EPA DOCKET NO. A-98-49; II-A4-143 

 

WASTE CHARACTERIZATION INSPECTION REPORT 

EPA UNANNOUNCED CONTINUED COMPLIANCE INSPECTION 

NO. EPA-AMWTP-CH-UA-10.10.24 OF THE CONTACT-HANDLED 

WASTE CHARACTERIZATION PROGRAM 

AT THE ADVANCED MIXED WASTE TREATMENT PROJECT 

 

November 17-18, 2010 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

March 2011 
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TABLE OF CONTENTS 

Section Page

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

2.0 Purpose of Continued Compliance Evaluations ................................................................. 1

3.0 Purpose of This Report ....................................................................................................... 2

4.0 Scope of the Continued Compliance Inspection ................................................................. 2

5.0 Performance of Continued Compliance Inspection ............................................................ 3

6.0 Technical Waste Characterization Areas ............................................................................ 5

6.1 Acceptable Knowledge and Load Management ..................................................... 5

6.2 Nondestructive Assay ........................................................................................... 18

6.3 Real-Time Radiography ........................................................................................ 21

6.4 Visual Examination ............................................................................................... 22

7.0 Summary of Results and Conclusions .............................................................................. 22

LIST OF TABLES 

Table 1. Continued Compliance Inspection Participants .................................................................4

Table 2. Personnel Contacted During Inspection ............................................................................5

Table 3. Example Traceability of Hanford Drums through the Advanced Mixed Waste 

Treatment Project ............................................................................................................12

Table 4. Predominant Transuranic Radionuclides Expected in Debris Wastes by Generator 

Site ..................................................................................................................................13

Table 5. BN510.1 Waste Material Parameters for Supercompacted Debris Waste .......................14

Table 6. Waste Material Parameter Estimated Percentages for Hanford Waste Streams ..............15

Table 7. Tiering of Transuranic Waste Characterization Processes Implemented by the 

Advanced Mixed Waste Treatment Project ....................................................................24
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ACRONYMS AND ABBREVIATIONS 

AK acceptable knowledge 

AKE Acceptable Knowledge Expert 

AKSR Acceptable Knowledge Summary Report 

Am americium 

AMWTP Advanced Mixed Waste Treatment Project 

BC Battelle Columbus 

BDR batch data report 

BN AMWTP (prefix) 

CBFO Carlsbad Field Office 

CCP Central Characterization Project 

CFR Code of Federal Regulations 

CH contact-handled 

D&D decontamination and decommissioning 

DOE U.S. Department of Energy 

DU depleted uranium 

EA Expert Analyst 

EPA U.S. Environmental Protection Agency 

ES&H Environment, Safety, and Health 

EU enriched uranium 

FGE fissile gram equivalent 

FR Federal Register 

HLW high-level waste 

HS heat source 

IDC Item Description Code 

INL Idaho National Laboratory 

ITR Independent Technical Reviewer 

IWAS Integrated Waste Assay System 

LWA Land Withdrawal Act 

MD Mound 
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nCi/g nanocuries per gram 

NCR nonconformance report 

NDA nondestructive assay 

NWPA Nuclear Waste Policy Act of 1982 

PFP Plutonium Finishing Plant 

PK process knowledge 

PPE personal protective equipment 

Pu plutonium 

RCRA Resource Conservation and Recovery Act 

RF Rocky Flats

RFETS Rocky Flats Environmental Technology Site

RL Hanford

RTR real-time radiography 

SDOP six-drum overpack 

SHENC Super High Efficiency Neutron Counter 

SNF spent nuclear fuel 

SPM Site Project Manager 

T1 Tier 1 

T2 Tier 2 

TBD to be determined 

Th thorium 

TRU transuranic 

U uranium 

VE visual examination 

WAC Waste Acceptance Criteria 

WG weapons-grade 

WIPP Waste Isolation Pilot Plant 

WMC waste matrix code 

WMP waste material parameter 

WSPF waste stream profile form 

WTS Waste Tracking System 
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1.0 EXECUTIVE SUMMARY 

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

Agency) conducted unannounced continued compliance Inspection No. EPA-AMWTP-CH-UA10.10.24 of the waste characterization program for contact-handled (CH) transuranic (TRU) 

wastes at the U.S. Department of Energy (DOE) Advanced Mixed Waste Treatment Project 

(AMWTP). This on-site inspection occurred at the AMWTP1 on November 17–18, 2010, and 

covered selected aspects of AMWTP’s approved TRU waste characterization processes. 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 an unannounced continued 

compliance inspection of the site’s program to characterize wastes proposed for disposal at the 

Waste Isolation Pilot Plant (WIPP). Following the inspection, while reviewing AMWTP 

provided documents, EPA inspectors identified one issue requiring December 6, 2010 

discussion. AMWTP had used Acceptable Knowledge (AK) information prepared by the 

Hanford Central Characterization Project which EPA had not approved. For this Hanford waste, 

AMWTP should have used AK generated under the old Hanford program that EPA approved in 

August 2008 (EPA Docket No. A-98-49; II-A4, 106). AMWTP revised relevant AK reports 

which EPA received in February. As a result of this unannounced continued compliance 

inspection, EPA confirmed that the AMWTP CH TRU waste characterization program continues 

to maintain its approval to characterize CH TRU waste consistent with the conditions and 

limitations that are discussed in the baseline inspection report (see EPA Docket No. A-98-49; 

IIA4-66). There were no changes to the Tier 1 (T1) or Tier 2 (T2) designations indicated in the 

initial AMWTP approval table as a result of this unannounced continued compliance inspection. 

The approval table has been updated to reflect format changes and the revised AMWTP approval 

table is provided as Table 7 of this report. 

During this inspection, the Agency evaluated samples of the following waste characterization 

activities used to characterize CH TRU debris waste from Hanford:2

• Acceptable knowledge (AK) 

• Nondestructive assay (NDA) 

• Real-time radiography (RTR) for CH retrievably stored TRU debris waste (S5000) 

• Visual examination (VE) for newly generated TRU waste 

2.0 PURPOSE OF CONTINUED COMPLIANCE EVALUATIONS 

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

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

continues to use only the approved waste characterization processes to characterize the waste and 

remains in compliance with all the regulatory requirements. This inspection was performed for 

 1

 The AMWTP is located on DOE’s Idaho National Laboratory (INL) outside of Idaho Falls, Idaho. 

2

 Hanford is sending approximately 800 55-gallon drums of debris waste belonging to four waste streams that 

were characterized by Hanford prior to termination of the non-CCP Hanford waste characterization program in 

2008. 
2 

the purpose of determining AMWTP waste characterization program compliance with 

40 CFR 194.24. 

3.0 PURPOSE OF THIS REPORT 

This report documents the basis for EPA’s decision to maintain the approval of the AMWTP 

waste characterization program for CH TRU wastes. Specifically, this report does the following: 

• Describes the sample of the AMWTP waste characterization systems evaluated during 

this inspection 

• Identifies all areas where waste characterization systems have changed relative to the 

baseline approval configuration and assesses the impact, if any, of those changes 

• Provides objective evidence to support the EPA continued approval basis for all waste 

characterization systems 

• Provides objective evidence of outstanding findings or concerns, as applicable 

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

their relevance to EPA’s approval decision 

Sections of 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, write to the 

following address: 

Quality Assurance Manager 

USDOE/Carlsbad Area Field Office 

P.O. Box 3090 

Carlsbad, NM 88221 

EPA’s continued approval of the AMWTP waste characterization program will be conveyed to 

DOE separately by letter. More information is also on EPA’s website at 

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

4.0 SCOPE OF THE CONTINUED COMPLIANCE INSPECTION 

The scope of EPA’s unannounced continued compliance Inspection No. EPA-AMWTP-CH-UA10.10.24 was the evaluation of selected elements of the waste characterization systems in use at 

AMWTP to characterize TRU wastes that had been approved during the baseline inspection. 

Specifically, the EPA inspection team focused on the following: 

• AK: AMWTP components implemented to characterize Hanford TRU BN510.1 waste, 

including AK Summary Reports (AKSRs); Waste Stream Profile Forms (WSPFs) for 

both the BN510.1 waste stream and the BN510 waste stream, the latter of which has been 

emplaced in the WIPP since October 1, 2009; Batch Data Reports (BDRs) for NDA, VE 

and RTR; traceability of containers through the entire characterization process; and 
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tracking of EPA-selected Hanford containers from receipt at AMWTP through 

certification and/or emplacement in the WIPP 

• NDA: Direct observation of the two Z-211-102 and Z-211-103 Integrated Waste Assay 

System (IWAS) NDA units in Building WMF-634 and evaluation of the two in-plant 

Z-390-100 and Z-390-101 IWAS NDA units in Building 639 by evaluation of NDA 

BDRs provided in October 2010 

• VE/RTR training through interviews of personnel, review of training records, and 

examination of training materials; audio/video tapes recording physical contents of 

selected repackaged containers included in the provided VE/RTR BDRs. 

5.0 PERFORMANCE OF CONTINUED COMPLIANCE INSPECTION 

Background

In preparation for a scheduled inspection, the EPA technical inspectors typically obtain and 

review the latest revisions of key procedures and reports in the preparation of inspection 

checklists. For an unannounced inspection, EPA technical inspectors prepare using what they 

know to be the latest revisions of these documents. However, these documents may have been 

revised or superceded without EPA’s knowledge. This requires that the EPA inspection team 

modify or adjust the inspection’s scope on short notice while onsite. For this inspection, the 

revisions of the relevant documents for AK, NDA, RTR, and VE that the EPA inspection team 

used to prepare were sufficient to obtain a general understanding of the processes, although 

many AK documents had been updated without provision to EPA, and other AK documents 

required changes subsequent to the inspection. AMWTP also provided revisions of some 

documents during the inspection. 

Logistics

The logistics of an unannounced inspection are different from a scheduled inspection. Because 

site personnel do not know an inspection will be occurring on a given day, certain aspects of the 

site’s waste characterization program or key personnel may not be available for evaluation. For 

this inspection, key personnel in the areas of AK, NDA, RTR, and VE were available. 

EPA’s unannounced Inspection No. AMWTP-CH-UA-10.10.24 took place November 17–18, 

2010. EPA reviewed additional documents that were provided after the inspection to complete its 

evaluation of several of the technical areas within the inspection’s scope. The inspection 

involved the following steps: 

(1) Reviewing the waste characterization processes that were approved under EPA’s baseline 

inspection; 

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

to waste characterization activities at AMWTP in advance of the inspection; and 

(3) Examining draft checklists specific to each technical area before the inspection. 
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As part of this unannounced inspection, EPA inspectors did the following: 

(1) Interacted with Carlsbad Field Office (CBFO) and AMWTP personnel to arrange 

inspection logistics; 

(2) Verified onsite the technical adequacy or qualifications of waste characterization 

personnel, procedures, processes, and equipment by means of interviews, observation, 

and demonstrations, and recorded the results, as appropriate; 

(3) Recorded all concerns on EPA Inspection Issue Tracking Forms, as appropriate, and 

provided completed forms to CBFO and site personnel as they were generated; 

(4) Communicated all pertinent information to CBFO and AMWTP personnel onsite, as 

appropriate; 

(5) Pursued resolution of all identified issues before completion of the inspection by 

discussions with CBFO and AMWTP personnel; 

(6) Conducted entrance, exit, and daily briefings for CBFO and AMWTP management 

personnel, as appropriate; and 

(7) Reviewed additional information provided by AMWTP after the inspection, and 

achieved resolution of outstanding issues with AMWTP and CBFO. 

The evaluation consisted of interviewing personnel, observing equipment operations that follow 

site procedures, and inspecting records related to each of the waste characterization processes 

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

documenting the effectiveness of the waste characterization processes. Objective evidence 

typically takes the form of BDRs, radioassay data sheets, AKSRs and related documents, AK 

accuracy reports, and RTR tapes. During this inspection, EPA selected samples of each of these 

items, based on the number and variety of items each waste characterization process produced, 

consistent with standard inspection techniques. Based on the evaluation of the waste 

characterization processes in conjunction with the sample of objective evidence, EPA determined 

the technical adequacy of the waste characterization processes within the inspection’s scope. The 

EPA inspection team consisted of the personnel shown in Table 1. 

Table 1. Continued Compliance Inspection Participants

Name Affiliation, Area of Expertise 

Rajani Joglekar EPA Headquarters, Lead Inspector 

Ed Feltcorn EPA Headquarters, Inspector 

Lindsey Bender EPA Headquarters, Inspector 

Kathy Economy EPA Headquarters, Observer 

Connie Walker SC&A, AK Technical Evaluator 

Patrick Kelly SC&A, NDA Technical Evaluator 

Dorothy Gill SC&A, RTR & VE Technical Evaluator 

Kira Darlow SC&A, AK Observer 

Rose Gogliotti SC&A, NDA Technical Evaluator-In-Training 
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The EPA inspection team interviewed and obtained information and/or inspection support from a 

number of AMWTP, CBFO, and DOE personnel listed in Table 2. 

Table 2. Personnel Contacted During Inspection 

Personnel Affiliation Area of Expertise/Function 

Courtland Fesmire DOE-CBFO Observer 

Lisa Frost CWI 

Eric Schweinsberg AMWTP SPM 

James Seamens AMWTP NDA, EA, AKE 

Tom Johnson CWI-CH TRU STR 

Gina Tedford BNWI-AMWTP SPM, AKE 

Barbara Broomfield WTS-CCP 

Bill Vercanic WTS-CCP 

Steve Carpenter AMWTP SPM, AKE 

Randy Morris AMWTP AKE 

Rachelle Hubler AMWTP AKE 

6.0 TECHNICAL WASTE CHARACTERIZATION AREAS 

Sections 6.1 through 6.4 of this report detail the four technical areas assessed during this 

inspection—Acceptable Knowledge (AK), Non-Destructive Assay (NDA), Real-Time 

Radiography (RTR), and Visual Examination (VE). 

6.1 Acceptable Knowledge and Load Management 

Background

EPA examined the AK process and associated information to determine whether AMWTP 

remained in compliance with 40 CFR 194.8 requirements for CH newly generated soil, debris, 

and solid waste present in the Subsurface Disposal Area. AMWTP is also approved for 

retrievably-stored debris and solid waste originating from AMWTP, but these categories were 

not evaluated during EPA’s unannounced continued compliance inspection. 

The BN510 waste stream was a newly generated S5000 waste stream composed of waste that 

originated from Mound (MD), Rocky Flats Environmental Technology Site (RFETS), Battelle 

Columbus (BC), and Bettis Atomic Power Laboratory (Bettis). The waste stream is managed in 

the AMWTP facility. EPA’s baseline approval of the AMWTP stated that addition of any waste 

streams to BN510 outside of those already included in the waste stream (i.e., Mound, RFETS, 

Battelle Columbus, and Bettis) is a T1 change requiring EPA’s approval prior to implementation. 

This requirement is documented in EPA’s baseline approval (Docket No: A-98-49, II-A4-66, 

September 2006) and in Table 7 of this report. 

CBFO requested the addition of four Hanford waste streams to BN510 in March 2010 on behalf 

of AMWTP. At that time, Hanford’s original certified program was no longer in place and DOE 
6 

contracted the Central Characterization Project (CCP) to characterize and ship Hanford wastes to 

AMWTP for characterization and ultimate emplacement in WIPP. Prior to termination of their 

program, Hanford shipped several thousand drums from three of the four proposed waste streams 

to WIPP under Hanford’s original WIPP waste characterization program. CBFO approved the 

remaining waste stream (RLMPFPCD), but Hanford did not ship it to WIPP because an 

approved WSPF was not issued, although the AKSR had been approved. Below is a description 

of these four waste streams discussed in the Hanford AKSR (RPT-TRUW-82, Revision 2A). 

• Waste Stream RLM231ZD.001: Hanford 231 Z Building Waste. This waste stream is 

composed of 66 containers of CH debris [S5400 Waste Matrix Code (WMC)] packaged 

in 55-gallon drums that were emplaced in 85-gallon overpacks. Waste Stream 

RLM231ZD.001 was generated by the 231-Z metallurgical research and plutonium 

fabrication, decontamination and decommissioning (D&D), technology development, and 

facility cleanout activities. 

• Waste Stream RLM325D.001: Hanford 325 Building Radiochemical Processing 

Laboratory Waste. This waste stream is composed of CH debris (S5400 WMC) in 

55-gallon drums that were placed in 85-gallon overpacks. Waste Stream RLM325D.001 

consists of debris waste generated at the 325 Building Radiochemical Processing 

Laboratory and includes 220 containers with generation dates from September 28, 1972, 

through February 12, 1990. 

• Waste Stream MPFPD: Mixed Plutonium Finishing Plant Debris. This waste stream 

consists of mixed TRU debris waste (S5490 WMC) generated between 1970 and the 

present in support of plutonium metal production operations and glove box activities 

(e.g., maintenance, clean out, decontamination, decommissioning, stabilization) 

associated with the Plutonium Finishing Plant (PFP) Complex. 

• Waste Stream RLMPFPCD: The Richland Mixed PFP Comprehensive Debris 

Waste Stream. The RLMPFPCD waste stream is a mixed, heterogeneous debris waste 

stream (S5400 WMC) generated from 1970 through the present in support of PFP’s 

plutonium production and stabilization activities. It is composed of a variety of inorganic, 

organic and other debris including both process and D&D waste. All of the facilities 

included in the MPFPD waste stream are included in Waste Stream RLMPFPCD, which 

includes the Building 242-Z-Waste Treatment Facility, 291-Z-Ventilation/Exhaust Air 

Stack Building, and PFP Ancillary Facilities. 

EPA reviewed information pertaining to the Hanford waste streams proposed for shipment, and 

approved shipment of the waste streams to AMWTP in June 2010 (see EPA Air Docket No. 

A-98-49, II-A4-127). Hanford-CCP began shipping drums to AMWTP during September 2010. 

EPA’s June 2010 approval stated that AMWTP must provide specific documentation for EPA’s 

review to verify that the Hanford debris was adequately characterized by AMWTP for inclusion 

in the BN510 waste stream. During the unannounced continued compliance inspection, EPA 

evaluated this required documentation, including: 
7 

• Revised AK documentation for the BN510.1 waste stream showing how Hanford AK and 

other documentation have been incorporated 

• The revised WSPF for AMWTP’s BN510.1 waste stream to include Hanford waste 

• BDRs from VE for physical contents and NDA for radiological contents of the BN510.1 

waste stream debris 

• Evidence tracing Hanford debris waste in AMWTP’s waste tracking system. 

As required by the WIPP Resource Conservation and Recovery Act (RCRA) permit, AMWTP 

integrated the Hanford waste streams, retired the BN510 waste stream, and created Waste Stream 

BN510.1. This waste stream includes all previous waste streams that feed into BN510, as well as 

the new waste streams from the Hanford site. 

Technical Evaluation 

EPA’s previous AMWTP T1 approval (EPA Docket No. A-98-49, II-A4-127) addressed whether 

sufficient data were available to demonstrate that the waste being shipped from Hanford fits the 

acceptable envelope for the BN510.1 waste stream. The scope of this unannounced, continued 

compliance inspection included evaluating whether AMWTP has sufficiently implemented the 

characterization process with respect to these new waste streams, including incorporation, 

interpretation, and integration of AK and RTR/VE/NDA characterization. 

In September 2010, Hanford-CCP (on behalf of DOE) initiated shipment of several hundred 

previously characterized and certified drums from Waste Streams RLM325D.001, 

RLM231ZD.001 MPFPD, and RLMPFPCD to AMWTP. These wastes will be repackaged, 

characterized, supercompacted, and shipped to WIPP as part of the BN510.1 waste stream. EPA 

examined the technical elements listed in this section for each of the waste streams to determine 

whether the information was adequately integrated into the waste stream and related 

documentation, i.e., the AMWTP “envelope.” These technical elements include those presented 

in EPA’s June 2010 approval letter. Additionally, the new BN510.1 waste stream was evaluated 

to determine whether it was adequately defined, including radiological and physical composition. 

Key limitations, as specified in the Land Withdrawal Act (LWA), were also evaluated. 

(1) Acceptable knowledge documentation associated with the BN510.1 waste stream was 

evaluated to determine the adequacy of the Advanced Mixed Waste Treatment Project’s 

Hanford waste stream document review and integration and was found to be adequate. 

EPA examined references as part of this inspection, including the following: 

• RPT-TRUW-03, Drum Assay Technical Review Report, Advanced Mixed Waste Treatment 

Project, Revision 7, December 7, 2006

• RPT-TRUW-06, AMWTP Baseline AK for Newly-Generated Waste, Advanced Mixed 

Waste Treatment Project, Revision 12, August 16, 2010 
8 

• RPT-TRUW-07, Determination of Radioisotopic Content in TRU Waste Based on 

Acceptable Knowledge, Advanced Mixed Waste Treatment Project, Revision 16, August 12, 

2010 

• RPT-TRUW-12, AMWTP Waste Stream Designations, Advanced Mixed Waste Treatment 

Project, Revision 15, November 3, 2010 

• RPT-TRUW-30, Acceptable Knowledge Summary for Supercompacted Debris Waste 

(BN510), Advanced Mixed Waste Treatment Project, Revision 6, September 11, 2008 

• RPT-TRUW-82, Acceptable Knowledge Document for Hanford Debris Waste Shipped to 

AMWTP, Advanced Mixed Waste Treatment Project, Revision 1, June 21, 2010 

• RPT-TRUW-82, Acceptable Knowledge Document for Hanford Debris Waste Shipped to 

AMWTP, Advanced Mixed Waste Treatment Project, Revision 2A, date to be determined 

(TBD) 

• RPT-TRUW-83, Acceptable Knowledge Summary for Supercompacted Debris Waste 

(BN510.1), Advanced Mixed Waste Treatment Project, Revision 0, September 10, 2010 

• RPT-TRUW-83, Acceptable Knowledge Summary for Supercompacted Debris Waste 

(BN510.1), Advanced Mixed Waste Treatment Project, Revision 1A, date TBD 

• P853A, Revision 1, CCP-PK-RL-101, Revision 2, Central Characterization Project Process 

Knowledge Summary Report For Hanford Plutonium Finishing Plant Contact-Handled 

Transuranic Debris Waste, 85-Gallon Overpacked Drums, Waste Stream: MPFPDD, Larry 

Porter, Central Characterization Project (CCP), June 4, 2010

• P854A, Revision 1, CCP-PK-RL-102, Revision 2, Central Characterization Project Process 

Knowledge Summary Report For The Hanford 325 Building Radiochemical Processing 

Laboratory Contact-Handled Transuranic Debris Waste, 85-Gallon Overpacked Drums, 

Waste Stream: RLM325D.001, Larry Porter, Central Characterization Project (CCP), June 4, 

2010

• P855A, Revision 1, CCP-PK-RL-103, Revision 2, Central Characterization Project Process 

Knowledge Summary Report For Hanford 231-Z Building Contact-Handled Transuranic 

Debris Waste, 85-Gallon Overpacked Drums, Waste Stream: RLM231ZD.001, Larry Porter, 

Central Characterization Project (CCP), June 4, 2010

• HNF-36515 Hanford Mixed PFP Comprehensive Debris (RLMPFPCD), Revision 0, revised 

document will have new title, date and “P” reference number

• HNF-6489, Revision 1, Hanford Mixed PFP Debris Waste Stream (MPFPD), revised 

document will have new title, date and “P” reference number. 

To understand the interrelationships of these documents, one must understand the history of the 

Hanford waste streams accepted at the AMWTP and the characterization program approval 

process. EPA evaluated the information and concluded as follows. 

AMWTP used Hanford-CCP process knowledge (PK) reports for debris Waste Streams 

MPFPDD, RLM231ZS.001 and RLM325D.001 to compile a new Hanford AKSR 

(RPT-TRUW-82, Revision 1). Information from RPT-TRUW-82, Revision 1 was then used to 
9 

generate a new, broader AKSR (RPT-TRUW-83, Revision 0) for the Hanford BN510.1 waste 

stream. Hanford-CCP’s MPFPDD waste stream is similar to Waste Streams RLMPFPCD and 

MPFPD from the original Hanford program. EPA concluded that AMWTP’s use of HanfordCCP’s PK documents for the three waste streams was inappropriate, since at the time of the 

unannounced inspection, EPA had not approved Hanford-CCP’s baseline program. EPA also 

concluded that AMWTP had not integrated AK information generated by Hanford, who had 

characterized these drums for WIPP disposal prior to termination of the Hanford program. 

During a conference call with EPA, AMWTP, Hanford-CCP, and CBFO on December 6, 2010, 

EPA informed the participants that AMWTP should have used AK documents for the subject 

waste streams that were prepared under the old Hanford program and asked that AMWTP revise 

relevant documents. 

AMWTP acknowledged EPA’s decision and agreed that the Hanford and BN510.1 AKSRs 

required revision. AMWTP then submitted Revision 2A of RPT-TRUW-82 that modified the 

document to include the Hanford-approved AKSRs, rather than the Hanford-CCP PK reports. 

EPA found that the AMWTP RPT-TRUW reports were adequately modified to include 

information about the four Hanford waste streams, and the modifications were based on data 

presented in the Hanford-approved AKSRs. EPA finds the revision to be acceptable. 

The AKSR for the Hanford waste streams (RPT-TRUW-82, Revision 2A) was created simply by 

combining the Hanford-approved AKSRs for the four waste streams (RLM231ZA.001, 

RLM325D.001, MPFPD, and RLMPFPCD) and adding a title page to the merged document. 

AMWTP representatives indicated that this information was accepted “as is,” with little review 

of associated references or the AKSRs. The AKSRs for the Hanford waste stream were 

generated under EPA-approved programs. In the future, EPA expects any AKSR to be based on 

AK generated through an EPA-approved program and that source documents used to generate 

AKSRs are available in the AMWTP record. AMWTP representatives provided a cross-reference 

that showed that the source documents were in the AMWTP record. 

(2) The revised waste stream profile form for the Advanced Mixed Waste Treatment Project 

BN510.1 waste stream was reviewed and found to be adequate. 

The WSPF for BN510 was retired and a new WSPF was generated for the BN510.1 waste 

stream. The WSPF for the new waste stream is dated September 10, 2010, and AMWTP 

representatives indicated that this profile had not been modified since its latest approval. 

Contents of the WSPF were compared to the requirements in AMWTP Form 1900, Revision 1, 

and the WSPF was found to be complete with respect to required contents. 

(3) Data tracking and data traceability of Hanford waste in the Advanced Mixed Waste 

Treatment Project system, including traceability of batch data reports, was examined and 

found to be adequate. 

AMWTP uses the AMWTP Waste Tracking System (WTS) to track information pertaining to 

incoming drums from offsite sources, including the Hanford drums. Figure 1 presents the data 

flow and characterization process associated with Hanford drums. As shown in this chart, drums 

from Hanford arrive and are assigned an AMWTP drum number; drums then undergo screening 
10 

NDA and RTR (i.e., “fast scan”) to evaluate their acceptability according to the INL waste 

acceptance criteria. If a drum is acceptable, it is combined with others into a six-drum overpack 

(SDOP). The SDOP is then shredded, and the shredded SDOP is loaded into 55-gallon drums 

called “silvers.” VE is performed on a “silver” at the time of drum loading and is followed by 

NDA, after which it is supercompacted or “pucked.”3 The pucks are placed in a 100-gallon drum 

which may be sent to the INL-CCP Super High Efficiency Neutron Counter (SHENC) for 

additional assay if data suggest the drum’s TRU alpha activity may be less than 100 nanocuries 

per gram (nCi/g). Table 3 presents examples of drums sent from Hanford as they went through 

the AMWTP process described above (the table progresses from left to right). The table does not 

include all of the “silvers” generated from the specified SDOP, but includes examples to 

demonstrate traceability of the process. Table 3 and Figure 1 indicate that data are traceable from 

the original Hanford drums through the final 100-gallon product drum. Per agreements with the 

State of Idaho, any drum from Hanford must undergo characterization within six months of 

receipt at AMWTP, and must be removed from Idaho within six months of characterization. The 

first Hanford drums arrived at AMWTP in September 2010. 

(4) The integration of Hanford waste into the BN510.1 waste stream with respect to waste 

stream definition was evaluated and found to be adequate. 

The BN510.1 newly generated debris waste stream is produced from supercompaction of 

55-gallon containers of debris waste. The supercompacted debris consists of material with 

similar chemical matrices, physical form, and hazardous constituents and is a single waste 

stream. 

The original AMWTP BN510 feedstock debris was generated during plutonium pit production; 

depleted uranium component fabrication; enriched uranium processing; support operations 

including: recovery, treatment, maintenance, laboratory analysis, and machining of non-nuclear 

weapon components; research and development; special order work; fabrication of plutonium238 (238Pu) heat sources and manufacture of radioisotopic thermoelectric generators; D&D 

activities; and materials development. Waste streams generated at Hanford, as described above in 

the AK Background section and in RPT-TRUW-83, Revision 1A, fit the general feedstock 

descriptions expected at the AMWTP facility. It should be noted that all feedstock debris is 

commingled during unpackaging/shredding, sorting, and supercompaction, with the resulting 

WMC being S5490, “Unknown or Other Heterogeneous Debris.” See Item (1) for requirements 

pertaining to integration of data into documents, and Items (5) and (6) for information about the 

radiological and physical composition of the waste stream and Hanford feedstock. 

 3 Pucks are 55-gallon drums of TRU waste that have been compacted into smaller disks by crushing; the pucks

are then over-packed in 100-gallon drums, which are referred to as pucked drums. 
11 

za 

Figure 1. Hanford Drum Process Flow through the Advanced Mixed Waste Treatment Project 

Hanford Drum Arrives at AMWTP Assign AMWTP Drum No. 

Determine Appropriate SDOP 

Combinations

Assign Drums to SDOP and 

Generate SDOP filled with 

multiple Hanford drums 

Send SDOP through Boxline 

Load silvers from Boxline and 

Perform VE while loading 

NDA each silver 

Supercompact to generate pucks 

Assemble Pucks into 100-gallon Product 

Drum undergoes “quick scan” 

characterization for INL Waste 

Acceptance: 

- NDA 

- RTR 

- FGE determination 

- IDC evaluation 

Acceptable? Back to Generator 

No 

Yes 

Yes Sum of silver assay becomes assay 

of record; 

WIPP eligible 

Sent to SHENC and SHENC becomes 

measurement of record for WIPP – 

ship to WIPP if >100 nCi/g 

No Questionable Assay 

TRU α <100 nCi/g?
12 

Table 3. Example Traceability of Hanford Drums through the Advanced Mixed Waste Treatme

Hanford Drum 

Number/Waste 

Stream 

Fast Scan 

NDA BDR 

Fast Scan 

RTR BDR 

AMWTP 

Drum 

Number SDOP 

Silver number -

No association 

with original 

AMWTP or 

Hanford Drum 

Number* 

VE BDR 

(generated 

during 

loading of 

silver) 

NDA BDR 

(generated by 

NDA of silver 

prior to 

pucking) 

Pr

n

gall

0026719/MPFPDD ASY10-

01501 

RTR10-00152 10373072 10378197 10379920 VEB10-

00914 

ASY10-01912 B

0030006/RLM325D ASY10-

01503 

RTR10-00140 10369476 10378197 10379915 VEB10-

00914 

ASY10-01912 B

0030209/RLM325D ASY10-

01474 

RTR10-00140 10369559 10378197 10379905 VEB10-

00914 

ASY10-01912 B

0037465/RLM231ZD ASY10-

01474 

RTR10-00140 10369566 10378197 10379919 VEB10-

00914 

ASY10-01911 B

0044257/MPFPDD ASY10-

01502 

RTR10-00141 10373041 10378197 10379917 VEB10-

00914 

ASY10-01911 B

0044837/MPFPDD ASY10-

01501 

RTR10-00142 10373073 10378197 10379950 VEB10-

00915 

ASY10-01916 B

* A total of 13 “silvers” were generated from shredding of SDOP10378197; only six are shown in this table. 
13 

(5) Acceptable knowledge information pertaining to the radiological characteristics of 

transuranic wastes was examined with respect to the BN510.1 envelope and found to be 

adequate. 

 

The radionuclides of concern for BN510 were: 238Pu, 239Pu, 240Pu, 242Pu, uranium-233 (233U), 

234U, 238U, and americium-241 (241Am). AMWTP indicated that they did not expect the feedstock 

waste to contain measurable quantities of the remaining WIPP-tracked radionuclides, 

cesium-137 and strontium-90. Additional radionuclides which may be present in feedstock 

debris, as indicated the BN510 AKSR, were 241Pu, thorium-228 (228Th), 231Th, 232Th, 234Th, 235U, 

236U, curium-244, and neptunium-237. The two most prevalent radionuclides by activity 

expected in the majority of BN510 AMWTP supercompacted debris product drums are 239Pu and 

240Pu, while the most prevalent radionuclides by activity will likely always include 239Pu and a 

different second TRU or U radionuclide due to waste commingling. Addition of the Hanford 

waste streams in BN510.1 did not significantly modify the general discussion in the AKSR 

pertaining to the radionuclides of concern or the expected radionuclides. Table 4 presents the two 

most prevalent radionuclides by feedstock as identified in the AKSR (RPT-TRUW-83, 

Revision 1A) for the BN510 waste stream. A combination of any two of the common 

radionuclides identified may be detected as the most prevalent in waste containers that have 

multiple generators and a mixture of weapons-grade (WG) and heat source (HS) Pu, enriched 

uranium (EU), and depleted uranium (DU). 

Table 4. Predominant Transuranic Radionuclides Expected in Debris Wastes 

by Generator Site 

Generator Site Principal Pu Type Predominant TRU Radionuclides 

RF WG 239Pu, 240Pu 

RF WG/DU/EU 239Pu (235U or 238U)a

MD WG 239Pu, 240Pu 

MD HS 238Pu, 239Pu 

BC WG 239Pu, 240Pu 

RL Combination WG/Fuel-grade Pu 239Pu (241Pu or 241Am) 

BN RFETS waste 239Pu, 240Pu 

BN Combination WG/HS 238Pu, 239Pu 

BN Combination WG/HS & U 239Pu (240 Pu, 238Pu, 241Am, 235U or 238U)a

a

 When waste contains DU or EU, and WG Pu, the prevalent radionuclides will include U. 

EPA examined the information above against data presented in RPT-TRUW-82, Revision 2A, to 

determine whether the Hanford waste streams were adequately represented in the BN510.1 

AKSR. This review indicated that 240Pu, 241Pu, 241Am, and 238U are expected, and 238U may be a 

predominant radionuclide based on mass. 

EPA also interviewed Mr. Randy Morris, AMWTP Acceptable Knowledge Expert (AKE), to 

understand how AK data from each of the AKSRs were reviewed and integrated into the 

BN510.1 waste stream. He stated that historic AK container data, previously approved Hanford 

AKSRs and representative source documents were reviewed to ensure that the radiological 

compositions of accepted containers were well understood. Mr. Morris also stated that the 

predominant radionuclide AK information from each AKSR was evaluated and incorporated in 
14 

the BN510.1 AKSR “as is.” EPA’s comparison of the BN510.1 report and individual AKSRs 

showed that Mr. Morris’ approach was followed and is acceptable. EPA also interviewed 

Mr. Jim Seamens to better understand the use of AK by NDA Expert Analysts (EAs). 

Mr. Seamens stated that default isotopics are used when the NDA isotopic determinations are 

inconclusive, as necessary. Mr. Seamens stated that he reviewed NDA data provided by Hanford 

and data obtained through site screening to determine whether drums from the four waste 

streams are acceptable and were “assayable” by the AMWTP system. All but six drums were 

found to be acceptable. In instances where default isotopics were used, Mr. Seamens indicated 

these were developed on a case-by-case basis, using available AK information. EPA found that 

AMWTP had adequately considered the radiological composition of the Hanford waste streams 

and adequately integrated that information into the BN510.1 AKSR. 

(6) Identification of physical form including waste material parameters and prohibited items 

was assessed with respect to the BN510.1 envelope and found to be adequate. 

The BN510 waste stream was composed of supercompacted debris waste that included 

combustibles (e.g., rags, gloves, wipes); personal protective equipment (PPE); plastic and rubber 

items; filters; leaded gloves, aprons, bricks and sheeting; metal with and without lead or 

cadmium; glass; wood; inorganic debris; Plexiglas®; Benelex®; pieces of equipment; small 

amounts of process residue and graphite; asphalt, concrete, dirt and sand; and noncombustible 

solids packaged in 55-gallon drums, supercompacted, and packaged into 100-gallon product 

drums. AMWTP estimated the waste material parameter (WMP) weight percentages for BN510 

using WMP data from 100% of the completed RTR and VE of supercompacted debris waste 

drums as obtained from the AMWTP WTS database as of October 11, 2006. The AKSR states 

that this represents 19% of the AMWTP-estimated number of drums for this waste stream and 

100% of characterized waste stream containers. 

AMWTP updated this understanding of physical composition in the BN510.1 report by 

examining information from the WIPP Data System/WIPP Waste Information System RTR and 

VE data for 22,399 Hanford containers shipped to WIPP between 2005 and 2009. The estimated 

WMPs are representative of the BN510.1 waste stream and are summarized in Table 5. 

Table 5. BN510.1 Waste Material Parameters for Supercompacted Debris Waste 

Waste Material Parameters Estimated 

WMP Weight Percent 

Iron-based Metals/Alloys 52 

Aluminum-based Metals/Alloys <1 

Other Metals <1 

Other Inorganic Materials 3 

Cellulosics 22 

Rubber 1 

Plastics (waste materials) 22 

Organic Material <1 

Soils/Gravel <1 

Inorganic Matrix <1 
15 

The AKSR for BN510.1 was not updated to specifically include the anticipated physical 

composition of the Hanford waste. Instead, the waste stream was modified to reflect data 

acquired through ongoing VE of the BN510 waste stream in 2009. Therefore, the physical 

composition of each of the four Hanford waste streams was examined to determine whether the 

composition would “fit” the general BN510.1 envelope. RPT-TRUW-82, Revision 2A provides 

WMP distributions by weight percent for each of the four waste streams, as listed in Table 6. 

Table 6. Waste Material Parameter Estimated Percentages for Hanford Waste Streams 

WMPs WMP Weight/Unit Waste (Anticipated Weight Percent Range) 

RLMPFPCD MPFPD RLM325ZD.001 RLM231ZD.001 

Iron-based Metals/Alloys 40 (0-83) 48 (0-100) 40.91 (0 - 96.58) 74 (1-98) 

Aluminum-based 

Metals/Alloys <1 (0-100) <1 (0-83) 0.08 (0 - 6.54) <1 (0-1) 

Other Metals 1 (0-70) 5 (0-87) 1.83 (0 - 56.73) <1 (0-10) 

Other Inorganic Materials 11 (0-85) 8 (0-100) 26.21 (0 - 90.67) 3 (0-38) 

Cellulosics 15 (0-73) 12 (0-92) 9.13 (0 - 87.58) 10 (0-86) 

Rubber 8 (0-49) 9 (0-91) 3.76 (0 - 59.64) 2 (0-19) 

Plastics (waste materials) 25 (0-67) 18 (0-100) 18.10 (2.74 - 98.16) 11 (2-58) 

Organic Material <1 (0-49) <1 Not reported Not reported 

Soils/Gravel <1 (0-49) <1 Not reported Not reported 

Inorganic Matrix <1(0-49) <1 Not reported Not reported 

The Hanford MPFPD AKSR did not provide estimated percentages; those presented were included in reference 

P853A. 

These data suggest that the anticipated weight percent range for each waste stream encompasses 

the previously identified WMP percentages. Regardless of individual WMP percentage, the 

overall organic and inorganic percentages of the Hanford waste streams compare favorably with 

the anticipated WMPs. 

Liquid is a prohibited item that is related to EPA compliance. Feedstock debris containers that 

are identified as containing prohibited items during RTR or VE are treated or rejected, as 

appropriate. 

(7) Defense status of the new waste streams incorporated into BN510.1 was evaluated and 

found to be adequate. 

DOE-WIPP-3122 (the WIPP waste acceptance criteria or WAC) requires generator sites to use 

AK to determine if a WIPP-bound TRU waste stream meets the definition of defense waste. 

Based on DOE guidance, a TRU waste is eligible for disposal at WIPP if it has been generated in 

whole or in part by one of the atomic energy defense activities listed in Section 10101(3) of the 

Nuclear Waste Policy Act of 1982 (NWPA). All feedstock to the BN510.1 waste stream (Rocky 

Flats, Mound, Battelle Columbus, Hanford, and AMWTP) were generated from defense-related 

processes or activities. With respect to Hanford, the waste was generated during nuclear 

materials production, nuclear waste and materials byproducts management, and defense research 

and development activities conducted at Hanford facilities. Hanford analytical labs or facilities 

may have carried out non-defense activities concurrently with defense-related activities, but 

segregation of waste into defense and non-defense subsets is not possible. The defense 

determination discussions specific to the RLMPFPCD, MPFPD, RLM325ZD.001, and 
16 

RLM231SD.001 AKSRs included in RPT-TRUW-82, Revision 2A state that all four waste 

streams were derived by defense-related activities in whole or in part and meet the definition of 

defense waste. EPA has examined the arguments presented in RPT-TRUW-82, Revision 2A and 

agrees that the waste streams include defense-related waste material. 

(8) The identification of BN510.1 feed waste streams as transuranic and not high-level waste 

or spent nuclear fuel was examined and found to be adequate. 

The Public Law 102-579, LWA, bans the disposal at WIPP of spent nuclear fuel (SNF) and highlevel waste (HLW) as defined by the NWPA. HLW is defined by the NWPA as “the highly 

radioactive material resulting from the reprocessing of spent nuclear fuel, including liquid waste 

produced directly in reprocessing and any solid material derived from such liquid waste that 

contains fission products in sufficient concentrations, and other highly radioactive material that 

the Commission, consistent with existing law, determines by rule requires permanent isolation.” 

According to the NWPA, SNF is “fuel that has been withdrawn from a nuclear reactor following 

irradiation, the constituent elements of which have not been separated by reprocessing.” DOE 

Manual 435.1, Radioactive Waste Management, expands on this definition to clarify that “test 

specimens of fissionable material irradiated for research and development only, and not 

production of power or plutonium, may be classified as waste, and managed in accordance with 

the requirements of this Order when it is technically infeasible, cost prohibitive, or would 

increase worker exposure to separate the remaining test specimens from other contaminated 

material.” 

EPA examined RPT-TRUW-82, Revision 2A and RPT-TRUW-83, Revision 1A and determined 

that the BN510.1 feed stock waste streams are not SNF or HLW. With regard to Waste Streams 

MPFPD and RLMPFPCD (RPT-TRUW-82, Revision 2A), PFP did not process SNF nor was the 

facility involved with the separation or reprocessing of constituent elements from reactor fuel, so 

their resulting wastes do not contain irradiated fuel elements withdrawn from a reactor, only unirradiated materials from testing. Therefore, these PFP wastes are not SNF or HLW. Waste 

Stream RLM325D.001 contains laboratory wastes and other debris items and does not contain 

SNF, and the debris items it does contain are incidental to reprocessing, as described in DOE M 

435.1-1. This determination was submitted to and approved by the DOE Richland Operations 

Office in December 2006. Therefore, the waste is not SNF, HLW, and is not a waste historically 

managed as HLW. With regard to Waste Stream RLM231ZD.001, the 231-Z Building converted 

Pu nitrate to metal, performed casting and machining operations for weapons components, and 

recovered Pu from waste and scrap generated at Hanford and offsite facilities. The 231-Z 

Building did not reprocess SNF, was not involved with the separation or reprocessing of 

constituent elements from reactor fuel and did not manage or generate HLW. 

(9) The radiological controls associated with BN510.1 feed waste streams designed to ensure 

that the waste is transuranic were evaluated and found to be adequate. 

TRU alpha contamination is composed of radionuclides with atomic numbers greater than 92 and 

half-lives greater than 20 years. Drums destined for emplacement in WIPP must contain more 

than 100 nCi/g TRU alpha activity. As presented in Figure 1 and Table 3, Hanford feedstock 

undergoes screening assay prior to emplacement in SDOPs. “Silvers” generated by packaging of 
17 

shredded SDOPs also undergo NDA before pucking, and 100-gallon drums may undergo further 

assay using the SHENC if previous assays are of question. Each Hanford drum is assayed prior 

to shipment to AMWTP, and the INL WAC requires that these drums be TRU. The radiological 

composition of the waste streams and BN510.1 feed waste streams is well understood. 

RPT-TRUW-07, Appendix G presents the anticipated percentages of wastes that may be less 

than or equal to 100 nCi/g. As shown in this appendix, no wastes from Hanford are expected to 

be less than 100 nCi/g. As part of the transfer of waste from Hanford to AMWTP for 

management as BN510.1, AMWTP is supposed to receive only drums whose TRU alpha 

concentration is greater than 100 nCi/g. Therefore, AMWTP will not receive any non-TRU 

debris waste from Hanford for management as BN510.1 waste. 

(10) Load Management of the BN510.1 waste stream was evaluated with respect to the new 

Hanford feed waste streams and found to be adequate. 

 

Load management is approved for the BN510.1 waste stream, and sufficient information was 

available to evaluate whether the Hanford waste would require this option. For waste streams 

that are TRU in the aggregate, AMWTP may employ load management. Specifically, individual 

containers in a TRU waste stream vary in their TRU alpha activity concentration, i.e., some 

containing more than 100 nCi/g and some containing less than 100 nCi/g. A final payload 

container, typically a ten-drum overpack, can be loaded such that on the whole the payload’s 

TRU alpha activity exceeds 100 nCi/g, but the TRU alpha activity of the individual containers 

within the payload may be less than 100 nCi/g. As mentioned above, no waste drums from 

Hanford will have TRU alpha activity less than 100 nCi/g. This means that while load 

management is allowed in the AMWTP program, load management is not expected for these 

Hanford wastes. 

Acceptable Knowledge Findings and Concerns

EPA did not identify any findings or concerns associated with AK during this inspection. 

However, EPA raised an issue concerning inappropriate use of Hanford-CCP prepared AK 

information specific to the Hanford waste integrated as BN510.1 waste by AMWTP. AMWTP 

revised two documents (RPT-TRUW-82, Revision 2A, and RPT-TRUW-83, Revision 1A) to 

address EPA issue. The revisions are acceptable. 

Acceptable Knowledge Summary

EPA’s unannounced inspection verified that AMWTP has sufficiently implemented the 

characterization process with respect to these new waste streams. EPA determined that 

integration of Hanford waste into the BN510.1 waste stream was appropriately documented and 

the BN510.1 waste streams were adequately defined, including the radiological and physical 

composition of the waste streams. 

Changes to AK Tiering

There are no changes to the AK T1 and T2 assignments made during the baseline inspection as a 

result of this inspection. 
18 

6.2 Nondestructive Assay 

Because this unannounced inspection focused on the continued compliance of a site that had an 

existing baseline approval, the emphasis was on the continued operations of a subset of the 

approved equipment. Accordingly, an evaluation of the design and basic operating principles of 

the Z-211-102 and -103 and Z-390-100 and -101 IWAS is not addressed in this report, but is 

addressed in detail in EPA’s baseline inspection report (see EPA Docket No.A-98-49; II-A4-66). 

This report focuses on selected operational aspects of the IWAS Z-211-102 and -103 NDA 

systems and the preparation of NDA BDRs for the BN510.1 wastes. Specifically, this inspection 

focused on the following: 

 

• Confirming that the design and technical capabilities of the NDA systems’ hardware and 

software had not changed since EPA’s last inspection 

• Adequacy of the current revisions of pertinent AMWTP NDA procedures and documents 

• Operational and maintenance history of the NDA systems in the last year 

• Knowledge, understanding and training status of AMWTP NDA personnel 

EPA examined references as part of this inspection, including the following: 

• RPT-TRUW-03, Drum Assay Technical Review Report, Advanced Mixed Waste Treatment 

Project, Revision 7, December 7, 2006

• RPT-TRUW-30, Acceptable Knowledge Summary for Supercompacted Debris Waste 

(BN510), Advanced Mixed Waste Treatment Project, Revision 6, September 11, 2008

• INST-FO1-01, In-Plant Drum Assay Operations, Revision 19, November 23, 2009

• INST-TRUW-8.1.1, Drum Assay Post-Maintenance Calibration and Verification, Revision 

11, January 5, 2010

• INST-O1-14, Drum Assay Operations, Revision 25, November 18, 2009

• RPT-TRUW-07, Determination of Radioisotopic Content in TRU Waste Based on 

Acceptable Knowledge, Advanced Mixed Waste Treatment Project, Revision 16, August 12, 

2010 

• MP-TRUW-8.8, Level 1 Data Validation, Revision 29, May 27, 2010 

• AMWTP Work Order No. 327399, K Normalization Failure for the Z-390-101 IWAS NDA 

Unit, March 20, 2010 

• Nonconformance Report No. 55734, Assay 100 (Z-390-100) 3 Sigma Failure, September 26, 

2010 

• AMWTP Work Order No. 327399, K Normalization Failure for the Z-390-100 IWAS NDA 

Unit, October 20, 2010 
19 

• Employees by Qualifications/Certifications, November 18, 2010: TCNDAETR – NonDestructive Assay ETR; QCASYITR– Non-Destructive Assay Independent Technical 

Reviewer (ITR); and FQPOT9BO – Drum Assay 

• CBFO Memorandum: Approval Status Notification – Primary NDA PDP Drum Cycle 16A, 

June 25, 2009 

• NDA BDRs from the Z-390-100 and 101 IWAS Systems Nos. ASY-10-01885, ASY-10-

01892, ASY-10-01893, ASY-10-01896, ASY-10-01897, ASY-10-01905, ASY-10-01906, 

ASY-10-001907 and ASY-10-001910. 

Technical Evaluation

The following aspects of the Z-211-102 and -103 IWAS were evaluated during this inspection: 

(1) The Z-211-102 and Z-211-103 Integrated Waste Assay System nondestructive assay 

systems are the same systems that were approved previously. 

The Z-211-102 and -103 IWAS systems are located at AMWTP in Building WMF-634. By 

direct observation of the systems and their documentation, the EPA inspection team verified that 

the systems have not been moved and that there have been no substantive hardware or software 

changes to these systems since EPA’s baseline approval (see EPA Docket No. A-98-49; 

IIA4-66). 

(2) The design and operational range of the Z-211-102, Z-211-103, Z-390-100 and 

Z-390-101 Integrated Waste Assay System nondestructive assay systems were assessed 

and were found to be unchanged from EPA’s baseline approval and remain adequate for 

the wastes currently being assayed. 

The Z-211-102, Z-211-103, Z-390-100 and Z-390-101 IWAS NDA systems function using the 

same technical approach as was observed during EPA’s baseline inspection. The active mode for 

neutron assays has been turned off and must be intentionally initiated by the operator for the 

neutron generator to fire. This leaves the passive mode neutron with californium-252 Add-ASource matrix correction and the high-resolution gamma system with two broad energy 

germanium detectors. This is the same hardware configuration as was observed during the 

baseline inspection. 

(3) Performance/maintenance of the Z-211-102, Z-211-103, Z-390-100 and Z-390-101 

Integrated Waste Assay System nondestructive assay systems and documentation thereof 

were evaluated and found to be adequate. 

Two performance-related issues were identified with the assay of the DCAL 1999 standard: one 

3-Sigma failure on the 240PuEFF

4

 on January 31, 2010, for the Z-390-100 IWAS unit, and another 

on October 18, 2010, for the Z-390-101 IWAS unit. Both events were addressed via the 

 4 240PuEFF is defined as the mass of 240Pu that would produce the same coincidence response upon assay as that 

obtained from all the even-numbered isotopes of Pu in an actual sample. Typically, the 240PuEFF is 2-20% larger than 

the actual 240Pu content. 
20 

AMWTP nonconformance process in a technically correct manner and were appropriately 

documented. Additionally, there were two K Normalization failures: one in March 2010 on the 

Z-390-101 IWAS NDA unit, and another in October 2010 on the Z-390-100 IWAS NDA unit. 

Both events were addressed via the AMWTP nonconformance process in a technically correct 

manner and were appropriately documented. There were no performance/maintenance issues 

relative to the Z-211-102, Z-211-103, Z-390-100 and Z-390-101 IWAS NDA units as a result of 

this inspection. 

(4) All four Advanced Mixed Waste Treatment Project Integrated Waste Assay System 

nondestructive assay units, i.e., Z-211-102, Z-211-103, Z-390-100 and Z-390-101, had 

successfully participated in Drum Cycle 16A of the Carlsbad Field Office-sponsored 

Performance Demonstration Program, as required. 

(5) Personnel training was assessed and found to be adequate. 

All AMWTP NDA EAs, ITRs, and NDA operators associated with the calibration, operation and 

data review and approval of the Z-211-102, Z-211-103, Z-390-100 and Z-390-101 IWAS NDA 

systems had current training. AMWTP provided the following three training forms: Employees 

by Qualifications/Certifications, QCNDAETR – Non-Destructive Assay Expert; QCASITR – 

Nondestructive Assay ITR; and FQPOT9B0 – Drum Assay. All forms were dated November 18, 

2010. 

(6) Nondestructive assay batch data reports were evaluated and found to be adequate. 

AWMTP had provided nine NDA BDRs to EPA in early October 2010. These had been 

requested as part of the two-step approval of the T1 change adding new Hanford waste streams 

to BN510 and were provided upon completion of supercompaction and assay of the Hanford 

waste using the in-plant Z-390-100 and Z-390-101 IWAS NDA units located in Building 639 at 

AMWTP. EPA’s review of paper copies of these BDRs in advance of this inspection had 

generated a series of specific questions regarding preparation of the BDRs, and addressing these 

was the main focus of this inspection. AMWTP’s position is that the official NDA BDR is the 

electronic version; therefore, several aspects of the NDA BDRs are not adequately represented in 

the paper copy and are available only in the electronic version. Mr. Jim Seamens, NDA EA, 

provided information during the inspection, and upon viewing the electronic NDA BDRs, EPA 

determined that they were adequate. 

Nondestructive Assay Findings and Concerns

EPA did not identify any findings or concerns associated with NDA during this inspection. 

Nondestructive Assay Summary 

The Z-211-102, Z-211-103, Z-390-100 and Z-390-101 IWAS NDA units at AMWTP continue to 

be in compliance with EPA’s baseline approval. 
21 

Changes to Nondestructive Assay Tiering

There are no changes to the NDA T1 and T2 assignments made during the baseline inspection as 

a result of this inspection. 

6.3 Real-Time Radiography 

Real-Time Radiography for Retrievably Stored (Legacy) Waste

EPA limited its review of RTR to ITR and Site Project Manager (SPM) review, nonconformance 

report (NCR) processing, and liquid volume determination. AMWTP personnel informed EPA 

that RTR operators do not calculate the volume of liquid in waste drums. They estimate the 

volume and use the table in procedure INST-OI-12 to convert the estimate to consistent units of 

measure. NCR No. 54679 was initiated for drum No. 10375763 because of the presence of 

liquid. This NCR was properly processed and closed. For BDR RTR10-00150, EPA determined 

that ITR- and SPM-level reviews were performed and documented. 

Real-Time Radiography Findings and Concerns

EPA did not identify any findings or concerns associated with RTR procedures and processes 

during this inspection. 

Real-Time Radiography Summary 

EPA determined that RTR data continue to be generated in accordance with an approved 

procedure by qualified personnel.

Changes to Real-Time Radiography Tiering

There are no changes to the RTR T1 and T2 assignments made during the baseline inspection as 

a result of this inspection. 
22 

6.4 Visual Examination 

Visual Examination for Newly Generated Waste 

In March 2010, CBFO requested a T1 change for the AMWTP BN510.1 waste stream on behalf 

of AMWTP and provided eight VE BDRs for EPA’s review. During the onsite visit, EPA 

inspectors interviewed a VE operator and a VE expert to verify that these BDRs had been 

generated in accordance with procedure INST-OI-17, Facility Visual Examination Operations. 

BN510.1 waste is generated when BN-508 waste is subject to VE and supercompaction. The 

final configuration of the BN510.1 waste is compacted waste in 100-gallon containers. EPA 

reviewed BDR Nos.VEB10-00898, VEB10-00899, VEB10-00903, VEB10-00904, VEB10-

00905, VEB10-00906, VEB10-00909 and VEB10-00910. Site VE personnel answered EPA’s 

questions with regard to WMP weight assignment, balance information, calculation of liquid 

volumes, and ITR. No NCRs were associated with the BDRs under review. VE personnel 

provided a general description of the waste stream that was consistent with RPT-TRUW-83, 

Revision 1A, Acceptable Knowledge Summary for Supercompacted Debris Waste (BN510.1). 

EPA verified continuing qualification of one VE operator. 

Visual Examination Findings and Concerns

EPA did not identify any findings or concerns associated with VE procedures and processes 

during this inspection. 

Visual Examination Summary

EPA determined that VE data continue to be generated in accordance with an approved 

procedure by qualified personnel. 

Changes to Visual Examination Tiering

There are no changes to the VE T1 and T2 assignments made during the baseline inspection as a 

result of this inspection. 

7.0 SUMMARY OF RESULTS AND CONCLUSIONS 

Findings and Concerns

EPA did not identify any findings or concerns associated with AK, NDA, RTR, or VE during 

this inspection. 

Approval

Based on EPA’s inspection completed November 17–18, 2010, the EPA inspection team 

determined that the AMWTP waste characterization program activities continue to function in 

accordance with the baseline approval. 
23 

Tiering Changes

There are no changes to the AK, NDA, RTR, or VE T1 and T2 assignments made during the 

baseline inspection as a result of this inspection. 
24 

Table 7. Tiering of Transuranic Waste Characterization Processes Implemented by the 

Advanced Mixed Waste Treatment Project 

(Based on March 28–30, 2006, Baseline Inspection, Revised February 2011)

Process Elements AMWTP T1 Changes AMWTP T2 Changesa

AK including 

Load Management 

Any new waste category 

Changes to WDS algorithms specific to 

load management 

Notification to EPA upon the following: 

- Changes in load management status of approved waste 

stream(s) 

- Availability of WSPFs, including updates or additions 

to waste stream(s) within an approved waste category 

- Changesb

 to site procedures requiring approvals by 

CBFO and other changes as discussed in Section 8.1 of 

the baseline report

NDA New equipment or physical 

modifications to approved equipmentc

Changes to approved calibration range 

for approved equipment

Notification to EPA upon completion of changes to 

software for approved equipment, operating range(s), and 

site procedures that require CBFO approval and other 

changes as discussed in Section 8.2 of the baseline report 

RTR There are no T1 changes at this time Notification to EPA upon the following: 

- Implementation of new equipment 

- Modificationc to approved equipment 

- Changes to site procedures requiring CBFO approvals 

and other changes as discussed in Section 8.3 of the 

baseline report 

VE Performance of VE by a different vendor Notification to EPA upon the following: 

- Addition of new waste category 

- Addition of new procedure or site equipment identifier 

- Changes to site procedures requiring CBFO approvals 

and other changes as discussed in Section 8.4 of the 

baseline report

WWIS/WDS There are no T1 changes at this time Notification to EPA upon changes to site procedures 

requiring CBFO approvals and other changes as discussed 

in Section 8.5 of the baseline report 

a Upon receiving EPA approval, AMWTP will report all T2 changes to EPA at the end of each fiscal year quarter. Note: EPA may 

request specific T2 change items before the end of a fiscal quarter. 

b “Substantive changes” means changes with the potential to impact the site’s waste characterization activities or documentation 

thereof, excluding changes that are solely related to ES&H, nuclear safety, RCRA or are editorial in nature. c Modifications to approved equipment include all changes with the potential to affect NDA and/or RTR data relative to waste 

isolation and exclude minor changes, such as the addition of safety-related equipment.