# 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 Man agement 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) Checklis t

Attachment A.6 Visual Examination (VE) Checklist

Attachment A.7 Visual Examination Technique (VET) f or 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 Conta iner 52331, HENC #1 System

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Attachment B.22 Replicate Testing Results for Conta iner 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 Fo rm

, Issue No. LANL-CCP-AK-06-002C

Attachment C.3 EPA Inspection Issue Tracking Fo rm, 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 Fo rm

, Issue No. LANL-CCP-VE-06-005CR

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

Attachment C.7 EPA Inspection Issue Tracking Fo rm, 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

# 1



# 1.0 EXECUTIVE SUMMARY

In accordance with 40 CFR 194.8(b), the U.S. Enviro nmental 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 a t 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 inspe ction of the visual examination (VE)

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

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

issues. (See Sections 8.1 and 8.4 for the issues t hat 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 b aseline 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 discu ssed in this report, in accordance with 40 CFR

194.8(b).

On April 18, 2007, EPA issued a Federal Register (F R) 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 t he LANL Baseline Inspection Report

(EPA Air Docket A-98-49, II-A4-87). The comment pe riod 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 re sponded to the public comments (see

Attachment D of this report), and made changes to t he 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 befor e waste may be disposed of at the WIPP,

as specified in Condition 3 of the Agency’s certifi cation 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 LAN L, 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 inspection s was to evaluate the adequacy of the

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

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

examined the following activities:

• Acceptable knowledge (AK) and load management for c ontact-handled (CH) retrievablystored TRU debris waste (S5000) and solid waste (S3 000) and AK for CH newlygenerated, repackaged debris waste from the OSRP

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

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

1 

# The OSRP is described in EPA Docket No. A-98-49, I I-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 (S50 00) and solid waste (S3000)

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

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

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

(S5000) 2 

# only

• WIPP Waste Information System (WWIS) for CH retriev ably-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 resp onse 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 concern s. Personnel from LANL, the Carlsbad Field

Office (CBFO), and CCP provided information to reso lve 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 th at did not require a response. Between May

2006 and March 2007, CCP provided satisfactory reso lution 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 re sponses for the four outstanding issues that

EPA evaluated for completeness and adequacy, and co ncluded 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-CC P CH WC program activities were

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

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

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

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

wastes and for newly-generated debris wastes from t he OSRP

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

wastes

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

(4) VE as a QC check of the RTR process 3 

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

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

wastes

2 

# NDA systems are typically not matrix-specific in t he 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 ran ge may be assayed.

3 

# However DOE is not required to maintain the abilit y to perform VE as a QC check of RTR (see EPA lette r 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 an y Tier 1 (T1) changes to the LANLCCP WC activities from the date of the baseline ins pection, and must notify EPA regarding

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

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

letters in several ways. The most important of the se 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 spec ific T2 changes, whereas the tiering tables in

the previous inspection reports stated that the sit e 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 wor d changes to the table for the sake of

legibility.

The 40 CFR 194.8 regulatory changes gave EPA flexib ility 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 a bout changes at the sites on a regular basis.

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

specific conditions where inspectors are able to co mpare 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. Fo r AK, the AK Reassessment Memoranda

(reflecting resolution to concern LANL-CCP-AK-06-00 1CR) and the AK-VE Memoranda

related to VE cited under T2 changes (reflecting re solution 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 usi ng 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 docu ment begins with the AK information, it

resides under the AK section in the tiering table.

Similarly, requesting revisions to CCP-AK-008 or no tification regarding the combination of

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

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

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

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

previous tiering tables. These were added to provi de 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 activit ies 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 Recov ery Act (RCRA) or editorial in nature.

# 4



# EPA will notify the public of the results of its ev aluations of T1 and T2 changes through postings

to the EPA Web site and by sending e-mails to the W IPPNEWS 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 WIPPNEW S list, as described above. Upon

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

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

the fourth quarter FY2007. Consistent with EPA’s a uthority 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-u p evaluation conducted on March 6, 2007.5Table 1. Tiering of TRU WC Processes Implemented by LANL-CCPBased on May 23–25, 2006 On Site Baseline Inspection, August 22, 2006 OSRP Inspection and March 6, 2007 EvaluationWC Process ElementsLANL-CCP WC T1 ChangesLANL-CCP WC T2 Changes*Acceptable Knowledge (AK) andLoad ManagementAny new waste category, or new OSRP wastesaddressed in AK Summaries separate fromCCP-AK-008; AK (3), AK (6), AK (16) and (AK) 17Implementation of Load Management for wastestreams other than AK-009; AK (5)Notification to EPA upon completion of AK AccuracyReports; AK (2)Notification to EPA upon completion of updates to or substantivemodifications*** of the following:-AK Reassessment Memoranda and combination of wastestreams thatwere distinct at the time of this inspection; AK (2) and AK (6)-AK-VE Memoranda related to VE and/or RTR techniques; VE (2)-AK-NDA Memoranda; AK (2 and 3)-AK Accuracy Reports; AK (2)-Site procedures requiring CBFO approval; AK (4)-AK Summary CCP-AK-008, if changed since the baseline inspectionand/or following the addition of new sealed sourcesAK (6)-Change Notices used to modify and update WSPFs, including additionsto waste stream(s) within an approved waste category; AK (9)Nondestructive Assay (NDA) New equipment or physical modifications to approvedequipment**; NDA (1-1, 2-1, 3-1)Extension or changes to approved calibration rangeforapproved equipment; NDA (1-2, 2-2, 3-2)Notification to EPA upon completion of changes to software for approvedequipment, operating range(s) and site procedures that require CBFO approval;NDA (1-2, 2-2, 3-2)Real-Time Radiography (RTR) N/A Notification to EPAupon the following:-Implementation of new equipment or substantive changes*** toapproved equipment; RTR (1)-Completion of changes to site procedures requiringCBFO approvals;RTR (2)Visual Examination (VE) andVisual Examination Technique (VET),including OSRP Wastes (Sealed SourceVET or SSVET)N/A Notification to EPA upon the following:-Completion of changes to site VE and VET proceduresrequiring CBFOapprovals, including OSRP VET procedure; VE (1) andSSVET (1)WIPP Waste Information System(WWIS)N/A Notification to EPA upon the following:-Completion of changes to WWIS procedure(s) requiring CBFOapprovals; WWIS (1) and WWIS (2)-Changes to the Excel spreadsheet, WWIS data entry summary,characterization and certification*** that requireCBFO approval;WWIS (1) and WWIS (2)* Upon receiving EPA approval, LANL-CCP will report all T2 changes to EPA at the end of each fiscalyear quarter.** Modifications to approved equipment include allchanges with the potential to affect NDA data relative to waste isolation and exclude minor changes,such as the additionof safety-related equipment.6***Substantive changesmeans changes with the potential to impact the site’s waste characterization activities or documentation thereof, excluding changes that are solelyrelated to Environmental Safety & Health (ES&H), nuclear safety, the Resource Conservation and Recovery Act (RCRA) or are editorial in nature.

# 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 certificat ion, 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 describ ed 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 WIP P, and (2) implement a system of

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

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

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

Isolation Pilot Plant , 1996).

Under the changes to 40 CFR 194.8 promulgated in th e 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 an d limitations, can adequately characterize

TRU wastes and comply with the regulatory requireme nts imposed on TRU wastes destined for

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

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

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

Any compliance application shall: . . . Provide in formation which demonstrates

that a system of controls has been and will continu e 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 o f 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 inspect ion is to assess whether DOE sites that

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

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

limits. Before proposing the approval of CCP WC sy stems 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 h as replaced the term “process

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

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

well as data resulting from the analysis of waste c onducted prior to or separate from the waste certif ication process

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

5 

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

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 propose d 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 iden tified as belonging to the group of approved

waste streams.

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

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

conducting additional inspections under the authori ty 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, includ ing all conditions and limitations, EPA will

specify which subsequent WC program changes or modi fications must undergo further EPA

inspection or approval under 40 CFR 194.24. EPA wi ll 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 rece ive the Agency’s approval prior to

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

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

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

change that is not identified in this report, EPA r ecommends 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-assig ned 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 dur ing the inspection

• Provides objective evidence of the approval basis f or all WC systems

• Identifies all relevant system limitations and/or c onditions 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 dur ing the course of the inspection and

their relevance to EPA’s approval decision

6 

# The potential contents of a waste stream or group o f waste streams determine which processes can adequ ately

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

should select a nondestructive assay (NDA) techniqu e that suits such waste to ensure adequate measurem ents.

Radiography and visual examination (VE) help both t o confirm and quantify waste components, such as ce llulosics,

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 charact erize a wide

range of heterogeneous waste streams or only a few. A site’s stated limits on the applicability of pr oposed 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 attach ed 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 pr ogram is conveyed to DOE separately

by letter. More information is also on EPA’s Web s ite 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 characteriz e TRU wastes. The EPA inspection team

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

• Identify and quantify the activities of the 10 WIPP -tracked radionuclides ( 241 

# Am, 137 

# Cs,

238 

# Pu, 239 

# Pu, 240 

# Pu, 242 

# Pu, 90 

# Sr, 233 

# U, 234 

# U, and 238 

# U) using a combination of AK and NDA

systems

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

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

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

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

System (WWIS)

Specifically, these systems consisted of the follow ing components:

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

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

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

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

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

tomographic gamma scanner (PTGS), as described in t he 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 li eu 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 s olid 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 characte rization 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 re cords 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 Sheet s; 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 eac h of these items, based on the number and

variety of items each WC process produced, consiste nt 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, we re 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 process es 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 iden tified below:

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

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

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

compliance and, depending on the magnitude of the i ssue, 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 ac cepts 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 inspec tion 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.

# 11



# 6.2 Personnel Contacted

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

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

they are listed in the Table 3, along with their affilia tions 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 traini ng records of these individuals to assess their

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

responsible for characterizing TRU waste and certif ying it as TRU waste were qualified and had

received adequate training to perform their assigne d 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 i nterview the personnel to determine their

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

records is similar to the EPA’s evaluation during e ach 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 s tewardship components. In 1998, LANL

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

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

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

7.2 Inspection Process Overview

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

conducted two follow-up inspections on August 22, 2 006, and March 6, 2007. The purpose of

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

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

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

inspection in 2006. EPA inspectors also verified c hanges 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 analyse s 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 t he site’s compliance with 40 CFR 194.24. The

inspection involved the following steps:

(1) Preparing draft checklists specific to each technic al 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 concern s previously identified by EPA

and/or CBFO and corrective actions

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

to WC activities at LANL-CCP in advance of the insp ection

(4) Interacting with CBFO and LANL-CCP personnel to arr ange inspection logistics

# 13



# (5) Verifying onsite the technical adequacy or qualific ations of WC personnel, procedures,

processes, and equipment by means of interviews, ob servation, and demonstrations, and

recording the results on checklists

(6) Recording all concerns on EPA Inspection Issue Trac king 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; nondestructi ve 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 CF R 194.8 requirements for CH

retrievably-stored solid and debris wastes and newl y-generated OSRP debris wastes.

WC Element Description

As part of the inspection, EPA reviewed the followi ng 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 documen tation

• Characterization of required waste material paramet ers (WMPs) and radionuclides

• AK information assembly and compilation

• AK confirmation and associated discrepancy resoluti on

• Sufficiency of AK characterization results

• Assembly of required information and use of supplem ental information

• AK summary preparation

• Reassignment of waste stream due to AK and discrepa ncy 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 o f 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 a ccepted a variety of procedures and

documents related to AK. Documents were provided a s 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 conjunc tion with specific AK reports, i.e., AK-004,

AK-006, AK-008 and AK-009, most of which were provi ded 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-L ANL-0005-06, Waste Stream

Identification Summary Layers of Confinement, May 1 0, 2006

• LANL-007 NDA memorandum from Steve Shafer to CCP Cen tral 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 Re cords, Transmittal of Solids

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

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

2006

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

LA-RTR2-06-0063, Residual Liquids in Containers, Fe bruary 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 Sy stem (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 b ased on March 15–18 EPA

inspection

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

NC.001, LA-OS-00-01.001, LA-MHD02.001 [LANL –004, -0 08, -007]; note that only

LANL-007 was actually included, May 11, 2006

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

Knowledge Summary Report for Los Alamos National Lab oratory Off-Site Source

Recovery Project Sealed Sources, September 22, 2005

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

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

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

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

Facility, March 9, 2006

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

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

Facility Homogenous Inorganic Non-Cemented Waste, Ma rch 9, 2006

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

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

• DR003, RCRA EPA Hazardous Waste Code Assignment Dis crepancy 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 Repor t, RE: Variation in MT 83,

February 27, 2006

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

• CCP-T-005, Attachment 7, Radionuclides, LA-MHD02.00 1, Mixed 238 

# Pu Heterogeneous

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

• CCP-AK-LANL-007, Revision 2, Los Alamos National Lab oratory 238 

# Pu Contaminated

Mixed Heterogeneous Debris, Waste Stream LA-MHD02.0 01, April 13, 2006

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

238 

# Pu Operations Process Flow Diagrams, May 10, 2006

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

# Pu Contaminated Mixed

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

# 16



# • NDA-AK Memorandum for LANL-004, included in CCP-TP-0 05, Attachment 7,

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

April 29, 2004

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

241 

# Americium, 238 

# Plutonium, and 239 

# Plutonium Originally Contained in DOE Sources

That Were Recovered from a Foreign Country, Februar y 17, 2006

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

241 

# Americium and 238 

# Plutonium Sealed Sources Managed as Waste from DOE Sites,

February 17, 2006

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

241 

# Americium and 238 

# Plutonium Sealed Sources Recovered Domestically Con taining

Radioactive Material Originating from the DOE’s Wea pons 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 Ac ceptable Knowledge Data,

July 20, 2005

• NCR-LANL-0516-06, The Results of NDA Data Does Not Agr ee 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 Inorg anic 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 In dustrial Liquid Waste Treatment

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

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

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

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

• C018, RCRA Evaluation, Steve Schafer, April 14, 200 4

• C028, Memorandum to P. Rogers re: Secondary Radion uclides and Toxic Metals in TA55 TRU Waste, C. Foxx, A. Montoya, NMT-7-WM/EC-97-15 6, TWCP-882, September

5, 1997

• C009, Memorandum to B. Jorgensen re: RCRA Metals i n 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, Novembe r 2003

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

• D001, Process Acceptable Knowledge Report for Speci al 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 Wa ste Management Operations

Safety Analysis Report, TA-50 Radioactive Liquid Wa ste 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 NPDE S Regulated Chemical Species

in the Acid/Rad Lines of the CMR Building (TA-3, SM 29), 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-3-1 6, 65, 130, 208, 316, 477, 550,

1228, 1229, 1522, 1538, 1612, 1730, 1731, 1734, 176 2, 1898, 1944, 1945, 1946, 1949,

2003, 2004, 2005, 2006, 2007, 2008, 2009, 2010, 206 2, 2130, 2143, 2164, Santa Fe

Engineering, Ltd., February 1994 through July 1992

• D050, Decontamination and Size Reduction of Plutoni um 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 F acility, J. Harper and J. Warren,

LA-UR-87-1916, 1987

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

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

1995

• D089, Wastes from Plutonium Conversion and Scrap Re covery 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 Ope rations, H&R Technical

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

• D044, Wastewater Stream Characterization for TA-3-3 9, 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, L td., 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 3-2 9, 154, 503, 1196, 1610, 1614,

1615, Santa Fe Engineering, Ltd., March 1994-Octobe r 1992

# 18



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

Sludges, Ralph M. Parsons Company, August 1993

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

• D006, Environmental Information Document, Radioacti ve 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 Charac terization, J. Whitworth, April 15,

2004

• DR004, Acceptable Knowledge Source Document Discrep ancy Resolution – Debris

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

S817006 (LANL-0822-05), Randy Fitzgerald, May 1, 20 06

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

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

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

Facility Reports, J. Whitworth, D. Moss, December 1 7, 2003

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

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

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

Additional AK-007 Documents: 238 

# Pu Contaminated Mixed Heterogeneous Debris

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

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

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

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

TWCP, October 12, 2000

• C028, Email from SME: Sources of 137 

# Cs, 231 

# Pa and 244 

# Cm 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, 238 

# Pu Waste at TA-55, CBFO, CBFO:Oom: RPD:

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

• C035, Email From Wayne Punjak to Pamela Rogers: 227 

# Ac Drums, W. Punjak, July 10,

2002

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

February 21, 2006

# 19



# • C041, Detailed 238 

# Pu Operations Process Flow Diagrams, J. M. Schoen a nd M. J. Papp,

March 14, 2006

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

25, 2006

• C144, Packaging of 238 

# Pu Waste at TA-55, Interview of Dennis Wulff by Ste ve Shaffer,

November 28, 2006

• C145, Memorandum to CCP Central Records, Re: Evalua tion of LANL 238 

# Pu- 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 Misce llaneous Operations at TA-55, J.

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

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

• D015, Process Acceptable Knowledge Summary Report f or 238 

# Plutonium Operations at

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

• D032, Acceptable Knowledge Information Summary for LANL Transuranic Waste

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

• D033, Acceptable Knowledge Report for Debris Waste Streams Containing 239 

# Pu, B.J.

Humphrey, TWCP-AK-2.1-015, Revision 3, April 10, 20 03

• DR005, Acceptable Knowledge Source Document Discrep ancy Resolution – Container

Numbering Inconsistencies, Randy Fitzgerald, May 4, 2006

• M002, Assembled Tables Taken from Milliwatt Generat or Project Progress Reports,

Various, LA-9170-PR, LA-9672-PR, LA-11217-PR, LA-11 220-PR, LA-11346-PR, LA12236-PR, LA-13258-PR, December 1981 – July 1997

• M025, Waste Profile Form Guidance LANL LIG 404-00-0 3.1, 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 238 

# PuO 2 

# , G. Rinehart, NMT9-SOP-0089, Revision 2,

July 17, 2000

• P016, Inspecting, Packaging, Rejecting, and Remedia ting 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 Ne wly 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 Corn ell College, 320C23, TWCP18917/P2010-0956, April19, 1953, Nuclear Materials a nd Equipment Corporation

• DR001, Discrepancy Resolution, RE: Difference Betwe en 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, J uly 27, 2005

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

2005

• DR007, Discrepancy Resolution, Sources MRPuBe346-34 8, Pu Quantity, J. Whitworth,

June 20, 2005

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

2005

• DR009, Discrepancy Resolution, Discrepancy with Res pect to Sources MRPu228-252,

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

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

August 8, 2005

• C002, Memorandum: Approval to Generate OSRP Waste W ith 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 TW CP-0059 (Multiple

Revisions), last dated July 15, 2002

• C010, Memorandum RE: Evaluating the Radiological Ch aracterization of the OSRP

Waste Stream, LA-05-00-01, A. Feldman and J. Whitwo rth, 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/Spreadshee t 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 S ource Recovery Project Material,

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

• D007, Radiological Characterization of Actinide Sea led 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 238 

# Plutonium, Beryllium Annular Pellets, Monsanto Rese arch

Corporation, TWCP-24599, NPD-STD-051, September, 198 0

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

10, 2005

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

TWCP-23881, October 26, 2004

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

December 12, 1999

• M011, Development of Radionuclide Distribution and Uncertainties in 241 

# Am Sealed

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

• M010, Development of Radionuclide Distribution and Uncertainties in 239 

# Pu Sealed

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

• M009, Calculation-Development of Radionuclide Distr ibution and Uncertainties in 238 

# Pu

Sealed Source Material, J. Whitworth, January 27, 2 004 (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 Wa ste References

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

• C022, Record of Communication – Interview with Robe rt 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, Jenn ifer Griffin/Vivian Valencia,

TWCP-20848, January 6, 2004, Los Alamos National La boratory

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

Tom Krause, TWCP-00464, February14, 1994, Los Alamo s National Laboratory

• D003, Waste Management Site Plan, LANL, December 19 84, K. Balo, J. Warren, LAUR-85-336, December 1984, Los Alamos National Labor atory

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

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

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

TRU Waste Certification Plan, CLS-1, Joel Dahlby, A NC-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 La boratory

# 22



# • D021, CMR Waste Management Plan, W. Atencio, CMR-PL A-001, Revision 0,

December 6, 1994

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

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

• D028, Los Alamos National Laboratory Transuranic Was te Characterization Acceptable

Knowledge Information Summary, LANL-Project 2010, T WCP-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 Laborator y

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

December 19, 2003

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

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

• M017, MSDSs and Other Manufactures Information Vari ous 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 Docu ment, 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 se veral 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 LA 06-HGASLA-018 N/A

S814218 (solids) N/A LARTR2-05-0192 LANDA0257 LA-HG ASLA/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 LANDA007 2 LA06-HSGLA/LS006 N/A

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

PTS/CTS N/A

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

LS085 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 A K information specific to the CH TRU

retrievably-stored debris and solid waste in the fo llowing areas:

(1) Data management was evaluated.

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

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

spreadsheet to track container information that inc ludes 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 expert s (AKEs) for generating AK summaries and

populating the AK tracking spreadsheet are availabl e. 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 A KEs, including ongoing databases that LANL

7 

# Material Types (MTs) are addressed in detail in the Benchmark Env ironmental Corporation Memorandum

dated May 2, 1997 to K. Dziewinska from K. Gruetzma cher. 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 we ll AK and characterization information

coincide. It is important because it provides up-f ront 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 consi stently 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 m ost 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 r esults is important, and EPA recommends

that LANL-CCP develop these criteria

. Using these criteria, CCP then can determine whethe r

reassessment of or changes to the AK information us ing actual NDA measurements or

information from VE and/or RTR activities is necess ary.

Also, LANL-CCP may assess AK accuracy for radionucl ides by comparing the AK and NDAidentified weight percents of the two predominant n uclides. However, the accuracy assessment

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

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

are 238 

# U and 235 

# U, based on weight percent. However, this assignme nt of 238 

# U and 235 

# U to this

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

these few containers are not measured, the radionuc lide 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 prevale nt radionuclides by activity as well as by

mass. Providing notification to EPA that revised A K 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 rel ated 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 rea ssessment of waste if the AK data and related

confirmation consistently indicate discrepancies be tween AK and measurement (NDA) based

radionuclide values. Up to this point, LANL-CCP ha s 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. How ever, 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 f ollow-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 Acceptabl e Knowledge Documentation,

CCP has implemented Trend Code L for identifying NC Rs 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 pr eparation of an AK Discrepancy

Resolution report, an AK Re-Evaluation, and/or an u pdate 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 th e NCR.

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

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

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

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

conducted. CCP does not anticipate any re-evaluati on 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 ev ent an entire waste stream is

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

provide and document training to characterization p ersonnel 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 CC P Trend Report that

document the application of Trend Code L. This inf ormation 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- an d NDA-identified weight percents of the

two predominant radionuclides. However, this asses sment 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 stat es that the most prevalent isotopes

identified by AK are 238 

# U and 235 

# U, based on weight percent. However, the assignmen t of 235 

# U

and 238 

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

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

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

agreement in identifying the two most prevalent rad ionuclides 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 durin g 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 indicate s that it is essentially a complex

radiological mixture, with material input originati ng 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 isot opic data derived through

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

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

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

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

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

what is presented in the AK summary and NDA-AK memor andum.

LA-MHD02.001, 238 

# Pu Contaminated Mixed Heterogeneous Debris (AK-007)

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

applies to this waste stream. The NDA operator exam ines 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 defi nition 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 u sing AK based on information from various

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

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

used or otherwise verified by NDA. Therefore, NDA-A K 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 add ition, traces of other nuclides may be

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

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

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

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

communication is frequent and well documented, as t he 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 onl y AK is used, to drum-by-drum

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

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

appropriate units and inadequate referencing of sup port documents for specific statements

or conclusions.

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

calculations are lacking.

• Tables in all NDA-AK memoranda are not matched again st 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 in dicate 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 communicati on between these two important

technical areas. Specifically, the AK-NDA memorandu m 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 per sonnel 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 d etail how NDA personnel use AK to

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

T2 change).

During the inspection, the EPA inspection team note d inconsistencies with the AK- NDA

memoranda. This was discussed with LANL-CCP AK personnel and E PA 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 t o appropriate units and inadequate

referencing of support documents for specific state ments 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. Sp ecifically, 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-i dentified

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

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

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

that EPA’s issues and/or concerns are appropriatelyidentified and rectified. When such AKNDA memoranda are written they document AK-NDA commun ication 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 o f improvement, inconsistencies should be

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

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

convinced that when AK NDA communication occurs thro ugh 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 proc edure used by CCP. EPA evaluated this

procedure and found it to be adequate. Providing n otification 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 indicat ed 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 con tainer basis. The AKE indicated that the

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

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

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

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

LANL-CCP will not use load management for AK-004, A K-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 Criteri a for the Waste Isolation Pilot Plant (CH-WAC) , Revision 3, dated April 25, 2005, and notify

EPA. Implementation of load management for waste s treams 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 include d in the inspection with respect to whether

each was appropriately described and defined. AK-0 04, homogenous inorganic solids, had been

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

# Pu contaminated

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

which CCP combined because there was an approximate ly 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 238 

# Pu debris waste; if 239 

# Pu was detected in drums

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

When asked whether the 239 

# Pu containers could be placed in AK-006 in the May 2006

inspection, site representatives indicated that thi s 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 Permi t , 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 reeva luated these two waste streams and

determined that AK-006 and AK-007 belonged to a sin gle waste stream.

LANL-CCP representatives stated that 238 

# Pu bearing waste was not intentionally generated to

create a unique waste stream. Evidence they examin ed showed that wastes from both the 238 

# Pu

and 239 

# Pu lines, which were separate process lines, were c ommingled at packaging without

regard to the original process origin. LANL-CCP re presentatives stated that post generation,

238 

# Pu-bearing containers were singled out as a separat e 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-C CP 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 f rom various industries (e.g., universities,

health care and pharmaceuticals, oil exploration), are expected to have different pedigree hence,

different radiological contents. As additional sea led sources are recovered from various

commercial and industrial applications, as CH TRU d ebris waste destined for WIPP disposal,

they would be characterized using the peer-reviewed manufacturers’ information specific to the

radiological contents of each sealed source. Seale d sources recovered from different commercial

or industrial applications but with similar pedigre e 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 approve d or new waste stream is of interest to EPA

due to their potential for having different radiolo gical contents. Therefore, EPA has assigned a

T1 tier when new OSRP wastes are added to the AK Su mmaries since the baseline inspection

(CCP-AK-008). Also, EPA has assigned a T2 tier req uiring notification, when characterization

information in the AK Summaries for the approved wa ste streams (as part of the baseline

inspection and T1 change evaluation) has been revis ed to accurately account for the changes in

radiological contents.

In other words, because waste stream combination ca n greatly impact the radionuclide content,

any future combination of different waste streams t hat were distinct prior to the EPA baseline

inspection and are suitable candidates for combinin g together as a single waste stream will be

subject to EPA approval as a Tier 2 change. (See T able 1, where this is included as a T2

change). Also, this change was made because AK dat a and related confirmation consistently

indicated discrepancies that lead to reevaluation o f the waste streams as defined. As indicated in

EPA Inspection Issue No. LANL-CCP-AK-06-001CR discus sed in (3), above, LANL-CCP

agreed to prepare a memorandum to document this eve nt 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 239 

# Pu and 241 

# Am sealed sources as defense waste makes these wast es

eligible for disposal at the WIPP. EPA does not kn ow 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 so urces to adequately justify the waste

stream as defined. Providing AK summaries that inc lude 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 revis ed 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 addre ss whether RTR using QuickScan was

being performed. If so, LANL-CCP should include Qu ickScan 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)), an d Randy Fitzgerald (site project quality

assurance officer (SPQAO)). These individuals had performed required reading pertinent to

specific procedures and AK summaries associated wit h the site, as well as applicable WAP and

WAC requirements and discrepancy resolution, and no nconformance 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 par ticipation in internal audits. While the

individuals were clearly proficient as evidenced th rough 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 s everal containers—S850312 (solids),

S870375 (AK-007), S814218 (solids), S834538 ( 238 

# Pu debris), S817225 (solids), 54631 MT 83,

55700 238 

# Pu, OSR LA00000061432, and OSR LA00000062374. Info rmation for evaluated

containers was traceable from original LANL radioac tive solid waste disposal forms or similar

forms through the current AK spreadsheet to BDRs ge nerated through WIPP characterization

and subsequent tracking in PTS/CTS. EPA did not as sess input into the WWIS as part of AK.

WSPFs and related documents were examined. LANL-CC P often uses Change Notices to

modify WSPFs and these modifications can significan tly alter a waste stream. Accordingly,

EPA requires notification regarding the completion of all change notices and related

documentation including modified WSPFs, full AK Sum maries and AK-NDA communication

documentation for each waste stream modified as a T 2 change. (See Table 1, where this is

included as a T2 change). For all new waste stream s EPA requires the following documentation:

• Complete data packages for every waste stream, incl uding 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 th e AK record were assessed.

CCP-TP-005, Attachment 3, presents AK data limitati ons. This form addresses each source

document, and therefore each source document includ es a data limitation assessment.

LANL-CCP adequately assembles AK information and ke ys these data to specific AK

requirements (CCP-TP-005, Attachments 1 and 4). At tachments 1 and 4 to CCP-TP-005 act as

AK “roadmaps” in that they present specific support ing 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 f or EPA’s examination. The discrepancy

resolutions examined were comprehensive and complet e (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 doe s not comport with other

information with respect to sealed source radionucl ide 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 ( 239 

# Pu).

(12) Defense origin of waste was examined.

Each of the four AK summaries examined by EPA prese nted defense waste information. Up to

this point, the shippable portion of the AK-008 OSR P waste stream was limited to 239 

# Pu-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 defen se waste determinations for additional

waste streams. The waste streams obtaining a defen se waste determination were as follows:

• 241 

# Am and 238 

# Pu sealed sources containing radioactive material t hat were recovered

domestically and were stated to have originated fro m the DOE weapons program

• 241 

# Am, 238 

# Pu, and 239 

# Pu that were stated to be of DOE origin in sources recovered from a

foreign country

• 241 

# Am and 238 

# Pu sealed sources that were managed as waste from D OE 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 [fr om] activation of decay products of

defense materials production, resulting from materi als 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 c onsidered to be defense waste because it was

created as part of “defense nuclear material byprod uct 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 rel ies 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 r elieve onsite storage and capacity issues at

LANL.

(13) AK information pertaining to radiological cha racteristics of waste was examined.

EPA examined how CCP characterizes and quantifies r adionuclides for each of the waste

streams to better understand what is obtained throu gh AK and how this information is used to

determine the radiological components of the waste.

• LA-MIN03-NC.001, TA-50 Homogenous Inorganic Solids No n-Cemented Waste,

AK-004: Default isotopics are not available for this wast e stream due to the manner in

which the stream was created. Therefore, compariso n of measured and AK values to

confirm plutonium isotopes cannot be performed. Si milarly, while uranium information

was tracked in waste from an AK perspective since 1 985, the use of “valid AK” to

confirm measurements is not appropriate. CCP ident ified 235 

# U and 239 

# Pu as the two

prevalent isotopes by weight, but CCP did not indic ate a specific point at which this

assessment would be reconsidered to evaluate this i nitial determination. Determination

of predominant radionuclides by activity rather tha n weight is more meaningful for the

cumulative tracking of the total activity of each o f the 10 WIPP-tracking radionuclides

measured in the waste.

• LA-MHD02.001, 238 

# Pu Contaminated Mixed Heterogeneous Debris Waste, A K-007: At

the time of the inspection, AK defined this waste s tream as consisting entirely of MT 83,

so the waste’s isotopic ratios are well defined. B ecause NDA personnel know that this

waste stream consists of 238 

# Pu, they use these values when determining the spec ific

plutonium contents. It was assumed, therefore, tha t various measured values would

reflect the associated MT 83 ratios. If the measur ed 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 s tream. Note that post inspection

LANL-CCP combined this waste stream with AK-007 bec ause an occasional 239 

# Pubearing drum was found in the 238 

# Pu stream, and because CCP believed that the two

waste streams were not distinctly and intentionally generated. With respect to uranium,

little 233 

# U 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 sour ces. For each source, site personnel

assess NMMSS, source certificates, fabrication/shipp ing records, U.S. Nuclear

Regulatory Commission registry information, and oth er data, to determine the

radionuclide content of waste at the time of fabric ation, which is then corrected for

radiological decay and/or ingrowth, as appropriate. Following approval of the defense

determinations for 241 

# Pu and 241 

# Am, 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 t he initial composition assigned by the

manufacturer. EPA has not examined these sources, nor has the site posed a

# 33



# characterization methodology for these sources. Wh en these sources are brought on line,

an updated AK summary, a revised WSPF and radiologi cal 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 ( 242 

# Pu) mixtures are also important to identify.

Sometimes the AKE is required to evaluate informati on 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 pe rcent. 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 241 

# Pu was

determined by AK as opposed to by calculation based on measured 241 

# Am values, as

indicated in the WAC; 241 

# Pu is not a TRU radionuclide and is not one of the 10 WIPPtracked radionuclides. The Multi-Group Analysis (M GA) or Fixed-Energy Response

Function Analysis with Multiple Efficiencies (FRAM) routines calculate 242 

# Pu 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 242 

# Pu. With

respect to uranium, AK can help to some degree in d etermining the 234 

# U content on a

drum-by-drum basis, and a scaling factor is used to determine the 234 

# U content based on

the container’s observed 235 

# U and/or 238 

# U content. The AK memorandum states that 234 

# U

is quantified by calculation, and it provides the f ormula and assumptions for the HENCs

(LANL HNEC #1 and LANL HENC #2, see Section 8.2) base d on various factors,

including AK identification of drums containing MT 83, etc.

The EPA inspectors observed inconsistency in radion uclide presentation and reporting. For

example, it is important to distinguish radionuclid es that are “expected” because this directly

impacts how site personnel enter the information fo r these radionuclides in the WWIS.

Specifically, 233 

# U is expected in waste stream LANL-007, and EPA rec ommends 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 prev ious 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 o riginal concern

identified during the April 2005 LANL-CCP inspectio n. 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 complian ce. For example, Section B4-3e of

the WAP states, “Accuracy is the degree of agreemen t between an observed sample result

and the true value. The percentage of waste contai ners 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 report ed 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 EP A 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 beca use it is unlikely that every drum would

require reassignment. EPA recommends that in the f uture, 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 w as assessed.

AK summaries include general information pertaining to the WMP content of the streams. CCP

sometimes calculates WMP content based on individua l drum data, if available.

LANL-CCP elected to combine wastes distinguished as combustible and noncombustible debris

(e.g., AK-007). Although LANL continues to differe ntiate 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 sepa rate 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 characteri zation 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 t o ensure that the uncertainty associated with

AK-only WMP assignment is minimized.

AK documents also address some prohibited items, bu t do not provide specific information as to

their specific location or other aspects of those w astes. 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 o ut to be important, as liquid was identified in

the wastes at the bottom and in containers within d rums, not just at the top or along the sides of

the containers as might be anticipated through cond ensation/dewatering. Future AK discussions

would benefit from more precise statements about th e 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 A cceptable Knowledge Summary

Report for Los Alamos National Laboratory, TA-50- R adioactive Liquid Waste

Treatment Facility, Homogenous Inorganic Solids, No n-Cemented Waste, March 9, 2006

# 35



# • CCP-AK-LANL-007, Revision 2, Los Alamos National Lab oratory Pu-238

Contaminated Mixed Heterogeneous Debris, Waste Stre am LA-MHD02.001, April 13,

2006

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

Knowledge Summary Report for Los Alamos National Lab oratory Off-Site Source

Recovery Project Sealed Sources, September 22, 2005

• CCP-AK-LANL-009, Central Characterization Project A cceptable 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 d ata 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 modificat ion 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 i n an appropriate location(s)

• Ensure that all discussion of 10 WIPP-tracked radio nuclides 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 ensu re 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 fabr ication. AK-007 includes several

different current and historic 238 

# Pu waste generation processes, but it is hard to id entify

which of the processes are active versus those that are not, in large part because the

language pertaining to heat source fabrication is c onfusing.

• Always distinguish “expected” versus “suspected” ra dionuclides in radiological

discussions; it is important to identify “expected” radionuclides as this impacts how site

personnel enter radionuclide data into the WWIS (e. g., 233 

# U as presented in AK-007).

This baseline inspection addressed retrievably-stor ed S3000 solid and S5000 debris wastes, as

well as newly-generated S5000 debris wastes. The a ddition 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 241 

# Am and 238 

# Pu 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 re spect to radionuclide content,

predominant nuclides, etc. Similarly, LANL-CCP mus t update or create a new WSPF to reflect

this change which requires EPA approval. Because E PA has not assessed the radiological

characterization for new sealed sources, examinatio n 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 i s 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 findin gs related to AK and identified the concerns

that are discussed above. Copies of the EPA Inspec tion Issue Tracking Forms on which these

concerns were documented are provided in Attachment s C.1 through C.3 of this report. EPA

considers all concerns to have been adequately addr essed and there are no open findings or

concerns related to AK resulting from this inspecti on.

Baseline Approval

EPA is approving the AK and load management systems evaluated during this baseline

inspection for CH retrievably-stored debris and sol id wastes and newly-generated debris wastes

from the OSRP.

AK Tiers

Based on the inspection and the results discussed a bove, EPA is assigning the following tiers:

T1 AK changes will require EPA review and approval prior to impl ementation and will apply to

any new waste category not evaluated during the bas eline 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 informati on, choose to conduct a desktop review,

and/or confer with LANL-CCP personnel. Upon AK eva luation 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 d escription of the changes. Notification to

EPA must be made upon completion of updates to or s ubstantive 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 rela tionship to AK)

• AK-NDA Memoranda

• Site procedures requiring CBFO approval

• AK Summary CCP-AK-008, if changed since the baselin e inspection and/or following

the addition of new sealed sources

• Completion of AK Accuracy Reports

• Change Notices used to modify and update WSPFs, inc luding additions to waste

stream(s) within an approved waste category

The above changes to the WC activities from the dat e of the baseline inspection must be reported

to and approved by EPA according to Table 1. Follo wing EPA approval, LANL-CCP will notify

EPA of T2 changes along with a summary of each T2 c hange at the end of each fiscal year

quarter. EPA will evaluate the information and com municate with LANL-CCP as to whether

EPA needs additional information for further evalua tion, whether the changes raise any concerns

requiring LANL-CCP response, or whether LANL-CCP ca n continue to implement the changes.

Consistent with EPA’s authority under 194.24(h), EP A may request information relative to these

changes if EPA deems the information is necessary t o ensure continued compliance with EPA

regulations.

8.2 Nondestructive Assay

WC Element Description

EPA inspected three NDA systems that are used as par t 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 equival ent 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. Not e 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 u nchanged since EPA Inspection No.

LANL-CCP-04.05-8, conducted in April 2005, and repo rted 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 procedur es

# 38



# • Knowledge and understanding of the personnel involv ed in the NDA program

Additionally, EPA reviewed the performance of the H ENC #2 for the time period between the

initial inspection in May 2006 and March 6, 2007, a t the follow-up inspection, including the

replicate measurements in accordance with the EPA R eplicate 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 identi fy the objective evidence that EPA examined

for LANL HENC #1, LANL HENC #2, and the PTGS, respect ively. The following documents

were among those the EPA inspection team examined t o assess whether NDA was adequately

performed relative to all three measurement systems :

• CCP-PO-002, Revision 11, CCP Waste Certification Pl an, February 24, 2005

• CCP-TP-063, Revision 7, CCP Operating the High-Effi ciency Neutron Counter Using

NDA 2000, March 31, 2006

• CCP-TP-064, Revision 4, CCP Calibrating the High-Ef ficiency Neutron Counter Using

NDA 2000, March 31, 2006

• CCP-TP-103, Revision 6, CCP Data Reviewing, Validat ing and Reporting Procedure for

the High-Efficiency Neutron Counter Using NDA 2000, February 28, 2006

• CCP-TP-123, Revision 2, CCP Calibrating the Tomogra phic Gamma Scanning System,

September 21, 2005

• CCP-TP-124, Revision 2, CCP Determining Isotopic Ra tios 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 Meth od, July 5, 2005

• CCP-TP-126, Revision 4, CCP Waste Assay Using the P ortable Tomographic Gamma

Scanner, September 8, 2005

• Canberra Report: Energy Calibration and Verificatio n Report, Revision 0, S. Stanfield

and B. Gillespie, October 2005 (HENC #1)

• Canberra Report: Energy Calibration and Verificatio n Report, Revision 1, S. Stanfield

and J. Wachter, May 2006 (HENC #1)

• MCS HENC#2 Calibration Verification, Revision 0, Sea n Stanfield, July 21, 2006

• MCS HENC#2 Calibration Verification, Revision 0, Sea n Stanfield, September 12, 2006

• LANL HENC (HENC#2) Calibration Verification, Revision 0, Sean Stanfield,

December 14, 2006

• MCS HENC#2 Calibration Verification, Revision 0, She ri Chambers, January 25, 2007

• MCS HENC#2 Calibration Verification, Revision 0, She ri Chambers, January 29, 2007

• MCS HENC#2 Calibration Verification, Revision 0, She ri Chambers, January 29, 2007

# 39



# • HENC#2 Calibration Verification, Revision 0, Sheri C hambers, March 5, 2007

• MCS-HENC1-NDA-1001, Revision 2, Calibration Report fo r the MCS HENC #1

Including Passive Neutron Calibration Verification a nd Gamma Spectrometer Calibration

and Conformation, April 28, 2004

• MCS-HENC1-NDA-1002, Revision 2, Supplemental Calibrat ion Report for the MCS

HENC #1 Including Passive Neutron and Gamma Spectrome ter Calibration and

Conformation, April 4, 2005

• MCS-HENC1-NDA-1002, Revision 3, Supplemental Calibrat ion Report for the MCS

HENC #1 Including Passive Neutron and Gamma Spectrome ter Calibration and

Conformation, April 13, 2005

• MCS-HENC1-NDA-1002, Revision 4, Supplemental Calibrat ion Report for the MCS

HENC #1 Including Passive Neutron and Gamma Spectrome ter 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 a nd Conformation, March 28,

2006

• CI-HENC-TMU-101, Revision 1, Total Measurement Uncer tainty for the MCS HENC #1

with Integral Gamma Spectrometer, March 23, 2005

• LANL-HENC2-TMU-101, Revision 0, Total Measurement Un certainty for the HENC #2

with Integral Gamma Spectrometer, April 10, 2006

• MCS HENC Calibration Verification, Sean Stanfield: S eptember 14, 2005; April 22,

2006; April 30, 2006; and Revision 1, May 3, 2006

• RRES-CH:03-058, Lower Limit of Detection for the LA NL Portable Tomographic

Gamma Scanner (PTGS), March 15, 2005

• NWIS-TP: 2005-01102, Revision to TWCP-23398, Total M easurement Uncertainty for

the Portable Tomographic Gamma Scanner (PTGS), Marc h 30, 2005

• Weekly Interfering Matrix Check Results for the LAN L 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 (HE NC #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 H ENC #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 incorp orates two measurement modalities—a passive

neutron counter and an integral gamma-ray spectrome ter. The passive neutron counter uses

multiple 3 

# He proportional counters, along with a multiplicity shift register and an external 252 

# Cf

source for the Add-a-Source matrix correction funct ion, to determine the spontaneously

fissioning mass content of waste containers, referr ed to as the 240 

# Pu Effective 

# ( 240 

# Pu Eff 

# ). The 240 

# Pu Eff



# is defined as the amount of 240 

# Pu 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 240 

# Pu Eff 

# by applying the ratios of other TRU or target

radionuclides, including all spontaneously fissioni ng radionuclides (i.e., 235 

# U). In LANL

HENC #1, these (isotopic) ratios are routinely deter mined by Multi Group Analysis (MGA) of

the gamma-ray spectrum based on measurement data ob tained with the integral gamma-ray

spectrometer, as discussed below.

The integral gamma-ray spectrometer is a high-purit y germanium (HPGe) detector used to

acquire the gamma-ray spectrum to be analyzed by MG A and to provide direct quantification of

a number of radionuclides, including 238 

# Pu, 239 

# Pu, 241 

# Pu, 241 

# Am, 233 

# U, 235 

# U, 238 

# U, 137 

# Cs, and

237 

# Np. 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 duri ng this inspection or physical modifications

to the HENC#1 described above is a T1 change (see Ta ble 1 where this is included as a T1

change).

(1-2) The passive neutron and gamma calibrations o f 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 Inspectio n 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 Ca libration and Confirmation , Revision 2,

dated April 4, 2005, addressed changes to gamma eff iciency calibration that were indicated by

# 41



# the system’s performance in the CBFO-sponsored NDA p erformance demonstration program

(PDP). The main change was the removal of the slud ge 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 fro m higher concentrations of 241 

# Am normally

associated with aged plutonium. The calibration wa s 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 plu tonium oxide (PuO 2 

# ) sources totaling

approximately 0.599, 15.0, and 160 grams of total p lutonium in a non-interfering matrix. The

upper end of the passive neutron’s original calibra ted range, which was the lower limit of

detection (LLD) to 100 g plutonium (6.55 g 240 

# Pu Eff 

# ), was extended to 177 g plutonium total

(12.159 g 240 

# Pu Eff



# ) for both solid and debris wastes. LANL-CCP perso nnel 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 239 

# Pu and 238 

# Pu, respectively. Both WG Pu and HS

Pu are correlated to a variety of MTs that were dis cussed in Section 8.1 of this report. The

passive neutron calibration for LANL HENC # 1 was te chnically adequate and appropriately

documented.

The integral gamma-ray spectrometer was originally calibrated in March 2004 using six

241 

# Am/ 152 

# Eu line sources in five surrogate waste drums with waste matrix densities of 0.018,

0.49, 0.69, 1.24, and 1.64 g/cm 3 

# . For each of the surrogate waste drums, the effic iency of the

detector was measured as a function of gamma-ray en ergy between 59 and 1,408 keV. Note that

the energy calibration for LANL HENC #1 differs slig htly from what was established for LANL

HENC #2, discussed later in this section. The calib ration of the integral gamma-ray

spectrometer was confirmed using the same WG Pu sou rces used to verify the passive neutron

calibration. This is still the calibration of reco rd, 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 calibra tion in the strict sense, although the

calibration/qualification summary in the supplement al calibration report states an operating range

of LLD to 175 g plutonium, which is more representa tive 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 appropriat ely documented.

The extension of or changes to the stated calibrati on 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 th e HENC#1, and to the site procedures that

govern its use that require CBFO approval are T2 ch anges (see Table 1 that includes these as T2

changes).

(1-3) The total measurement uncertainty (TMU) of a ssays performed on LANL HENC #1 had

been determined and documented.

CI-HENC-TMU-101, Total Measurement Uncertainty for the MCS HENC #1 w ith Integral

Gamma Spectrometer , Revision 2, dated April 28, 2004, documents the o riginal 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 i dentified issue related to drum fill height that

CI-HENC-TMU-101 (Revision 1, dated March 23, 2005) a lso documented. Among the

components of uncertainty included in the TMU deter mination 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, chemi cal 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 integra l gamma-ray spectrometer, the TMU

evaluation included counting statistics, background fluctuations, interferences from other

gamma-emitting radionuclides, calibration uncertain ties, matrix non-homogeneities, non-uniform

source distributions, isotopic measurement uncertai nties, and effects from self-absorption. The

TMU determination for the gamma component of this s ystem was unchanged since the last EPA

inspection in April 2005. LANL-CCP adequately dete rmined and documented the TMU for both

operational modes for LANL HENC #1.

(1-4) The LLD, including the minimum detectable co ncentration (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, yiel ds a measured value greater than

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

value which measurements of the background will exc eed 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 r eason, 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 reporte d LLD for that measurement were to be

reported and were used in calculations of derived q uantities, such as total TRU alpha activity and

TRU alpha activity concentration. LANL-HENC1-NDA-100 2, Revision 2, included the average

LLD for each of the WIPP-tracked radionuclides esti mated for two surrogate drums containing

38.3 kg of debris waste and 227 kg of homogenous wa ste. 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 test ing of LANL HENC #1.

The purpose of the replicate testing during this in spection 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 rad ionuclides ( 241 

# Am, 137 

# Cs, 238 

# Pu, 239 

# Pu, 240 

# Pu,

242 

# Pu, 90 

# Sr, 233 

# U, 234 

# U, and 238 

# U) and the TRU alpha concentration. This was accom plished by

reassaying drums previously characterized on the sa me system or instrument in order to evaluate

its ability to do the following:

• Produce results consistent with the reported TMU (a s judged by comparing the sample

standard deviation for a number of replicate measur ements 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 me asurement(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 li st 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 squa red (χ 2 

# ) 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 result s of the statistical analysis.

For all three drums the t

test showed no statistically significant differenc es between the original

measurement assay values and the average of the fiv e replicate measurements for all measured

parameters. The χ 2 

# tests for these same three containers showed a hig hly significant flag only for

242 

# Pu. This indicates that the variances in the repli cate measurements for 242 

# Pu were greater than

the reported uncertainties for all values relative to the limits of the test. For all three container s

this appears to be an artifact of the statistical e valuation. Specifically, the spread of values is s o

tight that the test effectively places an inordinat e emphasis on small variations, resulting in a

penalty for high precision. EPA has previously obs erved and reported this phenomenon during

inspections at other TRU WC sites. An evaluation o f the 242 

# Pu data outside of the χ 2 

# test

indicates that there is no real measurement issue. Although the software identified these

variances as “highly significant,” this does not in dicate a measurement issue that warrants

additional attention at this time. There is no tec hnical issue relative to the highly significant

flags for the 242 

# Pu values on the χ 2 

# test for the LANL HENC #1 replicates.

The t test for all three containers showed only statisti cally significant differences between the

original measurement assay values and the average o f 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 H ENC #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 passiv e neutron counter uses 113 3 

# He proportional

counters arranged in a 4 Β geometry, in conjunction with a multiplicity shift register and an

external 252 

# Cf source for the Add-a-Source matrix correction. This combination quantifies the

spontaneously fissioning content of waste container s, referred to as the 240 

# Pu Eff 

# , described above

As was observed for the LANL HENC#1, the quantities of individual radionuclides are related to

the 240 

# Pu Eff



# by applying the ratios of other TRU or target radi onuclides, including all

spontaneously fissioning radionuclides (i.e., 235 

# U). In the LANL HENC #2, the isotopic ratios

are routinely determined by MGA of the gamma-ray sp ectrum based on data obtained with the

integral gamma-ray spectrometer, as discussed below

.

The integral gamma-ray spectrometer is an HPGe dete ctor used to acquire the gamma-ray

spectrum to be analyzed by MGA and to provide direc t quantification of a number of

radionuclides, including 238 

# Pu, 239 

# Pu, 241 

# Pu, 241 

# Am, 233 

# U, 235 

# U, 238 

# U, 137 

# Cs and 237 

# Np. The

spectrometer used a multicurve efficiency calibrati on based on the waste density to correct for

photon attenuation inside the drum.

The use of a different NDA system not observed duri ng this inspection or physical modifications

to the HENC#2 described above is a T1 change (see Ta ble 1 where this is included as a T1

change).

Changes to the software or operating range(s) of th e HENC#2, and to the site procedures that

govern its use that require CBFO approval are T2 ch anges (see Table 1 that includes these as T2

changes).

(2-2) The passive neutron and gamma calibrations o f the LANL HENC #2 had been performed

and confirmed as required.

The original calibration of the LANL HENC #2 was per formed in 1999; however, the system

was recalibrated at LANL for use in the WIPP progra m 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 appl icable to S3000 homogenous solid wastes and

S5000 debris wastes packaged in 55-gallon drums, wi th or without polyethylene liners. The

calibration range of the passive neutron system is stated as the LLD to 16.29g 240 

# Pu Eff 

# , and

HENC#2-NDA-1002 includes documentation of a calibrati on confirmation using predominantly

238 

# Pu material.

The integral gamma-ray spectrometer was originally calibrated in February 2006 using six

241 

# Am/ 152 

# Eu line sources in five surrogate waste drums with waste matrix densities of 0.018,

0.49, 0.69, 1.24, and 1.64 g/cm 3 

# . For each of the surrogate waste drums, the effic iency of the

detector was measured as a function of gamma-ray en ergy 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 fun ctional range of the gamma component’s

operational range for LANL HENC #2 is slightly great er than 100 keV due to attenuation of the

Sn/Cu filters that were installed to prevent excess ive dead-time corrections from high

# 45



# concentrations of 241 

# Am. The calibration of the integral gamma-ray spec trometer was confirmed

using the same WG Pu sources that were used to veri fy 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 gam ma operating range of LLD to 217 g

total plutonium, which is limited by dead time. Li ke other gamma systems, there is no strict

upper mass limit, provided all operational paramete rs, such as dead time and resolution (peak

shape), are met. EPA found that the passive neutro n and gamma calibrations for LANL HENC

#2 were technically adequate and appropriately docu mented.

The extension of or changes to the stated calibrati on 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 ha d 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 o riginal determination of

the TMU for LANL HENC #2. Among the components of u ncertainty included in the TMU

determination for the passive neutron measurement w ere contributions from the calibration

uncertainty; calibration counting statistics; matri x and source distribution effects; background

effects for high atomic number waste matrices; and uncertainties due to isotopics, chemical

forms, and neutron multiplication. For the integra l gamma-ray spectrometer, the TMU

evaluation included counting statistics, background fluctuations, interferences from other

gamma-emitting radionuclides, calibration uncertain ties, matrix non-homogeneities, non-uniform

source distributions, isotopic measurement uncertai nties, and effects from self-absorption. The

approaches to TMU determination for the passive neu tron 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 techni cally 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, yiel ds a measured value greater than

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

value which measurements of the background will exc eed 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 r eason, 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 th e reported LLD for that measurement were

to be reported and were used in calculations of der ived 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 estimate d 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 doc umented.

(2-5) EPA evaluated the performance of the LANL HE NC #2 for the time period between May

25, 2006, and March 6, 2007.

There were 7calibration verifications performed bet ween May 25, 2006, and March 6, 2007, and

each was documented. The verifications were requir ed for the typical types of measurement

issues expected during routine operations, e.g., ex ceeding a 3 σ Control Limit on the daily 152 

# Eu

source check. The complete list of the documentati on for each verification that was reviewed on

March 6, 2007 is provided above. All calibration v erifications were acceptable. The dates on

which the verifications were documented 8 

# and a summary of each are as provided below:

• July 21, 2006 – 3 σ failure on the 152 

# Eu 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) o n the

152 

# Eu 122 keV line

• January 25, 2007 – computer failure

• January 28, 2007 – 3 σ failure on the 152 

# Eu source

• January 29, 2007 – 3 σ failure on the 152 

# Eu source

• March 5, 2007 – 3 σ failure on the FWHM on the 152 

# Eu 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 document ed appropriately. The EPA inspection

team observed the assay of the Weekly Interfering M atrix using PDP Matrix Drum No. 003 that

was loaded with the RANT 50-1, RANT 50-2, RANT 50-3 an d 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 o perational 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 HE NC #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 a t the time of this inspection. A sample of this

label was provided and the EPA inspection team obse rved actual waste drums that had been

assayed on the LANL HENC #2.

Following the May 2006 inspection, LANL-CCP initiat ed a Corrective Action Plan (CAP) in

response to the CBFO Corrective Action Report CAR-L ANL-0007-06, Revision 0 related to a

8 

# The actual date of the measurement event that prom pted the calibration verification is not necessaril y the same

as the date of the calibration verification report. The actual date of the measurement event is docum ented in the

calibration report in all cases.

# 47



# measurement failure during Cycle 13A of the CBFO sp onsored NDA Performance

Demonstration Program (PDP). Specifically, the LAN L HENC #1, LANL HENC #2, and the

PTGS had failed the accuracy criterion on the NDA PD P 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 a llowed the NDA systems to continue the

assay until sufficient counts were obtained irrespe ctive of the measurement time as opposed to

assaying for a preset time. This approach was succ essful for both LANL HENC units but was

not successful for the PTGS. As of January 2007, t he following CBFO approvals are in effect:

• LANL HENC #1 – approved for WG Pu and HS Pu in all m atrices

• LANL HENC #2 – approved for WG Pu and HS Pu in all m atrices

• 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 CA P.

(2-6) EPA coordinated and evaluated replicate test ing of LANL HENC #2.

The purpose of the replicate testing during this in spection 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 rad ionuclides ( 241 

# Am, 137 

# Cs, 238 

# Pu, 239 

# Pu, 240 

# Pu,

242 

# Pu, 90 

# Sr, 233 

# U, 234 

# U, and 238 

# U) 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 (a s judged by comparing the sample

standard deviation for a number of replicate measur ements 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 me asurement(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 li st of drums previously assayed on LANL

HENC #2 that was provided by LANL-CCP. The drums se lected were identified as Containers

555700, 52277, and 53991. At EPA’s request, site p ersonnel 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 χ 2 

# test for all measured parameters for all three con tainers showed that the observed

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

all values within the statistical limits of the tes t.

For Containers 55700 and 52277, the t test showed no statistically significant differenc es

between the original measurement assay values and t he average of the five replicate

# 48



# measurements for all measured parameters. For Cont ainer 53991, the t test showed a “highly

significant” flag for only 242 

# Pu, indicating that the variances in the replicate measurements for

242 

# Pu 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 or iginal measurement differs slightly from the

mean of the five replicates, although the differenc e is minimal. There are several possible

reasons for this—actual changes in the physical con figuration of the drums’ contents due to

movement or settling; fluctuations in the measureme nt system’s background; or actual changes

in the measurement system, the very aspect that thi s test is designed to query. Although the

software identified these variances as “highly sign ificant,” this does not necessarily indicate a

measurement issue that warrants additional attentio n at this time. EPA may, however, request

additional replicate analyses for the LANL HENC #2 a t a later date. There is no technical issue

at this time relative to the highly significant fla gs for the 242 

# Pu values on the χ 2 

# 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 fo r 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 p resented below.

Container No.61209, showed no statistically differen ces between the original measurement assay

values and the average of the five replicate measur ements for all measured parameters using the t

test and a “highly significant” flag for 239 

# Pu, 240 

# Pu, 242 

# Pu and 241 

# Am using the χ 2 

# test. Container

No. 61209 was a very low signal drum with a total TR U alpha concentration of approximately

230 nCi/g, and the original measurement differs sli ghtly from the mean of the five replicates,

although the difference is minimal. There are seve ral possible reasons for this:

• Changes in the physical configuration of a drum’s c ontents due to settling or shifting

resulting from drum movement/staging or related was te management activities on site

over the time period between the initial and replic ate 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 a ssociated with nuclear transitions can

produce effects that appear large using these stati stical metrics. Irrespective of the assignment of

a “highly significant” flag to these differences, t heir 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 techn ical issue at this time relative to the “highly

significant” flags for the 239 

# Pu, 240 

# Pu, 242 

# Pu and 241 

# Am values using the χ 2 

# test.

# 49



# Container No. S817309 showed a “highly significant” flag for a single radionuclide, 242 

# Pu, using

the t test and a “highly significant” flag for 238 

# Pu, 240 

# Pu, 242 

# Pu and 241 

# Am as well as 137 

# Cs and 90 

# Sr

using the χ

2 

# test. The magnitude of the differences for the χ 2 

# test are small, and the 238 

# Pu values

for the original measurement and the mean of the fi ve replicates are virtually identical, i.e.,

1.53E-01 and 1.51E-01. With the exception of 242 

# Pu, the differences between the original and

mean of the five replicates for the other TRU radio nuclides are similarly small and do not

represent a technical concern regarding precision o f the LANL HENC #2. Regarding the 137 

# Cs

and 90 

# Sr results, although the χ 2 

# test identified these results as “highly significa nt”, this does not

necessarily represent a measurement concern for the LANL HENC #2. It is important to note

that 137 

# Cs is quantified based on a disproportionate respon se at the 662 keV line of 241 

# Am

relative to that peak’s 722 keV line, which is then attributed to 137 

# Cs based on predetermined

statistical spectral criteria. This results in a h ighly variable quantity as a function of the

technique used to indirectly determine the quantity of 137 

# Cs independent of the true

measurement-related attributes of the photon measur ement system, i.e., amplifier gain or detector

reliability. Examination of the results reveals th at the replicate measurements were all very close

with a small standard deviation. Because the 137 

# Cs value is in turn used to derive the container’s

90 

# Sr content by applying a scaling factor, any statis tical anomaly for 137 

# Cs will by definition also

apply to 90 

# Sr.

There are no technical issues relative to the addit ional replicate testing for the LANL HENC #2.

Technical Evaluation: PTGS

(3-1) The design and operational history of the PT GS was assessed.

EPA found that the PTGS, which is located in Buildi ng 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 th e amount of 239 

# Pu in a 55-gallon waste

drum and that uses a single HPGe detector to detect gamma rays emitted by 239 

# Pu. A tungsten

shield and collimator limit the detector view and p rovide shielding. In addition to measuring the

emission rate of 239 

# Pu, the HPGe detector also measures the attenuation of gamma rays emitted

by a 75 

# Se transmission source located on the opposite side of the drum from the detector.

Detector signals were processed by an EG&G DSPEC TM 

# signal processor, and the assay was

controlled by ANTECH’s MasterScan software package. The PTGS used a 109 

# Cd source to

correct for the dead time of the system. During th e assay, the drum was rotated and translated

vertically and horizontally. By viewing the drum f rom many positions, the operators calculate

239 

# Pu emission and matrix attenuation properties for e ach volume element (voxel) of the drum.

Each voxel was approximately the size of 2 in. 3 

# (approximately 5 cm 3 

# ). By summing the

quantity of 239 

# Pu in each voxel, the total quantity of 239 

# Pu in the drum is calculated. During the

inspection it was observed that the PTGS had been a ssigned standby operational status for

reasons not related to performance (i.e., it was id le due to logistical factors or drum availability).

Two separate HPGe detector systems are located in B uilding B54-439 on Pad G in TA-54, and

they are referred to as FRAM 1 and FRAM 3 (currentl y there is not a FRAM 2). FRAM 1

consists of HPGe Detector No. 137-P407961, Nomad Anal yzer SN 95 7378, and Dell Computer

No. 1138460. FRAM 2 consists of HPGe Detector No. 40 P21213B, Nomad Analyzer SN

917943, and Dell Computer No. 1138459. Each FRAM u nit has a corresponding logbook that

# 50



# site personnel use to record pertinent assay-relate d information and the system’s operational

status. During the inspection, it was observed tha t 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 ratio s of gamma-ray emitting radionuclides to

239 

# Pu using the FRAM software. By combining the isoto pic data from one of the FRAM systems

with the 239 

# Pu data determined by the PTGS, site personnel calc ulate the total quantity of

individual radionuclides along with other derived q uantities, such as the total TRU alpha activity,

TRU alpha activity concentration, decay heat, and p lutonium equivalent curies. EPA found that

all aspects of the PTGS and FRAM units were technic ally adequate and appropriately

documented.

The use of a different NDA system not observed duri ng this inspection or physical modifications

to the PTGS described above is a T1 change (see Tab le 1 where this is included as a T1 change).

Changes to the software or operating range(s) of th e PTGS, and to the site procedures that

govern its use that require CBFO approval are T2 ch anges (see Table 1 that includes these as T2

changes).

(3-2) System calibration of the PTGS had been perf ormed as required.

NWIS-TP:05-0141, Portable TGS Mass Calibration and Calibration Confi rmation 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. T he recalibration was performed using

PDP-style encapsulated weapons-grade PuO 2 

# sources with masses of 0 g, 0.6 g, 3 g, 10 g, 100 g,

and 189 g in a combustible matrix. This provides a n operational range of 0.565 g 239 

# Pu (0.6 g

total plutonium) and 176.75 g 239 

# Pu (189 g total plutonium) that LANL-CCP states is identical to

the system’s calibrated range. The calibration pro tocol and its execution were technically

adequate and appropriately documented. In July 200 5, LANL-CCP confirmed the calibration as

required by assaying different 239 

# PuO 2 

# sources in a series of combinations that resulted in assay

totals of 0.9 g, 9 g, and 160 g in the same combust ible (non-interfering) matrix. The calibration

confirmation passed the WAC-stipulated measurement criteria for precision and accuracy—

percent relative standard deviation and relative pe rcent accuracy, respectively—and was

technically acceptable in other aspects and adequat ely documented. LANL-CCP personnel

stated that no actual waste drums for WIPP were aff ected 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 manne r as the PTGS. The FRAM software

contains a series of internal performance checks th at 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 calibrati on 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 d ocumented.

The determination of the TMU for the PTGS was docum ented 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 lis ted as Document No. P2010-0516)

and Revision to TWCP-23398, Total Measurement Uncertain ty 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 syste m calibration. LANL-CCP personnel referred

to these combined components as the system uncertai nty. The system uncertainty, estimated to

be 11.7%, was combined with uncertainties from coun ting statistics and the FRAM isotopic

analysis, and was calculated for each individual as say to determine the TMU of the reported

values. EPA found that the TMU for the PTGS was te chnically 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, yiel ds a measured value greater than

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

value which measurements of the background will exc eed with 5% probability

.

The LLD of any given NDA measurement is predominant ly a function of both the properties of

the waste matrix being assayed and the environmenta l 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 Tomograph ic Gamma Scanner

(PTGS) , dated March 15, 2005, documented the determinatio n 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 239 

# Pu, which is considerably less than the lower end o f the

PTGS operating range of 0.565 g 239 

# Pu. EPA found that the LLD for the PTGS was techni cally

adequate and appropriately documented.

(3-5) EPA coordinated and evaluated replicate test ing of the PTGS.

The purpose of the replicate testing during this in spection was to provide EPA with an

independent means to verify that the PTGS could pro vide consistent, reproducible results for the

determination of the quantity of 10 WIPP-tracked ra dionuclides ( 241 

# Am, 137 

# Cs, 238 

# Pu, 239 

# Pu,

240 

# Pu, 242 

# Pu, 90 

# Sr, 233 

# U, 234 

# U and 238 

# U) and the TRU alpha concentration. This was accom plished

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 (a s judged by comparing the sample

standard deviation for a number of replicate measur ements 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 me asurement(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 Cont ainer Nos. 52338, 53551, and 54857. At

EPA’s request, LANL-CCP reassayed each of these pre viously assayed drums five times for this

inspection. Two statistical tests, a χ 2 

# test and t

test, were performed on the replicate data for eac h

container. Attachments B.13 through B.18 to this r eport include analytical data for each assay

event and results of the statistical analysis.

The t test for Container No. 52338 showed no statistical ly significant differences between the

original measurement assay values and the average o f the five replicate measurements for all

measured parameters. The t test for Container Nos. 53551 and 54857 showed “hig hly

significant” flags for 238 

# Pu, 239 

# Pu, 242 

# Pu and 241 

# Am, as well as for TRU alpha activity, indicating

statistically significant differences between the o riginal measurement assay values and the

average of the five replicate measurements for thes e radionuclides. The “highly significant” flag

for 238 

# Pu, 239 

# Pu, 242 

# Pu and 241 

# Am, as well as for TRU alpha activity, indicates th at 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 238 

# Pu and 239 

# Pu are the major contributors to this, this

flag is expected for TRU alpha activity. Close exa mination 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 valu es 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 sy stem’s background; or, actual changes in the

measurement system, the aspect that this test is de signed to query. Although the software

identified these variances as “highly significant,” this does not necessarily indicate a

measurement issue that warrants additional attentio n 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, 239 

# Pu. The source material ( 239 

# Pu) within the drum may in fact be quite

small in physical size and could have shifted throu gh drum movement. The new configuration of

239 

# Pu within the container may represent an essentiall y new measurement geometry for the

container, in violation of a test assumption that t he original and replicate measurements are

performed on the same container. Unfortunately, th is is difficult to avoid since containers must

be moved for purposes of storage, staging and analy sis. There is no technical issue at this time

relative to these highly significant flags on the χ 2 

# test for the PTGS.

The χ 2 

# test for all three containers showed that the obse rved 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 findin gs or concerns related to the LANL HENC

#1, LANL HENC #2 or PTGS NDA systems during this ins pection.

# 53



# Baseline Approval

The baseline conditions that the EPA inspection tea m evaluated during this inspection consist of

the following NDA systems, as described in this rep ort:

• LANL HENC #1 for passive neutron- and gamma-based qu antitative assays and isotopic

determinations as described above and detailed in t he LANL HENC #1 checklist

(Attachment A.2 to this report) over the system’s c alibrated mass range of LLD to 177 g

total plutonium (12.159 g 240 

# Pu EFF 

# ) for passive neutron assays and calibrated range f or

energy and efficiency of photon emissions from 59 k eV to 1,408 keV at sample densities

between 0.018 and 1.649 g/cm 3



# • LANL HENC #2 for passive neutron- and gamma-based qu antitative assays and isotopic

determinations as described above and detailed in t he LANL HENC #2 checklist

(Attachment A.3 to this report) over the system’s c alibrated mass range of LLD to

16.29 g 240 

# Pu Eff



# for passive neutron assays and calibrated range fo r energy and efficiency

of photon emission from 50 keV to 1,228 keV at samp le densities between 0.018 and

1.649 g/cm 3



# • PTGS system for gamma-based assays of 239 

# Pu using measured isotopic distributions

from the FRAM 1 and/or FRAM 3 gamma systems as desc ribed above and detailed in the

PTGS checklist (Attachment A.4 to this report) over the system’s calibrated/operational

range of 0.565 g 239 

# Pu to 176.75 g 239 

# Pu

EPA has approved each system, along with its range of applicability for disintegration rate

(activity) and matrix and any limitations, as descr ibed in this report and detailed in the NDA

checklists (Attachments A.2, A.3, and A.4 to this r eport). 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 i s 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 mo difications 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 a bove, EPA assigns the following tiers:

T1 NDA changes require EPA review and approval prior to implementation. They include the

following:

• New NDA equipment 9

9 

# New NDA equipment refers to a system or component not previously eval uated by EPA. Specifically, this is

defined as a physically distinct or different syste m or apparatus; an assay system that is reported to be the equivalent

of or identical to a previously approved system, bu t which has not been formally inspected and approve d by EPA, is

a new system and must be approved by EPA prior to i mplementation to characterize WIPP wastes.

# 54



# • Physical modifications to approved equipment 10



# • Extension or changes of an approved calibration ran ge(s) for approved equipment

The last bulleted item above refers to the extensio n 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 t his inspection. An EPA technical

inspection involves the evaluation of several chara cteristics 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 fol lowing two aspects:

• Activity—the nuclear disintegration rate of specifi c radiation types (neutron or gamma),

typically special nuclear material or TRU radionucl ides; 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 sys tem’s ability to detect them); examples

include attenuation of photons (gamma) and moderati on and absorption of neutrons

During the inspection, the system’s technical capab ilities being evaluated represent the

conditions observed, and they define the operationa l 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 condi tions 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 al ways, a subset of a calibration range; that is,

systems that are calibrated to make valid measureme nts 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 ra nges are identical (i.e., 0.56 to 176.79 g

239 

# Pu). Provided the system’s calibrated range is val id, 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/cm 3 

# 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 (S 5000)” and “solids (S3000),” both of which

are within the calibrated density range. Actual wa ste assays may be restricted to a portion or

subset of this range (i.e., debris only, for a vari ety of technical and/or administrative reasons).

Changing the calibrated range by extending it beyon d 1.649 g/cm 3 

# 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 T 1 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 chan ges and/or modifications to approved equipment that

have the potential to affect the quality of NDA dat a used for the purposes of WC and/or waste isolatio n. 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. E PA may request additional information,

choose to conduct a desktop review, and/or confer w ith LANL-CCP NDA personnel. Upon

evaluation (with or without site inspection), EPA w ill 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 L ANL-CCP to notify EPA

upon implementation of such changes and submit a br ief description of the changes. These

include the following:

• Changes to software for approved equipment

• Changes to the approved operating range(s) of appro ved NDA systems upon CBFO

approval (see discussion above)

• Changes to procedures that require CBFO approval

Examples of the first bulleted item above would inc lude the following:

• Changing a system’s operating system (e.g., first u se of Canberra NDA 2000)

• Identification of a systematic problem with a softw are 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 softwa re 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 w ould be a T2 change. For example, if the

PTGS failed to pass a PDP cycle for a specific matr ix 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 an d communicate with LANL-CCP as to

whether EPA needs additional information for furthe r evaluation, whether the changes raise any

concerns requiring LANL-CCP response, or whether LA NL-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 informat ion 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, th e EPA inspection team focused on overall

procedural technical adequacy and implementation, a s well as the identification of WMPs and

prohibited items, in reviewing the following RTR el ements:

• Documentation of RTR activities through use of an a pproved 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 s pecifically placed items

Documents, BDRs, and Objective Evidence Reviewed

The following documents were among those the EPA in spection team examined to assess

whether all RTR operations follow the appropriate a pproved procedures:

• CCP-TP-053, Revision 4, CCP Standard Real-Time Radi ography (RTR) Inspection

Procedure, December 22, 2005

• CCP-TP-028, Revision 3, Radiography Test and Traini ng 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 Validat ion and Verification, March 23,

2005

• CCP-QP-008, Revision 11, Records Management, August 22, 2005

• CCP-TP-003, Revision 14, Sampling Design and Data A nalysis 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 objectiv e 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-RT R1-06-0001, 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 fo r waste stream LA-MHD02.001

• LANL-NDE-TEST-001-CL, Latest capability demonstratio n drum audio/visual recording

for RTR subject matter expert (SME), May 3, 2006

• Latest capability demonstration drum audio/visual r ecording 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 th e following technical elements of the RTR

process (see also Attachment A.5 to this report):

(1) Overall procedural technical adequacy and implement ation were considered.

The RTR procedure, documented in CCP-TP-053, Revisi on 4, Standard Real-Time Radiography

(RTR) Inspection Procedure , contained specific information on performing non- intrusive

radiography, including operational setup and checko ut, identification of prohibited items,

assignment of WMPs and estimation of weights and vo lumes, confirmation of WMCs, input of

data, issuance of NCRs, and technical review of radi ography results.

(2) Characterization of WMPs and prohibited items was assessed.

Procedure CCP-TP-053, Revision 4, required that rad iography 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 R TR events for containers S852566 (RTR

Unit 1, S5000) and 58959 (RTR Unit 2, S5000), and r eview 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 an y waste containers, the operator runs a scan

on the lines-pair resolution test gauge to determin e that images are clearly visible. On the day of

the inspection, the operator had performed this che ck before EPA arrived at the facility, but the

# 58



# inspectors reviewed the image quality checks for Ba tches 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 gener ated Concern LANL-CCP-VE-06-005CR to

address this issue (see Attachment C.5 to this repo rt for a copy of this form) that is discussed in

Section 8.4.

For each container undergoing examination, the oper ator makes an audio/video recording of the

RTR event. The first notations that the operator m akes on the audio/video recording are the

drum number and the date and time on the audio/vide o recording before beginning the

radiography process. The examination of the drum b egins at the top drum lid, where the operator

identifies the seal and vent. The drum rotates thr ough 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 staf f 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 personne l record the weight of leaded rubber

gloves as rubber only. However, VE personnel recor d the weights of leaded rubber gloves as

60% rubber and 40% other metals. EPA generated con cern 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 th e 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 rev iewed the audio/visual recordings of

Containers S834121 and S831784 (LA-RTR2-05-0103), S 834131 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-RTR 1-06-0002), and their associated data

forms. In all cases the information on the audio/v isual recording matched the written RTR

record (BDR).

(3) Documentation of radiography activities was ex amined.

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 radiogr aphy data sheet during the RTR event.

(4) EPA ascertained that documentation of radiogra phy procedures was adequate.

Radiography procedures are well defined and the doc uments are controlled. During the

inspection, the EPA team reviewed the adequacy and implementation of all radiography-related

procedures. QC examinations were performed as requ ired by the procedure. In Batch LARTR1-06-0002, an independent observation was perfor med on Container 54374 and a replicate

scan was performed on Container 55434. In Batch LA NL-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 o perators performed the original and the

replicate scan.

Site personnel generate NCRs as needed. For exampl e, 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 polychlorinate d biphenyls. NCR-LANL-0125-05 was

initiated for Drum S834116 because it contained gre ater 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 docume ntation of the capability demonstration for

selected radiography personnel. The inspectors vie wed the audio/visual recording for the latest

capability demonstration drum for an RTR SME and RT R operator during the inspection.

Training records reviewed indicate that only traine d personnel were operating the RTR

equipment and that the technical supervisor is resp onsible for the verification of qualification for

RTR operators. RTR operators must review the resul ts of the RTR/VE comparison

examinations, but they had not received “lessons le arned” training for the last two annual

VE/RTR comparison reports. EPA presented this on a n EPA Inspection Issue Tracking Form

(see Attachments C.8 of this report for a copy of t his 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” tr aining 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 c orrectly for purposes of viewing and

reference. The documents reviewed include the foll owing:

• List of currently qualified RTR personnel

• PowerPoint presentation for operational training fo r Waste Stream LA0MHD02.001

EPA inspectors also viewed the following RTR test d rum audio/visual recording and verified

that the operator identified all prohibited items:

• Requalification checklist and audio/visual recordin g for RTR SME and RTR operator

# 60



# Summary of RTR Findings and Concerns

The EPA inspection team did not identify any findin gs 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 Attachmen t 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 tea m 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, Re vision 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, an d RTR BDRs

This system is suitable for RTR of S5000 (debris) a nd S3000 (solid) wastes.

RTR Tiers

Based on the inspection and the results discussed a bove, EPA assigns the following tiers:

T1 RTR changes: None.

T2 RTR changes do not require prior EPA approval but do require L ANL-CCP to notify EPA

upon implementation of such changes and submit a br ief description of the changes. These

include the following:

• New RTR equipment or modifications to approved equip ment

• 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 an d communicate with LANL-CCP as to

whether EPA needs additional information for furthe r evaluation, whether the changes raise any

concerns requiring LANL-CCP response, or whether LA NL-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 informat ion 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 ma nual examination to determine the following

aspects of TRU WC:

• Confirmation of WMP and WMC

• Confirmation of presence or absence of prohibited i tems

• Confirmation of RTR analysis

• Generation of data for calculation of miscertificat ion 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 re viewed to assess whether VE operations

follow the appropriate approved procedures and meet VE requirements:

• CCP-TP-113, Revision 4, CCP Standard Waste Visual E xamination, December 22, 2005

• CCP-QP-002, Revision 20, Training and Qualification Plan, May 3, 2006

• CCP-TP-001, Revision 11, Project Level Data Validat ion and Verification, March 23,

2005

• CCP-QP-008, Revision 11, Records Management, August 22, 2005

• CCP-TP-003, Revision 14, Sampling Design and Data A nalysis for RCRA

Characterization, September 3, 2003

• VE in lieu of RTR BDRs LAVE540025, LAVE500081 (unva lidated BDR for

demonstration drum)

• VE as a QC check of RTR BDRs LAVE540027, LAVE500060 , LAVE500061

Following is a complete list of all objective evide nce that the EPA inspection team evaluated

during the inspection:

• VE BDRs LAVE540025, LAVE500081, LAVE540027, LAVE500 060, LAVE500061

• Audio/visual recording for BDRs LAVE540025, LAVE540 027, 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 As sessment of the Site Specific

Annual Miscertification Rate (S3000 and S5000), Feb ruary 10, 2006

• Memorandum, 2005 Selection of Visual Examination Dr ums from S3000 Summary

Category Group, March 30, 2005

• Memorandum, 2005 Selection of Visual Examination Dr ums 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 Compari son Report for Los Alamos

National Laboratory April 2004 Through March 2005 (R elative Percent Difference

Comparison Report for Radiography and Visual Examin ation), April 12, 2005

• Memorandum, Waste Material Parameter Weight Compari son Report for Los Alamos

National Laboratory June 2004 Through April 2005 (Re lative Percent Difference

Comparison Report for Radiography and Visual Examin ation): Waste Stream LAMIN03-NC.001, May 26, 2005

• Memorandum, Waste Material Parameter Weight Compari son Report for Los Alamos

National Laboratory April 2005 Through December 2005 (Relative Percent Difference

Comparison Report for Radiography and Visual Examin ation), February 7, 2006

Technical Evaluation

During the inspection, the EPA team evaluated the t echnical elements of the VE process using

the checklist included as Attachment A.6 to this re port. These areas are summarized as follows:

(1) Overall procedural technical adequacy and implement ation were assessed.

The VE procedure, documented in CCP-TP-113, Revisio n 4, contained specific information on

performing VE, including operational setup and chec kout, identification of prohibited items,

assignment of WMPs and estimation of weights and vo lumes, confirmation of WMCs, input of

data, issuance of NCRs, and technical review of VE r esults.

(2) Characterization of WMPs and prohibited items was e valuated.

During the inspection, EPA observed VE in lieu of R TR 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 au dio/visual check for the day of the

demonstration before the EPA inspection team arrive d. The EPA inspectors did, however, verify

that audio/visual checks were successfully complete d by reviewing tapes for BDR Nos.

LAVE540025, LAVE540027, LAVE500060, LAVE500061, as well as the unvalidated batch

from the demonstration for LAVE500081. The inspect ors 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 empti ed, sorted by WMP, and weighed. The

EPA inspectors observed the scale calibration perfo rmed 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 rub ber glove weights to rubber. In order to

address the discrepancy between RTR and VE data rec ording, 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 rubb er 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 assig n 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 c ontained in both were the same. By review

of the audio/visual recordings, EPA also verified t hat image quality checks were performed as

required. The EPA inspectors reviewed the BDRs lis ted below:

• BDR LAVE540025 (VE in lieu of RTR, S3000)

• Audio/visual recording for BDRs LAVE540025

• BDR LAVE500081 (unvalidated BDR for demonstration d rum, 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 rev iewed were correctly completed and had

been reviewed at both the data generation and proje ct level.

It is the policy of LANL-CCP to open all bags durin g VE, although the VEE is permitted to

document decisions with regard to opening bags in t he BDR. The drums from BDR

LAVE500061, reviewed by the EPA inspectors, contain ed 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 item s inside the cans and how they were able to

verify the absence of prohibited items. The VE dat a forms did not include any justification for

# 64



# not emptying the cans. EPA presented this as a Fin ding 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 lo cation 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 wa s not communicated to AK personnel to

enable updating of the AK record. CCP personnel us ed 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 unsuitabl e for containers of solid (S3000) wastes. Until

corrective action is taken, the use of this techniq ue to characterize WIPP wastes, in particular

dewatered sludge, at CCP sites is unacceptable.

Resolution: CBFO Interpreted this finding as a prohibition of t he 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 thi s on multiple occasions. EPA did intend this

finding to prohibit the use VE for de-watered sludg e 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 committ ed to conducting additional training for

the SPMs and AKEs to develop and issue, as necessar y, 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 memoran dum 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 th e 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 fo rm) 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 th e 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 (v erbal) 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 th e public comment

period documenting the completion of the VE trainin g 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 par agraph (2) above to verify that the VE data

were documented correctly and completely. Site per sonnel 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-leve l review checklists. Site personnel make

audio/visual recordings of the VE events, and the E PA 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 observ ed 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 th e waste streams examined.

EPA identified an issue with the documentation of V E activities during this inspection. This was

presented as a Concern on an EPA Inspection Issue T racking 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 l ine item that requires operators to verify that

the waste examined matches the waste stream’s descr iption. The VEE for the VE demonstration

and the operators of RTR units 1 and 2 who were obs erved by the EPA inspectors on May 24,

2006, could not explain how to complete this line i tem. 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 was te stream descriptions provided in the AK

summary report for the waste stream they were curre ntly examining.

Resolution: Prior to the March 6, 2007, follow-up inspection, E PA reviewed a copy of the

LANL-CCP RTR and VE Training Module (PowerPoint pre sentation) and the Non Destructive

Examination (NDE) RTR Comprehensive Examination. D uring 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 d etailed above. The operators also demonstrated

to EPA that they had access to both paper and elect ronic 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 calcula ted a miscertification rate for summary

category group (SCG) S5000 (debris) and S3000 (soli ds). Various interoffice memoranda

establish the miscertification rate for S5000 and S 3000 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 r eplacement 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 ob jective evidence:

# 66



# • Memorandum, Los Alamos National Laboratory Annual As sessment of the Site Specific

Annual Miscertification Rate (S3000 and S5000), Feb ruary 10, 2006

• Memorandum, 2005 Selection of Visual Examination Dr ums from S3000 Summary

Category Group, March 30, 2005

• Memorandum, 2005 Selection of Visual Examination Dr ums 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 Compari son Report for Los Alamos

National Laboratory April 2004 Through March 2005 (R elative Percent Difference

Comparison Report for Radiography and Visual Examin ation), April 12, 2005

• Memorandum, Waste Material Parameter Weight Compari son Report for Los Alamos

National Laboratory June 2004 Through April 2005 (Re lative Percent Difference

Comparison Report for Radiography and Visual Examin ation): Waste Stream LAMIN03-NC.001, May 26, 2005

• Memorandum, Waste Material Parameter Weight Compari son Report for Los Alamos

National Laboratory April 2005 Through December 2005 (Relative Percent Difference

Comparison Report for Radiography and Visual Examin ation), 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 qu alification packages for both

characterization and facility VE personnel and foun d 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 Issu e Tracking Forms are provided in

Attachments C.4 through C.7 of this report. EPA co nsiders all findings and concerns to have

been adequately addressed and there are no open fin dings 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 elem ents:

• Trained personnel—VE operators, VEEs, SPM, and SPQA O

• Approved and controlled operating procedures—CCP-TP -113, Revision 4; CCP-TP-028,

Revision 3; CCP-TP-003, Revision 14; CCP-TP-001, Re vision 11; CCP-QP-002,

Revision 20

• VE records and supporting data—electronic VE data f orm, CCP-TP-053 review

checklists, CCP-TP-001 review checklists, and VE BD Rs

VE as a QC check of RTR and VE in lieu of RTR are s uitable 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 a bove, EPA assigns the following tiers:

T1 VE changes: None.

T2 VE changes do not require prior EPA approval but do require L ANL-CCP to notify EPA

upon implementation of such changes and submit a br ief description of the changes. These

include the following:

• Changes made to site VE procedure(s) that require C BFO approval

Item below is listed as a T2 item under the AK sect ion 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 an d communicate with LANL-CCP as to

whether EPA needs additional information for furthe r evaluation, whether the changes raise any

concerns requiring LANL-CCP response, or whether LA NL-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 informat ion 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 exam ination to determine the following aspects

of TRU WC:

• Confirmation of WMP and WMC

• Confirmation of the presence or absence of prohibit ed items

Procedure CCP-TP-069, CCP Sealed Source Visual Examination and Packaging , Revision 3,

dated December 7, 2005, is used for VET of sealed s ources.

Documents, BDRs, and Objective Evidence Reviewed

The following documents were among those reviewed t o assess whether VET operations follow

the appropriate approved procedures and meet VE req uirements:

• CCP-TP-069, Revision 3, CCP Sealed Source Visual Ex amination 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 objectiv e 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 an d VE SME

Technical Evaluation

During the inspection, the technical elements of th e sealed source VET process were evaluated

using the checklist contained in Attachment A.7 and are summarized below.

(1) Overall procedural technical adequacy and impl ementation was evaluated.

The VET procedure, documented in CCP-TP-069, Revisi on 3, contains specific information on

performing VET of sealed sources, including the ide ntification 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 acc ordance with LANL Procedure OSR-OP-180,

Assembly Procedure for LANL Special Form Capsule, M odel 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 241 

# Am (80 mCi each) sources at Radiation Technology, I nc.,

located at 8407 Skyline Avenue, Odessa, Texas. The LANL personnel who performed this VET

event were a VET operator, a VET packager, and a Ra diological Control Technician (RCT).

Prior to arriving at the site, the LANL personnel c ompiled a work plan that included information

on the source’s radionuclides, expected activity, A K 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 requ ired in Section 7.3c of OSR-OP-170. As part

of the VET event, the operators verify that no proh ibited 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 des ignated as WMC S5100 (debris).

(3) Documentation of VET activities was examined.

The VET operator completed Attachment 4 to Procedur e CCP-TP-069 electronically as

information became available. The data recorded in cluded the presence/absence of prohibited

items, WMC, POC, and drum closure. Other informati on 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 chec klists 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 perf orm sealed source VET are listed under the

“Off-site Source Recovery Project, Visual Examinati on” section of the list of qualified

individuals. This list included the two VET operat ors who performed the offsite VET event

observed by EPA. As part of the inspection, the EP A 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 c omplete 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 o f sealed sources identified

during this inspection.

Baseline Approval

The VE system for sealed source examination and pac kaging 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 dat a recording forms, CCP-TP-069

review checklists, CCP-TP-001 review checklists, an d OSRP VE BDRs

This system is suitable for VET of S5000 (debris) w aste from the LANL OSRP.

Sealed Source VET Tiers

Based on the inspection and the results discussed a bove, EPA assigns the following tiers:

T1 VET changes: None.

T2 VET changes do not require prior EPA approval but do require L ANL-CCP to notify EPA

upon implementation of such changes and submit a br ief description of the changes. These

include the following:

• Changes made to the VET procedure for OSRP wastes t hat 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 an d communicate with LANL-CCP as to

whether EPA needs additional information for furthe r evaluation, whether the changes raise any

concerns requiring LANL-CCP response, or whether LA NL-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 informat ion 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, condu cted 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 cer tification data to the WWIS.

Documents, BDRs, and Objective Evidence Reviewed

The following documents were among those the EPA in spectors reviewed to assess whether

WWIS operations follow the appropriate approved pro cedures 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 objectiv e evidence during the inspection:

• Waste Container Data Report for Containers LA000000 52034 and LA00000061956

• WWIS data entry summary—characterization and certif ication for Containers S811270

and LA00000059179

• Correlation of container identification, May 4, 200 6

• WWIS data entry personnel qualification card

• WWIS shipment summary report

• List of NCR/corrective action report (CAR) status fo r selected containers

• CCP-WCO data entry activities, data checklist for c ontainers to be shipped, Container

S811270

• E-mail, Transmitting NCR/CAR Dispositions for Lot LA NL 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 an d controlled and contains complete

instructions for entering, reviewing, and transmitt ing data. The WWIS data entry procedure

incorporates adequate reviews to minimize the trans mittal of noncompliant or incorrect data.

The Microsoft Excel spreadsheet, used for data entr y, was also adequate and controlled. The

EPA inspectors identified no adequacy issues for th e 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 s o 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 (W CA). The waste certification official (WCO)

reviews the data to ensure that they are WIPP-compl iant and signs the spreadsheet to accept the

data. At this point, site personnel convert the da ta into ASCII format files and transmit them to

the WWIS

. The information contained in the drum file is subse quently used for transportation

activities. The EPA inspectors viewed demonstratio ns 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 LA00000 059179 and S811270

. 

# Changes made to the

WWIS data entry summary (e.g., Excel characterizati on 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 performa nce of a WCO to verify training and

qualification. Inspectors also reviewed the traini ng and qualification package for a WCA (data

entry personnel). Required training included use o f the WWIS user’s manual, and the required

reading list included the WIPP WAP and DOE/CBFO qua lity assurance program document

(DOE/CBFO-94-1012, Quality Assurance Program Description (QAPD) , Revision 7, dated July

2005). Training documentation was complete and fil ed correctly for viewing and reference.

Summary of WWIS Findings and Concerns

There were no findings or concerns related to WWIS identified dur ing this inspection.

Baseline Approval

The container certification system that the EPA eva luated during this baseline inspection

consisted of the following:

• Trained WWIS WCA (formerly, data entry personnel) a nd WCO

• Approved and controlled operating procedures—CCP-TP -030, Revision 18; and CCPQP-002, Revision 20

• Approved and controlled Excel spreadsheet, WWIS dat a entry summary—

characterization and certification

WWIS Tiers

Based on the inspection and the results discussed a bove, EPA proposes assigning the following

tiers:

T1 WWIS changes: None.

T2 WWIS changes do not require prior EPA approval but do require L ANL-CCP to notify EPA

upon implementation of such changes and submit a br ief 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 th e following:

• Changes to WWIS procedure(s) that require CBFO appr oval

• Changes to the Excel spreadsheet, WWIS data entry s ummary—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 an d communicate with LANL-CCP as to

whether EPA needs additional information for furthe r evaluation, whether the changes raise any

concerns requiring LANL-CCP response, or whether LA NL-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 informat ion is necessary to ensure continued

compliance with EPA regulations.

9.0 RESPONSE TO COMMENTS

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

2007) announcing the proposed approval of the CH wa ste 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 comme nts. EPA evaluated those comments and

revised the report accordingly. Attachment D provi des 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 o f 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 t he inspection. The EPA inspection team

members evaluated all responses for completeness an d adequacy, and concluded that each EPA

issue requiring a response had been resolved satisf actorily. No EPA issues related to this

inspection remain open at this time.

10.2 Conclusions

The EPA inspection team determined that the LANL-CC P WC program activities were

technically adequate. EPA is approving the LANL-CC P WC program in the configuration

# 74



# observed during this inspection and described in th is report and the attached checklists

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

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

wastes and for newly-generated debris wastes from t he OSRP

(2) The LANL HENC #1 and LANL HENC #2 NDA systems for assa ying solid and debris

wastes

(3) The PTGS NDA system for assaying debris waste

(4) VE as a QC check of the RTR process 11 

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

(5) The nondestructive examination process of RTR for r etrievably-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 an y 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 in spection reports and EPA site approval letters

in several ways. The most important of these invol ve presentation of the Tier 2 (T2) elements.

In previous reports there were two Tier 2 (T2) colu mns that have been merged into a single T2

column for LANL-CCP. The T2 column entries have al so been modified to better reflect the 40

CFR 194.24 (h) requirements that the site provide n otification regarding the completion or

availability of specific T2 elements, whereas the p revious tables stated that the site must actually

provide the T2 elements (document or procedure revi sions, etc.). This approach is similar to the

tiering tables used in EPA inspection reports for s ites 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. Fo r AK, the AK Reassessment Memoranda

(reflecting resolution to concern LANL-CCP-AK-06-00 1CR) and the AK-VE Memoranda

related to VE cited under T2 changes (reflecting re solution 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 sp ecific to the LANL OSRP or the result of

information identified during this inspection. Acc ordingly, these are absent from the tiering

tables in previous baseline inspection reports. Fo r WWIS, changes to specific process elements

(e.g., spreadsheets and data fields) are cited as T 2 changes and these did not appear in previous

tiering tables. These were added to provide a grea ter 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 wi th 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 abilit y to perform VE as a QC check of RTR (see EPA lette r of

December 6, 2006).

# 75



# that are solely related to Environmental Safety &He alth (ES&H), nuclear safety, the Resource

Conservation and Recovery Act (RCRA) or editorial i n 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-u p evaluation conducted on March 6, 200776Table 1. Tiering of TRU WC Processes Implemented by LANL-CCPBased on May 23–25, 2006 On Site Baseline Inspection, August 22, 2006 OSRP Inspection and March 6, 2007 EvaluationWC Process ElementsLANL-CCP WC T1 ChangesLANL-CCP WC T2 Changes*Acceptable Knowledge (AK) andLoad ManagementAny new waste category, or new OSRP wastesaddressed in AK Summaries separate fromCCP-AK-008; AK (3), AK (6), AK (16) and (AK) 17Implementation of Load Management for wastestreams other than AK-009; AK (5)Notification to EPA upon completion of AK AccuracyReports; AK (2)Notification to EPA upon completion of updates to or substantivemodifications*** of the following:-AK Reassessment Memoranda and combination of wastestreams thatwere distinct at the time of this inspection; AK (2) and AK (6)-AK-VE Memoranda related to VE and/or RTR techniques; VE (2)-AK-NDA Memoranda; AK (2 and 3)-AK Accuracy Reports; AK (2)-Site procedures requiring CBFO approval; AK (4)-AK Summary CCP-AK-008, if changed since the baseline inspectionand/or following the addition of new sealed sourcesAK (6)-Change Notices used to modify and update WSPFs, including additionsto waste stream(s) within an approved waste category; AK (9)Nondestructive Assay (NDA) New equipment or physical modifications to approvedequipment**; NDA (1-1, 2-1, 3-1)Extension or changes to approved calibration rangeforapproved equipment; NDA (1-2, 2-2, 3-2)Notification to EPA upon completion of changes to software for approvedequipment, operating range(s) and site procedures that require CBFO approval;NDA (1-2, 2-2, 3-2)Real-Time Radiography (RTR) N/A Notification to EPAupon the following:-Implementation of new equipment or substantive changes*** toapproved equipment; RTR (1)-Completion of changes to site procedures requiringCBFO approvals;RTR (2)Visual Examination (VE) andVisual Examination Technique (VET),including OSRP Wastes (Sealed SourceVET or SSVET)N/A Notification to EPA upon the following:-Completion of changes to site VE and VET proceduresrequiring CBFOapprovals, including OSRP VET procedure; VE (1) andSSVET (1)WIPP Waste Information System(WWIS)N/A Notification to EPA upon the following:-Completion of changes to WWIS procedure(s) requiring CBFOapprovals; WWIS (1) and WWIS (2)-Changes to the Excel spreadsheet, WWIS data entry summary,characterization and certification*** that requireCBFO approval;WWIS (1) and WWIS (2)* Upon receiving EPA approval, LANL-CCP will report all T2 changes to EPA at the end of each fiscalyear quarter.** Modifications to approved equipment include allchanges with the potential to affect NDA data relative to waste isolation and exclude minor changes,such as theaddition of safety-related equipment.77***Substantive changesmeans changes with the potential to impact the site’s waste characterization activities or documentation thereof, excluding changes that are solelyrelated to Environmental Safety & Health (ES&H), nuclear safety, the Resource Conservation and Recovery Act (RCRA) or are editorial in nature.

# 78



# 11.0 REFERENCES

New Mexico Environment Department, Waste Isolation P ilot Plant Hazardous Waste Facility

Permit (WAP), NM48901 139088-TSDF, Santa Fe, New Mexi co, 1989.

U.S. Code of Federal Regulations , Title 40, Protection of Environment, Part 191,

“Environmental Radiation Protection Standards for M anagement 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, Compli ance Certification Application for the

Waste Isolation Pilot Plant,” DOE/CAO 1996-2184, Ca rlsbad, New Mexico, 1996.

U.S. Department of Energy, “40 CFR Part 191, Subpar ts 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 P lant (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 Mex ico, July 2005.

U.S. Environmental Protection Agency, “Criteria for the Certification and Recertification of the

Waste Isolation Pilot Plant’s Compliance with the D isposal Regulations: Certification Decision;

Final Rule,” Federal Register , Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405.

U.S. Environmental Protection Agency, “EPA Replicat e Testing for WIPP Nondestructive Assay

(NDA) Systems,” Rev. 2, June 2002.

U.S. Nuclear Regulatory Commission, “Contact-Handle d Transuranic Waste Authorized

Methods for Payload Control” (CH-TRAMPAC).

# Attachments A.1 through A.8Revision No.: 2.0AK-1Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective EvidenceGENERALAK-1:Is the waste TRU by definition as presented in theLWA?(P.L.102-579)CCP-TP-005, Revision 16;CH WAC Revision 3; P.L.102-579Yes CCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). Load management to be performed for LANL-009only.AK-2:Do the presented volumes comport with LWAcapacity restrictions?(P.L.102-579)CCP-TP-005, Revision 16;CH WAC Revision 3; P.L.102-579YesCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009, (March 9,2006). Data examined identified no issues with respect towaste volume.AK-3:Are any wastes considered (or previouslyconsidered HLW? HLW are prohibited.(P.L.102-579)CCP-TP-005, Revision 16;CH WAC Revision 3; P.L.102-579YesCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). CCP representatives stated that none of thestreamsexamined contained HLW.AK-4:Are any wastes considered (or previouslyconsidered) Spent Nuclear Fuel?(P.L.102-579)CCP-TP-005, Revision 16;CH WAC Revision 3; P.L.102-579Yes CCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). CCP personnel stated that none of the streamscontained SNF.AK-5:Are these defense-related wastes?(P.L.102-579)CCP-TP-005, Revision 16;CH WAC Revision 3; P.L.102-579Yes CCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). Three waste streams of sealed sources containing241Am and238Pu have recently been given a defensedetermination by CBFO and the DOE Chief Counsel. Allthree streams are justified in the summaries as being defensewaste based on the following argument: “Radioactivematerials in the sealed sources are [from] activation of decayproducts of defense materials production, resultingfrommaterials separations during defense nuclear materialRevision No.: 2.0AK-2Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidencebyproduct management, and are now managed [as defensewaste] for defense nuclear materials security andsafeguards.” In essence, the material in the sealed sources isconsidered to be defense waste because it was created as partof “defense nuclear material byproduct management,”evenif the sources had a nondefense-related application. EPAdoes not make defense determinations.AK-6:What is the scope of authorization sought (i.e.,SCG, newly generated vs. retrievably stored, othersitespecific breakdowns)CCP-TP-005, Revision 16;CRA 2002Yes CCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). Audit scope is retrievably stored S5000 debris andS3000 solid TRU waste. OSR waste (LANL-008) isconsidered newly- generated debris.AK-7:Is AK being used that was assembled prior to anEPA approved QA program (retrievably stored). If so,what qualification process is used? Is this wasteundergoing 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.102-579Yes CCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). BDRs for waste containers 850312 (Solids), S870375(07), S814218 (solids), S834538 (238Pu debris), S817225(solids), 54631 HT 83, 55700238Pu, LA00000061432,LA00000062374. Waste undergoes 100% NDA and NDE.AK-8:Is AK being assembled as waste is generated afterEPA approval of the QA program (newly-generated)?Isthis 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.102-579YesCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). Waste streams LANL-007 and 009 have “projected”waste generation into the future, thus implying a newlygenerated debris component will be created. OSRP waste(LANL-008) is considered newly-generated debris waste.100% NDA and NDE is being performed on all containers.PERSONNEL TRAINING REQUIREMENTSAK-9:Procedures require staff to be qualified toassemble, compile, and confirm AK data, including butnot limited to:CCP-TP-005, Revision 16;CCP-QP-002PartialVerification, seeObjective EvidenceTraining records for Julia Whitworth (AKE), Kevin Peters(AKE), Steve Schafer (AKE), Mark Pearcy (SPM), andRandy Fitzgerald (SPQAO). Individuals were proficient asRevision No.: 2.0AK-3Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidencea.Identification of required reading list and successfulcompletion of all required reading including, but notlimited to:•Applicable portions of the WIPP WAP and TSDFWAC•WIPP Compliance Certification Decision Conditions2 and 3•State and Federal RCRA regulations associated withsolid and hazardous waste characterization•Discrepancy resolution and reporting processes•Site-specific procedures associated with wastecharacterization using acceptable knowledgeb. Successful completion of testing to demonstrateunderstanding of required reading listc. Completion of internal and/or external trainingprograms pertinent to AKd.Participation in internal audits to assess AK programe.Other methodologies for demonstrating AK proficiencyas developed on a site-specific basis(WAP B4, B4-3a)evidenced through interview, but additional EPA-specifictraining would help ensure consistent understandingof EPArequirements.PROCEDURE SCOPEAK-10:a. Are procedures adequate to encompass the spectrum ofwastes for which authorization is sought?b. Are there different procedures for newly-generated vs.retrievably-stored waste? Are there differentprocedures for solid, debris, or soil waste? Shouldthere be?CCP-TP-005, Revision 16;CCP-TP-101PartialVerification; seeObjective EvidenceCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). Procedure CCP-TP-005 includes newly-generated andretrievably-stored waste; OSRP wastes are characterizedusing AK as well as CCP-TP-101. Note that OSRP waste isentirely characterized prior to packaging.Revision No.: 2.0AK-4Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidencec. For newly-generated waste, have adequate proceduresbeen developed and implemented to characterize wasteusing acceptable knowledge prior to packaging?(WAP B4, B4-3b)ASSEMBLING AK INFORMATION AND COMPILING AK DOCUMENTATION INTO AN AUDITABLE RECORDAK-11:What is the breakdown of the types andquantities of TRU waste generated/stored at the site?(WAP B4, B4-2a)CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (March9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006), D041, D039, D074, D078 (004); D011, D014, D015,D032 (007); M055 (008); D028, M018 (009). Data includedin the above references included information pertinent totypes and quantities of wastes within the streams at this site.AK-12:Do procedures call for AK information to becollected for:a.241Am,238Pu,239Pu,240Pu,242Pu,233U,234U,238U,90Sr,137Cs plus any unexpected radionuclidesb. ferrous metals (in containers)c. cellulosics, plastics, rubberd. nonferrous metals (in containers)(CRA/CCA Ch 4 and Attachments/Appendices)CCP-TP-005, Revision 16;Manual IS Revision 5Yes CCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006), C028, C019, D01, D025, D041, D044, D040, D035,D004, M018, M117 (004); C028, C032, C042, D011, D014,D015 (007); C010, C011, D007, M037, M036, M011, M010,M009 (008); D011, D021, D028, M019 (009). Radiologicalcomponents are identified in various supporting documents.Note that the identification of WMPs to assign WMCisperformed; detailed breakdowns with respect to CRA/CCAquantities not included in AK Summaries.AK-13:Do procedures require documentation ofradionuclide process origin?Are the facility and TRU waste management operationscorrelated to specific waste stream information?(Attachment B4; CH WAC Appendix A.2.2)CCP-TP-005, Revision 16 YesCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006), C028, C019, D01, D025, D041, D044, D040, D035,D004, M018, M117 (004); C028, C032, C042, D011, D014,D015 (007); C010, C011, D007, M037, M036, M011, M010,M009 (008); D011, D021, D028, M019 (009). Processorigin discussed. Note that CCP personnel stated thatLANL-007 (MT 83) is a distinct process separate from theRevision No.: 2.0AK-5Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidence239Pu (006) stream; this was discussed because LANL-007appeared to contain an occasional container with239Pucontrary to the process definition of the stream.In the caseof LANL-004 is tied to numerous input streams; LANL-007is associated with MT83 processing only; LANL-008 isnewly-generated OSRP waste, and LANL-009 is associatedwith various activities in CMR.AK-14:Are correlations between waste streams, withregard to time of generation, waste-generating processes,and site-specific facilities clearly described? For newlygenerated wastes, the rate and quantity of waste tobegenerated shall be defined.(Attachment B4, B4-3c; CH WAC Appendix A, SectionA.2)CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (March9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). Four separate waste streams were examined and AKsummaries for each addressed the checklist elementrequirements.AK-15:a.Are wastes streams appropriately identified and arewastes characterized on a waste stream basis?b.Are wastes grouped on a waste stream basis usingAcceptable Knowledge and are they characterizedinthe same manner(i.e., by visual examination) as anewly-generated waste if a waste does not have allmandatory AK documentation requirements?(Attachment B4, Section B-1a)CCP-TP-005, Revision 16 PartialVerification, seeObjective EvidenceCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). Three waste streams of sealed sources containing241Am and238Pu have recently been given a defensedetermination by CBFO and the DOE Chief Counsel. CCPintends to assess whether new OSRP waste streams arewarranted based on both the new defense determinations andthe presence of irradiated sealed sources. If not,LANL-CCPwill update the current AK summary with respect toradionuclide content, predominant nuclides, etc.; similarly, itwill update or create a new WSPF to reflect this newapproval. Because EPA has not assessed the radiologicalcharacterization for new sealed sources, examination of thisapproach is required to ensure that the processes proposedare technically adequate.Also, CCP has consistently used material types todemonstrate similar material components in waste streams,specifically LANL-007 and -006. Combination of theseRevision No.: 2.0AK-6Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidencestreams in contradiction with past waste stream definitionpractices requires prior EPA notification and approval.AK-16:Do procedures demonstrate a logical progressionfrom general facility information to more detailedwastestream-specific information?CCP-TP-005, Revision 16 YesCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). Data were available to show programmatic towastestream information.AK-17:Does the process include review of AKinformation to evaluate and document AK-AKinformation discrepancies?(CH WAC Section A.2.2.3, Attachment B4, SectionB4-3)CCP-TP-005, Revision 16 PartialVerification, SeeObjective EvidenceCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). DR004 (004), DR005 (007), DR001, 0002, 004,006-010 (008), DR003 (009). The discrepancy resolutionsexamined were complete (although this does not necessarilymean that EPA concurred with the resolution therein, forexample, combining of waste streams, etc.). CCP hadrecently generated a number of discrepancy resolutionsspecific to the use of the NMMSS database for AK-008sealed sources, because the NMMSS database does notcomport with other information with respect to sealed sourceradionuclide content. Tracking of discrepancies between theNMMSS database and other sealed sources’ radiologicalcontent information is important to understand whether theNMMSS is still a reliable source of data, and is overallimportant because OSR relies entirely on AK for radiologicalcharacterization.AK-18:Do procedures require collection of informationregarding how waste is tracked and managed at thegenerator site (including historical and currentoperations)?(CH WAC Section A.2; Attachment B4 Section B4-2a)CCP-TP-005, Revision 16 Yes, in part CCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). CTS/PTS CCP print outs, CWSR container storagerecord database discardable waste lot sheets DWLS (variousexamples), CONCERT database, NMMSS. Note that CCPtracks data on an uncontrolled AK tracking spreadsheet thatincludes container, MT, and other information (containerstatus). CTS/PTS track data as well. Note that itis difficultRevision No.: 2.0AK-7Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidenceto follow the specific databases used; Chapter 6 ofeach AKScould include this listing. Data entry into WWIS was notexamined.AK-19:Is AK information compiled in an auditablerecord, including a road map for all applicableinformation?CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (March9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). Attachments 1 and 4 for CCP-TP-005 (prepared foreach waste stream). Attachments correlate mandatoryprogram and waste stream information with references tosupport the determination; Attachment 4 is a completereference list for each stream.AK-20:Has a reference list been provided that identifiesdocuments, databases, Quality Assurance protocols,andother sources of information that support AKinformation?(Attachment B4, Section B4-3c)CCP-TP-005, Revision 16 PartialVerification, SeeObjective EvidenceCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). Attachment 4 (CCP-TP-005) is a master reference listand is prepared for each stream. However, it is very difficultto track source documents between streams because they usecommon identifiers (e.g., there could be a reference D011 forLANL-004 and D011 for LANL-009, but the referencesaredifferent). It is recommended that some sort of uniqueidentifier be added to each reference indicating the wastestream it applies to, as the same reference list numbers areused in different reports to identify different references,which can lead to confusion.AK-21:Have the following mandatory informationrequirements been identified?•Map of the site that identifies the areas and facilitiesinvolved in TRU waste generation, treatment, andstorage•Facility mission description related to TRU wastegeneration and managementCCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (March9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). C028, C019, D01, D025, D041, D044, D040, D035,D004, M018, M117 (004); C028, C032, C042, D011, D014,D015 (007); C010, C011, D007, M037, M036, M011, M010,M009 (008); D011, D021, D028, M019 (009). Radiologicalinformation is also summarized in AK-NDA memorandaforRevision No.: 2.0AK-8Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidence•Description of the operations that generate TRU wasteat the site and process information, including:- Area(s) or building(s) from which the waste streamwas or is generated- Estimated waste stream volume and time period ofgeneration- Waste generating process description for eachbuilding or area- Process flow diagrams, if appropriate- Generalized material inputs or other information thatidentifies the radionuclide content of the wastestream and the physical waste form- Types and quantities of TRU waste generated,including historical generation through futureprojections•Physical/chemical waste composition that could affectisotopic distribution (i.e., processes to remove ingrown241Am)•Statement of all numerical adjustments applied toderive the material’s isotopic distribution, e.g.,scalingfactors, decay/ingrowth corrections and secularequilibrium considerations•Specification of isotopic ratios for the 10 WIPP-trackedradionuclides and, if applicable, the radionuclidesthatcomprise 95% of the hazard(CH WAC Section A.2.2; Attachment B4, B4-2a, B4-2b)CCP-AK-LANL-004, 007, and 009 (no AK-NDAmemorandum prepared for 008). Information presentedidentified the specific programmatic and waste streaminformation required in this checklist item. Thephysical/chemical information that could affect isotopicdistribution should be addressed in AK-NDA memoranda.Isotopic ratios could not be assigned for waste streamLANL-004; isotopic data are assembled on a drum-specificbasis for containers in streams LANL-008 and 009.MT 83isotopics are assigned to LANL-007.AK-22:Does the site have procedures for the collectionof supplemental information? Examples of supplementalinformation, from CH WAC, include:CCP-TP-005, Revision 16 YesCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). C028, C019, C061, D005, D025, D039, D041, D034,Revision No.: 2.0AK-9Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidence•Safeguards and security and other material controlsystems/programs•Reports of nuclear safety or criticality•Accidents involving SNM waste packaging and wastedisposal•Building or nuclear material management area logs orinventory records•Site databases that provide SNM or nuclear materialinformation test plans•Research project reports, or laboratory notebooks thatdescribe the radionuclide content of materials usedinexperiments•Information from site personnel•Historical analytical data relevant to isotopicdistribution in the waste stream(CH WAC Section A.2.2.2; Attachment B4 SectionB4-2c)D082, D051, D044, D035, D018, M117 (004); C032, C040,C041, D011, D014, D015, D032, P016 (007); M024, M001,D007, M040, M036, M026 (008); D001, D003, D010, D021,D028, M018, M019 (009). Supplemental information wasavailable for many of the examples listed.AK-23:Is all necessary supplemental informationassembled and has it been appropriately used?(Section B4-2c)CCP-TP-005, Revision 16 PartialVerification, seeObjective EvidenceCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). Supplemental information assembled appearedto beappropriately used at this point, although the combination ofcombustible/non combustible waste streams by CCP appearsto be based on the desire to increase waste streamsize, and itis unclear whether the justification for this combining ofstreams will hold true through the process.AK-24:a.Are waste categorization schemes presented and arethey appropriate?CCP-TP-005, Revision 16;CH WAC Revision 3PartialVerification, seeObjective EvidenceCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006), M025 (004); D015, D032, D033 (007), D029 (009).Revision No.: 2.0AK-10Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidenceb. Are waste identification/categorization schemesrelevant to the isotopic composition of waste?(Attachment B4 Section B1, CH WAC page ix, AppendixA.2)CCP explicitly defined CCP-AK-LANL-007 as consistingonlyof238Pu debris waste; if239Pu were to be detected indrums assigned to this stream, CCP representativessaid thedrums would be segregated for inclusion in anotherwastestream. When asked whether the239Pu containers could beplaced in AK-006, CCP personnel stated that this was not anoption, apparently due to how the waste streams wereassigned. However, the AK personnel indicated theywereconsidering broadening the definition of this wastestream toallow the inclusion of an occasional drum with isotopics notrepresented by MT 83, but at the time of the inspection thishad not been accomplished. CCP has determined thatAK006 and AK-007 are different waste streams based onthedefinition of waste streams presented in the WasteAnalysisPlan (WAP) and WAC. EPA agrees that they are separatewaste streams, and post-inspection modification orcombinations of waste streams examined by EPA during itsinspection would require revisiting and approval byEPA.Also, approval of239Pu and241Am sealed sources as defensewaste makes these wastes eligible for disposal at the WIPP;correct waste stream determination is expected.AK-25:Have data uses and limitations been assembledand are they technically adequate?(CRA/CCA; CH WAC Appendix A, Section A.2.2.3)CCP-TP-005, Revision 16 YesAll Source Documents examined (M, C, P, D). CCP-TP-005Attachment 3 Acceptable Knowledge Source DocumentSummary. This attachment is completed and placed atopeach reference; the attachment includes a locationwhere AKsource document limitations are documented.GENERATING AN AK SUMMARY/AK DOCUMENTAK-26:Site documents/procedures require the facilityprepare an AK summary document that summarizes allinformation collected, including the basis for allwastestream designations. Is the AK Summary of sufficientscope and detail?CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (March9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009, (March 9,2006). AK Summaries examined were comprehensive andaddressed most technical information needs. ExaminedRevision No.: 2.0AK-11Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidence(CH WAC Appendix A Section A.2.2; Attachment B4Section B4-2b)supporting references were sufficient for the specific itemsthey were reviewed to assess. The following items wereidentified:Remove Wing 1 discussion from Table 10 of LANL-009andrevise the text accordingly;Include waste stream generation dates in LANL-007 in anappropriate 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 impactshow site personnel enter the data into the WWIS;Examine WMP and prohibited item discussions to ensurethat an accurate description of the wastes is presented. Forexample, for AK-004, the AK summary indicates thatfluidsmay be present through dewatering and condensation,but itdoes not indicate where, specifically, this water may be inthe containers;Clarify the language pertaining to heat source fabrication.AK-007 includes several different current and historic238Puwaste generation processes, but it is hard to identify which ofthe processes are active versus those that are not,in largepart because the language pertaining to heat sourcefabrication is confusing;Always distinguish “expected” versus “suspected”radionuclides in radiological discussions; it is important toidentify “expected” radionuclides, as this impactshow sitepersonnel enter radionuclide data into the WWIS (e.g.,233Uas presented in AK-007);AK documents address some prohibited items, but donotspecify where in the waste those items might be. Forexample, liquid from condensation or dewatering wasidentified in AK-004, but the anticipated locationof thiswater in the containers was not specified. This turned out toRevision No.: 2.0AK-12Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidencebe important, as liquid was identified in the wastes (at thebottom and in containers within drums), not just atthe top oralong the sides of the containers as might be anticipatedthrough condensation/dewatering. AK should be morespecific, if possible, as to the location of liquidwithin waste.CCP-TP-005, Attachment 3, presents AK data limitations.Attachment 3 is included on front of all CCP C, D,P, and Mdocuments. This form addresses each source document, andtherefore each source document includes a source documentdata limitation assessment. Attachments 1 and 4 toCCP-TP005 act as AK “roadmaps” in that they present specificsupporting documents and spell out the relevancy ofthosedocuments to required AK elements.AK-27:Are conclusions and interpretations presented inthe AK Summary technically sound and supported byreferenced mandatory and supplemental information?CCP-TP-005, Revision 16 PartialVerification, seeObjective EvidenceSee reference lists and discussion under AK-21, AK-22, AK23, AK-25, and AK-26.AK-28:If AK data discrepancy is identified, site willevaluate the source of the discrepancy to determineifdiscrepant information is credible. Information that is notcredible will be identified as such and reasons fordismissing will be justified in writing. Limitationsconcerning information will be documented in the AKrecord and summarized in the AK report. If adiscrepancy cannot be resolved, the site will performdirect measurements for the impacted population.(CH WAC Appendix A.2, Section A.2.2.3)CCP-TP-005, Revision 16 PartialVerification, seeObjective EvidenceSee references and discussion under AK-17. As indicated inthis AK item, several discrepancies were identifiedthat bringto question the reliability of the NMMSS database.CCP isencouraged to examine these discrepancies in detail, sinceOSR relies solely on AK for radiological characterizationdata.AK-29 :Is load management proposed? Does the AKSummary include the following from the CH WAC,Revision 3, Appendix E?•Each TRU waste stream selected for payloadmanagement must include in its acceptable knowledgesummary report an estimate of the total waste volumeand the percentage of the waste volume that is aboveCCP-TP-005, Revision 16 PartialVerification, seeObjective EvidenceCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). Load management is being sought only for AK-009,Waste Stream LA-MHD03.001, CMR facility heterogeneousdebris waste. Between 3–33% of this waste stream isexpected to be less than 100 nCi/g on a container basis. CCPRevision No.: 2.0AK-13Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidenceand below 100 nCi/g. (It should be noted that thisinformation, although based on the best available AKinformation, is preliminary and subject to theperformance of WIPP-certified NDA measurementsand cannot and will not be used as a measure of AKaccuracy.) (Reference E3)(CH WAC, Appendix E)will not use load management for AK-004, AK-008, andAK-007 at this time. If CCP decides to use loadmanagement for these waste streams, it must meet therequirements of Appendix E of the CH WAC, Revision3.IDENTIFYING MANAGEMENT CONTROLS FOR DISCREPANT ITEMS/CONTAINERS/WASTE STREAMS AND DATA MANAGEMENT/TRACKINGAK-30:Are nonconforming wastes segregated? AreNCRs disposition in an appropriate and technicallydefensible manner?(Attachment B4, Section B4-3b, Attachment B3, SectionB3-13)CCP-TP-005, Revision 16 YesNCR-LANL-0537-05, NCR-LANL-0742-06, NCR-LANL0803-05, NCR-LANL-0516-06 (stream unclear). NCRsshow that CCP is capable of identifying nonconformingitems; the specific stream associated with NCR-LANL-0516-06 should be identified, as this deals with NDA/AKmismatches.AK-31:Do site procedures require that additionalinformation be collected before waste may be shipped ifthe required AK information is not available for awastestream or if available AK is poor or unacceptable?(Attachment B4, Section B1)CCP-TP-005, Revision 16 YesCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). See AK 28 and 10. The necessary information hasbeen available so far.CONFIRMING AK INFORMATION WITH OTHER ANALYTICAL RESULTSAK-32:Do these procedures facilitate the mandatorytraceability analysis performed for each Summary WasteCategory Group examined during the audit, noting thatEPA will determine whether the available waste streamsadequately demonstrate the full characterization processfor the proposed scope?(Attachment B4, Section B4-2)CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (March9, 2006), CCP-AK-LANL007, Revision 2 (April 13, 2006), CCP-AK-LANL-008,Revision 3, (September 22, 2005); CCP-AK-LANL-009(March 9, 2006). EPA examined traceability in wholeor inpart for several containers—S850312 (solids), S870375(stream238Pu debris), S814218 (solids), S834538 (238Pudebris), S817225 (solids), 54631 MT 83, 55700238Pu, OSRLA00000061432, and OSR LA00000062374. Informationfor evaluated containers was traceable from original LANLradioactive solid waste disposal forms, radioactivesolidwaste disposal records, or similar forms through the currentRevision No.: 2.0AK-14Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective EvidenceAK spreadsheet to BDRs generated through WIPPcharacterization and subsequent tracking in PTS/CTS. EPAdid not assess input into the WWIS as part of AK.AK-33:If AK was used (i.e., data collected prior to QAprogram), what method was employed to qualify theinformation? Approved methods or peer review,corroborating data, confirmatory testing, and QA programequivalency? If confirmatory testing is used, hasthefollowing been considered (from CH WAC)•At a minimum, to confirm existing AK data, it isnecessary to compare ratios of the two most prevalentradionuclides in the isotopic mixa. For238Pu,239Pu,240Pu,241Pu,242Pu and241Am:•Confirmation can be accomplished via comparison ofmeasured and AK values for239Pu/240Pu forweapons grade plutonium;238Pu/239Pu for heatsource•Measured241Am can be used to calculate241Pu (forsubsequent AK comparison) if time of chemicalseparation is known (no241Am at time of separationassumed)•241Pu can be compared (by ratio) to confirm AK ofany Pu isotope associated with WG/RG (i.e.,239Pu or240Pu)•238Pu from AK for wg/rg Pu is assumed to be valid ifthe AK values of239Pu and240Pu have beenconfirmed by measurement•242Pu calculated by correlation techniques, since itcan’t be measuredCCP-TP-005, Revision 16,CH WAC, Revision 3PartialVerification, seeObjective EvidenceCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). AK-NDA Memoranda for LANL-004, 007, and 009.LA-MIN03-NC.001, TA-50 Homogenous Inorganic SolidsNoncemented Waste (AK-004). No default isotopics areavailable for this waste stream due to the manner in whichthe stream was created. Therefore, comparison of measuredand AK values to confirm any plutonium isotopes cannot beperformed. Similarly, while uranium information wastracked from an AK perspective in waste since 1985,the useof “valid AK” to confirm U measurements is not appropriate.CCP identified235U and239Pu as the two prevalent isotopesby weight. CCP did not indicate a specific point at whichthis assessment would be reconsidered to accuratelyevaluatethis initial determination. Furthermore, determination ofpredominant radionuclides by activity rather than weight ismore meaningful for the cumulative tracking of thetotalactivity of each of the 10 WIPP-tracking radionuclidesmeasured in the waste.LA-MHD02.001,238Pu Contaminated Mixed HeterogeneousDebris Waste (AK-007). AK defined this waste stream asconsisting entirely of MT 83, so the waste’s isotopic ratiosare well defined. Because NDA personnel know thatthiswaste stream consists of238Pu, they use the specified isotopicratios for MT83 to determine Pu contents. If measuredvalues don’t match MT83, CCP representatives statedthatthe drums are not part of this waste stream and aresegregated for assignment to a new waste stream. Withrespect to uranium, little233U is anticipated, and it istherefore an “expected” rather than a “suspected” nuclide.Revision No.: 2.0AK-15Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidenceb. For235U,233U,238U,234U:•Were they tracked or measured in AK information?•If no valid AK exists, data generated can only beused to detect or calculate, or confirm absence ratiosfor234U calculated from235U enrichment•If valid AK exists, can confirm with certified systems•234U calculated by235U enrichment, because234Ucan’t be measuredc. For137Cs and90Sr:•Confirmed by WIPP-certified system via comparisonof241Am peak at 662 keV to 722241Am peak, i.e., adisproportionate response at 662 keV could meanpresence of137Cs)•90Sr calculated from137Cs using scaling factorsOther radionuclides – must identify via NDA and shouldidentify via AK(40 CFR 149.22(b), CH WAC, Appendix A, SectionA.2.1)LA-OS-00-01.001, OSRP Sealed Sources (AK-008). AK isthe exclusive means for determining the radionuclide contentof sealed sources. Therefore, for each source, site personnelassess NMMSS, source certificates, fabrication/shippingrecords, U.S. Nuclear Regulatory Commission registryinformation, and other data, to determine the preciseradionuclide content of waste at the time of fabrication,which is then corrected for radiological decay and/oringrowth, as appropriate. In addition to sealed sources forwhich AK has already been assessed, CCP representativesstated additional irradiated sources are present that willtherefore have an initial composition different than thatassigned by the manufacturer. EPA expects to examine bothnew OSRP waste streams based on newly approved defensewaste and irradiated sources prior to shipment.LA-MHD03.001, CMR Facility Debris (AK-009). Sitepersonnel assigned MTs to each container upon wastegeneration. NDA personnel get AK data from the AKEforeach container to assist in NDA measurements. Forexample, NDA personnel may need to know whether MT83is present based on AK; MT 42 (242Pu) mixtures are alsoimportant to identify. AKE may determine weightedaverageby material type(s) for use by NDA on a drum basis.Confirmation with respect to weapons versus heat sources asdescribed in the WAP apparently does not take place;instead, the AKE indicated that verification mighttake placeon an MT basis. The AKE indicated that241Pu wasdetermined by AK, as opposed to by calculation based onmeasured241Am values, as indicated in the WAC;241Pu isnot a TRU radionuclide or one of the 10 WIPP-trackedradionuclides. MGA or FRAM calculate242Pu as part of theNDA process, but site operators often use AK, particularlywhen AK identifies drums as containing high quantities of242Pu. AK used to help determine234U content on a drumby-drum basis; a scaling factor is used to determine the234Ucontent based on the observed235U. The AK memorandumRevision No.: 2.0AK-16Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidencestates that234U is quantified by calculation, and it providesthe formula and assumptions for the HENC. Note that EPAobserved inconsistency in radionuclide presentationandreporting. For example, it is important to distinguishradionuclides that are “expected,” because this directlyimpacts how site personnel enter the information for theseradionuclides in the WWIS. For example,233U is expectedin waste stream LANL-007. In all instances “conservative”assumptions must take into account requirements oftheCRA.AK-34:If waste is generated after an EPA-approved QAprogram, are radioassay and NDE results compared tothedata assembly process as a cross reference to verifyimplementation of the as-generated characterizationprogram?(194.24 (c)(3); 194.22(b))CCP-TP-005, Revision 16 YesCCP-AK-LANL-004 (March 9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). See Item AK-6, above.AK-35:This procedure requires a reevaluation of AK ifNDE identifies it to be a different waste matrix code.This procedure describes how the waste must bereassigned, based on the AK reevaluation.(Attachment B4, Section B4-3d)CCP-TP-005, Revision 16 YesAK Re-Evaluation Checklists, CCP-TP-005 Attachment10.Checklists are prepared when re-evaluation of AK isrequiredbased on NDE results. It is unclear if CCP representativesindicated thatFastscanorQuickscanis currently performed.If so, data must be in the AK record.AK-36:Does the generator site have written proceduresfor newly generated waste to document the confirmationof acceptable knowledge information with visualexamination 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 evaluation of visual examination/technique analysis.AK-37:Procedures require the following steps to befollowed if wastes are reassigned to a different wastematrix code based on NDE:CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004 (March9, 2006), CCP-AK-LANL-007,Revision 2 (April 13, 2006), CCP-AK-LANL-008, Revision3, (September 22, 2005); CCP-AK-LANL-009 (March 9,2006). Attachment 10 of CCP-TP-005. No examples of thisRevision No.: 2.0AK-17Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidence•Review existing information based on the containeridentification number and document all differences•Reassess and document all analytical data associatedwith the waste•Reevaluate waste material parameter determinationsand document any changes•Reevaluate the radionuclide content and document anychanges•Verify and document that the reassigned waste matrixcode was generated within the specified time period,area and buildings, waste generating process, and thatthe process material inputs are consistent with thewastematerial parameters identified during radiography orvisual examination•Record all changes to acceptable knowledge records•If discrepancies exist in the acceptable knowledgeinformation for the reassigned waste matrix code,complete a nonconformance report, document thesegregation of this container, and define the correctiveactions necessary to fully characterize the waste.(Attachment B4, Section B4-3d)process were provided; see item AK-35, above.AK-38:Has the acceptable knowledge expert calculatedthe percent changes in matrix parameter categories(MPCs) based on AK and NDE/VE? Were accuracyevaluations assigned? Are these acceptable?(Attachment B4, Section B4-3e; CH WAC Appendix A,Section A.6.5)CCP-TP-005, Revision 16 PartialVerification, seeObjective EvidenceAKE did not calculate the MPC based on AK/NDE. AKsummaries include general information pertaining totheWMP content of the streams. CCP sometimes calculatesWMP content based on individual drum data, if available.CCP elected to combine combustible and noncombustibledebris from two streams into one (LANL-007). AlthoughLANL continues to differentiate wastes as being combustibleor noncombustible, CCP representatives do not haveconfidence in these values and therefore believe itmoreRevision No.: 2.0AK-18Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidenceappropriate to combine the two streams. CCP oftencombines distinguishable waste streams into largergroupingsto decrease the number of WSPFs needed. In this instance,EPA received no information as to why the sites separated orcontinue to separate the waste based on these constituents(i.e., why LANL distinguishes two separate waste streamswhile CCP does not).NDA-AK DATA SHARING AND COMMUNICATION/PROCEDURALIZATIONAK-39:Are the following bullets addressed with respectto AK-NDA communication and use of AK data by NDApersonnel?•Do procedures require the identification of AK datalimitations?•Are AK data and associated limitations communicatedto NDA personnel and is this required by procedure?•How is AK used by NDA?•Do AK and NDA personnel communicate and agreeabout the use of AK?•Is this agreement proceduralized?(CH WAC, Appendix A)CCP-TP-005, Revision 16,Section 4.4.20PartialVerification, seeObjective EvidenceAK-NDA memoranda for LANL-004, LA-MIN03-NC.001,TA-50 Homogenous Inorganic Solids Non-cemented Waste(AK-004); LA-MHD02.001,238Pu Contaminated MixedHeterogeneous Debris (AK-007), and LA-MHD03.001,CMR Facility Debris (AK-009). AK limitations areidentified on all source documents Attachment 3 (Pu, U, M,C). The AK-NDA memoranda communicate AK data useand limitations to the NDA personnel; AK is used differentlyfor each waste stream (discussed below). Dual signature onAK-NDA memorandum shows that both AK and NDApersonnel are aware of its contents.LA-MIN03-NC.001, TA-50 Homogenous Inorganic SolidsNon-cemented Waste (AK-004):memorandum indicatescomposition highly complex and there are no defaultisotopics—determination of composition determined viameasurement only.LA-MHD02.001,238Pu Contaminated Mixed HeterogeneousDebris (AK-007).This is only MT 83 and is tightlycontrolled by process, so NDA assumes only this instreamwith little consultation with AK.LA-OS-00-01.001, OSRP Sealed Sources (AK-008).OSRcharacterized entirely using AK based on information fromvarious sources, including the NMMSS, source certificates,shipping documents, and manufacturer’s shipping records.No NDA used so there is no NDA-AK communication.Revision No.: 2.0AK-19Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective EvidenceLA-MHD03.001, CMR Facility Debris (AK-009).Wastegenerated from this facility originated from a number ofdifferent laboratory areas and MT types (MT 52, 54,83, 39).The generators documented the specific MT in each wastecontainer for more than 97% of the individual containers(unlike AK-004), so NDA personnel communicate constantlywith AK personnel to obtain drum-specific nuclideassignments.The NDA-AK memoranda have inconsistencies, as listedbelow:1. The LANL-004 NDA-AK memorandum includeseditorial issues with respect to appropriate unitsandinadequate referencing of support documents for specificstatements or conclusions. 2. In the NDA memoranda forLANL-007 and -009, references for formulas or othercalculations are lacking. 3. Tables in all NDA-AKmemoranda are not matched against data in the AKsummaries and attachments to ensure data consistency;specifically, Table 3 in the LANL-009 NDA-AKmemorandum is erroneous and should be revised to indicateexpected (rather than suspected) radionuclides, asthis affectshow site personnel enter the nuclides into the WWIS.AUDITING OF AK RECORDS AND AK DISCREPANCY IDENTIFICATION/RESOLUTIONAK-40:Have internal audits been performed?(Attachment B4, Section B4-3e)CCP-TP-005, Revision 16 YesManagement Assessment Report MA-CCP-0002-05,Maintenance of Acceptable Knowledge Data, July 20,2005.AK-41:Has a waste stream been revoked based either onAK information or reassessment as part ofreconfirmation? If so, was the procedure(s) followed?(Attachment B4, Section B4-4)CCP-TP-005, Revision 16 Yes CCP-AK-LANL-004. Whilenot formally revoked, thepresence of liquid was identified in drums, and thepotentialfor water within already-shipped drums was raised.See VEchecklist for additional information.AK-42:If data consistently indicate discrepancies withacceptable knowledge information, the site increasesCCP-TP-005, Revision 16 PartialVerification, seeNo example available to date. However, sites shouldestablish general criteria for entire stream re-evaluation toRevision No.: 2.0AK-20Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidencesampling, reassesses the materials and processes thatgenerate the waste, and resubmits waste stream profileinformation.(CH WAC Section A.2.2.3; Attachment B4, SectionsB4-3b, B4-3d)Objective Evidence address this requirement, notingthat many streams arerelatively mature with respect to the characterization process.QA OBJECTIVES FOR AK AND OTHER ELEMENTSAK-43:Are acceptable knowledge processesconsistently applied among all generator sites, anddoeseach generator site comply with the following dataqualityrequirements for acceptable knowledge documentation:a. Precision – Precision is not applicable to AK (seeAttachment B4)b. Accuracy – Accuracy is the degree of agreementbetween an observed sample result and the true value.The percentage of waste containers which requirereassignment to a new waste matrix code based on thereevaluation of acceptable knowledge and sampling andanalysis data will be reported as a measure ofacceptable knowledge accuracy. Accuracy based onradionuclide content is typically assessed by comparingmeasured results with AK data.c. Completeness – Completeness is an assessment ofthenumber of waste streams or number of samplescollected to the number of samples determined to beuseable through the data validation process. Theacceptable knowledge record must contain 100 percentof the information specified in Section B4-2. Theusability of the acceptable knowledge information willbe assessed for completeness during audits.d. Comparability – Data are considered comparable whenone set of data can be compared to another set of data.Comparability is ensured through sites meeting theCCP-TP-005, Revision 16 PartialVerification, seeObjective EvidenceAcceptable Knowledge Accuracy Report, LANL No. LA-0S00-01, Lots 1-5, AK Accuracy Report, Los Alamos NationalLaboratory Waste Stream LA-MHD01.01, Lots 1-26(LANL-06), December 20, 2005, Acceptable KnowledgeAccuracy Report: LANL Waste Stream No.LA-MIN03-NC.001, Lots 1-15, dated March 27, 2006. [LANL-004]Development of criteria for reassessment of AK accuracybased on radionuclide results is important, and EPArecommends that CCP develop these criteria. Also,determination of most prevalent nuclides by mass andactivity should be considered (not just mass) as the CH WACdoes not specify which, and CCP should use the mostmeaningful comparison. See item 38 for data limitations..Revision No.: 2.0AK-21Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidencetraining requirements and complying with the minimumstandards outlined for procedures that are used toimplement the acceptable knowledge process. CHWAC Section A.6.5: Additionally, comparison ofmeasured data with AK-derived or -based values, asapplicable, provides a means to assess comparability ona waste stream basis.e. Representativeness – Representativeness expresses thedegree to which sample data accurately and preciselyrepresent characteristics of a population.Representativeness is a qualitative parameter thatwillbe satisfied by ensuring that the process of obtaining,evaluating, and documenting acceptable knowledgeinformation is performed in accordance with theminimum standards established in Section B3. Sitesalso must assess and document the limitations of theacceptable knowledge information used to assign wasteparameters.(Attachment B4, Section B4-3e)AK-44:Does the generator site address quality controlby tracking its performance with regard to the useofacceptable knowledge by: 1) assessing the frequency ofinconsistencies among information, and 2) documentingthe results of acceptable knowledge confirmation throughradiography or visual examination? In addition, theacceptable knowledge process and waste streamdocumentation must be evaluated through internalassessments by quality assurance organizations andassessments by auditors or observers external to theorganization (i.e., CBFO, NMED, EPA).(Section B4-3e)CCP-TP-005, Revision 16 YesCCP-TP-005 Attachment 13, AK Confirmation Checklist(Attachment 13). CCP documents confirmation results viathis checklist. Internal assessments are performed(see ItemAK-40, above).AK-45: Did the generator site implement, ordoes it currently implement, process controls toCCP-TP-005, Revision 16 PartialVerification, seeNCR-LANL-0537-05, NCR-LANL-0742-06, NCR-LANL0803-05, NCR-LANL-0516-06 (stream unclear). It isRevision No.: 2.0AK-22Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective Evidenceensure that prohibited items are documented andmanaged in accordance with site-specificcertification plans and that the followingminimum site specific controls:•Identify the organization(s) responsible forcompliance with administrative controls•Identify the oversight procedures andfrequency of actions to verify compliance withadministrative controls•Develop on-the-job training specific toadministrative control procedures•Ensure that personnel may stop work ifnoncompliance with administrative controls isidentified•Develop a nonconformance process thatcomplies with the requirements in Section B3-13 of the WAP to document and establishcorrective actions•Address controlled changes to WAP-relatedplans or procedures as part of thenonconformance and corrective action process•As part of the corrective action process, assessthe potential time frame of the noncompliance,the potentially affected waste population(s),and the reassessment and recertification ofthose wastes(Attachment B4, Section B4-3b)Objective Evidenceunclear whether Quick or Fast Scan is being used asaprocess control; should include in AK Records. Itshould benoted that CCP AK personnel have noted little confidence insite process controls to eliminate prohibited itemssuch aswater, and have couched this discomfort in AK documentsby making relatively noncommittal statements regardingprohibited item occurrence.Revision No.: 2.0AK-23Date of Revision: 12/02/05ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Dates: May 23-25, 2006Required Technical ElementsProcedureLocation/AdequacyVerification ofActivityExamples of Objective EvidenceAK-46:Does the generator site document, justify, andconsistently delineate waste streams... based on site-specific permit requirements or state-enforcedagreements? How do these agreements impact wastecharacterization?(Section B4-4)CCP-TP-005, Revision 16 YesThe TWBIR delineates Waste Profiles that are sometimesused as a starting point for assigning and determining wastestreams. No state-enforced agreements or permitrequirements were identified during the inspectionthatimpact waste stream determination.Revision No.: 1.0HENC#1-1Date of Revision: 10/20/05ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSYSTEM DESCRIPTIONIdentify the NDA system by name, location,and number, as appropriate.NA NA The system is the LANL-HENC #1, previously known asthe MCS HENC. It is housed in Building No.,54506(trailer) located in Technical Area 54 (TA 54), Area G, Pad10 at LANL. The system has not been moved since the lastEPA inspection.Y Visual observation of the LANLHENC #1 system in place at Area Gof TA-54 at LANL.Describe the system’s operational historyincluding deployment at other DOE sites.NA NA The LANL-HENC #1 was initially deployed at LLNL andwas 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 Waste Characterization Reports:EPA Inspection Nos. EPA-LANLCCP-05.05.8, May 2005; EPA-LLNLCCP-05.04-8, May 2004For systems that have been deployed atmultiple DOE sites, document pertinentaspects 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 fromthe system calibration in response to PDP related problems;and, recalculation of the efficiency to address gammaattenuation in the calibration sources.Y Visual inspection of LANL HENC #1;Supplemental Calibration Report forthe MCS HENC #1 Including PassiveNeutron and Gamma SpectrometerCalibration and Confirmation,Revision 4SYSTEM PERFORMANCEIdentify the period of performance relevant tothis inspection and if this NDA system hasprior EPA approval(s).NA NA The period of performance relevant to this inspection isApril 15, 2005 to March 31, 2006, and March 31, 2006 toMarch 6, 2007.Y EPA Inspection Letters to D. Moody:April 6, 2006, outlining scope of EPALANL-CCP-05.06-8; February 8,2007, outlining scope of follow-upinspection at LANL-CCPIdentify the number of waste containers thissystem assayed during the period ofperformance. Of these, indicate how manyBatch Data Reports (BDRs) were assembled.Of the assembled BDRs, indicate how manyhave been promoted through Project LevelReview and are available for evaluationduring this inspection.NA NA During the time period of interest, 3589 assays of 55-gallon(208 liter) drums have been conducted, including PDPdrums and EPA replicates. These results have beencompiled in a total of 351 BDRs.Y Information provided by S. Stanfieldduring inspection.Revision No.: 1.0HENC#1-2Date of Revision: 10/20/05ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceGENERAL REPORTING REQUIREMENTSAssay systems must report quantitativevalues and uncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Quantitative values and uncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs are reported.Y BDRs LANDA0124,LANDA0361, 1LANDA0390,LANDA0227Each container characterized and intendedfor disposal at WIPP must contain TRUwaste.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Containers assayed for WIPP are TRUwaste, i.e., they contain >100 nCi/g oftransuranic alpha activity.Y BDRs LANDA0124,LANDA0361, 1LANDA0390,LANDA0227NDA instruments and procedures areappropriate for the waste streams beingassayed.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The LANL HENC #1 and supportingprocedures are appropriate for the wastescurrently being assayed.Y BDRs LANDA0124,LANDA0361, 1LANDA0390,LANDA0227NDA instruments and procedures result inunbiased values for the cumulative activity ofthe WIPP radionuclide inventory.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The radionuclide values produced by theLANL HENC #1 are appropriate forsupporting the cumulative activity of theWIPP radionuclide inventory.Y BDRs LANDA0124,LANDA0361, 1LANDA0390,LANDA0227Some radionuclides are derived by theapplication of scaling factors or correlationtechniques. Identify all radionuclides thatare quantified in this manner.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11234U,242Pu, and90Sr are derived by theapplication of scaling and/or correlationfactors.Y CCP-TP-103, Revision 6,Appendix 1, pages 15 - 24Assess the technical adequacy of thecalculations involving the application ofscaling factors and/or correlation techniques.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The scaling and/or correlation factors citedin the preceding checklist item aretechnically adequate and appropriatelydocumented.Y CCP-TP-103, Revision 6,Appendix 1, pages 15 - 24Identify the procedures that govern thisfunction and where the results of thesecalculations are documented.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The procedure that governs the applicationof scaling factors is identified and the resultsof these calculations are documented.Y CCP-TP-103, Revision 6,Appendix 1, pages 15 – 24;BDRs LANDA0124,LANDA0361, 1LANDA0390,LANDA0227Revision No.: 1.0HENC#1-3Date of Revision: 10/20/05ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceACCEPTABLE KNOWLEDGE (AK)If isotopic ratios based on AK are used, thevalues are qualified by confirmatory testing.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Isotopic ratios used in quantifyingradionuclides are qualified by confirmatorytesting when AK is used.Y CCP-TP-103, Revision 6,Appendix 1, pages 15 – 24Do NDA personnel use AK-derived isotopicvalues to calculate radionuclide values? Ifso, is this function performed according to aformal procedure? Assess the technicaladequacy of this process(s).Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11NDA personnel using AK derived isotopicvalues to calculate radionuclide values do soaccording to a formal procedure, thetechnical adequacy of which is adequate.Y CCP-TP-103, Revision 6,Appendix 1, pages 15 – 24Identify the procedure and where the resultsof these calculations are documented.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The procedure for AK calculations isidentified and results of these calculationsare documented in the LANL HENC #1BDRs.Y CCP-TP-103, Revision 6,Appendix 1, pages 15 – 24;BDRs LANDA0124,LANDA0361, 1LANDA0390,LANDA0227ISOTOPIC DETERMINATIONIdentify the radionuclides that are measureddirectly and the specific radiation type(gamma, AN, or PN) that is measured.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11240PuEFFis directly measured based onpassive neutron emission. Otherradionuclides (238Pu,239Pu,241Am, etc.) arederived from240PuEFFbased on isotopicsdetermined by gamma-based MGA or by adirect gamma determination, as appropriate.YCalibration Report for the MCSHENC #1 Including PassiveNeutron and GammaSpectrometer Calibration andConfirmation,Revision 2Identify the method(s) used to derive theisotopic contribution for the unmeasuredradionuclides, e.g., MGA, PC FRAM orother technique.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11MGA is used to derive the isotopiccontribution for unmeasured radionuclides.All containers (100%) are subject to routinegamma assay, although useable data may notbe available for each container. AK-basedisotopic values are used in the absence ofuseable MGA values when data to supportAK are documented in AK/NDAMemoranda.YCalibration Report for the MCSHENC #1 Including PassiveNeutron and GammaSpectrometer Calibration andConfirmation, Revision 2; CCPAK-LANL-009 AK/NDAMemorandum, Revision 0;Memorandum from W. Estill re:Evaluation of the RadiologicalCharacterization of LA-MIN03-NC Waste StreamRevision No.: 1.0HENC#1-4Date of Revision: 10/20/05ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceLOWER LEVEL OF DETECTION (LLD)The LLD for each NDA system must bedetermined. For multi-modal systems thismay require a separate determination for eachmode, i.e., active neutron, passive neutron,and gamma.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The LLD for the LANL HENC#1 has beendetermined for the passive neutron andgamma mode.Y MCS-HENC#1-NDA-1002,Revision 4, Tables 7a, 7b, 7c and7dSite-specific environmental backgrounds andcontainer-specific interferences must beaccounted for in LLD determinations.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Site-specific environmental backgroundsand container specific interferences areaccounted for in LLD determinations.Y MCS-HENC#1-NDA-1002,NDA instruments performing TRU/NonTRU waste discrimination measurements arerequired to have a LLD no greater than 100nCi/g.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Both the passive neutron and gammamodes have LLDs less than 100 nCi/g fordebris and solid matrices.Y MCS-HENC#1-NDA-1002,Revision 4, Tables 7a, 7b, 7c and7dThe technical basis and derivation for LLDsmust be adequate and appropriatelydocumented.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The technical bases and derivation for thepassive neutron and gamma modes aretechnically adequate and appropriatelydocumented.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4,Section 7For radionuclides that are not determinedprimarily by measurement, an LLD analog,i.e., a reporting threshold, must be used whenit is technically feasible. Identify allinstances when this occurs and the form ofthe documentation of these activities.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11A reporting threshold (LLD analog) hasbeen determined for90Sr,234U, and242Pu.These are technically adequate andappropriately documented.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4,Section 7Identify any/all instances where an LLDvalue for anon-measuredradionuclide is notprovided basis on a lack of technicalfeasibility.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11There are no instances where an LLD valuefor anon-measuredradionuclide is notprovided based on a lack of technicalfeasibility are documented.NA Not ApplicableRevision No.: 1.0HENC#1-5Date of Revision: 10/20/05ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceAre LLD values container/assay eventspecific or are typical LLD values applied toa class or type of wastes, i.e., those withsimilar attributes? If LLD values are notcontainer/assay event specific, identify theattributes or characteristics whereby wastecontainers are grouped.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The LLD values listed in MCS-HENC#1-NDA-1002, Revision 4, Tables 7a, 7b, 7c,and 7d are typical values that demonstratethe LANL HENC #1’s sensitivity with theunderstanding that these values listed maynot be obtained for every assay event.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4,Section 7TOTAL MEASUREMENT UNCERTAINTY (TMU)The method used to calculate the TMU for allrequired quantities must be documented andtechnically justified.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The method used to calculate the TMU forthe LANL HENC #1 is documented andtechnically justified.YTotal Measurement Uncertaintyfor the MCS HENC #1 WithIntegral Gamma Spectrometer,Document #CI-HENC-TMU101, Revision 1, March 24, 2005TMU determination accounts for all sourcesof uncertainty, specifically:•Random errors•Calibration•Isotopic determination•Matrix inhomogeneity•Difference between calibrationassumptions and actual waste•Non uniform source distribution•End effects•Self absorption•Transmission source•Self shielding•Neutron multiplicationY CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The TMU determined and documented forthe LANL HENC #1 includes all requiredelements.YTotal Measurement Uncertaintyfor the MCS HENC #1 WithIntegral Gamma Spectrometer,Document #CI-HENC-TMU101, Revision 1, March 24, 2005Methods to determine TMU must bedocumented, reviewed, and approved byCBFO for each NDA instrument.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11CBFO Technical Specialist D. Stuenkelconfirmed that the TMU report had beenreviewed and approved.Y Oral communication with D.Stuenkel and CCP issuance ofcontrolled copy of TMU report.Revision No.: 1.0HENC#1-6Date of Revision: 10/20/05ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSYSTEM CALIBRATIONEach NDA instrument must be calibratedbefore its initial use. Determine the date ofthe system’s calibration of record and wherethis is documented.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The LANL HENC #1 was originallycalibrated in 2004. There have been fourrevisions to the calibration report and eachwas available. The system’s currentcalibration is documented in Revision 4.The passive neutron and gamma calibrationsare technically adequate.YCalibration Report for the MCSHENC #1 Including PassiveNeutron and GammaSpectrometer Calibration andConfirmation, Revision 2;Supplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4The range of applicability of the system’scalibration(s) must be specified in siteprocedures or other formal documentation.Identify the manner in which the range isexpressed, i.e., curies or Pu/SNM mass foractivity and salient physical characteristicsfor matrix.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The operating range is the system LLD to16.278 g240PuEFFfor passive neutron; LLDto 217 g Pu total for gamma, but gammarange is best expressed as 122 to 1408 keV,limited by dead time. Matrix density rangefor gamma is 0.018 to 1.64 g/cc and issuitable to S3000 and S5000 wastes.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4Any matrix/source surrogate wastecombinations must be representative of theactivity ranges and relevant waste matrixcharacteristics currently in use or planned foruse by the system. The system must becalibrated to 100% recovery.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Matrix/source waste combinations arerepresentative of routine samples currentlymeasured by the LANL HENC #1. Thesystem is calibrated to 100% recovery.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4The use of consensus standards forcalibration is required, when such standardsexist. If consensus standards do not exist,the calibration technique must be approvedby CBFO.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Consensus standards have been used forcalibrating the LANL HENC #1, seechecklist item below.YCalibration Report for the MCSHENC #1 Including PassiveNeutron and GammaSpectrometer Calibration andConfirmation, Revision 2Revision No.: 1.0HENC#1-7Date of Revision: 10/20/05ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceIdentify the specific consensus standards thatwere used for the system calibration or, intheir absence, the alternate calibrationtechnique. Evaluate the CBFO approval ofthe alternate technique.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The specific consensus standards used forcalibration are: ASTM-C1030-95, ASTMC-1133-96, ASTM C-1207 and ASTM C1500.YCalibration Report for the MCSHENC #1 Including PassiveNeutron and GammaSpectrometer Calibration andConfirmation, Revision 2Primary standards must be obtained fromsuppliers maintaining a nationally accreditedmeasurement program. Identify thenationally accredited measurement program.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Primary gamma standards have beenobtained a commercial supplier; Pu sourcesfor passive neutron calibration were obtainedfrom R. Marshall’s group in the LANLCMR. Both organizations maintain anationally accredited measurement program.YCalibration Report for the MCSHENC #1 Including PassiveNeutron and GammaSpectrometer Calibration andConfirmation, Revision 2List the standards used for calibration andverify the pedigree of each standard.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The calibration standards are listed and thepedigree of each has been verified.YCalibration Report for the MCSHENC #1 Including PassiveNeutron and GammaSpectrometer Calibration andConfirmation, Revision 2CALIBRATION VERIFICATION & CONFIRMATIONVerification of an NDA instrument’scalibration must be performed after any ofthe following occurrences: major systemrepairs and/or modifications, replacement ofthe system’s components, significantchanges to the system’s software, andrelocation of the system.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The LANL HENC #1 has been recalibratedseveral times since the system’s initialcalibration at LANL in 2004. Eachrecalibration has been confirmed anddocumented appropriately as discussedabove in this checklist.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4Recalibration of the system must occur if thecalibration verification demonstrates that thesystem’s response has significantly changed.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Recalibration of the system has beenperformed if the calibration verificationdemonstrated that the system’s response hassignificantly changed and the recalibrationYSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andRevision No.: 1.0HENC#1-8Date of Revision: 10/20/05ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidencehas been documented.Confirmation, Revision 4The system calibration must be confirmed byperforming replicate measurements of a noninterfering matrix.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The LANL HENC #1’s calibration has beenconfirmed and documented appropriatelyfollowing each calibration.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4Replicate measurements must be performedwith containers of the same nominal size andaccording to the same procedures used foractual waste assays.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Replicate measurements have beenperformed with 55-gallon (208 liter) drumsand the operating and data reviewprocedures that are used for routine wasteassays.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4; CCPTP-064; CCP-TP-063; CCP-TP103Replicate measurements must be performedusing nationally recognized standards orstandards derived from nationally recognizedstandards that span the range of use of theinstrument with respect to disintegration rateand/or matrix effects. Identify all standardsthat were used and indicate their application(verification or confirmation).Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Replicate measurements have beenperformed with appropriate standards thatspan the operational range of use of theLANL HENC #1 with respect to activity andmatrix. All standards that were used forconfirmation have been identified in thecalibration report. See next checklist item,below.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4Identify the nationally accreditedmeasurement program. List the standardsused for verification/confirmation and verifythe pedigree of each standard.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Standards are listed in the calibration report.The LANL program’s standards are derivedfrom nationally recognized NIST standards.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4The standards used for calibrationconfirmation must not be the same sources asY CCP-PO-001, CCP TransuranicWaste Certification Plan,The standards used for calibrationconfirmation are different from those usedYSupplemental Calibration Reportfor the MCS HENC #1 IncludingRevision No.: 1.0HENC#1-9Date of Revision: 10/20/05ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidencethose used for the system’s calibration ofrecord.Revision 11 for the system’s calibration of record.Passive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4Requirements 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 precisionand∀30% for accuracy.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Requirements for accuracy and precisionhave been met as specified in DOE/WIPP02-3122, Appendix A, Table A-3.2 forprecision and∀30% for accuracy.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4Revision No.: 1.0HENC#1-10Date of Revision: 10/20/05ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceQUALITY CONTROLAll radioassay functions and data validationmust be performed by appropriately trainedand qualified personnel.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11All radioassay functions and data validationhave been performed by personnel who areappropriately trained and qualified.Y CCP-LANL List of QualifiedIndividuals, 5/22/2006, 10:30AM provided during inspectionIdentify the name, title, and function of allpersonnel performing NDA data validation.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The name, title and function of all NDApersonnel performing data validation for theLANL HENC#1 are documented.Y CCP-LANL List of QualifiedIndividuals, 5/22/2006, 10:30AM provided during inspectionRequalification of personnel must be basedon evidence of continued satisfactoryperformance and must be performed at leastevery two years.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Requalification of personnel be based onevidence of continued satisfactoryperformance has been performed at leastevery two years.Y CCP-LANL List of QualifiedIndividuals, 5/22/2006, 10:30AM provided during inspectionThe site must participate in relevantmeasurement comparison programssponsored or approved by CBFO, includingthe NDA PDP.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The site has participated successfully inCycle 13A of the CBFO sponsored NDAPDP. The conditional approval of theLANL HENC #1 effective in July 2006 wasmade permanent upon successfulimplementation of the LANL CorrectiveAction Plan that addressed the Cycle 13APDP failures for the glass matrix containerwith HS Pu.Y July 19, 2006 Memorandum fromM. Brown to C. FesmireScoringResults – Primary Cycle 13ANondestructive Assay PDP;January 19, 2007 Memorandumfrom M. Brown to C. Fesmireupdating status based on resultsof NDA PDP Primary Cycle 13ABACKGROUND AND PERFORMANCE CHECKSAssay system background measurementsmust be taken daily, unless otherwiseapproved by CBFO. Determine the form ofCBFO approval documentation of thealternate approach to backgrounds, ifapplicable. Contributions to backgroundsfrom nearby radiation sources must beY CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Daily background are taken and recorded.Contributions to backgrounds from highactivity containers that are stored or stagedin proximity to the LANL HENC #1 Trailerdo affect the background but NDA personnelcontrol this.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4; BDRsLANDA0124, LANDA0361,Revision No.: 1.0HENC#1-11Date of Revision: 10/20/05ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidencecarefully controlled, or more frequentbackgrounds must be measured.1LANDA0390, LANDA0227Assess how often background radiation wasproblematic to the extent that measurementpersonnel had to make adjustments.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Background control charts are used todocument the system’s performance overtime.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4; BDRsLANDA0124, LANDA0361,1LANDA0390, LANDA0227Identify the criteria used to evaluateinstrument backgrounds and assess thetechnical adequacy of this criterion, i.e.,statistical or administrative.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Backgrounds are evaluated againstpredetermined upper and lower boundariesand are non-statistical in nature. Initialcontrol limits are based on the system’s firstmonth of operations, and each day’smeasurements are automatically compared tothe established limits.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4; BDRsLANDA0124, LANDA0361,1LANDA0390, LANDA0227Identify the number of data points required toderive the initial control limit. At whatinterval(s) will new limits be calculated?Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Initial control limits for all performancemeasurements were based on sixmeasurements. Limits will be recalculatedas more data are acquired or the system isrecalibrated.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4System performance checks must beperformed at least once per operational day.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Performance checks have been performed atleast once per operational day and all checkshave been documented.Y BDRs LANDA0124,LANDA0361, 1LANDA0390,LANDA0227System performance checks must include, asapplicable, efficiency, matrix correctionchecks, and systems peak position andresolution for spectrometric systems.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Performance checks include: 121 keV peakcentroid and FWHM, 964 peak centroid andFWHM and weighted average of152Euactivity.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andRevision No.: 1.0HENC#1-12Date of Revision: 10/20/05ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceConfirmation, Revision 4; BDRsLANDA0124, LANDA0361,1LANDA0390, LANDA0227At a minimum of once per operational weekan interfering matrix must be assayed toassess the long-term stability of the NDAinstrument and its matrix corrections andhow this performance is documented.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Two matrix drums are available, a debris andhomogeneous solid. They are used with avariety of PDP-type Pu sources that span arange of activity. The acceptance criteria forthe Weekly Interfering Matrix checks werenot apparent during this inspection.YSupplemental Calibration Reportfor the MCS HENC #1 IncludingPassive Neutron and GammaSpectrometer Calibration andConfirmation, Revision 4; BDRsLANDA0124, LANDA0361,1LANDA0390, LANDA0227Interfering surrogate waste matrices must beconstructed in such a way that the salientmatrix characteristics do not change overtime.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Interfering surrogate waste matrices havebeen constructed such that the salient matrixcharacteristics do not change over time.Y Visual examination of matrixdrums, interviews with LANLCCP NDA personnel, andevaluation of PDP submittalsThe radionuclide sources used forperformance checks must be long-lived andof sufficient strength (activity) to providestatistically sufficient results over a shortmeasurement time.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The241Am,152Eu, and Pu sources used forperformance checks are of sufficient activityto provide statistically sufficient results overa short measurement time.Y Interviews with LANL-CCPNDA personnel and evaluation ofLANL HENC #1 performancedata and LANL HENC #1BDRs.Radioactive sources are decay corrected as afunction of their physical half-life, asappropriate, specifically133Ba,252Cf,137Cs,75Se and109Cd.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The241Am and152Eu sources are decaycorrected as a function of their physical halflife. Decay correction is not applicable to239Pu sources.Y Interviews with LANL-CCPNDA personnel and evaluation ofLANL HENC #1 performancedata and BDRs.Performance checks must be quantitative andbased on 2 and 3 sigma limits.CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Limits are based onStudentt-testfor 95%(warning limit) and 99% (control limit)confidence intervals.Y CCP-TP-103;SupplementalCalibration Report for the MCSHENC #1 Including PassiveNeutron and GammaSpectrometer Calibration andRevision No.: 1.0HENC#1-13Date of Revision: 10/20/05ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceConfirmation, Revision 4; LANLHENC #1 BDRs LANDA0124,LANDA0361, 1LANDA0390,LANDA0227Revision No.: 1.0HENC#1-14Date of Revision: 10/20/05ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceDATA MANAGEMENTAll radioassay data must be reviewed andapproved by qualified personnel before beingreported to WWIS.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Individual Radioassay Data Sheets(RDS) were reviewed, as indicated. Allwere acceptable.Y LANL HENC #1 BDRs:LANDA0124, LANDA0361,1LANDA0390, LANDA0227Identify the name, title, and function of theindividual(s) performing technical reviewand approval of NDA BRDs.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The name, title and function of theindividual(s) performing technicalreview and approval of NDA BRDs aredocumented.Y LANL HENC #1 BDRs:LANDA0124, LANDA0361,1LANDA0390, LANDA0227Radioassay BDRs must consist of thefollowing elements:•Testing facility name, testing batchnumber, container numbers, andsignature of the Site Project Officer(SPO) or designee(s)•Table of Contents•Background and performance check dataor control charts for the relevant timeperiod•Data validation per the QAPD and siteprocedures•Separate testing report sheets for eachcontainer.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The LANL HENC #1 BRDs reviewedduring this inspection contained allrequired elements.Y LANL HENC #1 BDRs:LANDA0124, LANDA0361,1LANDA0390, LANDA0227Revision No.: 1.0HENC#1-15Date of Revision: 10/20/05ATTACHMENT A.2: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #1 (LANL HENC #1)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceRadioassay data sheets must include:•Title “Radioassay Data Sheet”•Method/procedure used•Date of radioassay•Activities and associated TMU forindividual radionuclides•TRU alpha concentration and itsassociated TMU•Operator signature•Reviewer signatureY CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The LANL HENC #1 RDSs evaluatedduring this inspection included allrequired elements.Y Reviewed RDSs as follows:HENC #1 BDR Container No.LANDA0361: S844320, S3609LANDA0124: 60706, 591291LANDA0390: 57014, 56897The following nonpermanent records must bemaintained at the radioassay-testing facilityor forwarded to the site project office:•Testing batch reports•All raw data, including instrumentreadouts, calculation records, andradioassay QC results•All applicable instrument calibrationreportsY CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Nonpermanent records are maintainedin the LANL HENC #1 trailer in TA-54,Area G, and all raw data are included ontwo compact discs that are submittedwith each BDR to the CCP office.Y Interviews with LANL HENC #1operator and other LANL-CCPNDA personnelRevision No.: 1.0HENC#2-1Date of Revision: 10/20/05ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSYSTEM DESCRIPTIONIdentify the NDA system by name, location,and number, as appropriate.NA NA The system is the LANL-HENC #2 and is locatedatTechnical Area 54 (TA 54), Building 498, Area G, Pad 10 atLANL. This is the first EPA inspection of this system.Y Visual observation of the LANLHENC #2 system in place at AreaG of TA-54 at LANLDescribe the system’s operational history,including deployment at other DOE sites.NA NA The LANL-HENC #2 was initially deployed at LANL andwas previously operated under the LANL WIPP program.YCalibration Report for HENC #2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 0For systems that have been deployed atmultiple DOE sites, document pertinentaspects 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 Visual inspection of LANL HENC#2;Calibration Report for HENC#2 Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 0SYSTEM PERFORMANCEIdentify the period of performance relevant tothis inspection and if this NDA system hasprior EPA approval(s).NA NA The period of performance relevant to this inspection is thesystem’s initial calibration to March 31, 2006, andMarch 31,2006 to March 6, 2007Y EPA Inspection Letters to D.Moody: April 6, 2006, outliningscope of EPA-LANL-CCP-05.06-8;February 8, 2007, outlining scopeof follow-up inspection at LANLCCPIdentify the number of waste containers thissystem assayed during the period ofperformance. Of these, indicate how manyBDRs were assembled. Of the assembledBDRs, indicate how many have beenpromoted through Project Level Review andare available for evaluation during thisinspection.NA NA During the time period of interest 218 assaysof 55-gallon(208 liter) drums have been conducted, including PDP drumsand EPA replicates. These results have been compiled in atotal of 20 BDRs.Y Information provided by S.Stanfield during inspectionRevision No.: 1.0HENC#2-2Date of Revision: 10/20/05ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceGENERAL REPORTING REQUIREMENTSAssay systems must report quantitativevalues and uncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs.Y CCP-PO-001,CCP TransuranicWaste Certification Plan,Revision 11Quantitative values and uncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs are reported.Y HENC #2 BDRs 2LANDA0002,2LANDA0005, 2LANDA0010,2LANDA0006Each container characterized and intendedfor disposal at WIPP must contain TRUwaste.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Containers assayed for WIPP are TRUwaste, i.e., they contain >100 nCi/g oftransuranic alpha activity.Y HENC #2 BDRs 2LANDA0002,2LANDA0005, 2LANDA0010,2LANDA0006NDA instruments and procedures areappropriate for the waste streams beingassayed.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The LANL HENC #2 and supportingprocedures are appropriate for the wastescurrently being assayed.Y HENC #2 BDRs 2LANDA0002,2LANDA0005, 2LANDA0010,2LANDA0006NDA instruments and procedures result inunbiased values for the cumulative activity ofthe WIPP radionuclide inventory.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The radionuclide values produced by theLANL HENC #2 are appropriate forsupporting the cumulative activity of theWIPP radionuclide inventory.Y HENC #2 BDRs 2LANDA0002,2LANDA0005, 2LANDA0010,2LANDA0006Some radionuclides are derived by theapplication of scaling factors or correlationtechniques. Identify all radionuclides thatare quantified in this manner.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11234U,242Pu, and90Sr are derived by theapplication of scaling and/or correlationfactors.Y CCP-TP-103, Revision 6,Appendix 1, pages 15 - 24Assess the technical adequacy of thecalculations involving the application ofscaling factors and/or correlation techniques.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The scaling and/or correlation factors citedin the preceding checklist item aretechnically adequate and appropriatelydocumented.Y CCP-TP-103, Revision 6,Appendix 1, pages 15 - 24Identify the procedures that govern thisfunction and where the results of thesecalculations are documented.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The procedure that governs the applicationof scaling factors is identified and the resultsof these calculations are documented.Y CCP-TP-103, Revision 6,Appendix 1, pages 15 – 24;HENC #2 BDRs 2LANDA0002,2LANDA0005, 2LANDA0010,2LANDA0006Revision No.: 1.0HENC#2-3Date of Revision: 10/20/05ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceACCEPTABLE KNOWLEDGE (AK)If isotopic ratios based on AK are used, thevalues are qualified by confirmatory testing.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Isotopic ratios used in quantifyingradionuclides are qualified by confirmatorytesting when AK is used.Y CCP-TP-103, Revision 6,Appendix 1, pages 15 – 24Do NDA personnel use A- derived isotopicvalues to calculate radionuclide values? Ifso, is this function performed according to aformal procedure? Assess the technicaladequacy of this process(s).Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11NDA personnel using AK-derived isotopicvalues to calculate radionuclide values do soaccording to a formal procedure, thetechnical adequacy of which is adequate.Y CCP-TP-103, Revision 6,Appendix 1, pages 15 – 24Identify the procedure and where the resultsof these calculations are documented.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The procedure for AK calculations isidentified and results of these calculationsare documented in the LANL HENC #2BDRs.Y CCP-TP-103, Revision 6,Appendix 1, pages 15 – 24;HENC #2 BDRs 2LANDA0002,2LANDA0005, 2LANDA0010,2LANDA0006ISOTOPIC DETERMINATIONIdentify the radionuclides that are measureddirectly and the specific radiation type(gamma, AN or PN) that is measured.Y CCP-PO-001CCP TransuranicWaste Certification Plan,Revision 11240PuEFFis directly measured based onpassive neutron emission. Otherradionuclides (238Pu,239, Pu242, Am241, etc.)are derived from240PuEFFbased on isotopicsdetermined by gamma-based MGA or by adirect gamma determination, as appropriate.YCalibration Report for HENC #2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 0Identify the method(s) used to derive theisotopic contribution for the unmeasuredradionuclides, e.g., MGA, PC FRAM, orother technique.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11MGA is used to derive the isotopiccontribution for unmeasured radionuclides.All containers (100%) are subject to routinegamma assay, although useable data may notbe available for each container. AK-basedisotopic values are used in the absence ofuseable MGA values when data to supportAK are documented in AK/NDAMemoranda.Y CCP-AK-LANL-009 AK/NDAMemorandum, Revision 0;Calibration Report for HENC #2Including Passive Neutron andGamma Spectrometer Calibrationand Confirmation, Revision 0;Memorandum from W. Estill re:Evaluation of the RadiologicalCharacterization of LA-MIN03-NC Waste StreamRevision No.: 1.0HENC#2-4Date of Revision: 10/20/05ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceLOWER LEVEL OF DETECTION (LLD)The LLD for each NDA system must bedetermined. For multimodal systems thismay require a separate determination for eachmode, i.e., active neutron, passive neutron,and gamma.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The LLD for the LANL HENC#1 has beendetermined for the passive neutron andgamma mode.Y MCS-HENC#1-NDA-1002,Revision 0, Tables 8a, 8b, 8c, and8dSite-specific environmental backgrounds andcontainer-specific interferences must beaccounted for in LLD determinations.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Site-specific environmental backgroundsand container specific interferences areaccounted for in LLD determinations.Y MCS-HENC#1-NDA-1002,Revision 0NDA instruments performing TRU/NonTRU waste discrimination measurements arerequired to have an LLD no greater than 100nCi/g.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Both the passive neutron and gammamodes have LLDs less than 100 nCi/g fordebris and solid matrices.Y MCS-HENC#1-NDA-1002,Revision 0, Tables 8a, 8b, 8c, and8dThe technical basis and derivation for LLDsmust be adequate and appropriatelydocumented.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The technical bases and derivation for thepassive neutron and gamma modes aretechnically adequate and appropriatelydocumented.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0For radionuclides that are not determinedprimarily by measurement, an LLD analog,i.e., a reporting threshold, must be used whenit is technically feasible. Identify allinstances when this occurs and the form ofthe documentation of these activities.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11A reporting threshold (LLD analog) hasbeen determined for90Sr,234U, and242Pu.These are technically adequate andappropriately documented.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0Identify any/all instances where an LLDvalue for anon-measuredradionuclide is notprovided basis on a lack of technicalfeasibility.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11There are no instances where an LLD valuefor anon-measuredradionuclide is notprovided based on a lack of technicalfeasibility are documented.NA Not ApplicableRevision No.: 1.0HENC#2-5Date of Revision: 10/20/05ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceAre LLD values container/assay eventspecific or are typical LLD values applied toa class or type of wastes, i.e., those withsimilar attributes? If LLD values are notcontainer/assay event specific, identify theattributes or characteristics whereby wastecontainers are grouped.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The LLD values listed in MCS-HENC#2-NDA-1002, Revision 0, Tables 8a, 8b, 8c,and 8d are typical values that demonstratethe LANL HENC #2’s sensitivity with theunderstanding that these values listed maynot be obtained for every assay event.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0TOTAL MEASUREMENT UNCERTAINTY (TMU)The method used to calculate the TMU for allrequired quantities must be documented andtechnically justified.CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The method used to calculate the TMU forthe LANL HENC #2 is documented andtechnically justified.Y LANL-HENC2-TMU-101,TotalMeasurement Uncertainty for theHENC #2 with Integral GammaSpectrometer, Revision 0, April10, 2006TMU determination accounts for all sourcesof uncertainty, specifically:•Random errors•Calibration•Isotopic determination•Matrix inhomogeneity•Difference between calibrationassumptions and actual waste•Non-uniform source distribution•End effects•Self absorption•Transmission source•Self shielding•Neutron multiplicationY CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The LANL HENC #2 TMU addresses allrequired elements.Y LANL-HENC2-TMU-101,TotalMeasurement Uncertainty for theHENC #2 with Integral GammaSpectrometer, Revision 0, April10, 2006Methods to determine TMU must bedocumented, reviewed and approved byCBFO for each NDA instrument.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11CBFO Technical Specialist D. Stuenkelconfirmed that the TMU report had beenreviewed and approved.Y Oral communication with D.Stuenkel and issuance ofcontrolled copy of TMU reportRevision No.: 1.0HENC#2-6Date of Revision: 10/20/05ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSYSTEM CALIBRATIONEach NDA instrument must be calibratedbefore its initial use. Determine the date ofthe system’s calibration of record and wherethis is documented.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The LANL HENC #2 was originally for bothgamma and passive neutron in February2006. The passive neutron and gammacalibrations are technically adequate.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0The range of applicability of the system’scalibration(s) must be specified in siteprocedures or other formal documentation.Identify the manner in which the range isexpressed, i.e., curies or Pu/SNM mass foractivity and salient physical characteristicsfor matrix.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The operating range is the system LLD to16.29 g240PuEFFfor passive neutron; LLD to217 g Pu total for gamma, but gamma rangeis best expressed as ~50 to 1228 keV,limited by dead time. Matrix density rangefor gamma is 0.018 to 1.64 g/cc and issuitable to S3000 and S5000 wastes.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0Any matrix/source surrogate wastecombinations must be representative of theactivity ranges and relevant waste matrixcharacteristics currently in use or planned foruse by the system. The system must becalibrated to 100% recovery.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Matrix/source waste combinations arerepresentative of routine samples currentlymeasured by the LANL HENC #2. Thesystem is calibrated to 100% recovery.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0The use of consensus standards forcalibration is required, when such standardsexist. If consensus standards do not exist,the calibration technique must be approvedby CBFO.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Consensus standards have been used forcalibrating the LANL HENC #2, seechecklist item below.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0Revision No.: 1.0HENC#2-7Date of Revision: 10/20/05ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceIdentify the specific consensus standards thatwere used for the system calibration or, intheir absence, the alternate calibrationtechnique. Evaluate the CBFO approval ofthe alternate technique.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The specific consensus standards used forcalibration are: ASTM-C1030-95, ASTMC-1133-96, ASTM C-1207 and ASTM C1500.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0Primary standards must be obtained fromsuppliers maintaining a nationally accreditedmeasurement program. Identify thenationally accredited measurement program.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Primary gamma standards have beenobtained from a commercial supplier; Pusources for passive neutron calibration wereobtained from R. Marshall’s group in theLANL CMR. Both organizations maintain anationally accredited measurement program.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0List the standards used for calibration andverify the pedigree of each standard.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The gamma and neutron calibrationstandards are listed and the pedigree of eachhas been verified.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0CALIBRATION VERIFICATION & CONFIRMATIONVerification of an NDA instrument’scalibration must be performed after any ofthe following occurrences: major systemrepairs and/or modifications, replacement ofthe system’s components, significantchanges to the system’s software, andrelocation of the system.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The LANL HENC #2 has not beenrecalibrated since the system’s initialcalibration at LANL in 2006.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0Revision No.: 1.0HENC#2-8Date of Revision: 10/20/05ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceRecalibration of the system must occur if thecalibration verification demonstrates that thesystem’s response has significantly changed.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The system has not been recalibrated. Therehave been 7 calibration verifications forperformance-related reasons between 6-21-06 and 3-5-07, see Section 8.2, LANLHENC#2, (5).YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0The system calibration must be confirmed byperforming replicate measurements of a noninterfering matrix.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The LANL HENC #2’s calibration has beenconfirmed and documented appropriatelyfollowing each calibration.Calibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0Replicate measurements must be performedwith containers of the same nominal size andaccording to the same procedures used foractual waste assays.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Replicate measurements have beenperformed with 55-gallon (208 liter) drumsand the operating and data reviewprocedures that are used for routine wasteassays.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0; CCP-TP-064; CCPTP-063; CCP-TP-103Replicate measurements must be performedusing nationally recognized standards orstandards derived from nationally recognizedstandards that span the range of use of theinstrument with respect to disintegration rateand/or matrix effects. Identify all standardsthat were used and indicate their application(verification or confirmation).Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Replicate measurements have beenperformed using nationally recognizedstandards or standards derived fromnationally recognized standards that span therange of use of the instrument with respectto disintegration rate and/or matrix effects.All standards that were used have beenidentified and their application documented.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0Revision No.: 1.0HENC#2-9Date of Revision: 10/20/05ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceIdentify the nationally accreditedmeasurement program. List the standardsused for verification/confirmation and verifythe pedigree of each standard.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Standards are listed in the calibration report.The LANL program’s standards are derivedfrom nationally recognized NIST standardsYCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0The standards used for calibrationconfirmation must not be the same sources asthose used for the system’s calibration ofrecord.CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The standards used for calibrationconfirmation are different from those usedfor the system’s calibration of record.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0Requirements 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 precisionand∀30% for accuracy.CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Requirements for accuracy and precisionhave been met as specified in DOE/WIPP02-3122, Appendix A, Table A-3.2 forprecision and∀30% for accuracy.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0Revision No.: 1.0HENC#2-10Date of Revision: 10/20/05ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceQUALITY CONTROLAll radioassay and data validation must beperformed by appropriately trained andqualified personnel.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11All radioassay functions and data validationhave been performed by appropriatelytrained and qualified personnel.Y CCP-LANL List of QualifiedIndividuals, 5/22/2006, 10:30AM provided during inspectionIdentify the name, title, and function of allpersonnel performing NDA data validation.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The name, title, and function of all NDApersonnel performing data validation for theLANL HENC#1 are documented.Y CCP-LANL List of QualifiedIndividuals, 5/22/2006, 10:30AM provided during inspectionRequalification of personnel must be basedon evidence of continued satisfactoryperformance and must be performed at leastevery two years.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Requalification of personnel based onevidence of continued satisfactoryperformance has been performed at leastevery two years.Y CCP-LANL List of QualifiedIndividuals, 5/22/2006, 10:30AM provided during inspectionThe site must participate in relevantmeasurement comparison programssponsored or approved by CBFO, includingthe NDA PDP.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The site has participated successfully inCycle 13A of the CBFO-sponsored NDAPDP. The conditional approval of theLANL HENC #2 effective in July 2006 wasmade permanent upon successfulimplementation of the LANL CorrectiveAction Plan that addressed the Cycle 13APDP failures for the glass matrix containerwith HS Pu.Y July 19, 2006 Memorandum fromM. Brown to C. FesmireScoringResults – Primary Cycle 13ANondestructive Assay PDP;January 19, 2007 Memorandumfrom M. Brown to C. Fesmireupdating status based on resultsof NDA PDP Primary Cycle 13ABACKGROUND AND PERFORMANCE CHECKSAssay system background measurementsmust be taken daily, unless otherwiseapproved by CBFO. Determine the form ofCBFO approval documentation of thealternate approach to backgrounds, ifapplicable. Contributions to backgroundsfrom nearby radiation sources must beY CCP-PO-001,CCPTransuranic WasteCertification Plan,Revision 11Daily background measurements are takenand recorded. Contributions to backgroundsfrom high activity containers that are storedor staged in proximity to the LANL HENC#2 Trailer do affect the background, butNDA personnel control this.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0; HENC #2 BDRs2LANDA0002, 2LANDA0005,Revision No.: 1.0HENC#2-11Date of Revision: 10/20/05ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidencecarefully controlled, or more frequentbackgrounds must be measured.2LANDA0010, 2LANDA0006Assess how often background radiation wasproblematic to the extent that measurementpersonnel had to make adjustments.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Background control charts are used todocument the system’s performance overtime.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0; HENC #2 BDRs2LANDA0002, 2LANDA0005,2LANDA0010, 2LANDA0006Identify the criteria used to evaluateinstrument backgrounds and assess thetechnical adequacy of this criterion, i.e.,statistical or administrative.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Backgrounds are evaluated againstpredetermined upper and lower boundariesand are non-statistical in nature. Initialcontrol limits are based on the system’s firstmonth of operations and each day’smeasurements are automatically compared tothe established limits.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0; HENC #2 BDRs2LANDA0002, 2LANDA0005,2LANDA0010, 2LANDA0006Identify the number of data points required toderive the initial control limit. At whatinterval(s) will new limits be calculated?Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Initial control limits for all performancemeasurements were based on sixmeasurements. Limits will be recalculatedas more data are acquired or the system isrecalibrated.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0; HENC #2 BDRs2LANDA0002, 2LANDA0005,2LANDA0010, 2LANDA0006System performance checks must beperformed at least once per operational day.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Performance checks have been performed atleast once per operational day and all checkshave been documented.Y HENC #2 BDRs 2LANDA0002,2LANDA0005, 2LANDA0010,2LANDA0006System performance checks must include, asapplicable, efficiency, matrix correctionY CCP-PO-001, CCPTransuranic WastePerformance checks include: 121 keV peakcentroid and FWHM, 964 kev peak centroidYCalibration Report for HENC #2Including Passive Neutron andRevision No.: 1.0HENC#2-12Date of Revision: 10/20/05ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidencechecks, and systems peak position andresolution for spectrometric systems.Certification Plan,Revision 11 and FWHM and weighted average of152Euactivity.Gamma SpectrometerCalibration and Confirmation,Revision 0; HENC #2 BDRs2LANDA0002, 2LANDA0005,2LANDA0010, 2LANDA0006At a minimum of once per operational week,an interfering matrix must be assayed toassess the long-term stability of the NDAinstrument and its matrix corrections andhow this performance is documented.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Two matrix drums are available, a debris andhomogeneous solid. They are used with avariety of PDP-type Pu sources that span arange of activity. The acceptance criteria forthe Weekly Interfering Matrix checks werenot apparent during this inspection.YCalibration Report for HENC #2Including Passive Neutron andGamma SpectrometerCalibration and Confirmation,Revision 0; HENC #2 BDRs2LANDA0002, 2LANDA0005,2LANDA0010, 2LANDA0006Interfering surrogate waste matrices must beconstructed in such a way that the salientmatrix characteristics do not change overtime.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Interfering surrogate waste matrices havebeen constructed such that the salient matrixcharacteristics do not change over time.Y Visual examination of matrixdrums, interviews with LANLCCP NDA personnel andevaluation of PDP submittalsThe radionuclide sources used forperformance checks must be long-lived andof sufficient strength (activity) to providestatistically sufficient results over a shortmeasurement time.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The241Am,152Eu, and Pu sources used forperformance checks are of sufficient activityto provide statistically sufficient results overa short measurement time.Y Interviews with LANL-CCPNDA personnel and evaluation ofLANL HENC #2 performancedata and LANL HENC #2BDRs.Radioactive sources are decay corrected as afunction of their physical half-life, asappropriate, specifically133Ba,252Cf,137Cs,75Se, and109Cd.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The241Am and152Eu sources are decaycorrected as a function of their physical halflife. Decay correction is not applicable to239Pu sources.Y Interviews with LANL-CCPNDA personnel and evaluation ofLANL HENC #2 performancedata and BDRs.Performance checks must be quantitative andbased on 2 and 3 sigma limits.CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Limits are based onStudentt-testfor 95%(warning limit) and 99% (control limit)confidence intervals.Y CCP-TP-103;Calibration Reportfor HENC #2 Including PassiveNeutron and GammaRevision No.: 1.0HENC#2-13Date of Revision: 10/20/05ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSpectrometer Calibration andConfirmation, Revision 0; HENC#2 BDRs 2LANDA0002,2LANDA0005, 2LANDA0010,2LANDA0006Revision No.: 1.0HENC#2-14Date of Revision: 10/20/05ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceDATA MANAGEMENTAll radioassay data must be reviewed andapproved by qualified personnel before beingreported to WWIS.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Individual Radioassay Data Sheets(RDS) were reviewed, as indicated. Allwere acceptable.Y HENC #2 BDRs 2LANDA0002,2LANDA0005, 2LANDA0010,2LANDA0006Identify the name, title, and function of theindividual(s) performing technical reviewand approval of NDA BRDs.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The name, title, and function of theindividual(s) performing technicalreview and approval of NDA BRDs aredocumented.Y HENC #2 BDRs 2LANDA0002,2LANDA0005, 2LANDA0010,2LANDA0006Radioassay BDRs must consist of thefollowing elements:•Testing facility name, testing batchnumber, container numbers, andsignature of the Site Project Officer(SPO) or designee(s)•Table of Contents•Background and performance check dataor control charts for the relevant timeperiod.•Data validation per the QAPD and siteprocedures•Separate testing report sheets for eachcontainer.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The LANL HENC #2 BRDs reviewedduring this inspection contained allrequired elements.Y HENC #2 BDRs 2LANDA0002,2LANDA0005, 2LANDA0010,2LANDA0006Revision No.: 1.0HENC#2-15Date of Revision: 10/20/05ATTACHMENT A.3: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: LANL High Efficiency Neutron Counter #2 (LANL HENC #2)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceRadioassay data sheets must include:•Title “Radioassay Data Sheet”•Method/procedure used•Date of radioassay•Activities and associated TMU forindividual radionuclides•TRU alpha concentration and itsassociated TMU•Operator signature•Reviewer signatureY CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The LANL HENC #2 RDSs evaluatedduring this inspection included allrequired elements.Y Reviewed RDSs as follows:HENC #2 BDR Container No.2LANDA0002 536732LANDA0005 S8025652LANDA0010 S8258132LANDA0006 57221The following nonpermanent records must bemaintained at the radioassay-testing facilityor forwarded to the site project office:•Testing batch reports•All raw data, including instrumentreadouts, calculation records, andradioassay QC results•All applicable instrument calibrationreportsY CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Nonpermanent records are maintainedin the LANL HENC #2 trailer in TA-54,Area G, and all raw data are included ontwo compact discs that are submittedwith each BDR to the CCP office.Y Interviews with LANL HENC #2operator and other LANL-CCPNDA personnel.Revision No.: 1.0PTGS-1Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSYSTEM DESCRIPTIONIdentify 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 inTechnical Area 54 (TA-54), Area G, Pad 10.Y Visual observation of the PTGSsystem in place at Area G of TA54 at LANL.Describe the system’s operational history,including deployment at other DOE sites.NA NA This is the same PTGS unit that was evaluatedby EPApreviously during EPA-LANL-CCP-04.08.8 in August2004 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 TrailerNo.TA-54-B439 in TA-54, Area G.Y Visual observation of the PTGSand FRAM systems in place atArea G of TA-54 at LANL.For systems that have been deployed atmultiple DOE sites, document pertinentaspects 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 initialdeployment, including software upgrades (MasterAnalysis, Master Scan and Maestro), repair of theDSPEC+ spectrometer and modifications to secure the109Cd rate-loss correction source to the detector face.These have been appropriately documented.Y EPA Waste CharacterizationReports: EPA Inspection Nos.EPA-LANL-CCP-4.04-08,August 2004; EPA-LANL-CCP05.05.8, May 2005SYSTEM PERFORMANCEIdentify the period of performance relevant tothis inspection and if this NDA system hasprior EPA approval(s).NA NA The period of performance relevant to this inspection isApril 15, 2005 to March 31, 2006, and March 31, 2006 toMarch 6, 2007.Y EPA Inspection Letters to D.Moody: April 6, 2006, outliningscope of EPA-LANL-CCP-05.06-8; February 8, 2007, outliningscope of follow-up inspection atLANL-CCPIdentify the number of waste containers thissystem assayed during the period ofperformance. Of these, indicate how manyBDRs were assembled and how many havebeen promoted through Project LevelReview.NA NA During the time period of interest, 951 55-gallon drumshave been assayed, and these results have been compiledin a total of 136 BDRs.YSummary of Waste DrumsMeasurements on the LANLPTGS/FRAM Systems from April15, 2005 thru March 31, 2006,May 25, 2006, provided by JoeWachter during inspection.Revision No.: 1.0PTGS-2Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceGENERAL REPORTING REQUIREMENTSAssay systems must reportquantitative values and uncertaintiesfor238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Quantitative values and uncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs are reported.Y Radioassay Data Sheets in BDR Nos. LA05-PTGS092, LA05-PTGS-027, LA05-PTGS-042, LA05-PTGS-057Each container characterized andintended for disposal at WIPP mustcontain TRU waste.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Only payload containers that contain TRUradionuclides concentrations greater than 100nCi/g are eligible for disposal at WIPP.Y BDR Nos. LA05-PTGS-092, LA05-PTGS-027,LA05-PTGS-042, LA05-PTGS-057NDA instruments and procedures areappropriate for the waste streamsbeing assayed.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11PTGS and associated FRAM procedures areappropriate for S5000 debris waste. In thischecklist, the termPTGSrefers to thecombination of the PTGS for quantitative239Pu determination in conjunction with anisotopic distribution from one of the twoFRAM units.Y Calibration Reports:Portable TGS MassCalibration and Calibration Confirmation for Pu239, NWIS-TP: 2005-0105, March 31, 2005;Portable TGS Mass Calibration and CalibrationConfirmation for Pu-239, NWIS-TP:05-0141,August 1, 2005NDA instruments and proceduresresult in unbiased values for thecumulative activity of the WIPPradionuclide inventory.Y CCP-PO-001CCPTransuranic WasteCertification Plan,Revision 11The radionuclide values produced by thePTGS are appropriate for supporting thecumulative activity of the WIPP radionuclideinventory.YPortable TGS Mass Calibration and CalibrationConfirmation for Pu-239, NWIS-TP: 2005-0105,March 31, 2005Some radionuclides are derived bythe application of scaling factors orcorrelation techniques. Identify allradionuclides that are quantified inthis manner.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11All measurements are scaled to the measured239Pu value, using FRAM or AK-basedisotopic values.234U is scaled to measuredvalues of235U and238Pu;242Pu and90Sr arescaled to the measured value of137Cs; and242Pu is correlated to239Pu,240Pu and241Pu.Y LANL Reports:234U and90Sr Calculations forNDA Reporting, LANL, TWCP-12684, April 7,2003;CCP-TP-124 Determining Isotopic Ratios inWaste Containers Using the PC/FRAM AssaySystem, May 17, 2004Revision No.: 1.0PTGS-3Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceAssess the technical adequacy of thecalculations involving the applicationof scaling factors and/or correlationtechniques.Y CCP-PO-001,CCPTransuranic WasteCertification Plan,Revision 11The calculations used to apply scaling factorsto determine235U,242Pu, and90Sr aretechnically adequate and appropriatelydocumented.Y CCP Technical Procedures: CCP-TP-124,Revision 2; CCP-TP-125, Revision 2, Appendix AIdentify the procedures that governthis function and where the results ofthese calculations are documented.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The procedures controlling the application ofscaling factors to determine235U,242Pu, and90Sr are identified. The results aredocumented in radioassay BDRs.Y CCP-TP-124, Revision 2; CCP-TP-125, Revision2, Appendix A; Radioassay BDR Nos. LA05-PTGS-092, LA05-PTGS-027, LA05-PTGS-042,LA05-PTGS-057ACCEPTABLE KNOWLEDGE (AK)If isotopic ratios based on AK areused, the values are qualified byconfirmatory testing.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Isotopic ratios are determined using samplespecific gamma data and PC-FRAM. AKindicates that debris waste is primarily WGPu. If default isotopic ratios are unavailable,only radionuclides that are directly measuredwill be reported.Y CCP Technical Procedures: CCP-TP-124,Revision 2; CCP-TP-125, Revision 2Do NDA personnel use AK-derivedisotopic values to calculateradionuclide values? If so, is thisfunction performed according to aformal procedure? Assess thetechnical adequacy of this process(s).Y CCP-PO-001,CCPTransuranic WasteCertification Plan,Revision 11AK derived isotopic values are documented inCCP-AK/NDA Memoranda. This activity istechnically adequate and is executed inaccordance with CCP procedures.Y CCP-AK-LANL-009 AK/NDA Memorandum,Revision 0; Memoranda from S. Schafer and W.Estill regarding Waste Stream LA-MIN03-NC;CCP-TP-124, Revision 2; CCP-TP-125, Revision 2Identify the procedure and where theresults of these calculations aredocumented.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The results of these calculations aredocumented in PTGS BDRs.Y BDR Nos. LA05-PTGS-092, LA05-PTGS-027,LA05-PTGS-042, LA05-PTGS-057ISOTOPIC DETERMINATIONIdentify the radionuclides that aremeasured directly and the specificradiation type (gamma, AN, or PN)that is measured.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The PTGS measures the gamma emission ofthe 414 keV line of239Pu. All otherradionuclides that are reported are based onthis measurement.Y CCP-TP-126, Revision 4; CCP-TP-123, Revision 2Revision No.: 1.0PTGS-4Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceIdentify the method(s) used to derivethe isotopic contribution for theunmeasured radionuclides, e.g.,MGA, PC FRAM, or other technique.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11FRAM is used for the isotopic determination.AK isotopics (default) are used when required.Y CCP Technical Procedures: CCP-TP-124,Revision 2; CCP-TP-125, Revision 2Revision No.: 1.0PTGS-5Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceLOWER LEVEL OF DETECTION (LLD)The LLD for each NDA system must bedetermined. For multimodal systems thismay require a separate determination foreach mode, i.e., active neutron, passiveneutron, and gamma.Y CCP-PO-001, CCP TransuranicWaste Certification PlanRevision 11The LLD for the PTGS has beendetermined and is technically adequateand appropriately documented.YLower Limit of Detection for theLANL Portable TomographicGamma Scanner (PTGS), NWISTP:05-0094, March 15, 2005Site-specific environmental backgroundsand container-specific interferences mustbe accounted for in LLD determinations.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11LLD determinations are containerspecific. TA-54 Area G backgroundsare addressed in all LLDdeterminations.YLower Limit of Detection for theLANL Portable TomographicGamma Scanner (PTGS), NWISTP:05-0094, March 15, 2005NDA instruments performing TRU/NonTRU waste discrimination measurementsare required to have an LLD no greaterthan 100 nCi/g.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The PTGS is not used to distinguishTRU and Non-TRU wastes. The LLDis approximately 0.09 g239Pu, which iswell below the system’s operationalrange of 0.565 – 176.76 g of239Pu.YLower Limit of Detection for theLANL Portable TomographicGamma Scanner (PTGS), NWISTP:05-0094, March 15, 2005The technical basis and derivation forLLDs must be adequate and appropriatelydocumented.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Only assay values above the LLD andsystem’s operational range of 0.565 –176.76 g of239Pu will be reported.Assays that are below the system’s LLDare flagged asfailed assays, inaccordance with CCP-TP-125, and anNCR is initiated for each.YLower Limit of Detection for theLANL Portable TomographicGamma Scanner (PTGS), NWISTP:05-0094, March 15, 2005For radionuclides that are not determinedprimarily by measurement, an LLD analog,i.e., a reporting threshold, must be usedwhen it is technically feasible. Identify allinstances when this occurs and the form ofthe documentation of these activities.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11LLDs for all radionuclides except239Puare determined relative to the239PuLLD, and all could be considered atechnically based reporting threshold.YLower Limit of Detection for theLANL Portable TomographicGamma Scanner (PTGS), NWISTP:05-0094, March 15, 2005Revision No.: 1.0PTGS-6Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceIdentify any/all instances where an LLDvalue for anon-measuredradionuclide isnot provided based on a lack of technicalfeasibility.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11There are no instances where an LLDvalue for anon-measuredradionuclideis not provided based on a lack oftechnical feasibility.NA Not ApplicableAre LLD values container/assay eventspecific or are typical LLD values appliedto a class or type of wastes, i.e., those withsimilar attributes? If LLD values are notcontainer/assay event specific, identify theattributes or characteristics whereby wastecontainers are grouped.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11LLDs are measurement-event specific,based on the system’s response to the414 keV239Pu line.YLower Limit of Detection for theLANL Portable TomographicGamma Scanner (PTGS), NWISTP:05-0094, March 15, 2005TOTAL MEASUREMENT UNCERTAINTY (TMU)The method used to calculate the TMU forall required quantities must be documentedand technically justified.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The TMU determination for the PTGSis documented and technically adequate.YRevision to TWCP-23398, TotalMeasurement Uncertainty (TMU)Report for the PortableTomographic Gamma Scanner(PTGS), NWIS-TP: 2005-0102,March 30, 2005TMU determination accounts for allsources of uncertainty, as appropriate,specifically:•Random errors•Calibration•Isotopic determination•Matrix inhomogeneity•Difference between calibrationassumptions and actual waste•Non-uniform source distribution•End effects•Self absorption•Transmission sourceY CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The TMU determination accounts for allsources of uncertainty applicable to thePTGS.YRevision to TWCP-23398, TotalMeasurement Uncertainty (TMU)Report for the PortableTomographic Gamma Scanner(PTGS), NWIS-TP: 2005-0102,March 30, 2005Revision No.: 1.0PTGS-7Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidence•Self shielding•Neutron multiplicationMethods to determine TMU must bedocumented, reviewed, and approved byCBFO for each NDA instrument.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11CBFO Technical Specialist D. Stuenkelconfirmed that the TMU report hadbeen reviewed and approvedY Oral communication with D.Stuenkel and issuance ofcontrolled copy of TMU reportRevision No.: 1.0PTGS-8Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSYSTEM CALIBRATIONEach NDA instrument must be calibratedbefore its initial use. Determine the date ofthe system’s calibration of record andwhere this is documented.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The PTGS was initially calibrated inDecember 2003. It was recalibrated inDecember 2004, and again in August2005. All calibrations are appropriatelydocumented.Y Calibration Reports: PortableTGS Mass Calibration andCalibration for Pu-239, RRESCH:04-005, January 7, 2004;Portable TGS Mass Calibrationand Calibration Confirmation forPu-239, NWIS-TP: 2005-0105,March 31, 2005;Portable TGSMass Calibration andCalibration Confirmation for Pu239, NWIS-TP:05-0141, August1, 2005The range of applicability of the system’scalibration(s) must be specified in siteprocedures or other formal documentation.Identify the manner in which the range isexpressed, i.e., curies or Pu/SNM mass foractivity and salient physical characteristicsfor matrix.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The calibration range of the PTGS isfrom 0.565 – 176.76 g of239Pu. ThePTGS assays only debris (S5000)wastes. The PTGS is prohibited fromassaying HS Pu in any matrix due to aNDA PDP failure of Cycle 13A.YPortable TGS Mass Calibrationand Calibration Confirmation forPu-239, NWIS-TP:05-0141,August 1, 2005; January 19, 2007Memorandum from M. Brown toC. Fesmire updating status basedon results of NDA PDP PrimaryCycle 13AAny matrix/source surrogate wastecombinations must be representative of theactivity ranges and relevant waste matrixcharacteristics currently in use or plannedfor use by the system. The system must becalibrated to 100% recovery.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The calibration was performed in a 55-gallon (208 liter) drum using acombustibles matrix similar to theroutine waste matrix. The PTGS iscalibrated to 100% recovery.YPortable TGS Mass Calibrationand Calibration Confirmation forPu-239, NWIS-TP:05-0141,August 1, 2005The use of consensus standards forcalibration is required, when suchY CCP-PO-001, CCP TransuranicWaste Certification Plan,Consensus standard for calibration havenot been identified. CBFO hasY CCP-TP-123, Revision 2;Recalibration and ConfirmationRevision No.: 1.0PTGS-9Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidencestandards exist. If consensus standards donot exist, the calibration technique must beapproved by CBFO.Revision 11 approvedRecalibration andConfirmation Plan for the PortableTomographic Gamma Scanner – June2005.Plan for the PortableTomographic Gamma Scanner –June 2005.Identify the specific consensus standardsthat were used for the system calibrationor, in their absence, the alternatecalibration technique. Evaluate the CBFOapproval of the alternate technique.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11See previous checklist item. Y See previous checklist item.Primary standards must be obtained fromsuppliers maintaining a nationallyaccredited measurement program. Identifythe nationally accredited measurementprogram.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Certificates for the PuO2sources usedfor calibration were reviewed and foundto be acceptable. All are PDP-stylesources traceable to NIST.Y LANLCertificate of Content andTraceabilitysigned by R.Marshall for sources: 2.8, 25.0,93.0, 139.5 and 164.5 g of239PuList the standards used for calibration andverify the pedigree of each standard.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Standards used for calibration includedcombinations of PuO2sources totaling0, 0.6, 3, 10, 100, and 189 g total Pu andwere obtained by combining the specific239Pu sources listed to the right. Eachsource has an acceptable pedigree.Y LANLCertificate of Content andTraceabilitysigned by R.Marshall for239Pu sources PDP1-0.1, PDP1-0.5, PDP1-3.0, PDP1-10, TANT25-1, RANT50-1,RANT50-2 and RANT50-3CALIBRATION VERIFICATION & CONFIRMATIONVerification of an NDA instrument’scalibration must be performed after any ofthe following occurrences: major systemrepairs and/or modifications, replacementof the system’s components, significantchanges to the system’s software, andrelocation of the system.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Initial verification of the PTGScalibration was performed anddocumented. Two subsequentverifications were performed on August1-2, 2005, and October 3-4, 2005.These were required due to replacementof the system’s spectrometer and aY Calibration Verification Reports:Calibration Verification of thePortable Tomographic GammaScanner, NWIS-TA-54EAST:05-0148, August 16, 2005;Calibration Verification of thePortable Tomographic GammaRevision No.: 1.0PTGS-10Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidenceshutter problem, respectively. Bothverifications were performed anddocumented appropriately.Scanner, NWIS-TA-54EAST:06-005, November 7, 2005Recalibration of the system must occur ifthe calibration verification demonstratesthat the system’s response has significantlychanged.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The PTGS was recalibrated in August2005, see previous checklist entry.YPortable TGS Mass Calibrationand Calibration Confirmation forPu-239, NWIS-TP:05-0141,August 1, 2005.The system calibration must be confirmedby performing replicate measurements of anon-interfering matrix.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Calibration confirmation has beenperformed by making six (6) replicatemeasurements for each of three (3)drums containing 0.9, 9, and 160 g totalPu in a non-interfering matrix, asdocumented in NWIS-TP: 2005-0105.YPortable TGS Mass Calibrationand Calibration Confirmation forPu-239, NWIS-TP:05-0141,August 1, 2005Replicate measurements must beperformed with containers of the samenominal size and according to the sameprocedures used for actual waste assays.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Replicate measurements have beenperformed with containers of the samenominal size and according to the sameprocedures as those used for actualwaste assays. Replicate measurementswere made using 55-gallon drums of thesame size and shape as those to beassayed.Y Replicate measurements weremade in accordance with CCPTP-126,Waste Assay Using thePortable Tomographic GammaScanner, Revision 3, the sameprocedure used for routineassays.Replicate measurements must beperformed using nationally recognizedstandards or standards derived fromnationally recognized standards that spanthe range of use of the instrument withrespect to disintegration rate and/or matrixY CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Replicate measurements have beenperformed using PuO2sources of thesame type as those discussed above forcalibration. Sources span the range ofuse of the PTGS with respect to activityand matrix. All standards have beenYPortable TGS Mass Calibrationand Calibration Confirmation forPu-239, NWIS-TP:05-0141,August 1, 2005;239Pu sourcesNTP-0085, NTP-0092, NTP0099, NTP-0120, NTP-0106,Revision No.: 1.0PTGS-11Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidenceeffects. Identify all standards that wereused and indicate their application(verification or confirmation).identified and are listed in the column tothe right.NTP-0113, NTP-0140, NTP0148, NTP-0156 and NTP-0164Identify the nationally accreditedmeasurement program. List the standardsused for verification/confirmation andverify the pedigree of each standard.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The LANL program that fabricated thePuO2sources is a nationally accreditedmeasurement program. All PuO2sources used for verification and/orconfirmation are traceable to NIST.Y Sources for verification and/orconfirmation are listed in the cellabove. The pedigrees of allsources have been verified.The standards used for calibrationconfirmation must not be the same sourcesas those used for the system’s calibrationof record.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The standards used for calibrationconfirmation are different from thesources used for the system’s calibrationof record.YPortable TGS Mass Calibrationand Calibration Confirmation forPu-239, NWIS-TP:05-0141,August 1, 2005Requirements 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 forprecision and∀30% for accuracy.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Requirements for accuracy andprecision have been met as specified inDOE/WIPP-02-3122, Appendix A,Table A-3.2 for precision and∀30% foraccuracy.Y Performance goals for accuracy(70% < %R < 130%) andprecision (%RSD < 14%) havebeen met for each of the threemass loadings.Revision No.: 1.0PTGS-12Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceQUALITY CONTROLAll radioassay data validation must beperformed by appropriately trained andqualified personnel.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11All radioassay data validation andreview personnel have been trained andare currently listed as qualifiedpersonnel.Y CCP-LANL List of QualifiedIndividuals, 5/22/2006, 10:30AM (NDA PTGS/FRAM)provided during inspectionIdentify the name, title, and function of allpersonnel performing NDA datavalidation.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Expert Analysts: DougCramer, Harald Poths, andJoseph Wachter IndependentTechnical ReviewersY CCP-LANL List of QualifiedIndividuals, 5/22/2006, 10:30AM (NDA PTGS/FRAM)provided during inspectionRequalification of personnel must be basedon evidence of continued satisfactoryperformance and must be performed atleast every two years.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Requalification of personnel based onevidence of continued satisfactoryperformance has been performed at leastevery two years.Y CCP-LANL List of QualifiedIndividuals, 5/22/2006, 10:30AM (NDA PTGS/FRAM)provided during inspectionAll computer programs, includingspreadsheets used for data reduction oranalysis, must meet the applicablerequirements in the CBFO QAPD.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11All computer programs, includingspreadsheets used for data reduction oranalysis, meet the applicablerequirements in the CBFO QAPD.Y Software includes MasterAnalysis V4.1.2, Master ScanV3.1.6 and Maestro V6.03.The site must participate in relevantmeasurement comparison programssponsored or approved by CBFO,including the NDA PDP.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The site has participated successfully inthe CBFO-sponsored NDA PDPPrimary Cycle 13A. PTGS is prohibitedfrom assaying HS Pu.Y July 19, 2006 Memorandum fromM. Brown to C. FesmireScoringResults – Primary Cycle 13ANondestructive Assay PDP;January 19, 2007 Memorandumfrom M. Brown to C. Fesmireupdating status based on resultsof NDA PDP Primary Cycle13A.Revision No.: 1.0PTGS-13Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceBACKGROUND AND PERFORMANCE CHECKSAssay system background measurementsmust be taken daily, unless otherwiseapproved by CBFO. Determine the formof CBFO approval documentation of thealternate approach to backgrounds, ifapplicable. Contributions to backgroundsfrom nearby radiation sources must becarefully controlled, or more frequentbackgrounds must be measured.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The PTGS background is measureddaily for each assay event using the 414keV emission line of239Pu, andbackgrounds are recorded in PTGSBDRs. Contributions to backgroundsfrom nearby radiation sources (highactivity staged drums) have the potentialto affect PTGS backgrounds and theseare controlled.Y PTGS BDR Nos. LA05-PTGS092, LA05-PTGS-027, LA05-PTGS-042, LA05-PTGS-057Assess how often background radiationwas problematic to the extent thatmeasurement personnel had to makeadjustments.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Background records in the PTGS BRDsreviewed for this inspection do notindicate a serious background problem.Y PTGS BDR Nos. LA05-PTGS092, LA05-PTGS-027, LA05-PTGS-042, LA05-PTGS-057Identify the criteria used to evaluateinstrument backgrounds and assess thetechnical adequacy of this criterion, i.e.,statistical or administrative.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Backgrounds have been evaluatedagainst an acceptance criterion derivedby dividing the net counts by theuncertainty.Y PTGS BDR Nos. LA05-PTGS092, LA05-PTGS-027, LA05-PTGS-042, LA05-PTGS-057Identify the number of data points requiredto derive the initial control limit and for allsubsequent changes to the limits. At whatinterval(s) will new limits be calculated?Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11The number of data points required toderive the initial control limit and theinterval(s) at which will new limits becalculated are documented.YLower Limit of Detection for theLANL Portable TomographicGamma Scanner (PTGS), NWISTP:05-0094, 03/15/05System performance checks must beperformed at least once per operationalday.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Performance checks have beenperformed at least once per operationalday and all checks have beendocumented.Y Reviewed control charts in BDRNos. LA05-PTGS-092, LA05-PTGS-027, LA05-PTGS-042,LA05-PTGS-057System performance checks must include,as applicable, efficiency, matrix correctionchecks, and systems peak position andresolution for spectrometric systems.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Checks include: Efficiency using TGS#for133Ba at 356 keV; FWHM for109Cdand133Ba; energy calibration control at88 and 356 keV using75SeY Reviewed control charts in BDRNos. LA05-PTGS-092, LA05-PTGS-027, LA05-PTGS-042,LA05-PTGS-057Revision No.: 1.0PTGS-14Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceAt a minimum of once per operationalweek, an interfering matrix must beassayed to assess the long-term stability ofthe NDA instrument and its matrixcorrections and how this performance isdocumented.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Combustibles (debris) matrix is usedwith PuO2sources of 2.8, 25.0, 93.0,135.5, and 164.5 g total Pu for weeklyinterfering matrix checks.Y Interfering Matrix Reports:Weekly Interfering Matrix CheckResults LANL PTGS and FRAMSystems, 10/1/2005 – 3/31/2006;NWIS-TA-54EAST: 06-0024,May 1, 2006; andWeeklyInterfering Matrix Check Resultsfor the Los Alamos NationalLaboratory (LANL) PTGS andFixed Energy Response FunctionAnalysis (FRAM) Systems PTGSand FRAM Systems, 10/1/2005 –3/31/2006; NWIS-TA-54EAST:06-0014, January 5, 2006Interfering surrogate waste matrices mustbe constructed in such a way that thesalient matrix characteristics do not changeover time.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Matrix containers are the same as thoseused for the CBFO sponsored NDAPDP and are adequately constructed.Y Visual examination of matrixdrums, interviews with LANLCCP NDA personnel andevaluation of PDP submittalsThe radionuclide sources used forperformance checks must be long-livedand of sufficient strength (activity) toprovide statistically sufficient results overa short measurement time.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11133Ba,109Cd,75Se, and239Pu sources areof adequate intensity for their intendedpurposes.Y Interviews with LANL-CCPNDA personnel and evaluation ofPTGS performance data andPTGS BDRs.Radioactive sources are decay corrected asa function of their physical half-life, asappropriate, specifically133Ba,252Cf,137Cs,75Se, and109Cd.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11133Ba,109Cd, and75Se sources are decaycorrected as appropriate. Decaycorrection is not applicable to239Pusources.Y Interviews with LANL-CCPNDA personnel and evaluation ofPTGS performance data andPTGS BDRs.Performance checks must be quantitativeand based on 2 and 3 sigma limits.Y CCP-PO-001, CCP TransuranicWaste Certification Plan,Revision 11Limits are based onStudentt-testfor95% (warning limit) and 99% (controllimit) confidence intervals.Y CCP-TP-125, Revision 2; PTGSBDR Nos. LA05-PTGS-092,LA05-PTGS-027, LA05-PTGS042, LA05-PTGS-057Revision No.: 1.0PTGS-15Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceDATA MANAGEMENTAll radioassay data must be reviewed andapproved by qualified personnel beforebeing reported to WWIS.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Individual Radioassay Data Sheets (RDS)were reviewed, as indicated. All wereacceptable.Y Reviewed RDSs as follows:PTGS BDR Container No.LA05-PTGS-092: 53352, S834686LA05-PTGS-027: 53973, S855579LA05-PTGS-042: 60727, S835392LA05-PTGS-057: S845254, S84153Identify the name, title, and function of theindividual(s) performing technical reviewand approval of NDA BRDs.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The name, title, and function of allpersonnel performing review andapproval of BRDs are documented. Allpersonnel are appropriately qualified.Y PTGS BDR Nos. LA05-PTGS-092,LA05-PTGS-027, LA05-PTGS-042,LA05-PTGS-057Radioassay BDRs must consist of thefollowing elements:•Testing facility name, testing batchnumber, container numbers, andsignature of the Site Project Officer(SPO) or designee(s)•Table of Contents•Background and performance checkdata or control charts for the relevanttime period.•Data validation per the QAPD and siteprocedures•Separate testing report sheets for eachcontainer.Y CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The PTGS BRDs reviewed during thisinspection contained all requiredelements.Y PTGS BDR Nos. LA05-PTGS-092,LA05-PTGS-027, LA05-PTGS-042,LA05-PTGS-057Revision No.: 1.0PTGS-16Date of Revision: 10/20/05ATTACHMENT A.4: NONDESTRUCTIVE ASSAY (NDA) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006NDA System: Portable Tomographic Gamma Scanner (PTGS)Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceRadioassay data sheets must include:•Title “Radioassay Data Sheet”•Method/procedure used•Date of radioassay•Activities and associated TMU forindividual radionuclides•TRU alpha concentration and itsassociated TMU•Operator signature•Reviewer signatureY CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11The PTGS RDSs evaluated during thisinspection included all required elements.Y Reviewed RDSs as follows:PTGS BDR Container No.LA05-PTGS-092: 53352, S834686LA05-PTGS-027: 53973, S855579LA05-PTGS-042: 60727, S835392LA05-PTGS-057: S845254,S84153The following nonpermanent records mustbe maintained at the radioassay-testingfacility or forwarded to the site projectoffice:•Testing batch reports•All raw data, including instrumentreadouts, calculation records, andradioassay QC results•All applicable instrument calibrationreportsY CCP-PO-001, CCPTransuranic WasteCertification Plan,Revision 11Nonpermanent records are maintained inthe PTGS trailer in TA-54, Area G, andall raw data are included on two compactdiscs that are submitted with each BDR tothe CCP office.Y Interviews with PTGS operator andother personnelRevision No.: 1.0RTR-1Date of Revision: 10/20/05ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentRTR-1:Site procedures identifyrequired training andqualifications for RTRpersonnelYCCP-QP-002,Rev. 20CCP-TP-028,Rev. 3•Operator training was consistent withapplicable 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 thatincludes items common to the waste streamsexamined at the site (biannually)•Training drum contains all required items•RTR operators receive training on the wastematrix parameters and typical packagingconfigurations expected to be found in eachwaste stream.YCCP uses Qualification Cards to document andrecord training received by CCP personnel. The SiteProject Manager appoints RTR Subject MatterExperts (SME,) and this appointment is documentedby a letter included in the SME’s training file.The site maintains a List of Qualified Individualswhich is used to ensure all training is current. Duringthe inspection, EPA reviewed the latest competencydemonstration tape and documentation (requiredevery six months) for an RTR SME. The test wasperformed on May 3, 2006, and drum used wasLANL-NDE-TEST-001-CL. There were noproblems identified during this review.Training on specific waste generating processes,typical packaging configurations, and WMPsexpected to be found in each waste stream isprovided to the RTR personnel. However, thistraining is provided only once unless there is anupdate to the AK record.Objective evidence reviewed:1.Competency demonstration audio/visual tapeand associated documentation for SME2.List of Qualified Individuals for RTR3.RTR demonstration: RTR unit #1, debris drumS852566. RTR unit #2, debris drum 58959.RTR-2:Site procedure(s) providecomplete instructions foroperators to perform the RTRexamination and completion ofthe associated documentation.YCCP-TP-002,Rev. 20CCP-TP-053,Rev. 4, s. 4.0,Attachments1 & 2•RTR operator adequately explained the processfollowed for examining a drum and enteringdata into data forms (whether hard copy orelectronic data entry is used).Y During the on-site inspection, EPA observed theRTR event for a debris (S5000) drum, numberS852566, on RTR unit #1. EPA also observed theRTR event for a debris (S5000) drum, number58959, on RTR unit #2. The operators had a copy ofthe applicable procedure (CCP-TP-053) available inthe RTR operations area and performed the RTRevent in accordance with the procedure instructions.Revision No.: 1.0RTR-2Date of Revision: 10/20/05ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentRTR data are electronically entered into the dataform (Attachment 2 of procedure CCP-TP-053) bysecond person who acts as a data recorder only (theyare not qualified RTR operators). Although the LinesPair Resolution check for each unit was completedprior to EPA’s arrival, this quality check formed partof the audio/visual recordings and BDRs reviewed byEPA.EPA reviewed audio/visual recordings and BDRsgenerated from both RTR units. The tapes werecomplete, but one issue was identified with thegeneration of the RTR data. Waste MaterialParameter weights (WMPs) are inconsistentlyrecorded for leaded rubber gloves during RTR andVE. In RTR the weight of the glove is assignedsolely to Rubber but in VE the weight is split 60:40between Rubber and Other Metal (see also VEchecklist). EPA generated the following Concern toaddress this issue.LANL-CCP-VE-06-006CR:1.Waste Material Parameter weights areinconsistently recorded for leaded rubber gloves.In RTR, leaded gloves are recorded as onlyunder the rubber waste material parameter but inVE the weight of the gloves is assigned in thefollowing way: 60% rubber and 40% othermetals.2.VE personnel were unable to provide therationale for assigning the weights (60:40) in thismanner.Objective evidence reviewed:1.Batch Data Report and audio/visual recordingfor batches LA-RTR2-05-0103 (S5000), LARTR2-05-0111 (S3000 and S5000), LA-RTR2-Revision No.: 1.0RTR-3Date of Revision: 10/20/05ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Comment05-0112 (S3000), LA-RTR2-05-0194 (S5000),LA-RTR1-06-0003 (S3000 and S5000), LARTR1-06-0002 (S5000), LA-RTR1-06-0001(S5000)2.BDRs LA-RTR2-05-0123 (S5000), LA-RTR2-04-0007, LA-RTR2-05-0152 (S3000), LARTR2-05-0175 (S3000 and S5000)3.RTR demonstration: RTR unit #1, debris drumS852566; RTR unit #2, debris drum 58959.RTR-3:The RTR procedure(s) requirean image quality check to beperformed.YCCP-TP-053,Rev. 4, s. 4.3,Attachment 1•Operator adequately explained how theacceptability of an image is determined•Image quality check is performed once per day•Performance of the image quality check isdocumented and recordedY EPA observed the RTR examination of a debris drumon both RTR units #1and #2 (drums S852566 and58959). The operator varied the voltage used duringthe examination to accommodate the density of theWMPs present. The operator called out the WMPspresent and this information was recorded by asecond person (not a qualified RTR operator). At theconclusion of the examination, the operator assignedWMP weights based on the information recorded inAttachment 2 of the procedure.In each of the BDRs reviewed, the image qualitycheck was documented on Attachment 1 of theprocedure CCP-TP-053 (RTR Measurement ControlReport). EPA also reviewed the image quality checkon selected audio/visual recordings of RTRexaminations.Objective evidence reviewed:1.Batch Data Report and audio/visual recordingfor batches LA-RTR2-05-0103 (S5000), LARTR2-05-0111 (S3000 and S5000), LA-RTR2-05-0112 (S3000), LA-RTR2-05-0194 (S5000),LA-RTR1-06-0003 (S3000 and S5000), LARTR1-06-0002 (S5000), LA-RTR1-06-0001(S5000)Revision No.: 1.0RTR-4Date of Revision: 10/20/05ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Comment2.BDRs LA-RTR2-05-0123 (S5000), LA-RTR2-04-0007, LA-RTR2-05-0152 (S3000), LARTR2-05-0175 (S3000 and S5000)3.RTR demonstration: RTR unit #1, debris drumS852566; RTR unit #2, debris drum 58959RTR-4:The procedure allows theoperator to adjust the RTR toaccommodate the physicalproperties of the waste andwaste containers likely to beencountered at the site.YCCP-TP-053,Rev. 4, s. 4.3,4.4•Operator could identify applicable policies andprocedures governing the operation of RTRequipment•The RTR system could be adjusted•High-density material was examined with thex-ray device set on the maximum voltage andlow density material at a lower voltage•Operator adequately explained what is done ifan image is unacceptable (e.g., the waste issolidified or the container is lead-lined)Y EPA observed the RTR examination of a debris drumon both RTR units #1and #2 (drums S852566 and58959). The operator varied the voltage used duringthe examination to accommodate the density of theWMPs present. The operator called out the WMPspresent and this information was recorded by asecond person (not a qualified RTR operator). At theconclusion of the examination, the operator assignedWMP weights based on the information recorded inAttachment 2 of the procedure.The operator was able to explain when an NCRwould be written. Some of the BDRs reviewedcontained NCRs for prohibited items. For example,LA-RTR1-06-0003, containers S814989, S815999,and S815002, all had liners that were not adequatelyvented and NCR-LANL-0787-06 was written toaddress this issue. Also, LA-RTR2-05-0175, drumS822352, contained liquids greater than 1” and NCRLANL-0187-05 was written to address thisprohibited item.In each of the BDRs reviewed, the image qualitycheck was documented on Attachment 1 of theprocedure CCP-TP-053 (RTR Measurement ControlReport). EPA also reviewed the image quality checkon selected audio/visual recordings of RTRexaminations.Objective evidence reviewed:1.Batch Data Report and audio/visual recordingfor batches LA-RTR2-05-0103 (S5000), LA-Revision No.: 1.0RTR-5Date of Revision: 10/20/05ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentRTR2-05-0111 (S3000 and S5000), LA-RTR2-05-0112 (S3000), LA-RTR2-05-0194 (S5000),LA-RTR1-06-0003 (S3000 and S5000), LARTR1-06-0002 (S5000), LA-RTR1-06-0001(S5000)2.BDRs LA-RTR2-05-0123 (S5000), LA-RTR2-04-0007, LA-RTR2-05-0152 (S3000), LARTR2-05-0175 (S3000 and S5000)3.RTR demonstration: RTR unit #1, debris drumS852566; RTR unit #2, debris drum 58959RTR-5:YCCP-TP-053,Rev. 4, s. 4.0,Attachment 1•RTR tape is high quality, the sound track isaudible, and the required information iscontained on the audible portion of the tape•The RTR tape is consistent with the datapackage for the same drumY As part of the inspection, the tapes and BDRs forselected drums in batches LA-RTR2-05-0103(S5000), LA-RTR2-05-0111 (S3000 and S5000),LA-RTR2-05-0112 (S3000), LA-RTR2-05-0194(S5000), LA-RTR1-06-0003 (S3000 and S5000),LA-RTR1-06-0002 (S5000), LA-RTR1-06-0001(S5000) were reviewed. The data recorded on theaudio/visual tapes and BDRs for the drums reviewedwere consistent. The audio/visual tapes were audibleand of good quality.Objective evidence reviewed:1.Batch Data Report and audio/visual recordingfor batches LA-RTR2-05-0103 (S5000), LARTR2-05-0111 (S3000 and S5000), LA-RTR2-05-0112 (S3000), LA-RTR2-05-0194 (S5000),LA-RTR1-06-0003 (S3000 and S5000), LARTR1-06-0002 (S5000), LA-RTR1-06-0001(S5000)RTR-6:There is a procedure fordetermining whether the wastematches the waste streamdescription and Waste MatrixYCCP-TP-053,Rev. 4,s. 4.4.3[D]-[F], [H],•The procedure is adequately implemented•Operators verify that the waste matches thewaste stream description•Waste Matrix Code is verified. If not,Y Procedure CCP-TP-053 contains a standard weighttable, Table 3, which was available to the operatorsobserved by EPA. However, this table is not usedconsistently when estimating leaded glove WMPs(see EPA Concern LANL-CCP-VE-06-006CR inRevision No.: 1.0RTR-6Date of Revision: 10/20/05ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentCode, and for determiningWaste Material Parameters andweightsAttachment 2,Table 3corrective action is taken•WMP weights are estimated by compiling aninventory of waste items andresidual/packaging materials•Does the RTR operator use a standard weightlookup table to provide an estimate of WMPweights? If so, has the table been updated toreflect additional information gained throughprevious RTR/VE exams or updated AKinformation?RTR-2 above).Attachment 2, CCP-TP-053, Radiography DataSheet, documents that the physical form of the wastematches the waste stream description and the wastematrix code. During the RTR demonstrationobserved by EPA, neither of the operatorsinterviewed (RTR units # 1 and 2) were able toexplain how they verified that the waste examinedmatched the waste stream description. The operatorsdid not have a hard copy or electronic version of thewaste stream description available in the RTRtrailers, and they were not able to describe theexpected WMPs in the waste stream they wereexamining (see also the VE checklist). EPAgenerated the following Concern to address this issue(see also VE-6).LANL-CCP-VE-06-005CR:Attachments used for data entry for both RTR andVE include a line item that requires operators toverify that the waste examined matches the WasteStream description. The VEE for the VEdemonstration and the operators of RTR units 1 and2, observed by EPA on May 24, 2006, could notexplain how they were able to answer this question.These personnel did not have a copy of Waste Streamdescriptions, for example CCP-LANL-AK-9, in theirrespective work areas nor were they able to describethe items included in the Waste Stream descriptionsprovided in the AK Summary Report for the wastestream they were currently examining.Prior to theMarch 6, 2007 meeting, EPA reviewed a copy of theCCP RTR and VE Training Module (PowerPointpresentation) and the NDE RTR ComprehensiveExamination. During the March meeting, EPAinterviewed RTR operators who were able tocorrectly answer questions with the regard to the dataRevision No.: 1.0RTR-7Date of Revision: 10/20/05ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentform items detailed above. The operators alsodemonstrated that they had access to both paper andelectronic copies of the applicable waste streamdescription. EPA considers this concern to be closed.Objective evidence reviewed:1.Batch Data Report and audio/visual recordingfor batches LA-RTR2-05-0103 (S5000), LARTR2-05-0111 (S3000 and S5000), LA-RTR2-05-0112 (S3000), LA-RTR2-05-0194 (S5000),LA-RTR1-06-0003 (S3000 and S5000), LARTR1-06-0002 (S5000), LA-RTR1-06-0001(S5000)2.BDRs LA-RTR2-05-0123 (S5000), LA-RTR2-04-0007, LA-RTR2-05-0152 (S3000), LARTR2-05-0175 (S3000 and S5000)3.RTR demonstration: RTR unit #1, debris drumS852566; RTR unit #2, debris drum 58959.4.Visual Examination and Real-Time RadiographyTraining Module5.LANL – NDE RTR ComprehensiveExaminationRTR-7:The RTR procedure providesinstructions for identifyingprohibited items and forprocessing drums containingprohibited items.YCCP-TP-053,Rev. 4, s.4.4.3, Notefollowing [F],[G],Attachment 1,Table 1•Operator could name prohibited items•Operator adequately explained how thepresence of free liquids is determined•Operator’s explanation of required actions ifprohibited items were encountered wasconsistent with procedure•Corrective actions are taken when necessaryY The operator demonstrated how the presence of freeliquids is determined (rocking the container).Numerous NCRs had been generated in the BDRsreviewed for the presence of liquids (see EPAFinding LANL-CCP-VE-06-004F in the VEchecklist) and other prohibited items. For example,NCR-LANL-0786-06 was initiated for drumS833213 because of a sealed container greater than4liters and NCR-LANL-0727-06 was initiated for thepresence of PCBs. NCR-LANL-0125-05 wasinitiated for drum S834116 because of greater than1”of liquid at the 30” mark and greater than 1% volumeRevision No.: 1.0RTR-8Date of Revision: 10/20/05ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentof liquid in the drum.Prohibited items are listed in the procedure, Table1.Objective evidence reviewed:1.Batch Data Report and audio/visual recordingfor batches LA-RTR2-05-0103 (S5000), LARTR2-05-0111 (S3000 and S5000), LA-RTR2-05-0112 (S3000), LA-RTR2-05-0194 (S5000),LA-RTR1-06-0003 (S3000 and S5000), LARTR1-06-0002 (S5000), LA-RTR1-06-0001(S5000)2.BDRs LA-RTR2-05-0123 (S5000), LA-RTR2-04-0007, LA-RTR2-05-0152 (S3000), LARTR2-05-0175 (S3000 and S5000)RTR-8:RTR procedures include therequired QC examinations,evaluation accuracy andreproducibility of the RTRprocess.YCCP-TP-053,Rev. 4, s. 4.5,4.6•An independent replicate scan is performed onone waste container per day or on onecontainer per testing batch (whichever is lessfrequent)•An independent observation of one scan (notthe replicate) is performed, by a qualified RTRoperator (anyone but the initial RTR operator)Y In batch LA-RTR1-06-0002, an independentobservation was performed on container 54374 and areplicate scan was performed on container 55434. Inbatch LANL-RTR2-05-0123, an independentobservation was performed on container 59316 and areplicate scan was performed on container 57776.Both of the QC samples were performed by adifferent operator to the original.Objective evidence reviewed:1.Batch Data Report and audio/visual recordingfor batchs LA-RTR2-05-0103 (S5000), LARTR2-05-0111 (S3000 and S5000), LA-RTR2-05-0112 (S3000), LA-RTR2-05-0194 (S5000),LA-RTR1-06-0003 (S3000 and S5000), LARTR1-06-0002 (S5000), LA-RTR1-06-0001(S5000)2.BDRs LA-RTR2-05-0123 (S5000), LA-RTR2-04-0007, LA-RTR2-05-0152 (S3000), LARTR2-05-0175 (S3000 and S5000)Revision No.: 1.0RTR-9Date of Revision: 10/20/05ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentRTR-9:Procedure(s) containstandardized forms forrecording RTR data.YCCP-TP-053,Rev. 4,Attachments1 & 2•RTR operator adequately explained the processfollowed for examining a drum and enteringdata into data forms (whether hard copy orelectronic data entry is used).•Direct data entry into an electronic form isdone by the RTR operator using a computerwhile the operator is still in the RTR booth•The electronic data file undergoes the samequality control (QC) checks used for handwritten data entriesY During the on-site inspection, EPA observed theRTR event for a debris (S5000) drum on RTR unit #1and RTR unit #2. The operators had a copy of theapplicable procedure (CCP-TP-053) available in theRTR operations area and performed the RTR event inaccordance with the instructions contained in thatprocedure. RTR data are electronically entered intothe data form (Attachment 2 of procedure CCP-TP053) by an individual whose sole function is torecord the RTR data generated (this person is not aqualified RTR operator). The procedure contains astandard weight table (Table 3). BDRs are subjecttoboth data generation and project level reviews. Thechecklists for the BDRs reviewed were complete,signed, and dated.Objective evidence reviewed:1.Batch Data Report and audio/visual recordingfor batches LA-RTR2-05-0103 (S5000), LARTR2-05-0111 (S3000 and S5000), LA-RTR2-05-0112 (S3000), LA-RTR2-05-0194 (S5000),LA-RTR1-06-0003 (S3000 and S5000), LARTR1-06-0002 (S5000), LA-RTR1-06-0001(S5000)2.BDRs LA-RTR2-05-0123 (S5000), LA-RTR2-04-0007, LA-RTR2-05-0152 (S3000), LARTR2-05-0175 (S3000 and S5000)RTR-10:Site procedures require reviewof BDRs at the data generationand project level.YCCP-TP-053,Rev. 4, s.4.10-4.12,Attachments3-5CCP-TP-001,•Data generation level reviews are performedand documented•Project level reviews are performed anddocumentedY All BDRs reviewed during the on-site inspectioncontained complete and signed data generation levelreview checklists (Independent Technical Reviewer,Technical Supervisor, and Facility Quality AssuranceOfficer). The BDRs also contained a complete andsigned Site Project Quality Assurance Officer reviewchecklist and a complete and signed SPM DataValidation Summary checklist.Revision No.: 1.0RTR-10Date of Revision: 10/20/05ATTACHMENT A.5: REAL-TIME RADIOGRAPHY (RTR) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentRev. 11Objective evidence reviewed:1.Batch Data Report and audio/visual recordingfor batches LA-RTR2-05-0103 (S5000), LARTR2-05-0111 (S3000 and S5000), LA-RTR2-05-0112 (S3000), LA-RTR2-05-0194 (S5000),LA-RTR1-06-0003 (S3000 and S5000), LARTR1-06-0002 (S5000), LA-RTR1-06-0001(S5000)2.BDRs LA-RTR2-05-0123 (S5000), LA-RTR2-04-0007, LA-RTR2-05-0152 (S3000), LARTR2-05-0175 (S3000 and S5000)RTR-11:Procedures require that RTRoperators receive the results ofthe VE/RTR comparison.YCCP-TP-053,Rev. 4•RTR operators receive the results of theVE/RTR comparison•RTR operators receive lessons learnedinformation based on the comparison of RTRand VE data•Identify corrective action steps (additionaltraining) taken to address lessons learnedY Although CCP at LANL had generated two annualVE/RTR comparison reports, the RTR operators hadnot received any “lessons learned” training. EPAgenerated the following Concern to address thisissue.LANL-CCP-RTR-06-008C:CCP at LANL has generated two (2) annual VE/RTRComparison Reports, but at the time of thisinspection RTR operators had not received any“lessons learned” training on the discrepanciesbetween the RTR and VE results.Revision No.: 1.0RTR-11Date of Revision: 10/20/05Information Included in Batch Data ReportsRequired Testing Batch ContentPresentY or NRequired Testing Batch ContentPresentY or NRequired Testing Batch ContentPresentY or NBatch Date Y Description of liners Y Estimated weights for WasteMaterial ParametersYReport date Y Layers of confinement Y Verificationof Waste MatrixCodeYWaste container number Y Indication of vented rigidlinersY Reference to or copies of anyNCRsYWaste Matrix Code Y Description of containercontentsY Operator signature and testdateYImplementing procedurename or #Y Indication of sealedcontainers >4LY Data generation checklists YVideotape reference Y Amount of free liquid Y Datageneration checklists YQC documentation Y Container gross weight Y Projectlevel checklists YVerification that wastematches waste streamdescriptionYYRevision No.: 1.0VE-1Date of Revision: 10/20/05ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentVE-1:Site procedures identify requiredtraining and qualifications for VEpersonnel.YCCP-TP-002,Revision 20Visual Examination Expert’s (VEE)explanation of job duties was consistentwith applicable procedures.VE personnel’s training was consistent withapplicable procedures.VE personnel’s certification is current.VE personnel are re-qualified every twoyears.VE personnel received training on specificwaste generating processes, typicalpackaging configurations, and WMPsexpected to be found in each Waste MatrixCode.Y CCP uses Qualification Cards to document and record trainingreceived by CCP personnel. The SPM appoints VisualExamination Experts (VEE) and documents the selection in aletter that is included in the VEE’s training file.During theinspection, the Qualification Cards for two VEEs werereviewed and found to be complete and current.Training on specific waste-generating processes, typicalpackaging configurations, and WMPs that are expected ineach waste stream is provided to the RTR personnel.However, this training is provided only once unlessthere is anupdate to the AK record.The site maintains a List of Qualified Individualsthat is usedto ensure training is current.Objective evidence:1. Visual Examination Operator/ITR/TS/FQAO QualificationCard for two VEEs2. List of Qualified Individuals for VEVE-2:Procedures and technicalguidance documents providecomplete instructions forperforming VE.YCCP-TP-113,Revision 4, s.4.0, Tables 1-4The site uses AK to identify the matrixparameter category and to estimate wastematerial parameters present.Procedures are sufficiently detailed toenable the operator to determine if a wastecontainer meets the criteria of 40 CFR194.24 with regard to identifying applicableparameters with waste limits.Establish standard nomenclature, based oncurrent site practice, so that all staffrecognize waste by the same descriptors.Y Two types of VE were assessed during the inspection ofLANL-CCP, namely VE in lieu of RTR and VE as a QCcheck of RTR.Procedure CCP-TP-113 contains complete and detailedinstructions for performing VE as a QC check of RTRand VEin lieu of RTR. These two types of VE are performed inexactly the same manner and both are covered in section 4.1of the procedure. The procedure also includes a list of WIPPprohibited items, a description of layers of confinement, adescription of Waste Material Parameters (WMP), a look-uptable for waste item weights, and a table explaining the codesused to record some of the VE data.Revision No.: 1.0VE-2Date of Revision: 10/20/05ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentWhen a new AK summary becomes available, the operatorsreceive documented training with regard to expectedWMPsand packaging configurations in that waste stream.VE-3YCCP-TP-113,Revision 4,s. 3.2.3Prior to starting the VE, the VEE reviewsall documented data related to the wastecontainer and its contents to ensure thatthere are no safety hazards for the VEoperators.Y Objective evidence:1.Audio/visual recording and BDRs for:LAVE540025 (VE in Lieu of RTR, S3000)LAVE540027 (VE as a QC Check of RTR, S3000)LAVE500060 (VE as a QC Check of RTR, S5000)LAVE500061 (VE as a QC Check of RTR, S5000)Revision No.: 1.0VE-3Date of Revision: 10/20/05ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentVE-4:Procedure requires anaudio/visual recording of the VEevent to be recorded.YCCP-TP-113,Revision 4, s.4.1.2VEE/operator’s explanation of how tooperate the data recording system wasconsistent with applicable procedures.The video camera was focused prior to thestart of VE.An audio/videotape is made of the wastecontainer exam and maintained as anonpermanent record.Data on the audio/visual recording isconsistent with documentation.YDuring the inspection, EPA observed VE in lieu of RTR for adebris (S5000) drum. The drum # was 601142 and theVEevent took place in a glovebox in Room 102 of Building 69 atTA-50. The audio/visual check for the day of thedemonstration had already been successfully performed priorto EPA’s arrival. EPA did, however, verify that audio/visualchecks were successfully completed by reviewing tapes forBDRs LAVE540025, LAVE540027, LAVE500060, andLAVE500061, as well as the un-validated batch fromthedemonstration LAVE500081. Audio/visual tapes werereviewed in conjunction with the BDR to ensure consistencyof the visual and written records. No discrepancieswereidentified for the BDRs reviewed.For the demonstration, the drum contents were emptied,sorted by WMP and weighed. EPA observed the scalecalibration performed for this batch. The weights,recordedfor leaded rubber gloves, were assigned as 60% rubber and40% other metals. However, in RTR leaded rubber glovesweights are assigned totally to rubber. EPA generated thefollowing Concern for this discrepancy between RTRand VE(see also RTR checklist).LANL-CCP-VE-06-006CR:1. Waste Material Parameter weights are inconsistentlyrecorded for leaded rubber gloves. In RTR, leadedgloves are recorded as only under the rubber wastematerial parameter, but in VE the weight of the gloves isassigned in the following way: ,60% rubber and 40%other metals.2.VE personnel were unable to provide the rationale forassigning the weights (60:40) in this manner.Objective evidence:1.Audio/visual recording and BDRs for:LAVE540025 (VE in Lieu of RTR, S3000)Revision No.: 1.0VE-4Date of Revision: 10/20/05ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentLAVE540027 (VE as a QC Check of RTR, S3000)LAVE500060 (VE as a QC Check of RTR, S5000)LAVE500061 (VE as a QC Check of RTR, S5000)LAVE500081 (VE in Lieu of RTR, S5000)VE-5:There is a procedure for handlinginstances when the VE Expert isunable to see through the innerplastic bags/packages/containersof waste.YCCP-TP-113,Revision 4, s.4.1.4, [D],[F.3](b)The VEE has decision-making criteria forassessing the need to open thebags/packages in order to identify all oftheir contents.If the bags are not opened, a brief writtendescription of the contents of the bags isprepared with estimates of the amount ofeach waste type in the bags.YIt is CCP’s policy to open all bags during VE, although theVEE is permitted to document decisions with regardtoopening bags in the BDR. There were numerous smallcanscontained in the drums from BDR LAVE500061 reviewedbyEPA. The VE operators did not completely empty thecansprior to weighing and it was unclear how the operatorsprovided a complete inventory of the items inside the cans andhow they were able to verify the absence of prohibited items.The VE data forms did not include any justificationfor notemptying the cans. EPA generated the following concern toaddress this issue.LANL-CCP-VE-06-007CR:The containers examined by VE in BDR LAVE500061 (VEas a QC Check of RTR) contained numerous small cansthatwere opened but not emptied during the VE event. CCPpersonnel were unable to demonstrate that all of the WMPscontained in the cans were inventoried and the VE proceduredoes not address this circumstance.Objective evidence:1.Audio/visual recording and BDRs for:LAVE540025 (VE in Lieu of RTR, S3000)LAVE540027 (VE as a QC Check of RTR, S3000)LAVE500060 (VE as a QC Check of RTR, S5000)LAVE500061 (VE as a QC Check of RTR, S5000)LAVE500081 (VE in Lieu of RTR, S5000)VE-6:The VE procedure requiresYCCP-TP-113,If an automated data entry system is used,data entry VE personnel could navigateYCCP uses the WTS to enter data electronically. During the VEdemonstration observed by EPA, the VEE was unable toexplain how VE personnel verified that the waste examinedRevision No.: 1.0VE-5Date of Revision: 10/20/05ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentverification of Waste MatrixCode and WMP weights.Revision 4, s.4.1.4, Table 4,Attachment 1through the various screens.A VE data form is used to document thematrix parameter category and estimatedWMP weights of the waste.VE staff have access to standardized chartsor tables to aid in the consistent estimationor assignment of weights, waste materialparameters, and waste matrix codes.The estimated or weighed WMP weights aredetermined by compiling an inventory ofwaste items, residual materials, andpackaging materials.The items on the inventory list are sorted byWMP and combined with a standard weightlook-up table to provide an estimate ofWMP weights.References tables are updated as site gainsinformation from VE.VEE verifies Waste Matrix Code andrecommends changes as needed.matched the waste stream description. The VEE/operators didnot have a hard copy or electronic version of the waste streamdescription available in the VE operations area andthe VEEwas not able to describe the expected WMPs in the wastestream they were examining. Accordingly, EPA generated thefollowing Concern (see RTR-6):LANL-CCP-VE-06-005CR:Attachments used for data entry for both RTR and VEincludea line item that requires operators to verify thatthe wasteexamined matches the Waste Stream description. TheVEEfor the VE demonstration and the operators of RTR units 1and 2, observed by EPA on May 24, 2006, could not explainhow they were able to answer this question. Thesepersonneldid not have a copy of Waste Stream descriptions, e.g., CCPLANL-AK-9, in their respective work areas, nor weretheyable to describe the items included in the Waste Streamdescriptions provided in the AK Summary for the wastestream they were currently examining. Prior to theMarch 6,2007 meeting, EPA reviewed a copy of the CCP RTR and VETraining Module (PowerPoint presentation) and the NDERTR Comprehensive Examination. During the March 2007meeting, EPA interviewed RTR operators who were able tocorrectly answer questions with regard to the dataform itemsdetailed above. The operators also demonstrated that they hadaccess to both paper and electronic copies of the applicablewaste stream description. EPA considers this concern to beclosed.Objective evidence:1.Audio/visual recording and BDRs for:LAVE540025 (VE in Lieu of RTR, S3000)LAVE540027 (VE as a QC Check of RTR, S3000)LAVE500060 (VE as a QC Check of RTR, S5000)LAVE500061 (VE as a QC Check of RTR, S5000)LAVE500081 (VE in Lieu of RTR, S5000)Revision No.: 1.0VE-6Date of Revision: 10/20/05ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Comment2.Visual Examination and Real-time Radiography Training3.LANL – NDE RTR Comprehensive ExaminationVE-7:Procedure provides instructionsfor processing of containers withprohibited items.YCCP-TP-113,Revision 4, s.4.3, Table 1,Attachment 1,section 5VE expert could name prohibited items.VE expert’s explanation of required actionsif prohibited items were encountered wasconsistent with procedure.The VEE describes any liquids found,including a description of their location inthe container and estimated volume.Other prohibited items, including sealedcontainers, are identified and segregated.YThe data form used lists prohibited items and theVEE/operators are required to answer the required questions.The default answers in the form are “No” for prohibited items.The quantity and location of prohibited liquid encountered inthe RTR examinations of containers prior to May 2005 fromwaste stream number LA-MIN03-NC.001 were not predictedin the AK summary CCP-AK-LANL-004. Althoughcharacterization personnel initiated NCRs to address thepresence of prohibited liquids, this information was notcommunicated to AK personnel to enable updating ofthe AKrecord. CCP personnel used VE in Lieu of RTR tocharacterize wastes from this same waste stream from May 4through June 23, 2005. However, the presence of liquidsmade the use of this technique unsuitable for containers ofS3000 wastes. Until corrective action is taken theuse of thistechnique at CCP sites is unacceptable. EPA generatedfinding LANL-CCP-VE-06-004F to address this issue.NCRs were initiated as required. For example, NCRLANL0911-05 was initiated for drums S814064, S810436, andS814194 (BDR LAVE540025) because of residual liquid>1% of the container volume. NCR LANL-0904-05 wasinitiated for container 55598 because the balance switchedfrom Kg to lbs in the middle of the VE event.Objective evidence:1.Audio/visual recording and BDRs for:LAVE540025 (VE in Lieu of RTR, S3000)LAVE540027 (VE as a QC Check of RTR, S3000)LAVE500060 (VE as a QC Check of RTR, S5000)LAVE500061 (VE as a QC Check of RTR, S5000)LAVE500081 (VE in Lieu of RTR, S5000)Revision No.: 1.0VE-7Date of Revision: 10/20/05ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentVE-8:YCCP-TP-113,Revision 4, s.4.1.4, [C1] (a),[C8],Attachment 1,section 2The gross weight of the waste container(container plus contents) is recorded on theVE data form. Volume utilization of thecontainer is documented.YThe gross weight of containers and volume utilization of thecontainer are recorded in section 2 of Attachment 1of theCCP Waste Visual Examination Data Form.Objective evidence:1.Audio/visual recording and BDRs for:LAVE540025 (VE in Lieu of RTR, S3000)LAVE540027 (VE as a QC Check of RTR, S3000)LAVE500060 (VE as a QC Check of RTR, S5000)LAVE500061 (VE as a QC Check of RTR, S5000)LAVE500081 (VE in Lieu of RTR, S5000)VE-9:YCCP-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,#8The procedure is adequately implementedand corrective actions are taken whennecessary.YDuring the inspection, EPA observed VE in Lieu of RTR for adebris (S5000) drum. The drum # was 601142 and theVEevent took place in a glovebox in Room 102 of Building 69 atTA-50. The audio/visual check for the day of thedemonstration had already been successfully performed priorto EPA’s arrival. EPA did, however, verify that audio/visualchecks were successfully completed by reviewing tapes forBDRs LAVE540025, LAVE540027, LAVE500060,LAVE500061, and the un-validated batch from thedemonstration LAVE500081. Audio/visual tapes werereviewed in conjunction with the BDR to ensure consistencyof the visual and written records. No discrepancies wereidentified for the BDRs reviewed and all required informationwas recorded. For the demonstration, the drum contents wereemptied, sorted by WMP and weighed. EPA observed thescale calibration performed for this batch.NCRs were initiated as required. For example, NCRLANL0911-05 was initiated for drums S814064, S810436, andS814194 (BDR LAVE540025) because of residual liquid>1% of the container volume. NCR LANL-0904-05 wasinitiated for container 55598 because the balance switchedfrom Kg to lbs in the middle of the VE event.Revision No.: 1.0VE-8Date of Revision: 10/20/05ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentObjective evidence:1.Audio/visual recording and BDRs for:LAVE540025 (VE in Lieu of RTR, S3000)LAVE540027 (VE as a QC Check of RTR, S3000)LAVE500060 (VE as a QC Check of RTR, S5000)LAVE500061 (VE as a QC Check of RTR, S5000)LAVE500081 (VE in Lieu of RTR, S5000)VE-10:Site procedure(s) require datageneration and project levelreviews of BDRs.YCCP-TP-113,Revision 4,s. 4.6-4.8,Attachment2-4CCP-TP-001,Rev. 11BDRs contain all required information (seetable below). Data generation and projectlevel reviews are complete.Y The BDRs listed below contained completed data generationand project level review checklists. BDRs contained all of therequired information.Objective evidence:1.Audio/visual recording and BDRs for:LAVE540025 (VE in Lieu of RTR, S3000)LAVE540027 (VE as a QC Check of RTR, S3000)LAVE500060 (VE as a QC Check of RTR, S5000)LAVE500061 (VE as a QC Check of RTR, S5000)VE-11:The site has a procedure forusing the data obtained from VEas a QC check of RTR tocalculate the percentage ofmiscertified waste containers.The facility has a procedure forrandomly selecting wastecontainers.YCCP-TP-113,Rev. 4, s. 4.1CCP-TP-003,Rev. 14, s. 4.7,A13, Rev. 0CCP-TP-003,Rev. 14, A13,Rev. 0The number of waste containers to undergoVE is appropriately calculated.The site uses an initial miscertification rateof 11%.Miscertification rate is calculated for eachapplicable Summary Category Group after 6months or 50% of the SCG have undergoneRTR.Site uses 1% miscertification rate ifcalculated value is <1%.Rate is reassessed annually using a drumweighted average.Y The table used for determining the number of containersrequiring VE is a duplicate of that in WAP, Table B2-1(CCPTP-003, Table 1).Memoranda: March 30, 2005, 2005 Selection of VisualExamination Drums from S3000 Summary Category Group;June 27, 2005, 2005 Selection of Visual ExaminationDrumsfrom S3000 Summary Category Group identify the containersto undergo VE and a list of replacement container numbers.Letter: March 23, 2006, Selection of Visual ExaminationDrums from S3000 and S5000 2006 Category Groupsdocument the random selection of drums to be examined forcalculation of the miscertification rate as well identifyingreplacement drums.Revision No.: 1.0VE-9Date of Revision: 10/20/05ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentEPA also reviewed memoranda: April 26, 2005, InitialSummary Category Group-Specific S3120 MiscertificationRate; and March 29, 2005, Initial Summary CategoryGroupSpecific S5000 Miscertification Rate that documented theinitial rates calculated for these SCGs.Section 4.11 requires that a container-weighted average ofhistoric site-specific miscertifcation rates be calculated. Thiswas evidenced by review of a February 10, 2006 letter thatincluded the container weighted site-specific ratecalculation.Objective evidence:1.Memorandum dated March 30, 2005, 2005 Selection ofVisual Examination Drums from S3000 SummaryCategory Group and memorandum dated June 27, 2005,2005 Selection of Visual Examination Drums from S3000Summary Category Group2.Letter dated March 23, 2006, 2006 Selection of VisualExamination Drums from S3000 and S5000 CategoryGroups3.Memorandum dated February 10, 2006, LANL AnnualReassessment of the Site Specific MiscertificationRate(S3000 and S5000)4.Memorandum dated March 29, 2005, Initial SummaryCategory Group-Specific S5000 Miscertification Rate5.Memorandum dated April 26, 2005, Initial SummaryCategory Group-Specific S3120 Miscertification RateVE-12:The site has a documentedstratagem for selectingreplacement waste containers.YCCP-TP-003,Revision 14,s. 4.12 & 4.13If fewer containers were visually examinedthan were sampled, the reason for excludingthe containers is documented.The replacement stratagem is restricted tocontainers from the same waste stream.YWhen CCP selects the containers for VE as a QC Check pfRTR, extra containers are randomly selected so thatreplacement containers are available if needed. The reasonfor excluding containers in the original selectionisdocumented. EPA reviewed the status of containersselectedand reasons for rejection on a list provided by CCP.Revision No.: 1.0VE-10Date of Revision: 10/20/05ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentVE is performed on the replacementcontainers.Objective evidence:1.Status report for containers used to calculatemiscertification rate, including reasons for containerrejection.VE-13:The calculation used for themiscertification rate isdocumented.YCCP-TP-003,Revision 14,s. 4.9-4.11After the required number of containershave been visually examined, the UCL90forthe proportion miscertified is calculated.The site has used the appropriatedistribution for the UCL90calculation todetermine N.YThe table used for determining the number of containersrequiring VE is a duplicate of that in WAP, Table B2-1.The calculations used were appropriate and documented.Objective evidence:1.Memorandum dated March 26, 2005, Initial SummaryCategory Group-Specific S3120 Miscertification Rate2.Memorandum dated March 29, 2005, Initial SummaryCategory Group-Specific S5000 Miscertification Rate.3.Memorandum dated February 10, 2006, Los AlamosNational Laboratory Annual Reassessment of the SiteSpecific Annual Miscertification Rate (S3000 and S5000)VE-14:Site procedure requires thatresults of VE as a QC check ofRTR are forwarded to theradiography facility.RTR operators receive results of RTR/VEcomparison.Y Memoranda: April 12, 2005, Waste Material ParameterWeight Comparison Report for Los Alamos NationalLaboratory April 2004 Through March 2005 (RelativePercentDifference Comparison Report for Radiography and VisualExamination); May 26, 2005, Waste Material ParameterWeight Comparison Report for Los Alamos NationalLaboratory June 2004 Through April 2005 (Relative PercentDifference Comparison Report for Radiography and VisualExamination): Waste Stream LA-MIN03-NC.001; February7, 2006, Waste Material Parameter Weight ComparisonReport for Los Alamos National Laboratory April 2005Through December 2005 (Relative Percent DifferenceComparison Report for Radiography and Visual Examination)document the RTR/VE comparisons performed in ordertoRevision No.: 1.0VE-11Date of Revision: 10/20/05ATTACHMENT A.6: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentcalculate the miscertification rates.At the time of the inspection, “lessons learned” training hadnot been provided to the RTR operators. EPA generated thefollowing concern to address this issue:LANL-CCP-RTR-06-008C:CCP at LANL has generated two (2) annual VE/RTRComparison Reports but at the time of this inspection RTRoperators had not received any “lessons learned” training onthe discrepancies between the RTR and VE results.Objective evidence:1.Memorandum dated April 12, 2005, Waste MaterialParameter Weight Comparison Report for Los AlamosNational laboratory April 2004 Through March 2005(Relative Percent Difference Comparison Report forRadiography and Visual Examination)2.Memorandum dated May 26, 2005, Waste MaterialParameter Weight Comparison Report for Los AlamosNational laboratory June 2004 Through April 2005(Relative Percent Difference Comparison Report forRadiography and Visual Examination): Waste StreamLA-MIN03-NC.0013.Memorandum dated February 7, 2006, Waste MaterialParameter Weight Comparison Report for Los AlamosNational laboratory April 2005 Through December 2005(Relative Percent Difference Comparison Report forRadiography and Visual Examination) document theRTR/VE comparisons performed in order to calculatethemiscertification rates.Revision No.: 1.0VE-12Date of Revision: 10/20/05Information Included in BDRRequired Testing Batch ContentPresentY or NRequired Testing Batch ContentPresentY or NRequired Testing Batch ContentPresentY or NBatch Date Y Description of liners Y Verification of Waste Matrix Code YReport date Y Layers of confinement Y Reference toor copies of anyNCRsYWaste container number Y Indication of vented rigidlinersY VEE decisions YWaste Matrix Code Y Description of containercontentsY Operator signature and testdateYImplementing procedurename or #Y Indication of sealedcontainers >4LY VEE signature and test date YVideotape reference Y Amount of free liquid Y Completed data generationchecklistsYQC documentation Y Container gross weight Y Completed project levelchecklistsYVerification that wastematches waste streamdescriptionY Waste Material ParametersweightsYRevision No.: 1.0VET-OSRP-1Date of Revision: 10/20/05ATTACHMENT A.7: VISUAL EXAMINATION TECHNIQUE (VET)FOR OFF-SITE SOURCE RECOVERY PROGRAM (OSRP) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: August 22, 2006Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentOSRP-1:Procedures identify required trainingand qualifications for VE personnel.CCP-TP-069,Revision 3, s.2.2.1CCP-QP-002,R. 21•VE personnel’s training was consistent withapplicable procedures•VE personnel’s certification is current•VE personnel are re-qualified every two yearsCCP-QP-002, R. 21 does not contain any trainingrequirements for VE operators/ITR/TS/FQAO forCH waste.OSRP-2:Equipment requiredCCP-TP-069,Revision 3,s.2.4.1Calibrated torque wrench Y EPA observed the correctuse of the calibratedtorque wrench during the inspection (torque wrenchID # 026327, calibration expires December 20,2006. The wrench had a maximum limit of 150 ftlbs.Prior to arriving at each recovery site, LANLpersonnel ship the required equipment to the site tofacilitate operations.OSRP-3:Procedures and technical guidancedocuments provide completeinstructions for performing VE.CCP-TP-069,Revision 3, s.4.0•VE operator and VE packager required (bothVE operators)•Attachment 4Y EPA observed the packaging of four241Am (80mCi each) sources at Radiation Technology, Inc.located at 8407 Skyline Avenue, Odessa, Texas.The LANL personnel who performed this VE eventwere a VE operator, a VE packager, and an RCT.Prior to arriving at the site, the LANL personnelcompile a work plan that includes information onisotopes, activity, AK summary, and waste streamdescription, as available. The special form capsulewas inspected for usability at the start of theprocess in accordance with LANL procedure. TheVE operator inspected the sources to identify anyidentification markings. No such markings werefound on the sources to be packaged. Prior to beingloaded, the special form capsule is etched withinformation about the sealed sources to be placed init (this is not required by CCP-TP-069 but is byRevision No.: 1.0VET-OSRP-2Date of Revision: 10/20/05ATTACHMENT A.7: VISUAL EXAMINATION TECHNIQUE (VET)FOR OFF-SITE SOURCE RECOVERY PROGRAM (OSRP) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: August 22, 2006Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentOSR-OP-170, Section. 7.3 c).Attachment 4 of procedure CCP-TP-069 waselectronically completed by the VE operator asinformation became available. The data recordedinclude the presence/absence of prohibited items,WMC, POC, and drum closure. Other informationincluded:Drum # LA00000062745Filter # NucFil-013, serial # LC-734, date 12/02POC filter UT9400, serial # 025194, date Jan 2003S100 (6” pipe component)Capsule model # II-1-0268Outside TID # LANL 001416OSRP-4:VE operator verifies:CCP-TP-069,Revision 3, s.4.1.5•Source meets applicable regulatorydefinitions•Outer casing made of non volatile organicmaterial•Source is or is contained in rigid sealedcontainer ≤ 4 liters•Items match the waste stream description,WMC, and physical form/SCG provided byAK•No non-packaging items placed in thecontainer other than sources•No more than 2 layers of confinement•Source loaded using tongs or special toolY The VE operator electronically entered thisinformation into Attachment 4 during the VE event.Initially the VE operator could not locate the wastestream description for the subject sources (AKsummary Report AK-LANL-08, R.4), but was ableto obtain this information from LANL during thecourse of the VE event.For packaging of these four sources there was onlyone layer of confinement.Revision No.: 1.0VET-OSRP-3Date of Revision: 10/20/05ATTACHMENT A.7: VISUAL EXAMINATION TECHNIQUE (VET)FOR OFF-SITE SOURCE RECOVERY PROGRAM (OSRP) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: August 22, 2006Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentOSRP-5:CCP-TP-069,Revision 3, s.4.0Attachment 4 completed:•Sealed source description and identifier•WMP category from Attachment 1•Estimated weight•Item information verified during VE•Absence/presence of prohibited itemsAttachment 4 was completed as required andverified and signed by both the VE operator and theVE packager.Weights for items commonly encountered duringsealed source packaging activities are contained inAttachment 2 of procedure CCP-TP-069. TheWMP assigned, from Attachment 1, was OM (othermetals). The absence/presence of prohibited itemsis recorded in the Prohibited Hazardous Items andConditions section of Attachment 4.OSRP-6:Closing POCCCP-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 duedateY EPA observed the VE event for four241Am sources.The closure procedures for both the POC and drumwere observed and were determined to be inaccordance with the requirements of procedure CPTP-069.OSRP-7:Closing drumCCP-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 duedate•Apply TID to drumY The VE operator attached security tape to the POCafter closure. This security measure is required byLANL but is not required by CCP-TP-069. TheCCP procedure requires a TID to be attached to theclosure bolt of the drum; placement of TID wasobserved by EPA.OSRP-8:BDR assembled by VE operatorCCP-TP-069,Revision 3, s.4.2.1•Cover page (Attachment 5)•Table of Contents (Attachment 6)Revision No.: 1.0VET-OSRP-4Date of Revision: 10/20/05ATTACHMENT A.7: VISUAL EXAMINATION TECHNIQUE (VET)FOR OFF-SITE SOURCE RECOVERY PROGRAM (OSRP) CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: August 22, 2006Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Comment•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 MarkingsOSRP-9:BDR•Assign a unique BDR #, e.g. LAyy-OSR-VEnnn, and record on Attachment 5•Record waste stream name and number andcontainer type on Attachment 5•Record container ID # for each containerincluded in the BDR on Attachment 5OSRP-10:Data generation level review•ITR, Attachment 7•TS, Attachment 8•FQAO, Attachment 9LANL personnel (ITR/TS/FQAO) perform datageneration level reviewsOSRP-11:Project level review•SPM•SQAOCCP personnel perform project level reviewsRevision No.: 1.0WWIS-1Date of Revision: 10/20/05ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentWWIS-1:WWIS and Data Entry Personnel mustbe trained to assess data and properlyenter data into the WWIS.YCCP-QP-002,R. 20, CCPTP-030, R.18, s. 2.2.1•WCO and Data Entry Personnel are trained toassess data and properly enter and transfer alldata in the WWIS.•Training for Data Entry Personnel and datareviewers/verifiers include the WIPP WasteInformation System User’s Manual and theapplicable site procedures.•Training records are available for review andare complete.YTraining for data entry personnel (now WCA,Waste Certification Assistant) includes the WIPPWaste Information System User’s Manual and theapplicable site procedures. The WWIS DataAdministrator provides each trainee withorientation to WWIS, but this training is notdocumented.WCO/WCAs are based in Carlsbad, New Mexico,but a WCO was available at LANL to demonstratethe WWIS processes used. All CCP data entryinto WWIS takes place in Carlsbad. The trainingrecord, contained in the personnel qualificationcard, for a WCA was reviewed during the on-siteinspection. The training qualification card for theWCO interviewed had previously been reviewedduring baseline inspections at other CCP sites.The training was complete and appropriate forthese positions.The WCO and/or WCA build a file that contains allcharacterization/certifcation data for each containerto be entered into WWIS. Personnel are able toaccess BDR information for each container fromthe PTS (Project Office Tracking System). Thisadministrative system is used to identify containersthat are fully characterized and eligible for WWISentry.Objective evidence reviewed:1.Qualification Cards for Waste CertificationAssistant (WCA)WWIS-2:Security measures for ensuring dataintegrity and accessing WWIS areYCCP-TP-030,Access to WWIS is controlled. WWIS accessrequests are recorded in an access log, howevernamed, that is available for review.Y Access to WWIS is controlled by the WWIS DataAdministrator. CCP requests access for personneland the approval and password are transmitted toRevision No.: 1.0WWIS-2Date of Revision: 10/20/05ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentsufficient. R. 18, s. 4.1CCP via e-mail. WWIS access log is maintainedby the WWIS Data Administrator in Carlsbad, NewMexico.Objective evidence reviewed:1.E-mail, dated July 27, 2005, granting WWISaccess to WCAWWIS-3:There are adequate procedures forentering data into the WWIS andtransmitting data to WIPP.YCCP-TP-030,Revision 18,s. 3.0, 4.0Employee’s explanation of job duties wasconsistent with applicable procedures. WWIS andData Entry Personnel adequately explained howdata are assessed, input, and transferred intoWWIS.Y Data entry for all CCP sites takes place in Carlsbad,New Mexico. For the purpose of demonstration, aWCO was present at LANL for this inspection.The WWIS Data Entry Summary –Characterization and Certification, which is anExcel spreadsheet, is used to entercharacterization/certification data. Aftercompletion, the spreadsheet is printed andreviewed. By signing this summary, the WCOaccepts the data for submission to WWIS. Afterthe spreadsheet data have been approved by theWCO, ASCII, tab-delimited text files are generatedand then submitted to WWIS. The Excelspreadsheet is controlled by software QA. AllNCRs must be closed prior to data entry. DeanMooney verifies NCR closure and informs theWCO of containers that are eligible for data entryinto WWIS. After acceptance by WWIS, containerinformation can be accessed by the WasteContainer Data Report.Objective evidence reviewed:1.WWIS Data Entry Summary – Characterizationand Certification for container LA000000591792.WWIS Data Entry Summary – Characterizationand Certification for container LAS8112703.Waste Container Data Report for containerLA00000052034Revision No.: 1.0WWIS-3Date of Revision: 10/20/05ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Comment4.Waste Container Data Report for containerLA000000619565.E-mail, dated May 11, 2006, from DeanMooney with regard to NCR/CAR dispositionsfor Lot LANL 7016.List of NCR/CAR status for selected containers7.WCO Data Entry Activities, Data Checklist forContainers to be Shipped, containerLAS811270WWIS-4:Procedures require that only verifiedand validated data are entered intoWWIS.YCCP-TP-030,Revision 18,s. 4.3, 4.4Data generation and project level reviews ofcontainer data for WWIS entry have beenperformed and review checklists are complete.Y When all reviews have been completed, the SiteProject Manager (SPM) notifies the WCO/WCAsthat a lot evaluation is complete by issuing a CIS(container information summary). Theadministrative controls used by CCP ensure thatonly containers that have been through both levelsof review are available for WWIS submission.As part of this inspection, the EPA inspectorreviewed RTR and VE BDRs, all of whichcontained complete review checklists.Objective evidence reviewed:1.Correlation of Container Identification,Numbers to Batch Data Report Numbers.2.BDRs LAVE540025, LAVE540027,LAVE500060, LAVE500061, LA-RTR2-05-0194, LA-RTR2-05-00123, LA-RTR2-05-0152, LA-RTR2-05-0175, LA-RTR12-06-0002, LA-RTR12-06-0001, LA-RTR12-06-0003WWIS-5:Procedures include instructions forsubmission of data into theYCCP-TP-030,Revision 18,•To enable Waste Stream Profile Formapproval Data are entered into theCharacterization module of WWIS on aY Characterization data are entered into theCharacterization Module of WWIS so that a WasteStream Profile Form can be approved. Because thedata fields in the Characterization Module are aRevision No.: 1.0WWIS-4Date of Revision: 10/20/05ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentCharacterization and the Certificationmodule of WWIS.s. 4.4, 4.5 container basis.•To obtain shipping certification of acontainer, data are entered into theCertification module of WWIS.subset of those in the Certification Module,characterization data can be electronicallytransferred into the Certification Module. Spotchecks of electronically entered data are performed,but 100% of manually entered data are checked foraccuracy. The checks use the paper copy of BDRsand the WCO/WCA makes manual corrections tothe data. Any changes made are recorded in theBDR.The WCO is permitted to calculate the methaneconcentration from the hydrogen concentration ifmethane is flagged “U.”An Excel spreadsheet, WWIS Data Entry Summary–Characterization and Certification, is used toensure that all data are entered and are correct priorto uploading to WWIS. This spreadsheet containsmany of the same data checks as WWIS. BeforeWWIS submission the WCO must accept the databy signing the Excel spreadsheet.Objective evidence reviewed:1.WWIS Data Entry Summary –Characterization and Certification for containerLA000000591792.WWIS Data Entry Summary –Characterization and Certification for containerLAS8112703.Waste Container Data Report for containerLA000000520344.Waste Container Data Report for containerLA000000619565.Waste Stream Profile Form, LA-MHD02.001Revision No.: 1.0WWIS-5Date of Revision: 10/20/05ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentWWIS-6:Procedures include a requirement forreview of data prior to submission toWWIS.YCCP-TP-030,Revision 18,s. 4.3, 4.4•There is an independent review of data priorto submission to WIPP via the WWIS.•Procedures for resolution/correction ofnonconforming data are adequatelyimplemented.Y Characterization data are entered into theCharacterization Module of WWIS so that a WasteStream Profile Form can be approved. Because thedata fields in the Characterization Module are asubset of those in the Certification Module,characterization data can be electronicallytransferred into the Certification Module. Spotchecks of electronically entered data are performed,but 100% of manually entered data are checked foraccuracy. The checks use the paper copy of BDRsand the WCO/WCA makes manual corrections tothe data. Any changes made are recorded on theBDRs. The WCO accepts data for WWISsubmission by signing the Excel spreadsheet.WWIS contains checks that do not allow incorrector unusable data to be uploaded. CCP uses the PTSto identify containers that are fully characterizedand eligible for WWIS submission.Objective evidence reviewed:1.WWIS Data Entry Summary –Characterization and Certification for containerLA000000591792.WWIS Data Entry Summary –Characterization and Certification for containerLAS8112703.Waste Container Data Report for containerLA000000520344.Waste Container Data Report for containerLA000000619565.E-mail, dated May 11, 2006, from DeanMooney with regard to NCR/CAR dispositionsfor Lot LANL 7016.List of NCR/CAR status for selectedRevision No.: 1.0WWIS-6Date of Revision: 10/20/05ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentcontainers7.WCO Data Entry Activities, Data Checklist forContainers to be Shipped, containerLAS811270WWIS-7:There are adequate procedures forentering data into the WWIS andtransmitting the data to WIPP.YCCP-TP-030,Revision 18,s. 4.3, 4.4,4.5The site has successfully submittedcharacterization and certification data to WIPPvia WWIS.Y CCP at LANL has successfully submittedcharacterization and certification data for manycontainers to WIPP via WWIS (2270 alreadydisposed and 298 presently certified). The WCOwas able to access multiple certified containers todemonstrate CCP’s processes. LANL siteidentification number is C4.Objective evidence reviewed:1.WWIS Data Entry Summary –Characterization and Certification for containerLA000000591792.WWIS Data Entry Summary –Characterization and Certification for containerLAS8112703.Waste Container Data Report for containerLA000000520344.Waste Container Data Report for containerLA00000061956WWIS-8:Procedures provide instructions fordata correction if data are rejected byWWIS.YCCP-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 DataAdministrator, processes for datareconciliation/correction are implementedY WWIS contains checks that do not allow incorrector unusable data to be uploaded. If a problem withdata is detected by WWIS, the entry screen flashesred to indicate which data are not acceptable. TheWCO/WCA is then able to identify the problemwith the data and correct it. The Excel spreadsheet,used to compile the data for WWIS entry, containsmany of the same checks as WWIS. After data areaccepted by WWIS, an e-mail is sent to CCPinforming the WCO/WCA that the data areRevision No.: 1.0WWIS-7Date of Revision: 10/20/05ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentaccepted. WWIS contains codes that indicate thestatus of entered data.Objective evidence reviewed:1.WWIS Data Entry Summary –Characterization and Certification for containerLA000000591792.WWIS Data Entry Summary –Characterization and Certification for containerLAS8112703.Waste Container Data Report for containerLA000000520344.Waste Container Data Report for containerLA00000061956WWIS-9:Procedures for waste containercharacterization/certification datasubmittal to WWIS require theappropriate records to be retained.YCCP-TP-030,Revision 18,s. 5.0•WWIS access requests•WWIS access logs•Waste container data input reportsY The WCO demonstrating CCP’s WWIS processeswas able to retrieve all records requested by EPA.Data access logs are retained by the WWIS DataAdministrator in Carlsbad, New Mexico. Access toWWIS is requested by CCP and granted via emailby the WWIS Data Administrator.Objective evidence reviewed:1.E-mail, dated July 27, 2005, granting WWISaccess to WCA2.WWIS Data Entry Summary –Characterization and Certification for containerLA000000591793.WWIS Data Entry Summary –Characterization and Certification for containerLAS8112704.Waste Container Data Report for containerLA00000052034Revision No.: 1.0WWIS-8Date of Revision: 10/20/05ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM CHECKLISTEPA Inspection No.: EPA-LANL-CCP-05.06-8Inspection Date: May 23 – 25, 2006Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Comment5.Waste Container Data Report for containerLA00000061956WWIS-10:NA•Plans and procedures for payloadmanagement have been approved by CBFO.•CBFO informed EPA prior to approving thesite to use payload management forcontainers.•TRU alpha activity concentration is > 100nCi/g for the entire waste stream.•Only waste containers from the same wastestream are payload managed in the samepayload container.•Each waste container selected for payloadmanagement contains at least one TRUisotope.•TRU alpha activity concentration of thepayload container is determined and reported.NA CCP at LANL does not intend to payload managecontainers.

# 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 equi valent - 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 acti vity uncertainty - present

Waste Material Weight - present Radionuclide mass – present

Waste Material Parameter - present Radionuclide mas s uncertainty - present

Hazardous Code - present Radioassay method – presen t

Layers of packaging - present Assay date – present

Liner exists - present Characterization method - p resent

Filter model - present Characterization method dat e - 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 – pre sent

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 - pres ent 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 - p resent

Container weight - present Handling Code - present

Contact Dose Rate - present

# Attachments B.1 through B.22B-1ATTACHMENT B.1 REPLICATE TESTING DATA FOR CONTAINER 52331, HENC #1 SYSTEMInstrument: HENC#1Container: 52331Original Measurement Replicate #1 Replicate #2Quantity of Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value Uncertainty UncertaintyValue Uncertainty Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 6.77E-011.14E-011.68E-018.06E-011.60E-011.99E-014.51E-015.05E-021.12E-01239Pu Activity (Ci) 9.71E+002.34E+012.41E+009.64E+002.29E+012.38E+009.69E+002.34E+012.41E+00240Pu Activity (Ci) 2.63E+001.71E+006.52E-012.71E+001.81E+006.68E-012.77E+001.91E+006.90E-01242Pu Activity (Ci) 2.66E-041.75E-086.59E-052.73E-041.84E-086.75E-052.80E-042.00E-087.16E-05241Am Activity (Ci) 3.87E+003.72E+009.60E-010.00E+00N/A0.00E+000.00E+00N/A0.00E+0090Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00TRU Alpha Conc. (nCi/g) 4.25E+052.87E+106.75E+044.30E+052.88E+106.70E+044.27E+052.90E+106.80E+04Replicate #3 Replicate #4 Replicate #5Quantity ofInterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 7.41E-011.34E-011.81E-019.34E-012.14E-012.29E-014.97E-016.11E-021.23E-01239Pu Activity (Ci) 9.55E+002.23E+012.34E+009.58E+002.25E+012.35E+009.67E+002.32E+012.40E+00240Pu Activity (Ci) 2.80E+001.92E+006.86E-012.71E+001.80E+006.65E-012.74E+001.86E+006.80E-01242Pu Activity (Ci) 2.83E-041.96E-086.92E-052.74E-041.84E-086.72E-052.82E-041.97E-087.00E-05241Am Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+0090Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00TRU Alpha Conc. (nCi/g) 4.28E+052.83E+106.61E+044.30E+052.85E+106.62E+044.25E+052.87E+106.76E+04B-2ATTACHMENT B.2 REPLICATE TESTING RESULTS FOR CONTAINER 52331, HENC #1 SYSTEMInstrument: HENC#1Container: 52331Original Measurement Sample RelativeQuantity of Reported Absolute Sample Standard StandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| 

# χ2|)t Pr(x<|t|)233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A234U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A238Pu Activity (Ci) 6.77E-011.14E-016.86E-012.06E-013.00E-011.31E+011.06E-02-3.90E-029.71E-01239Pu Activity (Ci) 9.71E+002.34E+019.63E+005.94E-026.17E-032.58E-051.00E+001.29E+002.66E-01240Pu Activity (Ci) 2.63E+001.71E+002.75E+003.91E-021.42E-022.08E-031.00E+00-2.71E+005.37E-02242Pu Activity (Ci) 2.66E-041.75E-082.78E-044.62E-061.66E-022.77E+050.00E+00-2.45E+007.02E-02241Am Activity (Ci) 3.87E+003.72E+000.00E+000.00E+00N/A0.00E+001.00E+00N/AN/A90Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/ATRU Alpha Conc. (nCi/g) 4.25E+052.87E+104.28E+052.12E+034.96E-032.19E-141.00E+00-1.29E+002.66E-01Quantity ofInterestχ2Testt Test233U Activity (Ci) #VALUE! Not Applicable234U Activity (Ci) #VALUE! Not Applicable238U Activity (Ci) #VALUE! Not Applicable238Pu Activity (Ci) Significant Not Significant239Pu Activity (Ci)Not Significant Not Significant240Pu Activity (Ci)Not Significant Not Significant242Pu Activity (Ci)Highly SignificantNot Significant241Am Activity (Ci)Not SignificantNot Applicable90Sr Activity (Ci) #VALUE! Not Applicable137Cs Activity (Ci) #VALUE! Not ApplicableTRU Alpha Conc. (nCi/g)Not Significant Not SignificantB-3ATTACHMENT B.3 REPLICATE TESTING DATA FOR CONTAINER 52476, HENC #1 SYSTEMInstrument: HENC#1Container: 52476Original Measurement Replicate #1 Replicate #2Quantity of Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value Uncertainty UncertaintyValue Uncertainty Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 1.34E+005.13E-013.83E-011.46E+006.25E-014.28E-011.41E+005.80E-014.11E-01239Pu Activity (Ci) 9.75E+001.43E+011.47E+001.04E+011.87E+011.80E+001.00E+011.71E+011.71E+00240Pu Activity (Ci) 8.98E+001.26E+011.40E+009.61E+001.63E+011.70E+009.26E+001.50E+011.62E+00242Pu Activity (Ci) 4.43E-034.32E-069.76E-044.75E-035.32E-061.12E-034.58E-034.90E-061.07E-03241Am Activity (Ci) 2.12E+011.30E+026.12E+001.54E+011.26E+028.18E+000.00E+00N/A0.00E+0090Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00TRU Alpha Conc. (nCi/g) 4.51E+051.77E+103.93E+044.94E+055.73E+101.16E+054.84E+055.47E+101.13E+05Replicate #3 Replicate #4 Replicate #5Quantity ofInterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 1.41E+005.84E-014.14E-011.40E+005.74E-014.10E-011.47E+006.34E-014.31E-01239Pu Activity (Ci) 1.01E+011.75E+011.73E+001.00E+011.72E+011.72E+001.05E+011.90E+011.81E+00240Pu Activity (Ci) 9.30E+001.52E+011.63E+009.22E+001.49E+011.62E+009.66E+001.65E+011.71E+00242Pu Activity (Ci) 4.60E-034.97E-061.08E-034.55E-034.87E-061.07E-034.77E-035.39E-061.13E-03241Am Activity (Ci) 1.37E+013.27E+012.39E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+0090Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00TRU Alpha Conc. (nCi/g) 4.67E+052.14E+104.59E+044.82E+055.40E+101.12E+054.95E+055.59E+101.13E+05B-4ATTACHMENT B.4 REPLICATE TESTING RESULTS FOR CONTAINER 52476, HENC #1 SYSTEMInstrument: HENC#1Container: 52476Original Measurement Sample RelativeQuantity of Reported Absolute Sample Standard StandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| 

# χ2|)t Pr(x<|t|)233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A234U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A238Pu Activity (Ci) 1.34E+005.13E-011.43E+003.24E-022.27E-021.59E-021.00E+00-2.54E+006.43E-02239Pu Activity (Ci) 9.75E+001.43E+011.02E+012.35E-012.30E-021.07E-031.00E+00-1.75E+001.55E-01240Pu Activity (Ci) 8.98E+001.26E+019.41E+002.08E-012.21E-021.10E-031.00E+00-1.89E+001.32E-01242Pu Activity (Ci) 4.43E-034.32E-064.65E-031.02E-042.20E-022.24E+030.00E+00-1.96E+001.21E-01241Am Activity (Ci) 2.12E+011.30E+025.82E+007.99E+001.37E+001.52E-021.00E+001.76E+001.54E-0190Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/ATRU Alpha Conc. (nCi/g) 4.51E+051.77E+104.84E+051.13E+042.34E-021.63E-121.00E+00-2.69E+005.46E-02Quantity ofInterestχ2Testt Test233U Activity (Ci) #VALUE! Not Applicable234U Activity (Ci) #VALUE! Not Applicable238U Activity (Ci) #VALUE! Not Applicable238Pu Activity (Ci) Not Significant Not Significant239Pu Activity (Ci)Not Significant Not Significant240Pu Activity (Ci)Not Significant Not Significant242Pu Activity (Ci)Highly SignificantNot Significant241Am Activity (Ci)Not Significant Not Significant90Sr Activity (Ci) #VALUE! Not Applicable137Cs Activity (Ci) #VALUE! Not ApplicableTRU Alpha Conc. (nCi/g)Not Significant Not SignificantB-5ATTACHMENT B.5 REPLICATE TESTING DATA FOR CONTAINER 53093, HENC #1 SYSTEMInstrument: HENC#1Container: 53093Original Measurement Replicate #1 Replicate #2Quantity of Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value Uncertainty UncertaintyValue Uncertainty Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 5.14E-015.91E-021.15E-015.66E-017.87E-021.39E-014.42E-014.55E-021.03E-01239Pu Activity (Ci) 8.84E+001.75E+011.98E+009.67E+002.30E+012.38E+009.17E+001.96E+012.14E+00240Pu Activity (Ci) 2.59E+001.50E+005.81E-012.55E+001.60E+006.29E-012.54E+001.51E+005.93E-01242Pu Activity (Ci) 2.57E-041.48E-085.77E-052.61E-041.68E-086.44E-052.61E-041.59E-086.09E-05241Am Activity (Ci) 4.00E+003.95E+009.87E-010.00E+00N/A0.00E+003.91E+003.57E+009.13E-0190Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00TRU Alpha Conc. (nCi/g) 4.59E+053.01E+106.55E+044.95E+053.89E+107.85E+044.74E+053.36E+107.09E+04Replicate #3 Replicate #4 Replicate #5Quantity ofInterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 5.50E-017.32E-021.33E-014.51E-014.87E-021.08E-014.61E-014.98E-021.08E-01239Pu Activity (Ci) 9.50E+002.18E+012.29E+009.42E+002.12E+012.25E+009.23E+002.00E+012.17E+00240Pu Activity (Ci) 2.51E+001.52E+006.06E-012.59E+001.60E+006.18E-012.65E+001.65E+006.21E-01242Pu Activity (Ci) 2.58E-041.60E-086.22E-052.62E-041.64E-086.27E-052.67E-041.67E-086.26E-05241Am Activity (Ci) 4.02E+003.90E+009.69E-013.95E+003.72E+009.43E-013.87E+003.51E+009.08E-0190Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00TRU Alpha Conc. (nCi/g) 4.89E+053.70E+107.57E+044.84E+053.60E+107.44E+044.78E+053.43E+107.17E+04B-6ATTACHMENT B.6 REPLICATE TESTING RESULTS FOR CONTAINER 53093, HENC #1 SYSTEMInstrument: HENC#1Container: 53093Original Measurement Sample RelativeQuantity of Reported Absolute Sample Standard StandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| 

# χ2|)t Pr(x<|t|)233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A234U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A238Pu Activity (Ci) 5.14E-015.91E-024.94E-015.91E-021.20E-014.00E+004.07E-013.09E-017.73E-01239Pu Activity (Ci) 8.84E+001.75E+019.40E+002.03E-012.16E-025.39E-041.00E+00-2.51E+006.62E-02240Pu Activity (Ci) 2.59E+001.50E+002.57E+005.40E-022.10E-025.16E-031.00E+003.72E-017.29E-01242Pu Activity (Ci) 2.57E-041.48E-082.62E-043.27E-061.25E-021.95E+050.00E+00-1.34E+002.51E-01241Am Activity (Ci) 4.00E+003.95E+003.15E+001.76E+005.59E-017.97E-019.39E-014.40E-016.82E-0190Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/ATRU Alpha Conc. (nCi/g) 4.59E+053.01E+104.84E+058.40E+031.73E-023.12E-131.00E+00-2.72E+005.31E-02Quantity ofInterestχ2Testt Test233U Activity (Ci) #VALUE! Not Applicable234U Activity (Ci) #VALUE! Not Applicable238U Activity (Ci) #VALUE! Not Applicable238Pu Activity (Ci) Not Significant Not Significant239Pu Activity (Ci)Not Significant Not Significant240Pu Activity (Ci)Not Significant Not Significant242Pu Activity (Ci)Highly SignificantNot Significant241Am Activity (Ci)Not Significant Not Significant90Sr Activity (Ci) #VALUE! Not Applicable137Cs Activity (Ci) #VALUE! Not ApplicableTRU Alpha Conc. (nCi/g)Not Significant Not SignificantB-7ATTACHMENT B.7 REPLICATE TESTING DATA FOR CONTAINER D52277, HENC #2 SYSTEMInstrument: HENC#2Container: D52277Original Measurement Replicate #1 Replicate #2Quantity of Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value Uncertainty UncertaintyValue Uncertainty Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 9.94E-045.38E-055.41E-021.05E-035.68E-055.41E-021.01E-036.19E-056.13E-02238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 6.37E+009.39E-011.47E-016.76E+009.99E-011.48E-016.46E+009.50E-011.47E-01239Pu Activity (Ci) 1.38E-012.04E-021.48E-011.42E-012.11E-021.49E-011.40E-012.06E-021.47E-01240Pu Activity (Ci) 3.28E-024.84E-031.48E-013.38E-025.00E-031.48E-013.34E-024.90E-031.47E-01242Pu Activity (Ci) 2.17E-063.19E-071.47E-012.23E-063.30E-071.48E-012.20E-063.23E-071.47E-01241Am Activity (Ci) 1.82E-022.69E-031.48E-011.71E-023.08E-031.80E-011.81E-023.39E-031.87E-0190Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00TRU Alpha Conc. (nCi/g) 4.15E+055.94E+041.43E-014.40E+056.33E+041.44E-014.22E+056.01E+041.42E-01Replicate #3 Replicate #4 Replicate #5Quantity ofInterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 1.02E-035.73E-055.62E-021.05E-035.87E-055.59E-021.02E-035.96E-055.84E-02238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 6.54E+009.67E-011.48E-016.70E+009.86E-011.47E-016.54E+009.61E-011.47E-01239Pu Activity (Ci) 1.42E-012.10E-021.48E-011.46E-012.14E-021.47E-011.42E-012.09E-021.47E-01240Pu Activity (Ci) 3.37E-024.99E-031.48E-013.46E-025.09E-031.47E-013.37E-024.96E-031.47E-01242Pu Activity (Ci) 2.22E-063.29E-071.48E-012.28E-063.35E-071.47E-012.22E-063.27E-071.47E-01241Am Activity (Ci) 1.71E-023.22E-031.88E-011.74E-023.06E-031.76E-011.69E-023.11E-031.84E-0190Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00TRU Alpha Conc. (nCi/g) 4.27E+056.12E+041.43E-014.37E+056.24E+041.43E-014.26E+056.08E+041.43E-01B-8ATTACHMENT B.8 REPLICATE TESTING RESULTS FOR CONTAINER D52277, HENC #2 SYSTEMInstrument: HENC#2Container: D52277Original Measurement Sample RelativeQuantity of Reported Absolute Sample Standard StandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| 

# χ2|)t Pr(x<|t|)233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A234U Activity (Ci) 9.94E-045.38E-051.03E-031.87E-051.82E-024.84E-019.75E-01-1.76E+001.54E-01238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A238Pu Activity (Ci) 6.37E+009.39E-016.60E+001.25E-011.89E-027.08E-029.99E-01-1.68E+001.68E-01239Pu Activity (Ci) 1.38E-012.04E-021.42E-012.19E-031.54E-024.61E-021.00E+00-1.83E+001.41E-01240Pu Activity (Ci) 3.28E-024.84E-033.38E-024.51E-041.33E-023.47E-021.00E+00-2.11E+001.03E-01242Pu Activity (Ci) 2.17E-063.19E-072.23E-063.00E-081.35E-023.54E-021.00E+00-1.83E+001.42E-01241Am Activity (Ci) 1.82E-022.69E-031.73E-024.71E-042.72E-021.23E-019.98E-011.70E+001.63E-0190Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/ATRU Alpha Conc. (nCi/g) 4.15E+055.94E+044.30E+057.70E+031.79E-026.72E-029.99E-01-1.83E+001.42E-01Quantity ofInterestχ2Testt Test233U Activity (Ci) #VALUE! Not Applicable234U Activity (Ci) Not Significant Not Significant238U Activity (Ci) #VALUE! Not Applicable238Pu Activity (Ci) Not Significant Not Significant239Pu Activity (Ci)Not Significant Not Significant240Pu Activity (Ci)Not Significant Not Significant242Pu Activity (Ci)Not Significant Not Significant241Am Activity (Ci)Not Significant Not Significant90Sr Activity (Ci) #VALUE! Not Applicable137Cs Activity (Ci) #VALUE! Not ApplicableTRU Alpha Conc. (nCi/g)Not Significant Not SignificantB-9ATTACHMENT B.9 REPLICATE TESTING DATA FOR CONTAINER D53991, HENC #2 SYSTEMInstrument: HENC#2Container: D53991Original Measurement Replicate #1 Replicate #2Quantity of Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value Uncertainty UncertaintyValue Uncertainty Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 8.12E-021.08E-031.33E-026.20E-028.30E-031.34E-015.51E-027.26E-031.32E-01239Pu Activity (Ci) 8.04E-011.07E-011.33E-017.79E-011.04E-011.34E-017.14E-019.40E-021.32E-01240Pu Activity (Ci) 1.58E-012.11E-021.34E-011.58E-012.12E-021.34E-011.56E-012.05E-021.31E-01242Pu Activity (Ci) 1.73E-052.31E-061.34E-011.51E-052.02E-061.34E-011.57E-052.06E-061.31E-01241Am Activity (Ci) 2.73E-013.63E-021.33E-012.42E-013.24E-021.34E-012.29E-013.01E-021.31E-0190Sr Activity (Ci) 7.34E-084.16E-085.67E-010.00E+00N/A0.00E+000.00E+00N/A0.00E+00137Cs Activity (Ci) 7.34E-084.16E-085.67E-010.00E+00N/A0.00E+000.00E+00N/A0.00E+00TRU Alpha Conc. (nCi/g) 2.26E+041.98E+038.76E-022.13E+041.91E+038.97E-021.98E+041.73E+038.74E-02Replicate #3 Replicate #4 Replicate #5Quantity ofInterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 5.60E-027.38E-031.32E-015.00E-026.64E-031.33E-013.38E-024.52E-031.34E-01239Pu Activity (Ci) 8.40E-011.11E-011.32E-017.90E-011.05E-011.33E-018.44E-011.13E-011.34E-01240Pu Activity (Ci) 1.59E-012.10E-021.32E-011.60E-012.13E-021.33E-011.61E-012.16E-021.34E-01242Pu Activity (Ci) 1.52E-052.00E-061.32E-011.47E-051.95E-061.33E-011.52E-052.03E-061.34E-01241Am Activity (Ci) 2.55E-013.36E-021.32E-012.26E-013.00E-021.33E-012.43E-013.25E-021.34E-0190Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00TRU Alpha Conc. (nCi/g) 2.25E+042.02E+038.98E-022.10E+041.91E+039.10E-022.20E+042.05E+039.32E-02B-10ATTACHMENT B.10 REPLICATE TESTING RESULTS FOR CONTAINER D53991, HENC #2 SYSTEMInstrument: HENC#2Container: D53991Original Measurement Sample RelativeQuantity of Reported Absolute Sample Standard StandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| 

# χ2|)t Pr(x<|t|)233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A234U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A238Pu Activity (Ci) 8.12E-021.08E-035.14E-021.07E-022.08E-013.93E+027.21E-842.54E+006.39E-02239Pu Activity (Ci) 8.04E-011.07E-017.93E-015.30E-026.69E-029.83E-019.12E-011.82E-018.64E-01240Pu Activity (Ci) 1.58E-012.11E-021.59E-011.92E-031.21E-023.32E-021.00E+00-3.80E-017.23E-01242Pu Activity (Ci) 1.73E-052.31E-061.52E-053.56E-072.35E-029.52E-029.99E-015.43E+005.58E-03241Am Activity (Ci) 2.73E-013.63E-022.39E-011.17E-024.91E-024.17E-019.81E-012.65E+005.72E-0290Sr Activity (Ci) 7.34E-084.16E-080.00E+000.00E+00N/A0.00E+001.00E+00N/AN/A137Cs Activity (Ci) 7.34E-084.16E-080.00E+000.00E+00N/A0.00E+001.00E+00N/AN/ATRU Alpha Conc. (nCi/g) 2.26E+041.98E+032.13E+041.03E+034.85E-021.09E+008.96E-011.13E+003.21E-01Quantity ofInterestχ2Testt Test233U Activity (Ci) #VALUE! Not Applicable234U Activity (Ci) #VALUE! Not Applicable238U Activity (Ci) #VALUE! Not Applicable238Pu Activity (Ci) Highly Significant Not Significant239Pu Activity (Ci)Not Significant Not Significant240Pu Activity (Ci)Not Significant Not Significant242Pu Activity (Ci)Not SignificantHighly Significant241Am Activity (Ci)Not Significant Not Significant90Sr Activity (Ci)Not SignificantNot Applicable137Cs Activity (Ci)Not SignificantNot ApplicableTRU Alpha Conc. (nCi/g)Not Significant Not SignificantB-11ATTACHMENT B.11 REPLICATE TESTING DATA FOR CONTAINERD55700, HENC #2 SYSTEMInstrument: HENC#2Container: D55700Original Measurement Replicate #1 Replicate #2Quantity of Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value Uncertainty UncertaintyValue Uncertainty Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 4.10E-034.16E-041.01E-014.32E-034.20E-049.72E-024.02E-033.23E-048.03E-02238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 2.63E+014.26E+001.62E-012.77E+014.42E+001.60E-012.58E+014.22E-031.64E-04239Pu Activity (Ci) 8.06E-021.31E-021.63E-018.51E-021.36E-021.60E-017.92E-021.30E-021.64E-01240Pu Activity (Ci) 1.89E-023.06E-031.62E-011.99E-023.18E-031.60E-011.85E-023.04E-031.64E-01242Pu Activity (Ci) 6.88E-061.12E-061.63E-017.26E-061.16E-061.60E-016.76E-061.11E-061.64E-01241Am Activity (Ci) 1.82E-023.06E-031.68E-012.20E-024.58E-032.08E-012.46E-023.73E-031.52E-0190Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00TRU Alpha Conc. (nCi/g) 2.96E+064.78E+051.61E-013.15E+064.96E+051.57E-012.91E+064.75E+051.63E-01Replicate #3 Replicate #4 Replicate #5Quantity ofInterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 4.06E-034.16E-041.02E-014.41E-034.05E-049.18E-023.96E-034.16E-041.05E-01238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 2.60E+014.19E+001.61E-012.83E+014.53E+001.60E-012.54E+014.03E+001.59E-01239Pu Activity (Ci) 7.98E-021.29E-021.62E-018.68E-021.39E-021.60E-017.80E-021.24E-021.59E-01240Pu Activity (Ci) 1.87E-023.01E-031.61E-012.03E-023.26E-031.61E-011.83E-022.90E-031.58E-01242Pu Activity (Ci) 6.81E-061.10E-061.62E-017.41E-061.19E-061.61E-016.66E-061.06E-061.59E-01241Am Activity (Ci) 2.38E-024.53E-031.90E-011.92E-022.11E-031.10E-011.94E-022.13E-031.10E-0190Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00TRU Alpha Conc. (nCi/g) 2.93E+064.70E+051.60E-013.19E+065.09E+051.60E-012.86E+064.53E+051.58E-01B-12ATTACHMENT B.12 REPLICATE TESTING RESULTS FOR CONTAINER D55700, HENC #2 SYSTEMInstrument: HENC#2Container: D55700Original Measurement Sample RelativeQuantity of Reported Absolute Sample Standard StandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| 

# χ2|)t Pr(x<|t|)233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A234U Activity (Ci) 4.10E-034.16E-044.15E-031.98E-044.78E-029.10E-019.23E-01-2.48E-018.16E-01238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A238Pu Activity (Ci) 2.63E+014.26E+002.66E+011.28E+004.80E-023.60E-019.86E-01-2.43E-018.20E-01239Pu Activity (Ci) 8.06E-021.31E-028.18E-023.91E-034.78E-023.56E-019.86E-01-2.76E-017.96E-01240Pu Activity (Ci) 1.89E-023.06E-031.91E-028.99E-044.70E-023.45E-019.87E-01-2.44E-018.19E-01242Pu Activity (Ci) 6.88E-061.12E-066.98E-063.33E-074.77E-023.53E-019.86E-01-2.74E-017.97E-01241Am Activity (Ci) 1.82E-023.06E-032.18E-022.47E-031.13E-012.61E+006.26E-01-1.33E+002.54E-0190Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/ATRU Alpha Conc. (nCi/g) 2.96E+064.78E+053.01E+061.51E+055.01E-023.98E-019.83E-01-2.91E-017.86E-01Quantity ofInterestχ2Testt Test233U Activity (Ci) #VALUE! Not Applicable234U Activity (Ci) Not Significant Not Significant238U Activity (Ci) #VALUE! Not Applicable238Pu Activity (Ci) Not Significant Not Significant239Pu Activity (Ci)Not Significant Not Significant240Pu Activity (Ci)Not Significant Not Significant242Pu Activity (Ci)Not Significant Not Significant241Am Activity (Ci)Not Significant Not Significant90Sr Activity (Ci) #VALUE! Not Applicable137Cs Activity (Ci) #VALUE! Not ApplicableTRU Alpha Conc. (nCi/g)Not Significant Not SignificantB-13ATTACHMENT B.13 REPLICATE TESTING DATA FOR CONTAINER52338, PTGS SYSTEMInstrument: PTGSContainer: 52338Original Measurement Replicate #1 Replicate #2Quantity of Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value Uncertainty UncertaintyValue Uncertainty Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) <LLD #VALUE!#DIV/0! <LLD #VALUE!#DIV/0! <LLD #VALUE!#DIV/0!234U Activity (Ci) 1.10E-052.37E-062.15E-012.06E-052.78E-061.35E-011.88E-052.61E-061.39E-01238U Activity (Ci) <LLD #VALUE!#DIV/0! <LLD #VALUE!#DIV/0! <LLD #VALUE!#DIV/0!238Pu Activity (Ci) 7.07E-021.52E-022.15E-011.32E-011.78E-021.35E-011.20E-011.67E-021.39E-01239Pu Activity (Ci) 1.76E+002.11E-011.20E-011.73E+002.06E-011.19E-011.70E+002.04E-011.20E-01240Pu Activity (Ci) 4.41E-015.89E-021.34E-014.10E-015.19E-021.27E-014.03E-015.14E-021.28E-01242Pu Activity (Ci) 1.24E-053.45E-062.77E-011.08E-053.00E-062.78E-011.07E-052.96E-062.77E-01241Am Activity (Ci) 6.51E-017.82E-021.20E-015.73E-016.83E-021.19E-015.37E-016.44E-021.20E-0190Sr Activity (Ci) 2.83E-063.43E-071.21E-012.47E-062.97E-071.20E-012.54E-063.06E-071.20E-01137Cs Activity (Ci) 2.84E-063.44E-071.21E-012.48E-062.97E-071.20E-012.55E-063.07E-071.20E-01TRU Alpha Conc. (nCi/g) 2.14E+041.71E+037.99E-022.08E+041.64E+037.88E-022.02E+041.61E+037.97E-02Replicate #3 Replicate #4 Replicate #5Quantity ofInterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) <LLD #VALUE!#DIV/0! <LLD #VALUE!#DIV/0! <LLD #VALUE!#DIV/0!234U Activity (Ci) 2.03E-052.76E-061.36E-012.09E-052.86E-061.37E-012.03E-052.77E-061.36E-01238U Activity (Ci) <LLD #VALUE!#DIV/0! <LLD #VALUE!#DIV/0! <LLD #VALUE!#DIV/0!238Pu Activity (Ci) 1.30E-011.77E-021.36E-011.34E-011.83E-021.37E-011.30E-011.77E-021.36E-01239Pu Activity (Ci) 1.70E+002.02E-011.19E-011.75E+002.11E-011.21E-011.75E+002.09E-011.19E-01240Pu Activity (Ci) 4.36E-015.47E-021.25E-014.04E-015.17E-021.28E-014.16E-015.25E-021.26E-01242Pu Activity (Ci) 1.15E-053.19E-062.77E-011.04E-052.90E-062.79E-011.09E-053.01E-062.76E-01241Am Activity (Ci) 5.61E-016.67E-021.19E-015.58E-016.74E-021.21E-015.90E-017.04E-021.19E-0190Sr Activity (Ci) 2.56E-063.06E-071.20E-012.67E-063.24E-071.21E-012.74E-063.28E-071.20E-01137Cs Activity (Ci) 2.57E-063.07E-071.20E-012.68E-063.25E-071.21E-012.75E-063.29E-071.20E-01TRU Alpha Conc. (nCi/g) 2.07E+041.61E+037.78E-022.09E+041.67E+037.99E-022.11E+041.66E+037.87E-02B-14ATTACHMENT B.14 REPLICATE TESTING RESULTS FOR CONTAINER 52338, PTGS SYSTEMInstrument: PTGSContainer: 52338Original Measurement Sample RelativeQuantity of Reported Absolute Sample Standard StandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| 

# χ2|)t Pr(x<|t|)233U Activity (Ci) <LLD#VALUE!N/AN/AN/AN/AN/AN/AN/A234U Activity (Ci) 1.10E-052.37E-062.02E-058.11E-074.02E-024.68E-019.77E-01-1.03E+014.94E-04238U Activity (Ci) <LLD#VALUE!N/AN/AN/AN/AN/AN/AN/A238Pu Activity (Ci) 7.07E-021.52E-021.29E-015.40E-034.18E-025.06E-019.73E-01-9.88E+005.88E-04239Pu Activity (Ci) 1.76E+002.11E-011.73E+002.51E-021.45E-025.66E-021.00E+001.24E+002.84E-01240Pu Activity (Ci) 4.41E-015.89E-024.14E-011.35E-023.25E-022.09E-019.95E-011.84E+001.39E-01242Pu Activity (Ci) 1.24E-053.45E-061.09E-054.04E-073.72E-025.49E-021.00E+003.55E+002.38E-02241Am Activity (Ci) 6.51E-017.82E-025.64E-011.96E-023.47E-022.50E-019.93E-014.07E+001.52E-0290Sr Activity (Ci) 2.83E-063.43E-072.60E-061.08E-074.15E-023.95E-019.83E-011.98E+001.19E-01137Cs Activity (Ci) 2.84E-063.44E-072.61E-061.08E-074.14E-023.93E-019.83E-011.98E+001.19E-01TRU Alpha Conc. (nCi/g) 2.14E+041.71E+032.07E+043.36E+021.62E-021.55E-019.97E-011.79E+001.48E-01Quantity ofInterestχ2Testt Test233U Activity (Ci) Not Applicable Not Applicable234U Activity (Ci) Not Significant Highly Significant238U Activity (Ci) Not Applicable Not Applicable238Pu Activity (Ci) Not Significant Highly Significant239Pu Activity (Ci)Not Significant Not Significant240Pu Activity (Ci)Not Significant Not Significant242Pu Activity (Ci)Not SignificantSignificant241Am Activity (Ci)Not SignificantSignificant90Sr Activity (Ci)Not Significant Not Significant137Cs Activity (Ci)Not Significant Not SignificantTRU Alpha Conc. (nCi/g)Not Significant Not SignificantB-15ATTACHMENT B.15 REPLICATE TESTING DATA FOR CONTAINER53551, PTGS SYSTEMInstrument: PTGSContainer: 53551Original Measurement Replicate #1 Replicate #2Quantity of Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value Uncertainty UncertaintyValue Uncertainty Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) <LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!234U Activity (Ci) 2.45E-053.51E-061.43E-011.98E-052.89E-061.46E-012.56E-053.57E-061.39E-01238U Activity (Ci) <LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!238Pu Activity (Ci) 1.57E-012.25E-021.43E-011.27E-011.85E-021.46E-011.64E-012.29E-021.40E-01239Pu Activity (Ci) 5.83E+006.92E-011.19E-014.99E+005.95E-011.19E-015.13E+006.16E-011.20E-01240Pu Activity (Ci) 1.31E+001.59E-011.21E-011.13E+001.37E-011.21E-011.14E+001.39E-011.22E-01242Pu Activity (Ci) 3.08E-058.52E-062.77E-012.64E-057.32E-062.77E-012.59E-057.17E-062.77E-01241Am Activity (Ci) 3.98E+004.73E-011.19E-013.25E+003.87E-011.19E-013.40E+004.09E-011.20E-0190Sr Activity (Ci) 7.13E-078.96E-081.26E-014.48E-075.82E-081.30E-013.90E-075.22E-081.34E-01137Cs Activity (Ci) 7.15E-078.98E-081.26E-014.49E-075.84E-081.30E-013.91E-075.24E-081.34E-01TRU Alpha Conc. (nCi/g) 2.86E+052.16E+047.55E-022.41E+051.84E+047.63E-022.50E+051.91E+047.64E-02Replicate #3 Replicate #4 Replicate #5Quantity ofInterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) <LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!234U Activity (Ci) 2.64E-053.59E-061.36E-012.08E-053.03E-061.46E-012.26E-053.23E-061.43E-01238U Activity (Ci) <LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!238Pu Activity (Ci) 1.70E-012.30E-021.35E-011.33E-011.94E-021.46E-011.45E-012.07E-021.43E-01239Pu Activity (Ci) 5.15E+006.15E-011.19E-015.16E+006.15E-011.19E-015.33E+006.32E-011.19E-01240Pu Activity (Ci) 1.11E+001.36E-011.23E-011.15E+001.40E-011.22E-011.13E+001.36E-011.20E-01242Pu Activity (Ci) 2.58E-057.14E-062.77E-012.67E-057.38E-062.76E-012.60E-057.19E-062.77E-01241Am Activity (Ci) 3.35E+004.01E-011.20E-013.29E+009.32E-012.83E-013.45E+004.10E-011.19E-0190Sr Activity (Ci) 2.75E-073.92E-081.43E-014.08E-075.39E-081.32E-016.00E-077.59E-081.27E-01137Cs Activity (Ci) 2.76E-073.93E-081.42E-014.09E-075.41E-081.32E-016.02E-077.61E-081.26E-01TRU Alpha Conc. (nCi/g) 2.48E+051.90E+047.66E-022.47E+051.89E+047.65E-022.55E+051.94E+047.61E-02B-16ATTACHMENT B.16 REPLICATE TESTING RESULTS FOR CONTAINER 53551, PTGS SYSTEMInstrument: PTGSContainer: 53551Original Measurement Sample RelativeQuantity of Reported Absolute Sample Standard StandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| 

# χ2|)t Pr(x<|t|)233U Activity (Ci) <LLD#VALUE!N/AN/AN/AN/AN/AN/AN/A234U Activity (Ci) 2.45E-053.51E-062.30E-052.90E-061.26E-012.72E+006.05E-014.60E-016.69E-01238U Activity (Ci) <LLD#VALUE!N/AN/AN/AN/AN/AN/AN/A238Pu Activity (Ci) 1.57E-012.25E-021.48E-011.88E-021.27E-012.79E+005.93E-014.47E-016.78E-01239Pu Activity (Ci) 5.83E+006.92E-015.15E+001.21E-012.35E-021.22E-019.98E-015.12E+006.89E-03240Pu Activity (Ci) 1.31E+001.59E-011.13E+001.48E-021.31E-023.48E-021.00E+001.10E+013.94E-04242Pu Activity (Ci) 3.08E-058.52E-062.62E-053.78E-071.45E-027.88E-031.00E+001.12E+013.62E-04241Am Activity (Ci) 3.98E+004.73E-013.35E+008.07E-022.41E-021.17E-019.98E-017.15E+002.03E-0390Sr Activity (Ci) 7.13E-078.96E-084.24E-071.17E-072.77E-016.87E+001.43E-012.24E+008.81E-02137Cs Activity (Ci) 7.15E-078.98E-084.25E-071.18E-072.77E-016.88E+001.42E-012.24E+008.82E-02TRU Alpha Conc. (nCi/g) 2.86E+052.16E+042.48E+055.07E+032.04E-022.20E-019.94E-016.81E+002.43E-03Quantity ofInterestχ2Testt Test233U Activity (Ci) Not Applicable Not Applicable234U Activity (Ci) Not Significant Not Significant238U Activity (Ci) Not Applicable Not Applicable238Pu Activity (Ci) Not Significant Not Significant239Pu Activity (Ci)Not SignificantHighly Significant240Pu Activity (Ci)Not SignificantHighly Significant242Pu Activity (Ci)Not SignificantHighly Significant241Am Activity (Ci)Not SignificantHighly Significant90Sr Activity (Ci)Not Significant Not Significant137Cs Activity (Ci)Not Significant Not SignificantTRU Alpha Conc. (nCi/g)Not SignificantHighly SignificantB-17ATTACHMENT B.17 REPLICATE TESTING DATA FOR CONTAINER54857, PTGS SYSTEMInstrument: PTGSContainer: 54857Original Measurement Replicate #1 Replicate #2Quantity of Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) <LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!234U Activity (Ci) 3.27E-054.54E-061.39E-012.24E-053.29E-061.47E-012.26E-053.27E-061.45E-01238U Activity (Ci) <LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!238Pu Activity (Ci) 2.10E-012.91E-021.39E-011.44E-012.11E-021.47E-011.45E-012.09E-021.44E-01239Pu Activity (Ci) 4.82E+005.78E-011.20E-014.00E+004.74E-011.19E-014.02E+004.79E-011.19E-01240Pu Activity (Ci) 1.18E+001.45E-011.23E-019.96E-011.21E-011.21E-019.38E-011.15E-011.23E-01242Pu Activity (Ci) 2.98E-058.26E-062.77E-012.46E-056.80E-062.76E-012.30E-056.38E-062.77E-01241Am Activity (Ci) 1.89E+002.27E-011.20E-011.79E+002.13E-011.19E-011.78E+002.12E-011.19E-0190Sr Activity (Ci) 2.37E-073.22E-081.36E-012.44E-073.19E-081.31E-011.90E-072.62E-081.38E-01137Cs Activity (Ci) 2.38E-073.23E-081.36E-012.45E-073.20E-081.31E-011.90E-072.62E-081.38E-01TRU Alpha Conc. (nCi/g) 4.11E+053.24E+047.88E-023.52E+052.71E+047.70E-023.49E+052.72E+047.79E-02Replicate #3 Replicate #4 Replicate #5Quantity ofInterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) <LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!234U Activity (Ci) 2.22E-053.22E-061.45E-012.41E-053.42E-061.42E-012.55E-053.49E-061.37E-01238U Activity (Ci) <LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!<LLD#VALUE!#DIV/0!238Pu Activity (Ci) 1.42E-012.06E-021.45E-011.54E-012.19E-021.42E-011.63E-012.24E-021.37E-01239Pu Activity (Ci) 4.02E+004.80E-011.19E-013.99E+004.75E-011.19E-014.06E+004.78E-011.18E-01240Pu Activity (Ci) 9.78E-011.20E-011.23E-019.21E-011.13E-011.23E-011.01E+001.23E-011.22E-01242Pu Activity (Ci) 2.41E-056.69E-062.78E-012.25E-056.22E-062.76E-012.50E-056.92E-062.77E-01241Am Activity (Ci) 1.77E+002.12E-011.20E-011.75E+002.09E-011.19E-011.77E+002.08E-011.18E-0190Sr Activity (Ci) 2.96E-073.82E-081.29E-012.50E-073.28E-081.31E-011.59E-072.29E-081.44E-01137Cs Activity (Ci) 2.97E-073.83E-081.29E-012.51E-073.29E-081.31E-011.60E-072.29E-081.43E-01TRU Alpha Conc. (nCi/g) 3.51E+052.74E+047.81E-023.46E+052.70E+047.80E-023.55E+052.72E+047.66E-02B-18ATTACHMENT B.18 REPLICATE TESTING RESULTS FOR CONTAINER 54857, PTGS SYSTEMInstrument: PTGSContainer: 54857Original Measurement Sample RelativeQuantity of Reported Absolute Sample Standard StandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| 

# χ2|)t Pr(x<|t|)233U Activity (Ci) <LLD#VALUE!N/AN/AN/AN/AN/AN/AN/A234U Activity (Ci) 3.27E-054.54E-062.34E-051.41E-066.04E-023.87E-019.84E-016.04E+003.79E-03238U Activity (Ci) <LLD#VALUE!N/AN/AN/AN/AN/AN/AN/A238Pu Activity (Ci) 2.10E-012.91E-021.50E-018.79E-035.88E-023.65E-019.85E-016.27E+003.30E-03239Pu Activity (Ci) 4.82E+005.78E-014.02E+002.68E-026.68E-038.62E-031.00E+002.73E+011.07E-05240Pu Activity (Ci) 1.18E+001.45E-019.69E-013.79E-023.92E-022.74E-019.91E-015.09E+007.04E-03242Pu Activity (Ci) 2.98E-058.26E-062.38E-051.06E-064.45E-026.58E-029.99E-015.13E+006.82E-03241Am Activity (Ci) 1.89E+002.27E-011.77E+001.48E-028.37E-031.71E-021.00E+007.26E+001.91E-0390Sr Activity (Ci) 2.37E-073.22E-082.28E-075.38E-082.36E-011.12E+012.48E-021.56E-018.83E-01137Cs Activity (Ci) 2.38E-073.23E-082.29E-075.40E-082.36E-011.12E+012.48E-021.59E-018.81E-01TRU Alpha Conc. (nCi/g) 4.11E+053.24E+043.51E+053.36E+039.59E-034.31E-021.00E+001.64E+018.09E-05Quantity ofInterestχ2Testt Test233U Activity (Ci) Not Applicable Not Applicable234U Activity (Ci) Not Significant Highly Significant238U Activity (Ci) Not Applicable Not Applicable238Pu Activity (Ci) Not Significant Highly Significant239Pu Activity (Ci)Not SignificantHighly Significant240Pu Activity (Ci)Not SignificantHighly Significant242Pu Activity (Ci)Not SignificantHighly Significant241Am Activity (Ci)Not SignificantHighly Significant90Sr Activity (Ci)SignificantNot Significant137Cs Activity (Ci)SignificantNot SignificantTRU Alpha Conc. (nCi/g)Not SignificantHighly SignificantB-19ATTACHMENT B.19 REPLICATE TESTING DATA FOR CONTAINERS817309, HENC #2 SYSTEMInstrument: HENC#2Container: S817309Original Measurement Replicate #1 Replicate #2Quantity of Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 9.31E-032.10E-052.26E-031.96E-022.61E-041.33E-021.32E-021.47E-041.11E-02239Pu Activity (Ci) 1.53E-015.54E-033.62E-021.52E-015.47E-033.60E-021.51E-015.47E-033.62E-02240Pu Activity (Ci) 3.78E-026.69E-041.77E-023.32E-023.30E-049.95E-033.71E-023.97E-041.07E-02242Pu Activity (Ci) 5.16E-066.45E-121.25E-069.30E-063.73E-114.01E-068.48E-063.56E-114.20E-06241Am Activity (Ci) 1.53E-026.01E-053.93E-034.16E-025.12E-041.23E-024.67E-026.21E-041.33E-0290Sr Activity (Ci) 2.44E-051.41E-105.77E-062.39E-051.35E-105.66E-062.24E-051.19E-105.30E-06137Cs Activity (Ci) 2.44E-051.41E-105.77E-062.39E-051.35E-105.66E-062.24E-051.19E-105.30E-06TRU Alpha Conc. (nCi/g) 1.30E+033.19E+052.45E+021.48E+033.70E+052.50E+021.50E+033.75E+052.50E+02Replicate #3 Replicate #4 Replicate #5Quantity ofInterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 1.68E-022.18E-041.30E-022.56E-024.17E-041.63E-022.34E-023.21E-041.37E-02239Pu Activity (Ci) 1.51E-015.42E-033.59E-021.54E-015.62E-033.65E-021.48E-015.21E-033.52E-02240Pu Activity (Ci) 3.18E-023.13E-049.85E-033.24E-023.07E-049.46E-032.98E-022.76E-049.26E-03242Pu Activity (Ci) 8.40E-063.42E-114.07E-061.03E-054.32E-114.19E-069.40E-063.42E-113.64E-06241Am Activity (Ci) 3.01E-022.98E-049.91E-033.83E-026.51E-041.70E-025.94E-029.62E-041.62E-0290Sr Activity (Ci) 2.26E-051.21E-105.35E-062.27E-051.22E-105.37E-062.23E-051.18E-105.28E-06137Cs Activity (Ci) 2.26E-051.21E-105.35E-062.27E-051.22E-105.37E-062.23E-051.18E-105.28E-06TRU Alpha Conc. (nCi/g) 1.39E+033.41E+052.45E+021.51E+034.05E+052.68E+021.57E+033.99E+052.54E+02B-20ATTACHMENT B.20 REPLICATE TESTING RESULTS FOR CONTAINER S817309, HENC #2 SYSTEMInstrument: HENC#2Container: S817309Original Measurement Sample RelativeQuantity of Reported Absolute Sample Standard StandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| 

# χ2|)t Pr(x<|t|)233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A234U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A238Pu Activity (Ci) 9.31E-032.10E-051.97E-024.98E-032.52E-012.24E+050.00E+00-1.91E+001.29E-01239Pu Activity (Ci) 1.53E-015.54E-031.51E-012.17E-031.43E-026.13E-019.62E-017.58E-014.91E-01240Pu Activity (Ci) 3.78E-026.69E-043.29E-022.68E-038.16E-026.43E+013.58E-131.68E+001.68E-01242Pu Activity (Ci) 5.16E-066.45E-129.18E-067.77E-078.47E-025.81E+100.00E+00-4.72E+009.19E-03241Am Activity (Ci) 1.53E-026.01E-054.32E-021.09E-022.52E-011.31E+050.00E+00-2.34E+007.90E-0290Sr Activity (Ci) 2.44E-051.41E-102.28E-056.46E-072.83E-028.42E+070.00E+002.29E+008.38E-02137Cs Activity (Ci) 2.44E-051.41E-102.28E-056.46E-072.83E-028.42E+070.00E+002.29E+008.38E-02TRU Alpha Conc. (nCi/g) 1.30E+033.19E+051.49E+036.52E+014.38E-021.68E-071.00E+00-2.66E+005.64E-02Quantity ofInterestχ2Testt Test233U Activity (Ci) #VALUE! Not Applicable234U Activity (Ci) #VALUE! Not Applicable238U Activity (Ci) #VALUE! Not Applicable238Pu Activity (Ci) Highly Significant Not Significant239Pu Activity (Ci)Not Significant Not Significant240Pu Activity (Ci)Highly SignificantNot Significant242Pu Activity (Ci)Highly Significant Highly Significant241Am Activity (Ci)Highly SignificantNot Significant90Sr Activity (Ci)Highly SignificantNot Significant137Cs Activity (Ci)Highly SignificantNot SignificantTRU Alpha Conc. (nCi/g)Not Significant Not SignificantB-21ATTACHMENT B.21 REPLICATE TESTING DATA FOR CONTAINER61209, HENC #2 SYSTEMInstrument: HENC #2Container: 61209Original Measurement Replicate #1 Replicate #2Quantity of Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeInterest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value Uncertainty Uncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 1.17E-052.41E-112.06E-061.17E-051.85E-111.58E-061.20E-052.40E-112.00E-06238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 1.21E-033.05E-072.52E-042.48E-041.59E-086.40E-051.10E-032.48E-072.25E-04239Pu Activity (Ci) 8.59E-031.34E-051.56E-038.61E-031.67E-051.94E-038.63E-031.08E-051.25E-03240Pu Activity (Ci) 2.52E-031.42E-065.62E-042.06E-031.09E-065.30E-041.90E-038.25E-074.34E-04242Pu Activity (Ci) 1.87E-077.61E-154.07E-081.18E-073.60E-153.05E-081.64E-075.76E-153.51E-08241Am Activity (Ci) 8.17E-041.54E-071.89E-041.04E-032.71E-072.61E-042.35E-031.14E-064.83E-0490Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00TRU Alpha Conc. (nCi/g) 2.39E+027.34E+033.07E+012.40E+028.30E+033.46E+012.55E+027.75E+033.04E+01Replicate #3 Replicate #4 Replicate #5Quantity ofInterestReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00234U Activity (Ci) 1.23E-052.48E-112.02E-068.33E-061.42E-111.71E-061.02E-051.83E-111.79E-06238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00238Pu Activity (Ci) 1.92E-038.03E-074.18E-041.04E-032.25E-072.16E-042.01E-038.64E-074.30E-04239Pu Activity (Ci) 8.44E-031.38E-051.63E-038.45E-031.29E-051.53E-038.48E-031.35E-051.59E-03240Pu Activity (Ci) 2.11E-031.06E-065.01E-042.36E-031.25E-065.29E-042.44E-031.36E-065.58E-04242Pu Activity (Ci) 1.83E-077.58E-154.14E-081.58E-075.50E-153.48E-081.99E-078.78E-154.41E-08241Am Activity (Ci) 1.04E-032.51E-072.41E-048.93E-041.81E-072.03E-041.02E-032.39E-072.34E-0490Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A0.00E+000.00E+00N/A0.00E+00TRU Alpha Conc. (nCi/g) 2.46E+027.95E+033.23E+012.32E+026.96E+033.00E+012.54E+028.13E+033.20E+01B-22ATTACHMENT B.22 REPLICATE TESTING RESULTS FOR CONTAINER 61209, HENC #2 SYSTEMInstrument: HENC#2Container: 61209Original Measurement Sample RelativeQuantity of Reported Absolute Sample Standard StandardInterest Value Uncertainty Mean Deviation Deviationχ2Pr(x<| 

# χ2|)t Pr(x<|t|)233U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A234U Activity (Ci) 1.17E-052.41E-111.09E-051.65E-061.51E-011.88E+100.00E+004.39E-016.83E-01238U Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A238Pu Activity (Ci) 1.21E-033.05E-071.26E-037.24E-045.73E-012.25E+070.00E+00-6.76E-029.49E-01239Pu Activity (Ci) 8.59E-031.34E-058.52E-039.09E-051.07E-021.84E+029.26E-396.83E-015.32E-01240Pu Activity (Ci) 2.52E-031.42E-062.17E-032.22E-041.02E-019.85E+040.00E+001.42E+002.28E-01242Pu Activity (Ci) 1.87E-077.61E-151.64E-073.06E-081.86E-016.45E+130.00E+006.75E-015.37E-01241Am Activity (Ci) 8.17E-041.54E-071.27E-036.08E-044.79E-016.19E+070.00E+00-6.78E-015.35E-0190Sr Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/A137Cs Activity (Ci) 0.00E+00N/A0.00E+000.00E+00N/A#VALUE!#VALUE!N/AN/ATRU Alpha Conc. (nCi/g) 2.39E+027.34E+032.45E+029.69E+003.95E-026.97E-061.00E+00-6.03E-015.79E-01Quantity ofInterestχ2Testt Test233U Activity (Ci) #VALUE! Not Applicable234U Activity (Ci) Highly Significant Not Significant238U Activity (Ci) #VALUE! Not Applicable238Pu Activity (Ci) Highly Significant Not Significant239Pu Activity (Ci)Highly SignificantNot Significant240Pu Activity (Ci)Highly SignificantNot Significant242Pu Activity (Ci)Highly SignificantNot Significant241Am Activity (Ci)Highly SignificantNot Significant90Sr Activity (Ci) #VALUE! Not Applicable137Cs Activity (Ci) #VALUE! Not ApplicableTRU 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 consi stently 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 pr evalent nuclides do not comport because only a

portion of the waste stream had been measured. How ever, CCP should develop processes and criteria to

establish when reassessment would occur and what th is would entail.

B. Regulatory Reference: Attachment B4, Section B4-4; DOE-WIPP-02-3122, Atta chment 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 Personne l: 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 char acterization activities at all CCP TRU waste

characterization sites must be evaluated. Once the evaluation is complete, EPA must be informed of th e

results of CCP’s investigation.

F. Site Response Information and Issue Resoluti on:

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 c haracterization results and NCRs that identify

potential changes to the AK of a waste stream are t racked as Trend Code L. These NCRs are

evaluated by the AKE. The AKE evaluation and resol ution 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-Evalu ation, 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 th e NCR.

Trending of NCRs identified as Trend Code L is perfo rmed 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 discrepa ncies between AK and measurement

data, a re-evaluation of AK information will be con ducted. 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 memo randum 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 wa ste stream in the future, CCP will provide and

document training to characterization personnel reg arding 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 issu e 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 co mparing the AK and NDAidentified weight percents of the two predominant r adionuclides. However, this assessment would be mo re

meaningful if accuracy was also assessed in terms o f activity . For example, the March 27, 2006, AK

Accuracy Report for Waste Stream LA-MIN03-NC.001 sta tes that the most prevalent isotopes identified by

AK are 235 

# U and 235 

# U, based on weight percent. However, the assignmen t of 238 

# U and 235 

# U as the most

prevalent is based on the radionuclide content of a small number of containers. If these containers a re 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 A K-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 Personn el: Norm Frank

Other Personnel: NA

E. Additional Comments: The potential for this concern to impact waste char acterization activities at

all CCP TRU waste characterization sites must be ev aluated. Once the evaluation is complete, EPA must

be informed of the result of CCP’s investigation.

F. Site Response Information and Issue Resoluti on: 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 documen ts for specific statements or conclusions. In the NDA

memoranda for LANL-007 and -009, references for for mulas or other calculations should be included.

Tables in all NDA-AK memoranda should be checked aga inst data in the AK Summaries and Attachments

to ensure that the data presented therein are consi stent; specifically, Table 3 in the LANL-009 AK-NDA

memorandum should be revised to indicated expected (rather than suspected) radionuclides, as this make s 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 Personne l: Norm Frank

Other Personnel: NA

E. Additional Comments:

F. Site Response Information and Issue Resoluti on:

Site Response Required? YES NO

Site Response Due Date: 6-18-06

The NDA Memorandum is LANL-CCP’s method of addressing EPA-i dentified communication issues and

originated when EPA identified these issues at a Ha nford-CCP inspection. Some remedies implemented by

sites related to TRU WC processes in response to EP A issues or concerns are self imposed; however, the se

at times may, in fact, provide assurance that EPA’s issues and/or concerns are appropriately identifie d 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 a re aware of the use and limitations of AK as applie d

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

when they are found, and LANL-CCP has revised NDA me moranda for waste streams LANL-004, LANL007, and LANL-009 to address the issues that were i dentified. EPA is convinced that when AK-NDA

communication occurs through the process of using a n 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 enco untered in the RTR examinations of containers prior to

May 2005 from waste stream number LA-MIN03-NC.001 w ere not predicted in the AK summary CCPAK-LANL-004. Although characterization personnel i nitiated NCRs to address the presence of prohibited

liquids, this information was not communicated to A K personnel to enable updating of the AK record. A s a

result, more than 120 drums of waste with the poten tial to contain in excess of 1% liquids (the maximu m

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 characteriz e wastes from this same waste stream from May 4,

through June 23, 2005. However, the presence of li quids made the use of this technique unsuitable for

containers of S3000 wastes. Until corrective actio n 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 Ledf ord

Other Personnel: NA



# E. Additional Comments: The potential for this finding to impact waste char acterization activities at all CCP

TRU waste characterization sites must be evaluated. Once this is evaluated, EPA must be informed of t he result of

CCP’s investigation. EPA will perform its own inve stigation 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 appro ximately 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 t he use of VE for all solid (S3000) waste streams th roughout the

DOE complex. This was not EPA’s intention and EPA provided verbal clarification to CBFO regarding thi s on multiple occasions. EPA did intend this finding to prohibit the use of VE for de-watered sludge conta iners at LANLCCP and to prompt CBFO to reexamine the use of VE f or similar wastes throughout the complex. The form al CBFO

response that was submitted to EPA on March 21, 200 7 is provided below:

CCP will conduct additional training to the SPMs an d AKEs to develop and issue, as necessary, a

memorandum to be included in the AK record to docum ent 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 is sue 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 V E include a line item that

requires operators to verify that the waste examine d matches the Waste Stream description. The VEE fo r

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 quest ion. 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 des criptions 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 Exami nation, Attachment 1, Question #32

2. CCP-TP-053, Revision 4, Standard Real-Time Radiogra phy (RTR) Inspection Procedure,

Attachment 2, Section 5

D. Discussed with: Site Personnel: Steven Ewing, Bill Mussman, Collee n Monk, Israel Aragon,

Ricky Baros

DOE/CTAC Personnel: Annabelle Axinn

Other Personnel: NA

E. Additional Comments: The potential for this concern to impact waste char acterization activities at

all CCP TRU waste characterization sites must be ev aluated. Once this is evaluated, EPA must be infor med

of the result of CCP’s investigation.

F. Site Response Information and Issue Resoluti on:

Site Response Required? YES NO

Site Response Due Date: 6-18-06

Prior to the March 6, 2007, follow-up inspection, E PA reviewed a copy of the LANL-CCP RTR and VE

Training Module (PowerPoint presentation) and the No n Destructive Examination (NDE) RTR

Comprehensive Examination. During the March 2007 f ollow-up inspection, EPA interviewed RTR

operators who were able to correctly answer questio ns with the regard to the items on the data form th at are

detailed above. The operators also demonstrated to EPA that they had access to both paper and electro nic

copies of the applicable AK waste stream descriptio ns. 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 inconsiste ntly 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 w ay: 60% rubber and 40% other metals.

2. VE personnel were unable to provide the rationa le 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 Exami nation, Attachment 1, Section 3

2. CCP-TP-053, Revision 4, Standard Real-Time Radiogra phy (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 ch aracterization activities at

all CCP TRU waste characterization sites must be ev aluated. Once the evaluation is complete, EPA must

be informed of the results of CCP’s investigation.

F. Site Response Information and Issue Resoluti on:

Site Response Required? YES NO

Site Response Due Date: 6-18-06

CBFO’s response that was submitted to EPA is provid ed 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 is sue 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 th e WMPs contained in the cans were inventoried and t he

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 Exami nation

D. Discussed with: Site Personnel: Israel Aragon, Sue Peterman

DOE/CTAC Perso nnel: Annabelle Axinn

Other Personnel: NA

E. Additional Comments: The potential for this concern to impact waste char acterization activities at

all CCP TRU waste characterization sites must be ev aluated. Once the evaluation is complete, EPA must

be informed of the result of CCP’s investigation.

F. Site Response Information and Issue Resoluti on:

Site Response Required? YES NO

Site Response Due Date: 6/18/06

The CBFO response that was submitted to EPA is prov ided below:

CCP will conduct additional training to the VE ope rators/VE experts to verbalize more during VE

operations that would allow an independent person t o reach the same conclusion as the VE operator

or VE expert.

EPA accepts the CBFO response and considers this is sue 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 C omparison Reports, but

at the time of this inspection RTR operators had no t 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 Axin n

Other Personnel: ,NA

E. Additional Comments: None

F. Site Response Information and Issue Resoluti on: 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) i n response to the April 18, 2007 Federal

Register notice that proposed EPA’s decision to approve var ious components of the LANL CH

TRU waste characterization program implemented by C CP (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 co mments have been divided into six separate

issues, and each issue is provided verbatim below a long with EPA’s response. Please note that

wherever EPA has modified the text from the propose d approval to address a specific comment

the modified text presented in this attachment is u nderlined for emphasis. The text in the actual

report is not underlined.

Comment No. 1: The EPA proposes that CCP must report and, if app licable, receive EPA

approval of any changes to the waste characterizati on activities to the date of the LANL baseline

inspection. The EPA’s proposed reporting and appro val requirements are not identical to those

included in their previous baseline inspection repo rts and EPA approval letters.

EPA Response: This is correct. This was addressed in the Execu tive Summary of the

LANL CH Baseline Inspection report that is excerpted below:

“ LANL-CCP must report and receive EPA approval of an y T1 changes to the LANL-CCP

WC activities from the date of the baseline inspect ion, 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 in spection reports and EPA site approval

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

elements. In previous reports there were two T2 co lumns that have been merged into a

single T2 column for LANL-CCP. The T2 column entri es have also been modified to

better reflect the 40 CFR 194.24 (h) requirements t hat the site provide notification

regarding the completion or availability of specifi c T2 elements, whereas the previous

tables stated that the site must actually provide t he 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. Add itionally, there are other minor

word changes to the table for the sake of legibilit y.

The 40 CFR 194.8 regulatory changes gave EPA flexib ility whereby EPA now is able to

evaluate targeted WC program items (namely T1 and T 2 changes) in lieu of annual

continued compliance inspections at different sites more frequently (every fiscal year

quarter). Also, the slight variation in tiers amon g the sites reflects EPA’s site inspection

experience where inspectors are able to compare wha t they observed at the previouslyapproved CCP sites verses what they notice at the s ite that is being evaluated for

approval. The contents of the site-specific tierin g tables vary slightly because they depict

the waste characterization ability of the site in c ompiling 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 su mmary of the changes instead of

submitting the complete documents, unless specifica lly requested by EPA, on a quarterly

basis will significantly reduce paperwork requireme nts 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 mo difications 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 Executi ve Summary of the

LANL CH Baseline Inspection report that is excerpted below:

“There are changes to specific WC areas as well. F or AK, the AK Reassessment

Memoranda (reflecting resolution to concern LANL-CC P-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 ta bles in previous baseline inspection

reports. These memoranda are necessary as they pro vide evidence that the above issues

are sufficiently addressed. Similarly, requesting revisions to CCP-AK-008 or notification

regarding the combination of waste streams that wer e distinct at the time of inspection

are specific to the LANL OSRP or the result of info rmation 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 degr ee 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 ch anges with the potential to impact the

site’s waste characterization activities under 40 C FR 194.24 or documentation thereof,

excluding changes that are solely related to Enviro nmental Safety &Health (ES&H),

nuclear safety, the Resource Conservation and Recov ery Act (RCRA) or are editorial in

nature.”

Comment No. 3: Another difference requires notification to EPA upo n completion of changes

to the WIPP Waste Information System (WWIS), includ ing the following:

• Changes to the Excel spreadsheet, WWIS data entry s ummary

• 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 i nformation. 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 i nformation 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 o n 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 concerni ng T2 changes at the end of each

fiscal year quarter. EPA will evaluate these chang es and communicate with LANL-CCP

as to whether the changes raise any concerns and re quire a LANL-CCP response, or

whether LANL-CCP can continue to implement the chan ges. Consistent with EPA’s

authority under 194.24(h) EPA may request informati on relative to these changes if EPA

deems the information is necessary to ensure contin ued compliance with EPA

regulations.”

Regarding the reason for requiring information rela tive to the WWIS, please see Section

8.6 of the report and the text from the Executive S ummary 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 a ppear in previous tiering tables.

These were added to provide a greater degree of spe cificity 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 appr oves. Accordingly, changes

to the spreadsheet potentially represent a characte rization system different from

what was approved, and therefore require informing EPA as indicated in Table 1.

More generally, EPA understands CCP’s desire to hav e complete consistency

among all their WC sites. Differences among the sit es do exist and must be

addressed when they represent a change in the known characterization process.

EPA attempts to accurately reflect these difference s in each inspection and not

burden a CCP site with requirements that are irrele vant. Tiering differences

among sites reflect site-specific conditions (activ ities) and waste streams

evaluated during the baseline inspection.

During the follow-up inspection of March 2007, AK ex perts indicated that they

prepare the semi-annual CCP Trend Report, which ref lects changes in the AK

summary. During the closing, CCP and CBFO represent atives 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 progra mmatic controls exist to add waste to

existing AK reports. This new requirement is incon sistent 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, E PA must look at the unique circumstance.

The OSRP is indeed different from other CCP sites p reviously inspected and approved by

EPA and these differences are reflected in the Tier ing requirements.

In the OSRP program, sealed sources that are collec ted from various industries (e.g.,

universities, health care and pharmaceuticals, oil exploration), are expected to have

different pedigree hence, different radiological co ntents. As additional sealed sources are

recovered from various commercial and industrial ap plications 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. Seale d sources recovered from different

commercial or industrial applications but with a si milar pedigree could be combined in a

single waste stream designated as a new waste strea m 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 th eir 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, r equiring EPA notification as described

previously, when characterization information in th e AK Summaries for the approved

waste streams (as part of the baseline inspection a nd T1 change evaluation) has been

revised to accurately account for changes in radiol ogical 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 th e new defense determinations. Sealed

sources containing 241 

# Am and 238 

# Pu 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 wi th respect to radionuclide content,

predominant nuclides, etc. Similarly, LANL-CCP mus t 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 source s, 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 informa tion 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 c onducted within CCP’s program and overseen

by the CBFO.

EPA Response: EPA recognizes that DOE has its role in ensuring tha t it and its

contractors appropriately conduct waste characteriz ation and quality assurance

activities. However, as the regulator for WIPP, EPA has the responsibility and authority

to conduct unfettered inspections of DOE waste chara cterization 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 sa tisfied 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 re quirements; 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 t o obtain objective evidence that can

be used to substantiate our decisions.

Comment No. 6: In summary, reporting these changes will add unnece ssary complexity and

therefore costs to the current CCP process for repo rting Tier 1 and Tier 2 changes. Also, the

proposed criteria for reporting Tier 1 and Tier 2 c hanges 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 characteriz ing 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 d o 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 re quirements will

require more effort on DOE’s part reflects a misund erstanding. 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 p revious requirements. Table 1 has

been modified with an additional footnote for the p urpose 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 r educe the need for EPA to perform

our regulatory oversight function.