.45E-07 3.20E-08 1.31E-01 1.90ETRU Alpha Conc. (nCi/g) 4.11E+05 3.24E+04 7.88E-02 3.52E+05 2.71E+04 7.70E-02 3.49E

Replicate #3 Replicate #4 

Quantity of Interest

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) <LLD #VALUE! #DIV/0! <LLD #VALUE! #DIV/0! <LL234U Activity (Ci) 2.22E-05 3.22E-06 1.45E-01 2.41E-05 3.42E-06 1.42E-01 2.55E-238U Activity (Ci) <LLD #VALUE! #DIV/0! <LLD #VALUE! #DIV/0! <LL238Pu Activity (Ci) 1.42E-01 2.06E-02 1.45E-01 1.54E-01 2.19E-02 1.42E-01 1.63E-239Pu Activity (Ci) 4.02E+00 4.80E-01 1.19E-01 3.99E+00 4.75E-01 1.19E-01 4.06E+240Pu Activity (Ci) 9.78E-01 1.20E-01 1.23E-01 9.21E-01 1.13E-01 1.23E-01 1.01E+242Pu Activity (Ci) 2.41E-05 6.69E-06 2.78E-01 2.25E-05 6.22E-06 2.76E-01 2.50E-241Am Activity (Ci) 1.77E+00 2.12E-01 1.20E-01 1.75E+00 2.09E-01 1.19E-01 1.77E+90Sr Activity (Ci) 2.96E-07 3.82E-08 1.29E-01 2.50E-07 3.28E-08 1.31E-01 1.59E-137Cs Activity (Ci) 2.97E-07 3.83E-08 1.29E-01 2.51E-07 3.29E-08 1.31E-01 1.60E-TRU Alpha Conc. (nCi/g) 3.51E+05 2.74E+04 7.81E-02 3.46E+05 2.70E+04 7.80E-02 3.55E+
B-18 

ATTACHMENT B.18 REPLICATE TESTING RESULTS FOR CONTAINER 54857, PTGS 

Instrument: PTGS 

Container: 54857 

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ2 Pr(x <|χ2233U Activity (Ci) <LLD #VALUE! N/A N/A N/A N/A N234U Activity (Ci) 3.27E-05 4.54E-06 2.34E-05 1.41E-06 6.04E-02 3.87E-01 9.84E-238U Activity (Ci) <LLD #VALUE! N/A N/A N/A N/A N238Pu Activity (Ci) 2.10E-01 2.91E-02 1.50E-01 8.79E-03 5.88E-02 3.65E-01 9.85E-239Pu Activity (Ci) 4.82E+00 5.78E-01 4.02E+00 2.68E-02 6.68E-03 8.62E-03 1.00E+240Pu Activity (Ci) 1.18E+00 1.45E-01 9.69E-01 3.79E-02 3.92E-02 2.74E-01 9.91E-242Pu Activity (Ci) 2.98E-05 8.26E-06 2.38E-05 1.06E-06 4.45E-02 6.58E-02 9.99E-241Am Activity (Ci) 1.89E+00 2.27E-01 1.77E+00 1.48E-02 8.37E-03 1.71E-02 1.00E+90Sr Activity (Ci) 2.37E-07 3.22E-08 2.28E-07 5.38E-08 2.36E-01 1.12E+01 2.48E-137Cs Activity (Ci) 2.38E-07 3.23E-08 2.29E-07 5.40E-08 2.36E-01 1.12E+01 2.48E-TRU Alpha Conc. (nCi/g) 4.11E+05 3.24E+04 3.51E+05 3.36E+03 9.59E-03 4.31E-02 1.00E+

Quantity of Interest χ2 Test t Test233U Activity (Ci) Not Applicable Not Applicable 234U Activity (Ci) Not Significant Highly Significant 238U Activity (Ci) Not Applicable Not Applicable 238Pu Activity (Ci) Not Significant Highly Significant239Pu Activity (Ci) Not Significant Highly Significant 240Pu Activity (Ci) Not Significant Highly Significant 242Pu Activity (Ci) Not Significant Highly Significant 241Am Activity (Ci) Not Significant Highly Significant 90Sr Activity (Ci) Significant Not Significant 137Cs Activity (Ci) Significant Not Significant TRU Alpha Conc. (nCi/g) Not Significant Highly Significant 
B-19 

ATTACHMENT B.19 REPLICATE TESTING DATA FOR CONTAINER S817309, HENC #2 

Instrument: HENC#2 Container: S817309 

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reporte

Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E238Pu Activity (Ci) 9.31E-03 2.10E-05 2.26E-03 1.96E-02 2.61E-04 1.33E-02 1.32E239Pu Activity (Ci) 1.53E-01 5.54E-03 3.62E-02 1.52E-01 5.47E-03 3.60E-02 1.51E240Pu Activity (Ci) 3.78E-02 6.69E-04 1.77E-02 3.32E-02 3.30E-04 9.95E-03 3.71E242Pu Activity (Ci) 5.16E-06 6.45E-12 1.25E-06 9.30E-06 3.73E-11 4.01E-06 8.48E241Am Activity (Ci) 1.53E-02 6.01E-05 3.93E-03 4.16E-02 5.12E-04 1.23E-02 4.67E90Sr Activity (Ci) 2.44E-05 1.41E-10 5.77E-06 2.39E-05 1.35E-10 5.66E-06 2.24E137Cs Activity (Ci) 2.44E-05 1.41E-10 5.77E-06 2.39E-05 1.35E-10 5.66E-06 2.24ETRU Alpha Conc. (nCi/g) 1.30E+03 3.19E+05 2.45E+02 1.48E+03 3.70E+05 2.50E+02 1.50E

Replicate #3 Replicate #4 

Quantity of Interest

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238Pu Activity (Ci) 1.68E-02 2.18E-04 1.30E-02 2.56E-02 4.17E-04 1.63E-02 2.34E-239Pu Activity (Ci) 1.51E-01 5.42E-03 3.59E-02 1.54E-01 5.62E-03 3.65E-02 1.48E-240Pu Activity (Ci) 3.18E-02 3.13E-04 9.85E-03 3.24E-02 3.07E-04 9.46E-03 2.98E-242Pu Activity (Ci) 8.40E-06 3.42E-11 4.07E-06 1.03E-05 4.32E-11 4.19E-06 9.40E-241Am Activity (Ci) 3.01E-02 2.98E-04 9.91E-03 3.83E-02 6.51E-04 1.70E-02 5.94E-90Sr Activity (Ci) 2.26E-05 1.21E-10 5.35E-06 2.27E-05 1.22E-10 5.37E-06 2.23E-137Cs Activity (Ci) 2.26E-05 1.21E-10 5.35E-06 2.27E-05 1.22E-10 5.37E-06 2.23E-TRU Alpha Conc. (nCi/g) 1.39E+03 3.41E+05 2.45E+02 1.51E+03 4.05E+05 2.68E+02 1.57E+
B-20 

ATTACHMENT B.20 REPLICATE TESTING RESULTS FOR CONTAINER S817309, HENC 

Instrument: HENC#2

Container: S817309 

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ2 Pr(x <|χ2233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU238Pu Activity (Ci) 9.31E-03 2.10E-05 1.97E-02 4.98E-03 2.52E-01 2.24E+05 0.00E+239Pu Activity (Ci) 1.53E-01 5.54E-03 1.51E-01 2.17E-03 1.43E-02 6.13E-01 9.62E-240Pu Activity (Ci) 3.78E-02 6.69E-04 3.29E-02 2.68E-03 8.16E-02 6.43E+01 3.58E-242Pu Activity (Ci) 5.16E-06 6.45E-12 9.18E-06 7.77E-07 8.47E-02 5.81E+10 0.00E+241Am Activity (Ci) 1.53E-02 6.01E-05 4.32E-02 1.09E-02 2.52E-01 1.31E+05 0.00E+90Sr Activity (Ci) 2.44E-05 1.41E-10 2.28E-05 6.46E-07 2.83E-02 8.42E+07 0.00E+137Cs Activity (Ci) 2.44E-05 1.41E-10 2.28E-05 6.46E-07 2.83E-02 8.42E+07 0.00E+TRU Alpha Conc. (nCi/g) 1.30E+03 3.19E+05 1.49E+03 6.52E+01 4.38E-02 1.68E-07 1.00E+

Quantity of Interest χ2 Test t Test233U Activity (Ci) #VALUE! Not Applicable 234U Activity (Ci) #VALUE! Not Applicable 238U Activity (Ci) #VALUE! Not Applicable 238Pu Activity (Ci) Highly Significant Not Significant239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Highly Significant Not Significant 242Pu Activity (Ci) Highly Significant Highly Significant 241Am Activity (Ci) Highly Significant Not Significant 90Sr Activity (Ci) Highly Significant Not Significant 137Cs Activity (Ci) Highly Significant Not Significant TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
B-21 

ATTACHMENT B.21 REPLICATE TESTING DATA FOR CONTAINER 61209, HENC #2 S

Instrument: HENC #2 Container: 61209 

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reporte

Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E234U Activity (Ci) 1.17E-05 2.41E-11 2.06E-06 1.17E-05 1.85E-11 1.58E-06 1.20E238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E238Pu Activity (Ci) 1.21E-03 3.05E-07 2.52E-04 2.48E-04 1.59E-08 6.40E-05 1.10E239Pu Activity (Ci) 8.59E-03 1.34E-05 1.56E-03 8.61E-03 1.67E-05 1.94E-03 8.63E240Pu Activity (Ci) 2.52E-03 1.42E-06 5.62E-04 2.06E-03 1.09E-06 5.30E-04 1.90E242Pu Activity (Ci) 1.87E-07 7.61E-15 4.07E-08 1.18E-07 3.60E-15 3.05E-08 1.64E241Am Activity (Ci) 8.17E-04 1.54E-07 1.89E-04 1.04E-03 2.71E-07 2.61E-04 2.35E90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00ETRU Alpha Conc. (nCi/g) 2.39E+02 7.34E+03 3.07E+01 2.40E+02 8.30E+03 3.46E+01 2.55E

Replicate #3 Replicate #4 

Quantity of Interest

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+234U Activity (Ci) 1.23E-05 2.48E-11 2.02E-06 8.33E-06 1.42E-11 1.71E-06 1.02E-238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238Pu Activity (Ci) 1.92E-03 8.03E-07 4.18E-04 1.04E-03 2.25E-07 2.16E-04 2.01E-239Pu Activity (Ci) 8.44E-03 1.38E-05 1.63E-03 8.45E-03 1.29E-05 1.53E-03 8.48E-240Pu Activity (Ci) 2.11E-03 1.06E-06 5.01E-04 2.36E-03 1.25E-06 5.29E-04 2.44E-242Pu Activity (Ci) 1.83E-07 7.58E-15 4.14E-08 1.58E-07 5.50E-15 3.48E-08 1.99E-241Am Activity (Ci) 1.04E-03 2.51E-07 2.41E-04 8.93E-04 1.81E-07 2.03E-04 1.02E-90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+TRU Alpha Conc. (nCi/g) 2.46E+02 7.95E+03 3.23E+01 2.32E+02 6.96E+03 3.00E+01 2.54E+
B-22 

ATTACHMENT B.22 REPLICATE TESTING RESULTS FOR CONTAINER 61209, HENC #

Instrument: HENC#2

Container: 61209 

Original Measurement Sample Relative 

Quantity of Reported Absolute Sample Standard Standard Interest Value Uncertainty Mean Deviation Deviation χ2 Pr(x <|χ2233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU234U Activity (Ci) 1.17E-05 2.41E-11 1.09E-05 1.65E-06 1.51E-01 1.88E+10 0.00E+238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU238Pu Activity (Ci) 1.21E-03 3.05E-07 1.26E-03 7.24E-04 5.73E-01 2.25E+07 0.00E+239Pu Activity (Ci) 8.59E-03 1.34E-05 8.52E-03 9.09E-05 1.07E-02 1.84E+02 9.26E-240Pu Activity (Ci) 2.52E-03 1.42E-06 2.17E-03 2.22E-04 1.02E-01 9.85E+04 0.00E+242Pu Activity (Ci) 1.87E-07 7.61E-15 1.64E-07 3.06E-08 1.86E-01 6.45E+13 0.00E+241Am Activity (Ci) 8.17E-04 1.54E-07 1.27E-03 6.08E-04 4.79E-01 6.19E+07 0.00E+90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALU137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUTRU Alpha Conc. (nCi/g) 2.39E+02 7.34E+03 2.45E+02 9.69E+00 3.95E-02 6.97E-06 1.00E+

Quantity of Interest χ2 Test t Test233U Activity (Ci) #VALUE! Not Applicable 234U Activity (Ci) Highly Significant Not Significant 238U Activity (Ci) #VALUE! Not Applicable 238Pu Activity (Ci) Highly Significant Not Significant239Pu Activity (Ci) Highly Significant Not Significant 240Pu Activity (Ci) Highly Significant Not Significant 242Pu Activity (Ci) Highly Significant Not Significant 241Am Activity (Ci) Highly Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable 137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
Attachments C.1 through C.8 
 

C-1 

ATTACHMENT C.1 

EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. LANL-CCP-AK-06-001CR 

Inspection No. EPA-LANL-CCP-05.06-8 Issue Number: LANL-CCP-AK-06-001CR 

Date: 05-23-06 

Inspector: Connie Walker 

Attachments? YES NO 

Sample Size: All waste streams 

Population size (if known): All waste streams 

A. Description of Issue: EPA Checklist Elements 38, 42, and 48 are related to the reassessment of 

waste if the AK data and related confirmation consistently indicate discrepancies between acceptable 

knowledge information and measurement data. Up to this point, CCP has not formally re-evaluated waste

streams for which NDA data and AK-identified most prevalent nuclides do not comport because only a 

portion of the waste stream had been measured. However, CCP should develop processes and criteria to 

establish when reassessment would occur and what this would entail. 

B. Regulatory Reference: Attachment B4, Section B4-4; DOE-WIPP-02-3122, Attachment A, Section 

A.2.2.3 

C. Site Requirement(s): CCP-TP-005, Revision 16 

D. Discussed with: Site Personnel: Steve Schafer, Randy Fitzgerald 

 DOE/CTAC Personnel: Norm Frank 

 Other Personnel: NA 

E. Additional Comments: CCP should provide the path or process by which the above evaluation will 

be accomplished in the future. EPA shall evaluate the implementation of the process through periodic 

updates. 

The potential for this concern to impact waste characterization activities at all CCP TRU waste 

characterization sites must be evaluated. Once the evaluation is complete, EPA must be informed of the 

results of CCP’s investigation. 

F. Site Response Information and Issue Resolution: 

 Site Response Required? YES NO 

 Site Response Due Date: 6-18-06 

The formal CBFO response that was submitted to EPA on March 21, 2007 is provided below: 

 

In accordance with the requirements of CCP-QP-005, CCP TRU Nonconforming Item Reporting and 

Control and CCP-TP-005, CCP Acceptable Knowledge Documentation, CCP has implemented Trend 

Code L for identifying NCRs that potentially impact AK. NCRs that identify inconsistencies noted 

during the process of comparing AK information to characterization results and NCRs that identify 

potential changes to the AK of a waste stream are tracked as Trend Code L. These NCRs are 

evaluated by the AKE. The AKE evaluation and resolution of the NCR may include preparation of 
 

C-2 

Inspection No. EPA-LANL-CCP-05.06-8 Issue Number: LANL-CCP-AK-06-001CR 

Date: 05-23-06 

an AK Discrepancy Resolution report, an AK Re-Evaluation, and/or an update to the applicable AK 

report. Final disposition of Trend Code L NCRs is dependent upon the AKE’s evaluation and 

conclusions regarding actions necessary to close the NCR. 

 

Trending of NCRs identified as Trend Code L is performed and reported in the CCP Trend Report, 

which is prepared semi-annually in accordance with CCP-QP-014, CCP Data Analysis and 

Trending. If Trend Code L NCRs indicate consistent discrepancies between AK and measurement 

data, a re-evaluation of AK information will be conducted. CCP does not anticipate any reevaluation of an entire approved waste stream. If an approved waste stream is eliminated or 

combined with another approved waste stream, a memorandum written to the AK record will be 

prepared in accordance to CCP-TP-005, Section 4.3.3, to document the issues, evaluations, and 

conclusions regarding the waste stream reassignment. In the event an entire waste stream is 

eliminated or combined with an existing approved waste stream in the future, CCP will provide and 

document training to characterization personnel regarding changes to the delineation of the waste 

stream and the content of the memorandum written to the AK record. 

EPA accepts CBFO’s response and considers this issue to be closed. 
C-3 

ATTACHMENT C.2 

EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. LANL-CCP-AK-06-002C 

Inspection No. EPA-LANL-CCP-05.06-8 Issue Number: LANL-CCP-AK-06-002C 

Date: 5-23-06 

Inspector: Connie Walker 

Attachments? YES NO 

Sample Size: All waste stream AK Accuracy Reports 

Population size (if known): See above 

A. Description of Issue: AK Accuracy for radionuclides is determined by comparing the AK and NDAidentified weight percents of the two predominant radionuclides. However, this assessment would be more 

meaningful if accuracy was also assessed in terms of activity. For example, the March 27, 2006, AK 

Accuracy Report for Waste Stream LA-MIN03-NC.001 states that the most prevalent isotopes identified by 

AK are 235U and 235U, based on weight percent. However, the assignment of 238U and 235U as the most 

prevalent is based on the radionuclide content of a small number of containers. If these containers are not 

among those that are measured, the measured versus AK-predicted prevalence by mass would not match. 

Future AK Accuracy reports should also assess the AK-NDA agreement in identifying the two most 

prevalent radionuclides by activity as well as mass. 

B. Regulatory Reference: 40 CFR 194.24 (c)(3), CH WAC Appendix A, Section A.2

C. Site Requirement(s): CCP-TP-005, Revision 16, Section 4.5

D. Discussed with: Site Personnel: Steve Schafer, Randy Fitzgerald 

 DOE/CTAC Personnel: Norm Frank 

 Other Personnel: NA 

E. Additional Comments: The potential for this concern to impact waste characterization activities at 

all CCP TRU waste characterization sites must be evaluated. Once the evaluation is complete, EPA must

be informed of the result of CCP’s investigation. 

F. Site Response Information and Issue Resolution: EPA considers this issue to be closed. 

 Site Response Required? YES NO 

 Site Response Due Date: N/A 
C-4 

ATTACHMENT C.3 

EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. LANL-CCP-AK-06-003CR

Inspection No. EPA-LANL-CCP-05.06-8 Issue Number: LANL-CCP-AK-06-003CR 

Date: 10-31-05 

Inspector: Connie Walker 

Attachments? YES NO 

Sample Size: AK- NDA Memoranda 

Population size (if known): ,Three (3) 

A. Description of Issue: The AK-NDA memoranda have various inconsistencies that should be 

addressed. The LANL-004 NDA-AK memorandum includes editorial issues with respect to appropriate 

units and inadequate referencing of support documents for specific statements or conclusions. In the NDA 

memoranda for LANL-007 and -009, references for formulas or other calculations should be included. 

Tables in all NDA-AK memoranda should be checked against data in the AK Summaries and Attachments 

to ensure that the data presented therein are consistent; specifically, Table 3 in the LANL-009 AK-NDA 

memorandum should be revised to indicated expected (rather than suspected) radionuclides, as this makes a 

difference in how the nuclides are entered into the WWIS. 

B. Regulatory Reference: 40 CFR 194.24 (c), 

C. Site Requirement(s): CCP-TP-005 Revision 16, Section 4.4.20

D. Discussed with: Site Personnel: Steve Schafer, Randy Fitzgerald 

 DOE/CTAC Personnel: Norm Frank 

 Other Personnel: NA 

E. Additional Comments: 

F. Site Response Information and Issue Resolution: 

 Site Response Required? YES NO 

 Site Response Due Date: 6-18-06 

The NDA Memorandum is LANL-CCP’s method of addressing EPA-identified communication issues and 

originated when EPA identified these issues at a Hanford-CCP inspection. Some remedies implemented by

sites related to TRU WC processes in response to EPA issues or concerns are self imposed; however, these 

at times may, in fact, provide assurance that EPA’s issues and/or concerns are appropriately identified and 

rectified. When such AK-NDA memoranda are written, they document AK-NDA communication for the 

purpose of ensuring that both NDA and AK personnel are aware of the use and limitations of AK as applied 

to NDA. CBFO has stated that, as with any process of improvement, inconsistencies should be corrected 

when they are found, and LANL-CCP has revised NDA memoranda for waste streams LANL-004, LANL007, and LANL-009 to address the issues that were identified. EPA is convinced that when AK-NDA 

communication occurs through the process of using an AK-NDA memorandum, it avoids problems that 

could ultimately result in erroneous data use. EPA accepts the CBFO response and considers this issue to 

be closed. 
C-5 

ATTACHMENT C.4 

EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. LANL-CCP-VE-06-004F

Inspection No. EPA-LANL-CCP-05.06-8 Issue Number: LANL-CCP-VE-06-004F, Revision 1 

Date: 5/23/06 

Inspector: Dorothy E. Gill 

Attachments? YES NO 

Sample Size: Approximately 350 containers 

Population size (if known): NA 

A. Description of Issue: 

A. The quantity and location of prohibited liquid encountered in the RTR examinations of containers prior to 

May 2005 from waste stream number LA-MIN03-NC.001 were not predicted in the AK summary CCPAK-LANL-004. Although characterization personnel initiated NCRs to address the presence of prohibited

liquids, this information was not communicated to AK personnel to enable updating of the AK record. As a 

result, more than 120 drums of waste with the potential to contain in excess of 1% liquids (the maximum 

allowable on a per drum basis) were emplaced in the WIPP over the past 12 months. 

B. CCP personnel used VE in Lieu of RTR to characterize wastes from this same waste stream from May 4,

through June 23, 2005. However, the presence of liquids made the use of this technique unsuitable for

containers of S3000 wastes. Until corrective action is taken, the use of this technique at CCP sites is 

unacceptable. 

B. Regulatory Reference: 40 CFR 194.24 (c)

C. Site Requirement(s): CCP-TP-113, Revision 4

D. Discussed with: Site Personnel: Buddy Fussell, Sue Peterman

 DOE/CTAC Personnel: Annabelle Axinn, Wayne Ledford 

 Other Personnel: NA

E. Additional Comments: The potential for this finding to impact waste characterization activities at all CCP 

TRU waste characterization sites must be evaluated. Once this is evaluated, EPA must be informed of the result of 

CCP’s investigation. EPA will perform its own investigation during inspections at other CCP sites to make its own 

determination of the extent of this finding’s scope. DOE must also evaluate the impact of these approximately 120 

drums that may contain liquid on the containment of TRU waste at WIPP.

F. Site Response Information and Issue Resolution: 

Site Response Required? YES NO 

Site Response Due Date: 6/18/06 

CBFO Interpreted this finding as a prohibition of the use of VE for all solid (S3000) waste streams throughout the 

DOE complex. This was not EPA’s intention and EPA provided verbal clarification to CBFO regarding this on 

multiple occasions. EPA did intend this finding to prohibit the use of VE for de-watered sludge containers at LANLCCP and to prompt CBFO to reexamine the use of VE for similar wastes throughout the complex. The formal CBFO 

response that was submitted to EPA on March 21, 2007 is provided below: 

 CCP will conduct additional training to the SPMs and AKEs to develop and issue, as necessary, a 

memorandum to be included in the AK record to document special characterization requirements for 

S3000/S4000 summary category group wastes. This is primarily to document the technical basis for the 

decision to use VE in lieu of RTR. 

EPA accepts the CBFO response and considers this issue to be closed.
C-6 

ATTACHMENT C.5 

EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. LANL-CCP-VE-06-005CR

Inspection No. EPA-LANL-CCP-05.06-8 Issue Number: LANL-CCP-VE-06-005CR 

Date: 5/24/06 

Inspector: Dorothy E. Gill 

Attachments? YES NO 

Sample Size: 5 VE & RTR personnel 

Population size (if known): NA 

A. Description of Issue: Attachments used for data entry for both RTR and VE include a line item that 

requires operators to verify that the waste examined matches the Waste Stream description. The VEE for 

the VE demonstration and the operators of RTR units 1 and 2, observed by EPA on May 24, 2006, could 

not explain how they were able to answer this question. These personnel did not have a copy of Waste 

Stream descriptions, for example CCP-LANL-AK-9, in their respective work areas nor were they able to 

describe the items included in the Waste Stream descriptions provided in the AK Summary Report for the

waste stream they were currently examining. 

B. Regulatory Reference: 40 CFR 194.24 (c)

C. Site Requirement(s): 

1. CCP-TP-113, Revision 4, Standard Waste Visual Examination, Attachment 1, Question #32 

2. CCP-TP-053, Revision 4, Standard Real-Time Radiography (RTR) Inspection Procedure, 

Attachment 2, Section 5 

D. Discussed with: Site Personnel: Steven Ewing, Bill Mussman, Colleen Monk, Israel Aragon, 

 Ricky Baros

 DOE/CTAC Personnel: Annabelle Axinn 

 Other Personnel: NA 

E. Additional Comments: The potential for this concern to impact waste characterization activities at 

all CCP TRU waste characterization sites must be evaluated. Once this is evaluated, EPA must be informed 

of the result of CCP’s investigation. 

F. Site Response Information and Issue Resolution: 

 Site Response Required? YES NO 

 Site Response Due Date: 6-18-06 

Prior to the March 6, 2007, follow-up inspection, EPA reviewed a copy of the LANL-CCP RTR and VE 

Training Module (PowerPoint presentation) and the Non Destructive Examination (NDE) RTR 

Comprehensive Examination. During the March 2007 follow-up inspection, EPA interviewed RTR 

operators who were able to correctly answer questions with the regard to the items on the data form that are 

detailed above. The operators also demonstrated to EPA that they had access to both paper and electronic 

copies of the applicable AK waste stream descriptions. EPA considers this issue to be closed. 
C-7 

ATTACHMENT C.6 

EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. LANL-CCP-VE-06-006CR

Inspection No. EPA-LANL-CCP-05.06-8 Issue Number: LANL-CCP-VE-06-006CR 

Date: 05-25-06 

Inspector: Dorothy Gill 

Attachments? YES NO 

Sample Size: All containers reviewed 

Population size (if known): Unknown 

A. Description of Issue: 

1. Waste Material Parameter weights are inconsistently recorded for leaded rubber gloves. In RTR, 

leaded gloves are recorded as only under the rubber waste material parameter, but in VE the 

weight of the gloves is assigned in the following way: 60% rubber and 40% other metals. 

2. VE personnel were unable to provide the rationale for assigning the weights (60:40) in this 

manner. 

B. Regulatory Reference: 40 CFR 194.24 (c) 

C. Site requirement(s): 

1. CCP-TP-113, Revision 4, Standard Waste Visual Examination, Attachment 1, Section 3 

2. CCP-TP-053, Revision 4, Standard Real-Time Radiography (RTR) Inspection Procedure, 

Attachment 2, Section 4 

D. Discussed with: Site Personnel: Steve Ewing, Israel Aragon, Buddy Fussell 

 DOE/CTAC Personnel: Annabelle Axinn 

 Other Personnel: NA 

E. Additional Comments: The potential for this concern to impact waste characterization activities at 

all CCP TRU waste characterization sites must be evaluated. Once the evaluation is complete, EPA must

be informed of the results of CCP’s investigation. 

F. Site Response Information and Issue Resolution: 

 Site Response Required? YES NO 

 Site Response Due Date: 6-18-06 

CBFO’s response that was submitted to EPA is provided below: 

 CCP VPM and SPM gave verbal directions to stop this practice and provided training on June 22, 

2006. CCP will assign the weight of leaded rubber gloves as 100% rubber. 

EPA accepts the CBFO response and considers this issue to be closed. 
C-8 

ATTACHMENT C.7 

EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. LANL-CCP-VE-06-007CR

Inspection No. EPA-LANL-CCP-05.06-8 Issue Number: LANL-CCP-VE-06-007CR 

Date: 5-25-06 

Inspector: Dorothy Gill 

Attachments? YES NO 

Sample Size: Five (5) Batch Data Reports (BDRs) 

Population size (if known): Five (5) BDRs 

A. Description of Issue: The containers examined by VE in BDR LAVE500061 (VE as a QC Check of 

RTR) contained numerous small cans that were opened, but not empty, during the VE event. CCP 

personnel were unable to demonstrate that all of the WMPs contained in the cans were inventoried and the 

VE procedure does not address this circumstance. 

B. Regulatory Reference: 40 CFR 194.24 (c)

C. Site requirement(s): CCP-TP-113, Revision 4, Standard Waste Visual Examination

D. Discussed with: Site Personnel: Israel Aragon, Sue Peterman 

 DOE/CTAC Personnel: Annabelle Axinn 

 Other Personnel: NA 

E. Additional Comments: The potential for this concern to impact waste characterization activities at 

all CCP TRU waste characterization sites must be evaluated. Once the evaluation is complete, EPA must

be informed of the result of CCP’s investigation. 

F. Site Response Information and Issue Resolution: 

 Site Response Required? YES NO 

 Site Response Due Date: 6/18/06 

The CBFO response that was submitted to EPA is provided below: 

 CCP will conduct additional training to the VE operators/VE experts to verbalize more during VE 

operations that would allow an independent person to reach the same conclusion as the VE operator 

or VE expert. 

EPA accepts the CBFO response and considers this issue to be closed. 
C-9 

ATTACHMENT C.8 

EPA INSPECTION ISSUE TRACKING FORM, ISSUE NO. LANL-CCP-RTR-06-008C

Inspection No. EPA-LANL-CCP-05.06-8 Issue Number: LANL-CCP-RTR-06-008C 

Date: 5-25-06 

Inspector: Dorothy Gill 

Attachments? YES NO 

Sample Size: Two (2) 

Population size (if known): Two (2) 

A. Description of Issue: CCP at LANL has generated two (2) annual VE/RTR Comparison Reports, but 

at the time of this inspection RTR operators had not received any “lessons learned” training on the 

discrepancies between the RTR and VE results. 

B. Regulatory Reference: 40 CFR 194.24 (c) 

C. Site requirement(s): QAPD Revision 7, Section 1.1.1.4

D. Discussed with: Site Personnel: Steve Ewing, Buddy Fussell 

 DOE/CTAC Personnel: Annabelle Axinn 

 Other Personnel: ,NA 

E. Additional Comments: None 

F. Site Response Information and Issue Resolution: EPA considers this issue to be closed. 

 Site Response Required? YES NO 

 Site Response Due Date: 
Attachment D 
D-1 

Attachment D 

EPA’s Response to Public Comments 

EPA received one set of public comments on May 18, 2007 by from D. K. Ploetz (Washington 

TRU Solutions – Central Characterization Program) in response to the April 18, 2007 Federal 

Register notice that proposed EPA’s decision to approve various components of the LANL CH 

TRU waste characterization program implemented by CCP (72 FR 19494 - 19499, April 18, 

2007). (See EPA Docket ID Nos. EPA-HQ-OAR-2007-0326-0003 and EPA-HQ-OAR-2007-

0326-0003.1). To facilitate EPA’s response, the comments have been divided into six separate 

issues, and each issue is provided verbatim below along with EPA’s response. Please note that 

wherever EPA has modified the text from the proposed approval to address a specific comment 

the modified text presented in this attachment is underlined for emphasis. The text in the actual 

report is not underlined. 

Comment No. 1: The EPA proposes that CCP must report and, if applicable, receive EPA 

approval of any changes to the waste characterization activities to the date of the LANL baseline 

inspection. The EPA’s proposed reporting and approval requirements are not identical to those 

included in their previous baseline inspection reports and EPA approval letters. 

EPA Response: This is correct. This was addressed in the Executive Summary of the 

LANL CH Baseline Inspection report that is excerpted below: 

“LANL-CCP must report and receive EPA approval of any T1 changes to the LANL-CCP 

WC activities from the date of the baseline inspection, and must notify EPA regarding T2 

changes according to Table 1. It is worth noting that Table 1 in this report is not 

identical to those included in previous baseline inspection reports and EPA site approval 

letters in several ways. The most important of these involve presentation of the T2 

elements. In previous reports there were two T2 columns that have been merged into a 

single T2 column for LANL-CCP. The T2 column entries have also been modified to 

better reflect the 40 CFR 194.24 (h) requirements that the site provide notification

regarding the completion or availability of specific T2 elements, whereas the previous 

tables stated that the site must actually provide the T2 elements (document or procedure 

revisions, etc.). This approach is similar to the tiering tables used in EPA reports for 

sites characterizing remote handled TRU waste. Additionally, there are other minor 

word changes to the table for the sake of legibility. 

The 40 CFR 194.8 regulatory changes gave EPA flexibility whereby EPA now is able to 

evaluate targeted WC program items (namely T1 and T2 changes) in lieu of annual 

continued compliance inspections at different sites more frequently (every fiscal year 

quarter). Also, the slight variation in tiers among the sites reflects EPA’s site inspection 

experience where inspectors are able to compare what they observed at the previouslyapproved CCP sites verses what they notice at the site that is being evaluated for 

approval. The contents of the site-specific tiering tables vary slightly because they depict 

the waste characterization ability of the site in compiling waste characterization 

documentation which is reflective of the nature of the waste-specific information 

available from the parent sites.” 
D-2 

EPA believes that the simple notification with a summary of the changes instead of 

submitting the complete documents, unless specifically requested by EPA, on a quarterly 

basis will significantly reduce paperwork requirements for both DOE and EPA. 

Comment No.2: An important difference involves the addition of several aspects of Acceptable 

Knowledge (AK) to the Tier 2 change criteria. The proposed change will require notification to 

EPA upon completion of updates to or substantive modifications of the following: 

• AK Accuracy Reports (new) 

• AK Reassessment Memoranda (new) 

• AK Visual Examination (VE)-Memoranda related to VE and/or real-time radiography 

techniques (new) 

• AK-Nondestructive Assay Memoranda (new) 

• AK Summary CCP-AK-008 if changed (new) 

• Combination of waste streams (new)

EPA Response: This is correct. This was addressed in the Executive Summary of the 

LANL CH Baseline Inspection report that is excerpted below: 

“There are changes to specific WC areas as well. For AK, the AK Reassessment 

Memoranda (reflecting resolution to concern LANL-CCP-AK-06-001CR) and the AK-VE 

Memoranda related to VE cited under T2 changes (reflecting resolution to finding LANLCCP-VE-06-004F) and do not appear in the tiering tables in previous baseline inspection 

reports. These memoranda are necessary as they provide evidence that the above issues 

are sufficiently addressed. Similarly, requesting revisions to CCP-AK-008 or notification 

regarding the combination of waste streams that were distinct at the time of inspection 

are specific to the LANL OSRP or the result of information identified during this 

inspection. Accordingly, these are absent from the tiering tables in previous baseline 

inspection reports. For WWIS, changes to specific process elements (e.g., spreadsheets 

and data fields) are cited as T2 changes and these did not appear in previous tiering 

tables. These were added to provide a greater degree of specificity in an attempt to 

identify and focus on the key elements relevant to waste isolation. The ***footnote in 

Table 1 specifies that substantive changes means changes with the potential to impact the 

site’s waste characterization activities under 40 CFR 194.24 or documentation thereof, 

excluding changes that are solely related to Environmental Safety &Health (ES&H), 

nuclear safety, the Resource Conservation and Recovery Act (RCRA) or are editorial in 

nature.”

Comment No. 3: Another difference requires notification to EPA upon completion of changes 

to the WIPP Waste Information System (WWIS), including the following: 

• Changes to the Excel spreadsheet, WWIS data entry summary 

• Changes in waste characterization and certification
D-3 

There were no findings or concerns related to WWIS noted during the baseline audit. No reason 

was provided by EPA for requiring this additional information. Further, not all changes made to 

these documents or spreadsheets affect EPA. In the body of the report, EPA states they expect 

copies of the semi-annual CCP Trend Report. This information is redundant to other AK 

information requested previously. 

EPA Response: The comment reflects an apparent misunderstanding. The EPA report 

addresses notification upon completion of specific documents or milestones. Please note 

that the WWIS Tier 2 entry in Table 1 specifies the “completion of changes to WWIS 

procedure(s) requiring CBFO approvals” (emphasis added). Please see the section on 

Tier 2 Changes that is provided for each of the six technical WC areas, which has been 

modified as indicated. The specific sections are on pages 34, 35, 52, 53, 58, 65, 68 and 

70, an example of which is excerpted below: 

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

reported to and approved by EPA, according to Table 1. Following EPA approval, 

LANL-CCP will provide EPA with information concerning T2 changes at the end of each 

fiscal year quarter. EPA will evaluate these changes and communicate with LANL-CCP 

as to whether the changes raise any concerns and require a LANL-CCP response, or 

whether LANL-CCP can continue to implement the changes. Consistent with EPA’s 

authority under 194.24(h) EPA may request information relative to these changes if EPA 

deems the information is necessary to ensure continued compliance with EPA 

regulations.” 

Regarding the reason for requiring information relative to the WWIS, please see Section 

8.6 of the report and the text from the Executive Summary that is excerpted below: 

“For WWIS, changes to specific process elements (e.g., spreadsheets and data 

fields) are cited as T2 changes and these did not appear in previous tiering tables. 

These were added to provide a greater degree of specificity in an attempt to 

identify and focus on the key elements relevant to waste isolation.” 

Regarding WWIS, the Excel spreadsheet(s) represent the actual waste 

characterization process that EPA inspects and approves. Accordingly, changes 

to the spreadsheet potentially represent a characterization system different from 

what was approved, and therefore require informing EPA as indicated in Table 1. 

More generally, EPA understands CCP’s desire to have complete consistency 

among all their WC sites. Differences among the sites do exist and must be 

addressed when they represent a change in the known characterization process. 

EPA attempts to accurately reflect these differences in each inspection and not 

burden a CCP site with requirements that are irrelevant. Tiering differences 

among sites reflect site-specific conditions (activities) and waste streams 

evaluated during the baseline inspection. 

During the follow-up inspection of March 2007, AK experts indicated that they 

prepare the semi-annual CCP Trend Report, which reflects changes in the AK 

summary. During the closing, CCP and CBFO representatives agreed to provide 

the AK Trend Report when available. 
D-4 

Comment No. 4: A third difference requires a tier 1 change to add any waste to the Off-Site 

Source Recovery Program (OSRP). Appropriate programmatic controls exist to add waste to 

existing AK reports. This new requirement is inconsistent with EPA oversight of all other CCP 

waste streams. 

EPA Response: While EPA concurs that consistency is a goal, when a site has wastes that 

are differ from the rest of the waste generators, EPA must look at the unique circumstance. 

The OSRP is indeed different from other CCP sites previously inspected and approved by 

EPA and these differences are reflected in the Tiering requirements. 

In the OSRP program, sealed sources that are collected from various industries (e.g., 

universities, health care and pharmaceuticals, oil exploration), are expected to have 

different pedigree hence, different radiological contents. As additional sealed sources are 

recovered from various commercial and industrial applications that are slated for 

characterization as CH TRU debris waste destined for WIPP disposal, they would be 

characterized using the peer-reviewed manufacturers’ information that is specific to the 

radiological contents of each sealed source. Sealed sources recovered from different 

commercial or industrial applications but with a similar pedigree could be combined in a 

single waste stream designated as a new waste stream or added to the existing approved 

waste stream. Considering that LANL’s OSRP program could actively recover sealed 

sources, the characterization and categorization of the recovered sources into an approved 

or new waste stream is of interest to EPA due to their potential for future sealed sources 

having different radiological contents. Therefore, EPA has designated the addition of new 

OSRP wastes to the AK Summaries since the baseline inspection (CCP-K-008) to be a T1 

change. Also, EPA has assigned a T2 designation, requiring EPA notification as described 

previously, when characterization information in the AK Summaries for the approved 

waste streams (as part of the baseline inspection and T1 change evaluation) has been 

revised to accurately account for changes in radiological contents. 

Please see the report text from AK (13) on pages 29 through 31, and AK (17) on page 33 that is 

reproduced below: 

“The OSRP information was reassessed in light of the new defense determinations. Sealed 

sources containing 241Am and 238Pu have recently been given a defense determination. 

LANL-CCP intends to assess whether the creation of new waste streams is necessary. If 

not, LANL-CCP will update the current AK summary with respect to radionuclide content, 

predominant nuclides, etc. Similarly, LANL-CCP must update or create a new WSPF to 

reflect this change which requires EPA approval. Because EPA has not assessed the 

radiological characterization for new sealed sources, examination of this approach is 

required to ensure that the processes proposed are technically adequate. As discussed in 

section (13), above, the addition of sealed sources from new waste streams is a T1 change. 

(See Table 1, where this is included as a T1 change). “
D-5 

Comment No. 5: The reasons cited in the EPA report concerning why all of this information is 

needed, are unclear. This type of detailed information places the EPA in a position of 

performing an additional layer of quality assurance (QA) for the program, rather than the 

appropriate regulatory oversight function. QA is conducted within CCP’s program and overseen 

by the CBFO. 

EPA Response: EPA recognizes that DOE has its role in ensuring that it and its 

contractors appropriately conduct waste characterization and quality assurance 

activities. However, as the regulator for WIPP, EPA has the responsibility and authority 

to conduct unfettered inspections of DOE waste characterization programs under 40 

CFR 194.8, .21, to independently verify compliance with the requirements of 40 CFR 

194. In order to do this it is EPA that must be satisfied that the requirements of 40 CFR 

194.24 have been compiled with. EPA does not rely on any QA organization to 

determine compliance with waste characterization requirements; this is EPA’s role and 

cannot be delegated to the waste generator or CBFO QA. EPA’s decision making 

process is open to public comment and requires us to obtain objective evidence that can 

be used to substantiate our decisions. 

Comment No. 6: In summary, reporting these changes will add unnecessary complexity and 

therefore costs to the current CCP process for reporting Tier 1 and Tier 2 changes. Also, the 

proposed criteria for reporting Tier 1 and Tier 2 changes at LANL will be significantly different 

than that used at the other DOE sites for the same work scope (excluding LANL OSRP work). 

The processes currently used by CCP for characterizing contact handled TRU waste have been 

certified by CBFO after going through an extensive review process. These certified processes 

include detailed mechanisms for controlling changes that effect data quality. Significant 

changes, such as procedural revisions or equipment modifications, already require EPA 

notification and possible approval. Changes that do not impact data quality should not require 

EPA notification. Programmatic-level information, not operational details, should be provided to 

EPA on a periodic basis for oversight purposes. 

EPA Response: EPA believes that the comment stating that these requirements will 

require more effort on DOE’s part reflects a misunderstanding. By requiring notification 

when specific documents are substantively modified on a quarterly basis, EPA believes 

that DOE will have less of a burden than under the previous requirements. Table 1 has 

been modified with an additional footnote for the purpose of clarification. EPA will look 

at the summary of changes and determine if further review or action is necessary. While 

EPA respects the CBFO change process, it does not reduce the need for EPA to perform 

our regulatory oversight function.