DOCKET NO: A-98-49; II-A4-110 

WASTE CHARACTERIZATION REPORT 

TIER ONE CHANGE: 

EVALUATION OF VISUAL EXAMINATION BY REVIEWING PREVIOUSLY 

GENERATED AUDIO/VISUAL RECORDINGS OF WASTE PACKAGING FOR 

CONTACT-HANDLED TRANSURANIC DEBRIS WASTE 

AS IMPLEMENTED BY THE 

CENTRAL CHARACTERIZATION PROJECT (CCP) AT INL 

December 9-11, 2008 and February 2, 2009 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center of Federal Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

February 2009
i

TABLE OF CONTENTS 

Section Page

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

2.0 Purpose of Tier 1 Change Evaluations............................................................................ 2

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

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

5.0 Evaluation Team ............................................................................................................... 3

6.0 Performance of the Review: Visual Examination......................................................... 4

7.0 Conclusion ......................................................................................................................... 9

Attachment A EPA Concern Forms, Final 

Attachment B Summary of Interviews with NTS Waste Packaging Personnel 
1

1.0 EXECUTIVE SUMMARY 

This report describes the U.S. Environmental Protection Agency (EPA or the Agency)’s 

evaluation of a visual examination (VE) technique implemented by the Central Characterization 

Project (CCP) to characterize contact-handled (CH) transuranic (TRU) debris waste from the 

Nevada Test Site (NTS) packaged in standard waste boxes and 55-gallon drums. This is a Tier 1 

(T1) change to the non-destructive examination (NDE) processes implemented by CCP at the 

Idaho National Laboratory (INL) and approved by EPA in October 2005. EPA conditionally 

approves this VE technique (CCP-TP-163, CCP Standard Visual Examination of Records used 

in conjunction with CCP-TP-113, CCP Standard Contact-Handled Waste Visual Examination). 

The conditions are presented below, in Section 6.3 and in Section 7.0 of the report. 

In accordance with 40 CFR 194.8(b), from May 3–5, 2005, EPA conducted Baseline Inspection 

No. EPA-INL-CCP-05.05-8 of CCP’s waste characterization program located at the INL. EPA 

approved the baseline program in October 2005 allowing disposal of debris (S5000) and solid 

(S3000) waste at the Waste Isolation Pilot Plant (WIPP). (See EPA Docket No: A-98-49; II-A4-

59, October 2005). The October 2005 baseline approval of the CCP program at INL for contacthandled (CH) TRU wastes included the VE technique limited to VE as Quality Control (QC) 

Check of Real Time Radiography for CH retrievably-stored TRU debris and solid waste. 

On November 13, 2008, the Carlsbad Field Office (CBFO) requested EPA’s approval of a 

different VE technique to be implemented at INL-CCP (CCP-TP-163 in conjunction with CPTP-113) as a Tier 2 (T2) change to characterize CH TRU waste from NTS. The alternate VE 

technique comprises of a review of the audio/video (A/V) recordings using CCP procedure CCPTP-113 to characterize WMPs and estimated their weights. The A/V recordings were prepared 

by NTS when packaging CH TRU debris waste according to the Department of Energy (DOE) 

headquarters issued Contact-handled Transuranic Waste Packaging Instructions (10/8/2008). 

Upon review of the T2 change specific information provided with the approval request, EPA 

determined that the requested approval must be evaluated by EPA as a Tier 1 (T1) change for the 

following reasons. First, the A/V recordings of packaging and waste content records for 

individual containers were prepared by NTS, a small generator site (SGS) not approved by EPA 

for characterizing TRU waste. Second, NTS generated waste content information does not 

follow EPA’s quality assurance (QA) requirements at 40 CFR 194.22, hence, the NTS-generated 

data cannot be directly applied to WIPP-bound TRU waste. Finally, INL-CCP was 

implementing an alternate VE technique which EPA had not evaluated for adequacy previously 

and it was significantly different from the VE technique EPA approved in October 2005. Also, 

EPA concluded that more scrutiny and thorough evaluation of the proposed process was 

necessary as the process could be applied by CCP at other SGSs. 

In December 2008, therefore, EPA inspected implementation of the proposed INL-CCP’s VE 

technique implemented for NTS as a T1 change. During the December evaluation, EPA was not 

able to determine technical adequacy of the process for identifying and documenting the required 

waste characteristics, WMPs, verification of the absence of prohibited items, and verification 

that the waste matches the waste stream description for debris waste stream ID-NTLLNL-S5400. 

Section 6.1 discusses the results of EPA inspection. EPA issued a total of seven EPA concerns, 
2

six of which required a response. These are included in Attachment A to this report. On 

February 2, 2009, EPA performed a follow-up inspection to assess how INL-CCP had addressed 

EPA’s concerns. The results of this evaluation are discussed in Section 6.3 of the report. 

Additionally, EPA had a series of discussions with Department of Energy (DOE) headquarters 

(HQ) and CBFO staff to resolve outstanding issues. The outcome of these discussions is 

summarized in section 6.3 of the report. 

Based on the information presented in this report, EPA approves the process of generating VE 

information utilizing A/V recordings process (CCP-TP-163), for all debris waste packaged at 

NTS (sent to INL or destined for INL for further characterization and disposal by INL-CCP) that 

are supported by A/V recordings. Using the approved VE process, INL-CCP will generate VE 

batch data reports (BDRs) in accordance with the previously-approved procedure CCP-TP-113. 

Any available written waste packaging records will be part of the acceptable knowledge (AK) 

and may not be used for generating VE data. This approval requires that INL-CCP confirms by 

the VE process using the A/V recordings that waste has been packaged in containers verified to 

have been empty prior to packaging. At this time, EPA is not approving the use of waste 

packaging records by themselves for identifying WMPs and estimating their weights. EPA will 

separately determine whether these records may be used for the WC purposes by CCP when 

characterizing CH TRU waste packaged by small generator sites (SGSs). Such use of waste 

packaging records will also be evaluated as a T1 change. 

In addition, upon EPA notification, INL-CCP and other EPA-approved CCP sites may use the 

above approved process for characterizing CH TRU debris waste packaged at other SGSs. When 

characterizing SGS-generated CH TRU debris waste, CCP may only use the EPA-approved 

waste characterization procedures. 

 

2.0 PURPOSE OF TIER 1 CHANGE EVALUATIONS 

Certain changes to the WC activities from the date of the site’s baseline inspection must be 

reported to, and, if applicable, approved by EPA according to the tiering requirements set forth in 

40 CFR 194.8, regulation and incorporated in the INL Baseline Final Report cited above. 

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

EPA must perform a single baseline inspection of a TRU waste generator site’s WC program. 

(Vol. 69, No.136, pages 42571–42583, July 16, 2004). The purpose of a baseline inspection is to 

approve the site’s WC program based on the demonstration that the program’s components, with 

applicable conditions and limitations, can adequately characterize TRU wastes and comply with 

the regulatory requirements imposed on TRU wastes destined for disposal at the WIPP. An EPA 

inspection team conducts an onsite inspection to verify that the site’s system of controls is 

technically adequate and properly implemented. 

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

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

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

EPA notification and approval prior to implementation (T1) and those requiring post-
3

implementation (T2) notification are identified in the site-specific baseline inspection reports. 

DOE may choose to characterize and dispose of at risk while EPA considers the proposed T2 

changes. EPA may conduct continued compliance inspections (both announced and 

unannounced) to verify that the site continues to use only the approved WC processes to 

characterize approved summary waste categories and that those WC processes remain in 

compliance with all applicable regulatory requirements. 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of the EPA’s evaluation of a T1 change to the initial baseline 

approval of the CH TRU WC program at INL-CCP. Specifically, this report addresses the 

technical area of VE by review of previously-generated A/V recordings (using procedure CCPTP-163 in conjunction with CCP-TP-113) of waste packaging that occurred at NTS using 

Contact-handled Waste Packaging Instructions dated 10/8/2008 provided by DOE Headquarters. 

EPA evaluated this process to verify that it was adequate for identifying and documenting the 

required waste characteristics (WMPs, verification of the absence of prohibited items, and 

verification that the waste matches the waste stream description) for waste stream ID-NTLLNLS5400. The 2005 INL-CCP baseline report referenced above describes the conditions that EPA 

had approved and documents the basis for EPA’s initial approval decision of VE at INL-CCP. 

4.0 SCOPE OF REVIEW

This T1 change review included the evaluation of information supporting the WC technique of a 

VE process that involves generating VE data for CH debris waste from previously recorded 

waste packaging events. 

5.0 EVALUATION TEAM 

Ms. Dorothy Gill performed the evaluation of the proposed VE technique at CBFO office in 

Carlsbad, New Mexico in December 2008 and February 2009. A complete listing of all 

individuals who participated in both the December 2008 and February 2009 T1 evaluations is 

provided in Table 1. This includes personnel from NTS who were interviewed by telephone, as 

described in Section 6.2, below. 

Table 1. T1 Evaluation Participants

Inspection Team Member Affiliation Area of Expertise

Dorothy Gill S. Cohen & Associates, Inc. EPA Inspector 

Rhett Bradford CTAC Technical Specialist VE 

Dave Kimbro CTAC Lead Auditor QA 

Shane Miles CCP VEE/VPM 

Michael Walentine CCP SPM 
4

A.J. Fischer CCP CCP Support 

Tim Hall NMED Observer 

Alyca Attwood CCP Records 

Jon Tanaka* NTS Waste Handler 

Sherry Peczka* NTS Waste Examination Expert (WEE) 

Laura Kinstad* NTS Waste Handler 

Mike McCullough* NTS Waste Operations Manager 

Rick Wagner* NTS Division Manager 

Casey Gadbury CBFO NTP Manager 

Court Fesmire CBFO NTP co-ordinator 

 Patsy Gilbert CBFO Site Documents staff 

*NTS personnel were interviewed by telephone. 

6.0 PERFORMANCE OF THE REVIEW: VE BY REVIEWING AUDIO/VISUAL 

RECORDINGS 

6.1 December 2008 Evaluation 

On December 9 – 11, 2008, EPA conducted a limited scope evaluation of INL-CCP’s modified 

process for generating VE data for CH TRU debris waste from previously-recorded waste 

packaging events at NTS. NTS personnel made the original A/V recordings and also prepared 

physical waste content records for each container during packaging. NTS used a waste 

packaging procedure Contact-handled Waste Packaging Instructions dated 10/8/2008 provided 

by DOE HQ. EPA had not previously evaluated this process for CH waste. Because the NTS 

does not currently have an EPA-approved WC program, any WC activities completed by NTS 

and data generated from those activities may not be used for WIPP certification without the 

application of approved waste characterization processes by an approved site. 

The process observed during this inspection and follow-up allows INL-CCP personnel to 

visually examine existing A/V recordings and generate VE data under CCP’s EPA-approved 

waste characterization program. At the time of the review, CCP had generated three Batch Data 

Reports (BDRs), which contained a total of six Standard Waste Boxes (SWBs). Revision 1 of 

CCP-TP-163 was used to assess the acceptability of the A/V recordings prior to CCP beginning 

VE data generation. The VE process to identify WMPs and estimate their weights on a container 

basis was performed in accordance with a previous revision of CCP-TP-113 (Revision 11, 

November 12, 2008). 

Prior to and during the inspection, EPA reviewed the following documents and records: 

• CCP-TP-113, Revision 12, Standard Contact-Handled Waste Visual Examination, 

December 1, 2008 

• CCP-TP-163, Revision 1, Standard Visual Examination of Records, November 12, 2008 
5

• CCP-AK-INL-009, Revision 0, Acceptable Knowledge Summary Report for Idaho 

National Laboratory, Nevada Test Site, Lawrence Livermore National Laboratory Waste, 

Waste Streams ID-NTLLNL-S5400 and ID-NTLLNL-S3900, November 19, 2008 

• Non-conformance report NCR-INL-0516-08 

• Training Attendance Sheet for VE personnel for CCP-AK-INL-009, November 19, 2008 

• PowerPoint slides used for training in procedure CCP-AK-INL-009 

• List of Qualified Individuals (LOQI), Small Quantity Site (SQS) Program 

• Addendum H – Small Quantity Site (SQS) Waste Characterization at the Idaho National 

Laboratory (INL) for VE personnel: Jason Struchen, November 18, 2008; (Richard) 

Shane Miles, November 17, 2008; Donald Blunn, November 17, 2008; and Wes Root, 

November 17, 2008 

• Original packaging records for SWBs NT070702R, NT070705R, NT070682R, 

NT070699R, NT070694R and NT070722R 

• BDR Nos. NTVE080001, NTVE080002, and NTVE080003 

• A/V recordings for packaging of the six SWBs listed above 

EPA reviewed training records for INL-CCP VE personnel listed on the CCP LOQI for this 

process. As evidenced by the signature and date on the Addendum H for each operator, the 

training records demonstrated that these personnel were considered to be qualified before they 

had received the required AK training. EPA Concern No.INL-CCP-CH-VE-T1-001C was 

generated to address this issue. 

EPA reviewed procedure CCP-TP-113 used to generate VE data and complete data forms, and 

CCP-TP-163 used to determine if A/V recordings were adequate for the process. EPA Concern 

No.INL-CCP-CH-VE-T1-002CR was generated because these two procedures do not adequately 

reference each other and do not clearly state how they are used together. 

The A/V recordings reviewed were fragmented and locating the complete records for each 

container was difficult and burdensome. During review of the A/V recordings, original 

packaging records and INL-CCP’s written record of VE data, EPA identified five concerns with 

regard to the VE process used by INL-CCP which are included in Attachment A. These are 

summarized below: 

• EPA Concern No. INL-CCP-CH-VE-T1-003CR: The visual record did not clearly show 

that several of the SWBs were empty at the start of the packaging activities. Without this 

information, INL-CCP operators are unable to determine that prohibited items are not 

contained in each SWB. 

• EPA Concern No. INL-CCP-CH-VE-T1-004CR: INL-CCP VE operators did not always 

correctly identify WMPs. SWB No. NT070694R included “Gloves, Gaskets” as WMPs 

Iron-based metals/alloys but the A/V clearly showed these items to be rubber. This error 

was not identified by the two INL-CCP operators performing VE and was also not 

identified during review by the Independent Technical Review (ITR) and Site Project 

Manager (SPM) review. 
6

• EPA Concern No. INL-CCP-CH-VE-T1-005CR: When performing VE for container No. 

NT070705R, INL-CCP VE operators failed to record the presence of rubber gloves 

although this item was clearly called out on the A/V recording multiple times. Procedure 

CCP-TP-113, Attachment 2, Section 3, Waste Packaging Data was incomplete for this 

container. 

• EPA Concern No. INL-CCP-CH-VE-T1-006CR: The correct container number was not 

consistently used by personnel during the original VE. VE operators verify the absence 

of prohibited items and the container inventory by signing the VE data form (Attachment 

2, CCP-TP-113); due to the identification errors, INL-CCP may not be able to do this for 

container No. NT070705R. 

• EPA Concern No.INL-CCP-CH-VE-T1-007CR: INL-CCP recognizes the importance of 

secure storage for in-process containers by requiring lids to be replaced and secured using 

a Tamper Indicating Device (TID) in procedure CCP-TP-113. During the original 

packaging, in-process containers were covered with a plastic sheet or blanket but were 

not sealed to prevent addition or removal of waste items. INL-CCP VE operators were 

unable to verify that the contents of SWBs had not been changed. 

Late January 2009, INL-CCP responded to EPA’s concerns and these were evaluated during the 

February 2009 evaluation discussed below. 

6.2 February 2009 Evaluation 

On February 2, 2009, EPA performed a one-day follow-up, inspection to assess INL-CCP’s 

responses to the EPA concerns generated during the initial T1 assessment in December 2008, as 

described above. Each concern is summarized below along with the status of each following the 

February 2009 evaluation: 

Concern INL-CCP-CH-VE-T1-001C, Final: Training on document CCP-AK-INL-09 for the 

four VE personnel listed on the LOQI for SQS Program dated December 9, 2008, was performed 

on November 19, 2008. However, copies of CCP’s Addendum H – SQS Waste Characterized at 

INL for these personnel were dated between 1 and 2 days before the training took place. EPA 

does not consider signing off on training before the training is completed to be a desirable 

practice. 

Status: This concern did not require a response from CBFO and no further action is required. 

Concern INL-CCP-CH-VE-T1-002CR, Final: INL-CCP uses procedure CCP-TP-113 to 

generate and record VE data of CH TRU waste. INL-CCP uses procedure CCP-TP-163 to 

determine that existing A/V recordings used to generate VE data include all the required 

information pertaining to the waste in each container. Although INL-CCP intends to use these 

procedures in concert, they do not adequately reference each other and do not clearly state how 

they are used for this type of VE. Draft Revision B of CCP-TP-113, CCP Standard ContactHandled Waste Visual Examination, contained language that would allow VE data to be

generated from not only A/V recordings but also any packaging record. For example, Section 

2.6.4 defines VE of Records as: “VE performed using existing audio/video media of waste 
7

packaging or waste packaging data forms acceptable in accordance with CCP-TP-163, CCP 

Evaluation of Waste Packaging Records for Visual Examination Records.” EPA rejected the 

proposed revisions to procedure CCP-TP-113. 

Status: The INL-CCP response was unacceptable. EPA, DOE HQ and CBFO had a series of 

discussion to resolve this concern. The results of these discussions are given in section 6.3 

below. 

Concern INL-CCP-CH-VE-T1-003CR, Final: During the inspection EPA reviewed the 

existing VE generated using A/V recordings for three of the six containers processed to-date by 

INL-CCP. From the recordings it was not possible to determine that two of the three containers 

were empty at the start of the original VE event. This information is necessary to confirm that 

prohibited items were not present in the containers and therefore, these containers should have 

been rejected. A requirement to verify that the bottom of each container was empty prior to 

commencing packaging was not included in the draft revisions of CCP-TP-113, Revision 13, 

Draft B and CCP-TP-163, Revision 2, Draft A provided to EPA for review. EPA rejected the 

proposed revisions to procedures CCP-TP-113 and CCP-TP-163. 

EPA interviewed selected NTS waste packaging personnel via teleconference. Court Fesmire and 

Patsy Gilbert from CBFO observed the interviews. A summary of information gained during the 

interviews is included in Attachment B. The information gathered by EPA was sufficient to 

address concerns for the waste packaged to date with regard to the condition of the containers 

prior to packaging activities. However, EPA does require CBFO to revise its packaging process 

so that the A/V recordings show that containers are empty prior to any further packaging 

activities. EPA acknowledges that all NTS personnel interviewed were cooperative and 

provided the requested information without hesitation. CBFO NTP personnel committed to 

ensuring that all containers packaged in the future at NTS will be supported by A/V records that 

establish that the each waste container is empty prior to beginning packaging. 

Status: This concern is resolved based on interviews of NTS waste packaging personnel who 

confirmed that containers were empty prior to loading of waste. EPA wanted similar assurance 

for NTS waste not yet packaged. This was addressed during EPA, DOE HQ and CBFO 

discussions. The results of these discussions are given in section 6.3 below. 

Concern INL-CCP-CH-VE-T1-004CR, Final: Attachment 2 of CCP-TP-113, Section 3, Waste 

Package Data, for container No. NT070694R included “Gloves, Gaskets” as WMP Iron-based 

metals/alloys. Review of the VE recording clearly showed these items to be rubber. The two 

INL-CCP VE operators performing the event did not identify this error nor did the ITR or the 

SPM identify it. 

Resolution: The data sheets for the subject containers when corrected to respond to the 

Corrective Action Request (CAR) issued by CBFO Quality Assurance (QA) program will be 

sent to EPA. 

Status: This concern is resolved, contingent upon receipt of the corrected data sheets. 
8

Concern INL-CCP-CH-VE-T1-005CR, Final: The VE recording missed recording latex 

rubber gloves for container No. NT070705R where the items were called out more than ten 

separate times and were clearly identified. CCP-TP-113, Attachment 2, Section 3, Waste 

Package Data does not include these items and is therefore incomplete. The data sheets for the 

subject containers when corrected to respond to the Corrective Action Request (CAR) issued by 

CBFO QA program will be sent to EPA for review. 

Resolution: The Data Sheets for the subject containers have been corrected and will be 

presented to EPA for review after closure of the CAR issued by CBFO QA to address this issue. 

Status: This concern is resolved, contingent upon receipt of the corrected data sheets.

Concern INL-CCP-CH-VE-T1-006CR, Final: The VEE performing the original VE event 

incorrectly identified container No.NT070705R as NT070702R twice. These errors were clearly 

recorded on the A/V recording but the INL-CCP VE operators either did not recognize or did not 

record these errors. 

Resolution: CBFO explained that while the misidentifications had occurred in the A/V record, 

there was sufficient clarity regarding the container’s actual number. EPA accepts this 

explanation. 

Status: This concern is resolved. 

Concern INL-CCP-CH-VE-T1-007CR, Final: INL-CCP procedure CCP-TP-113, Section 

4.3.2, Note, contains the requirement: “Waste containers SHALL be closed and have a Tamper 

Indicating Device (TID)/Lock applied when left unattended”. The containers examined during 

the original VE event were left unattended and were only covered by a fire-proof blanket and 

plastic sheet per NTS procedures. While it is recognized that INL-CCP had no control over the 

original event, secure storage of in-process containers is recognized to be an essential element of 

the process that allows INL-CCP personnel to attest that neither the containers nor their contents 

are tampered with or altered. Because the subject containers were not stored securely, is unclear 

how INL-CCP VE operators can affirm that the containers and their contents have not been 

altered. 

Resolution: The language in CCP-TP-113, Revision 13, Draft B was changed from “when left 

unattended” to “when access to the container is uncontrolled”. EPA accepted this revision to the 

procedure. 

Status: This concern is closed, contingent upon receipt of the revised procedure. 

6.3 Discussions between EPA DOE HQ, and CBFO

At the end of the February 2, 2009, surveillance inspection some components of two concerns 

(Concern INL-CCP-CH-VE-T1-002CR, Final and Concern INL-CCP-CH-VE-T1-003CR, Final) 

remained unresolved requiring discussions between EPA, DOE HQ, and CBFO staff. During 
9

these discussions these concerns were resolved as follows. The proposed INL-CCP VE process 

(CCP-TP-163 in conjunction with CCP-TP-113) is approved provided that: 

• All waste packaged by NTS and sent to INL-CCP for further characterization and 

disposal must have A/V recordings showing and stating that container was empty when 

waste packaging began; 

• For NTS waste containers currently at INL with A/V recordings not documenting that 

containers were empty when used for packaging, NTS waste packaging personnel certify 

that containers were empty; and 

• INL-CCP when visually examining A/V recordings for NTS containers must document 

that the A/V recordings show that the container was empty. 

The above conditions require that (a) DOE HQ revises waste packaging instructions and (b) INLCCP revises CCP-TP-163 and CCP-TP-113 to incorporate above conditions as appropriate. This 

approval does not include use waste packaging records alone to generate BDRs for CH TRU 

waste containers without A/V recordings for disposal at WIPP. EPA, in future, will separately 

evaluate if waste packaging records alone from an unapproved SGS can be used by CCP to 

adequately identify WMPs and estimate their weights, verify absence of prohibited items, and 

validate that waste matches waste stream description when characterizing waste. This evaluation 

will be a T1 change and EPA approval prior to implementation will be necessary. 

 

6.4 Summary of Results 

During the December 2008 T1 evaluation, EPA evaluated the use of VE of A/V recordings from 

previously- recorded waste packaging events to identify and document CH TRU components of 

waste in waste stream ID-NTLLNL-S5400 being received by INL-CCP for characterization and 

disposal in compliance with 40 CFR 194.24 requirements. EPA identified a total of seven 

concerns: one that did not require a response and six that did require a response. These seven 

concerns are described in the previous section and copies of all EPA concern forms are provided 

in Attachment A. Upon receiving the INL-CCP responses EPA performed a follow up visit in 

February 2009 to determine whether INL-CCP had adequately resolved all concerns. In 

addition, EPA had several discussions with DOE and CBFO staff specific to Concern INL-CCPCH-VE-T1-002CR, Final and Concern INL-CCP-CH-VE-T1-003CR, Final. The status of each 

EPA concern is provided below. 

• INL-CCP-CH-VE-T1-001C: Concern closed. 

• INL-CCP-CH-VE-T1-002CR: Concern closed, pending receipt of revised procedure. 

• INL-CCP-CH-VE-T1-003CR: Concern closed, pending receipt of objective evidence of 

corrective actions. 

• INL-CCP-CH-VE-T1-004CR: Concern closed, contingent upon receipt of corrected data 

sheets. 
10

• INL-CCP-CH-VE-T1-005CR: Concern closed, contingent upon receipt of corrected data 

sheets. 

• INL-CCP-CH-VE-T1-006CR: Concern closed. 

• INL-CCP-CH-VE-T1-007CR: Concern closed, contingent upon receipt of revised 

procedure. 

7.0 CONCLUSION 

During this T1 evaluation, EPA evaluated use of procedures CCP-TP-163/CCP-TP-113 to 

generate VE BDRs from NTS- generated A/V recordings of debris waste packaged in SWBs and 

55-gallon drums. A total of seven EPA concerns were generated at the December 2008 

evaluation and EPA performed a one-day follow-up inspection February 2, 2009 to assess the 

INL-CCP’s responses to the EPA concerns. 

Subsequent to the February evaluation, EPA, DOE HQ, and CBFO personnel had discussions 

which enabled closure of the EPA concerns. Based on the information presented in this report, 

EPA approves the process of generating VE information utilizing A/V recordings process (CCPTP-163), for all debris waste packaged at NTS (sent to INL or destined for INL for further 

characterization and disposal by INL-CCP) that are supported by A/V recordings. Using the 

approved VE process, INL-CCP will generate VE batch data reports (BDRs) in accordance with 

the previously-approved procedure CCP-TP-113. Any available written waste packaging records 

will be part of the acceptable knowledge (AK) and may not be used for generating VE data. This 

approval requires that INL-CCP confirms by the VE process using the A/V recordings that waste 

has been packaged in containers verified to have been empty prior to packaging. At this time, 

EPA is not approving the use of waste packaging records by themselves for identifying WMPs 

and estimating their weights. EPA will separately determine whether these records may be used 

for the WC purposes by CCP when characterizing CH TRU waste packaged by small generator 

sites (SGSs). Such use of waste packaging records will also be evaluated as a T1 change. 

In addition, upon EPA notification, INL-CCP and other EPA-approved CCP sites may use the 

above approved process for characterizing CH TRU debris waste packaged at other SGSs. When 

characterizing SGS-generated CH TRU debris waste, CCP may only use the EPA-approved 

waste characterization procedures. 

 
11

Attachment A 

EPA Concerns Generated at the December 2008 T1 Evaluation 

Inspection No. EPA-INL-CCP-CH-VE-T1 Issue Number: INL-CCP-CH-VE-T1-001C, Final 

Date: December 9, 2008 

Inspector: Dorothy E. Gill 

Attachments? YES NO 

Sample Size: 4 Individuals 

Population size (if known): 4 Individuals 

Description of Issue: Training on document CCP-AK-INL-09 for the four visual examination (VE) 

personnel listed on the List of Qualified Individuals (LOQI) for Small Quantity Site (SQS) Program dated 

12/9/08 was performed on 11/19/08. However, copies of CCP’s Addendum H – SQS Waste Characterized 

at the Idaho National Laboratory (INL) for these personnel were dated between 1 and 2 days before the 

training took place. EPA does not consider signing off on training before the training is completed to be a 

desirable practice. 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable 

D. Discussed with: Rhett Bradford, Dave Kimbro, Dennis Miehls 

E. Additional Comments: During the first day of the inspection, CCP personnel were not available to 

discuss this concern. 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: NA 
12

Inspection No. EPA-INL-CCP-CH-VE-T1 Issue Number: INL-CCP-CH-VE-T1-002CR, Final 

Date: December 9, 2008 

Inspector: Dorothy E. Gill 

Attachments? YES NO 

Sample Size: 2 Procedures 

Population size (if known): Not Applicable 

Description of Issue: CCP uses procedure CCP-TP-113 to generate and record visual examination (VE) 

data of CH TRU waste. CCP uses procedure CCP-TP-163 to determine that existing audio/visual 

recordings used to generate VE data include all the required information. Although CCP intends to use

these procedures in concert, they do not adequately reference each other and do not clearly state how they 

are used for VE of this type. 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable 

D. Discussed with: Rhett Bradford, Dave Kimbro, Dennis Miehls 

 

E. Additional Comments: During the first day of the inspection, CCP personnel were not available to 

discuss this concern. 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: January 21, 2009 
13

Inspection No. EPA-INL-CCP-CH-VE-T1 Issue Number: INL-CCP-CH-VE-T1-003CR, Final 

Date: December 10, 2008 

Inspector: Dorothy E. Gill 

Attachments? YES NO 

Sample Size: 3 Containers 

Population size (if known): 6 Containers 

Description of Issue: During the inspection EPA reviewed the existing visual examination (VE) 

audio/visual recordings for three of the six containers processed to-date by CCP. From the recordings it 

was not possible to determine that two of the three containers were empty at the start of the original VE 

event. This information is necessary to confirm that prohibited items were not present in the containers 

and therefore, these containers should have been rejected. 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable 

D. Discussed with: Rhett Bradford, Dave Kimbro, Dennis Miehls, Shane Miles 

 

E. Additional Comments: None 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: January 21, 2009 
14

Inspection No. EPA-INL-CCP-CH-VE-T1 Issue Number: INL-CCP-CH-VE-T1-004CR, Final 

Date: December 10, 2008 

Inspector: Dorothy E. Gill 

Attachments? YES NO 

Sample Size: 1 Container 

Population size (if known): 6 Containers 

Description of Issue: Attachment 2 of CCP-TP-113, Section 3, Waste Package Data, for Container No. 

NT070694R included “Gloves, Gaskets” as Waste Material Parameter (WMP) Iron-based metals/alloys. 

Review of the VE recording clearly showed these items to be rubber. The two CCP VE operators 

performing the event did not identify this error nor did the Independent Technical Reviewer (ITR) or the 

Site Project Manager (SPM) identify it. 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable 

D. Discussed with: Rhett Bradford, Dave Kimbro, Dennis Miehls, Shane Miles 

 

E. Additional Comments: None 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: January 21, 2009 
15

Inspection No. EPA-INL-CCP-CH-VE-T1 Issue Number: INL-CCP-CH-VE-T1-005CR, Final 

Date: December 10, 2008 

Inspector: Dorothy E. Gill 

Attachments? YES NO 

Sample Size: 1 Container 

Population size (if known): 6 Containers 

Description of Issue: The VE recording missed recording latex rubber gloves for container No. 

NT070705R where the items were called out more than ten separate times and were clearly identified. 

CCP-TP-113, Attachment 2, Section 3, Waste Package Data does not include these items and is therefore 

incomplete. 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable 

D. Discussed with: Rhett Bradford, Dave Kimbro, Dennis Miehls, Shane Miles 

 

E. Additional Comments: None 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: January 21, 2009 
16

Inspection No. EPA-INL-CCP-CH-VE-T1 Issue Number: INL-CCP-CH-VE-T1-006CR, Final 

Date: December 10, 2008 

Inspector: Dorothy E. Gill 

Attachments? YES NO 

Sample Size: 1 Container 

Population size (if known): 6 Containers 

Description of Issue: The visual examination expert (VEE) performing the original VE event incorrectly 

identified container No.NT070705R as NT070702R twice. These errors were clearly recorded on the 

audio/visual recording but the CCP VE operators either did not recognize or did not record these errors. 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable 

D. Discussed with: Rhett Bradford, Dave Kimbro, Dennis Miehls, Shane Miles 

 

E. Additional Comments: None 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: January 21, 2009 
17

Inspection No. EPA-INL-CCP-CH-VE-T1 Issue Number: INL-CCP-CH-VE-T1-007CR, Final 

Date: December 10, 2008 

Inspector: Dorothy E. Gill 

Attachments? YES NO 

Sample Size: 6 Containers 

Population size (if known): 6 Containers 

Description of Issue: CCP procedure CCP-TP-113, Section 4.3.2, Note, contains the requirement: “Waste 

containers SHALL be closed and have a Tamper Indicating Device (TID)/Lock applied when left 

unattended”. The containers examined during the original VE event were left unattended and were only 

covered by a fire-proof blanket and plastic sheet per NTS procedures. While it is recognized that CCP had 

no control over the original event, secure storage of in-process containers is recognized to be an essential 

element of the process that allows CCP personnel to attest that neither the containers nor their contents are 

tampered with or altered. Because the subject containers were not stored securely, is unclear how CCP VE 

operators can affirm that the containers and their contents have not been altered. 

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable 

D. Discussed with: Rhett Bradford, Dave Kimbro, Dennis Miehls, Shane Miles 

 

E. Additional Comments: None 

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: January 21, 2009 
18

Attachment B

Summary of Interviews with NTS Waste Packaging Personnel 

EPA interviewed selected NTS waste packaging personnel via teleconference. Court Fesmire and 

Patsy Gilbert (CBFO) observed the interviews. A summary of the general information gained 

during the interviews is presented below followed by information obtained from interviews with 

individual NTS waste packaging personnel. 

General information from various sources:

• Approximately 15 SWBs have been rejected by INL-CCP and they will be repackaged to 

remediate the reasons for rejection. 

• This campaign consisted of 49 over-sized boxes (OSB) from Lawrence Livermore 

National Laboratory (LLNL), which were repackaged into SWBs. These were not all 

from the same waste stream. 

• There were 37 55-gallon drums, consisting of waste from LLNL, Lawrence Berkeley 

Laboratory (LBL) and EG&G. Some of this waste was repackaged into new 55-gallon 

containers; the remaining waste was loaded into SWBs. 

• The 55-gallon containers will be subjected to RTR. 

• To date, INL-CCP has only conducted VE on waste from waste stream NTLLNL-S5119, 

listed in CCP-AK-NTS-001, Revision 9. 

• The following are waste streams identified for preparation at NTS: 

NTLLNL-S3900 - approved waste stream, sludge will be subjected to RTR 

NTLLNL-S5400 - approved waste stream, present campaign 

NTLBL-S3900 - LBL, not an approved waste stream 

NTLBL-S5400 - LBL, not an approved waste stream 

NTLRC-S5400 - Lynchburg Research Center, 1 drum, not an approved waste stream 

NTS-EG&G-HET - EG&G, not an approved waste stream 

NTS-TTR-HET - Tonopah Test Range, 1 drum, not an approved waste stream 

• ALVI1

 waste was not accepted by INL-CCP because of insufficient AK. Only ALVI and 

containers rejected by INL-CCP remain to be processed. 

 

1

 ALVI was not defined. 
19

Information listed by NTS Waste Packaging Personnel:

Jon Tanaka, Waste Handler

• Standard waste boxes (SWBs) are stored in a secure area and if they were not empty at 

this stage they would be rejected for use at that time. The secure area is a “quality area” 

with administrative controls such postings lines to ensure only permitted personnel enter 

the area. 

• SWBs are inspected for damage prior to use and filters are installed and this inspection is 

documented. 

• SWB inspection takes place outside of the building used for packaging. 

• After container is moved inside the contamination area the lid is removed and the SWB is 

wrapped in heavy duty plastic. This wrapping is only applied to “free standing” SWBs 

(see below). 

• SWBs are then moved into the high contamination area (HCA) where packaging takes 

place. 

• There are two configurations used for packaging which were designated for ease of 

reference by EPA as “free standing” and “bag out”. 

• The “free standing” SWBs do not have plastic liners. “Bag out” SWBs have a plastic 

liner. 

• There is no specific check for container emptiness but the waste handlers would always 

report this type of situation to a supervisor. 

• There are two cameras in the HCA. These are fixed but the Waste Examination Expert 

(WEE) can change the angle of view and it should be possible to see the bottom of the 

“free standing” containers packaged. 

• “Bag out” containers are loaded through a port and are not physically in the HCA. There 

is no camera available at present to visually demonstrate that these containers are empty. 

• Mr. Tanaka has been qualified since August 24, 20008 when packaging of the waste 

began. 

Sherry Peczka, WEE: 

• An A/V check is performed prior to packaging activities using a bar code permanently 

positioned by the loading port. 
20

• Loading configuration of the SWB is recorded. 

• Main responsibility of WEE is to record the waste items loaded. WEE can communicate 

with all personnel in the HCA. This includes a Radiological Control Technican. 

• Provides direction to Waste Handlers. 

• WMPs are recorded electronically. 

• In process containers are covered with both plastic and a fire blanket. HCA is secured at 

all times. Documented Safety Analysis (DSA) is a DOE requirement which flows down 

to sites. Sites decide what will be implemented, in this case in process containers are 

covered with both plastic and a fire blanket. 

• Ms. Peczka, has been qualified since August 24, 20008 when packaging of the waste 

began. 

Laura Kinstad, Waste Handler:

• Iron workers are present in the HCA and they have experience to distinguish between 

different types of metal. 

• Ms. Kinstad has been qualified since August 24, 20008 when packaging of the waste 

began. 

Mike Mccullough, Waste Operations Manager:

• The packaging area is secure and locked at night and to get into the HCA breathing 

apparatus is required. 

Rick Wagner, Division Manager: 

• Operations began in August and training started before this. Numerous readiness reviews 

were performed prior to the start of packaging.