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 2011i 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 ............................................................................................................1 2
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 Char acterization Processes Implemented by the Advanced Mixed Waste Treatment Project ....................................................................24ii 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 Moundiii 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 Envir onmental 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 System1 1.0 EXECUTIVE SUMMARY

In accordance with 40 CFR 194.8(b), the U.S. Envi ronmental Protection Agency (EPA or the Agency) conducted unannounced continued comp liance Inspection No. EPA-AMWTP-CH-UA10.10.24 of the waste characterization program fo r contact-handled (CH) transuranic (TRU) wastes at the U.S. Department of Energy ( DOE) Advanced Mixed Waste Treatment Project (AMWTP). This on-site inspec tion occurred at the AMWTP 1 on November 17–18, 2010, and covered selected aspects of AMWTP’s approve d TRU waste characterization processes. In accordance with the provisions of 40 CF R 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 ch aracterize wastes proposed for disposal at the Waste Isolation Pilot Plant (WIPP). Following the inspection, while reviewing AMWTP provided documents, EPA inspectors identi fied one issue requiring December 6, 2010 discussion. AMWTP had used Acceptable Know ledge (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 resu lt of this unannounced continued compliance inspection, EPA confirmed that the AMWTP CH TRU waste characteriza tion program continues to maintain its approval to characterize CH TRU waste consistent wi th 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) design ations 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 Ta ble 7 of this report.

During this inspection, the Agency evaluated sa mples 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 retrie vably 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 comp liance inspections to verify that the site continues to use only the approve d waste characterization processe s to characterize the waste and remains in compliance with all the regulatory re quirements. This inspection was performed for

1 The AMWTP is located on DOE’s Idaho National La boratory (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 ch aracterization program compliance with

40 CFR 194.24.

3.0 PURPOSE OF THIS REPORT

This report documents the basis for EPA’s deci sion to maintain the approval of the AMWTP waste characterization program fo r 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 characteri zation systems have changed relative to the baseline approval configuration and assesse s the impact, if any, of those changes

• Provides objective evidence to support the EP A continued approval basis for all waste characterization systems

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

• Describes any tests or demonstrations comple ted during the course of the inspection and
their relevance to EP A’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 inform ation 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 co mpliance 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 th e 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); Wa ste Stream Profile Forms (WSPFs) for
both the BN510.1 waste stream and the BN510 wast e 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; and3 tracking of EPA-selected Hanford cont ainers 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 inte rviews of personnel, review of training records, and examination of training materials; audio/vi deo 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 pr eparation of inspection checklists. For an unannounced inspection, EPA t echnical inspectors prepare using what they
know to be the latest revisions of these docum ents. 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 shor t notice while onsite. For this inspection, the revisions of the relevant documents for AK, ND A, 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 inspecti on. 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 pe rsonnel 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. AMWT P-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 processe s that were approved under EPA’s baseline inspection;

(2) Obtaining and reviewing site procedures, repo rts, and other technical information related
to waste characterization activities at AM WTP in advance of the inspection; and

(3) Examining draft checklists sp ecific to each technical ar ea before the inspection.4 As part of this unannounced inspecti on, 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 equi pment by means of interviews, observation, and demonstrations, and recorded the results, as appropriate;

(3) Recorded all concerns on EPA Inspection Is sue Tracking Forms, as appropriate, and provided completed forms to CBFO and si te 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 CBF O and AMWTP personnel;

(6) Conducted entrance, exit, and daily brie fings 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 personn el, 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 eval uation was the objective evidence documenting the effectiveness of the waste ch aracterization processes. Objective evidence typically takes the form of BDRs, radioassay data sheets, AKSRs and related documents, AK accuracy reports, and RTR tapes. During this insp ection, 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 techni ques. Based on the evaluation of the waste characterization processes in conj unction with the samp le of objective evidence, EPA determined the technical adequacy of the wa ste characterization processes w ithin the inspection’s scope. The EPA inspection team consisted of the personnel show n in Table 1.

Table 1. Continued Complian ce 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-Training5 The EPA inspection team interviewed and obtaine d 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 technica l areas assessed during this inspection—Acceptable Knowle dge (AK), Non-Destructiv e 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 Di sposal 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 Envi ronmental 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 th e AMWTP stated that addition of any waste streams to BN510 outside of those already incl uded 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 Tabl e 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, Hanf ord’s original certified program was no longer in place and DOE6 contracted the Central Characteri zation Project (CCP) to characteri ze and ship Hanford wastes to
AMWTP for characterization and ul timate emplacement in WIPP. Prior to termination of their program, Hanford shipped several thousand drums fr om three of the four proposed waste streams to WIPP under Hanford’s origin al WIPP waste characterization program. CBFO approved the remaining waste stream (RLMPFPCD), but Hanf ord did not ship it to WIPP because an approved WSPF was not issued, although the AKSR ha d been approved. Below is a description
of these four waste streams discussed in the Hanford AKSR (RPT-T RUW-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 me tallurgical resear ch and plutonium fabrication, decontamination and decommi ssioning (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 c ontainers with generation dates from September 28, 1972, through February 12, 1990.

• Waste Stream MPFPD: Mixed Plut onium Finishing Plant Debris. This waste stream
consists of mixed TRU de bris waste (S5490 WMC) gene rated between 1970 and the present in support of plutonium metal pr oduction operations and glove box activities (e.g., maintenance, clean out, decontamin ation, decommissioning, stabilization) associated with the Plutonium Finishing Plant (PFP) Complex.

• Waste Stream RLMPFPCD: The Richla nd Mixed PFP Comprehensive Debris
Waste Stream. The RLMPFPCD waste stream is a mixed, heterogeneous debris waste stream (S5400 WMC) generated from 1970 th rough the present in support of PFP’s plutonium production and stabilizat ion activities. It is composed of a variety of inorganic, organic and other debris incl uding both process and D&D wa ste. All of the facilities
included in the MPFPD waste stream are in cluded in Waste Stream RLMPFPCD, which includes the Building 242-Z- Waste Treatment Facility, 291-Z-Ventilation/Exhaust Air Stack Building, and PFP An cillary Facilities.

EPA reviewed information pertaining to the Ha nford 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 ship ping 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 Hanf ord debris was adequately char acterized by AMWTP for inclusion in the BN510 waste stream. During the unannoun ced 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 wast e stream to include Hanford waste

• BDRs from VE for physical contents and NDA for radiologi cal contents of the BN510.1
waste stream debris

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

As required by the WIPP Resource Conservati on and Recovery Act (RCRA) permit, AMWTP integrated the Hanford waste st reams, retired the BN510 waste st ream, 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 Dock et 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 whet her AMWTP has sufficiently implemented the characterization process with respect to these new waste st reams, 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 se ction 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 define d, including radiological and physical composition. Key limitations, as specified in the Land Withdrawal Act (LWA), were also evaluated.

(1) Acceptable knowledge documentation associat ed with the BN510.1 waste stream was evaluated to determine the adequacy of th e Advanced Mixed Waste Treatment Project’s
Hanford waste stream document review and in tegration and was found to be adequate.

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

• RPT-TRUW-03, Drum Assay Tec hnical Review Report, Advan ced Mixed Waste Treatment Project, Revision 7, December 7, 2006

• RPT-TRUW-06, AMWTP Baseline AK for Newl y-Generated Waste, Advanced Mixed Waste Treatment Project, Revision 12, August 16, 20108 • RPT-TRUW-07, Determination of Radioiso topic Content in TRU Waste Based on Acceptable Knowledge, Advanced Mixed Wast e Treatment Project, Revision 16, August 12,

2010

• RPT-TRUW-12, AMWTP Waste Stream Designa tions, Advanced Mixed Waste Treatment Project, Revision 15, November 3, 2010

• RPT-TRUW-30, Acceptable Knowledge Summar y for Supercompacted Debris Waste (BN510), Advanced Mixed Waste Treatme nt Project, Revision 6, September 11, 2008

• RPT-TRUW-82, Acceptable Knowledge Document for Hanford Debris Waste Shipped to AMWTP, Advanced Mixed Waste Treat ment Project, Revision 1, June 21, 2010

• RPT-TRUW-82, Acceptable Knowledge Document for Hanford Debris Waste Shipped to AMWTP, Advanced Mixed Waste Treatment Proj ect, Revision 2A, date to be determined (TBD)

• RPT-TRUW-83, Acceptable Knowledge Summar y for Supercompacted Debris Waste (BN510.1), Advanced Mixed Waste Treatment Project, Revision 0, September 10, 2010

• RPT-TRUW-83, Acceptable Knowledge Summar y for Supercompacted Debris Waste (BN510.1), Advanced Mixed Waste Treatme nt Project, Revision 1A, date TBD

• P853A, Revision 1, CCP-PK-RL-101, Revision 2, Central Characterization Project Process Knowledge Summary Report For Hanford Plut onium Finishing Plant Contact-Handled Transuranic Debris Waste, 85-Gallon Overp acked Drums, Waste Stream: MPFPDD, Larry Porter, Central Characterizati on Project (CCP), June 4, 2010

• P854A, Revision 1, CCP-PK-RL-102, Revision 2, Central Characterization Project Process Knowledge Summary Report For The Hanfor d 325 Building Radiochemical Processing Laboratory Contact-Handled Tr ansuranic Debris Waste, 85- Gallon Overpacked Drums, Waste Stream: RLM325D.001, Larry Porter, Centra l 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 Debr is Waste Stream (MPFPD), revised document will have new title, date and “P” reference number.

To understand the interrelationships of these doc uments, one must understand the history of the Hanford waste streams accepted at the AMWTP and the charac terization 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 to9 generate a new, broader AKS R (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. EP A 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 Ha nford-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, AMWT P, Hanford-CCP, and CBFO on December 6, 2010, EPA informed the participants that AMWTP sh ould have used AK documents for the subject waste streams that were prepared under the ol d Hanford program and asked that AMWTP revise
relevant documents.

AMWTP acknowledged EPA’s decision and agr eed 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 stream s, 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 fo r the four waste streams (RLM231ZA.001, RLM325D.001, MPFPD, and RLMPFPCD) and adding a title page to the merged document. AMWTP representatives indicated th at this information was accepted “as is,” with little review
of associated references or the AKSRs. Th e 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 a nd that source documents used to generate
AKSRs are available in the AM WTP record. AMWTP representativ es provided a cross-reference
that showed that the source documen ts 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 str eam is dated September 10, 2010, and AMWTP representatives indicated that th is profile had not been modifi ed since its latest approval. Contents of the WSPF were compared to th e requirements in AM WTP Form 1900, Revision 1, and the WSPF was found to be complete with respect to required contents.

(3) Data tracking and data traceability of Hanf ord waste in the Advanced Mixed Waste Treatment Project system, incl uding traceability of batch da ta reports, was examined and found to be adequate.

AMWTP uses the AMWTP Waste Tr acking System (WTS) to track information pertaining to incoming drums from offsite sources, including th e 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 AMWT P drum number; drums then undergo screening10 NDA and RTR (i.e., “fast scan”) to evaluate their acceptability accord ing to the INL waste acceptance criteria. If a drum is acceptable, it is co mbined with others into a six-drum overpack (SDOP). The SDOP is then shredded, and the sh redded 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 Hi gh Efficiency Neutron Counter (SHENC) for additional assay if data suggest the drum’s TR U 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 proc ess. 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 characteriz ation 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 evaluate d and found to be adequate.

The BN510.1 newly generated debris waste stre am is produced from supercompaction of 55-gallon containers of debris wa ste. 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 wa s generated during plutonium pit production; depleted uranium component fabrication; en riched uranium processing; support operations including: recovery, treatment, maintenance, la boratory analysis, and machining of non-nuclear weapon components; research and development; sp ecial order work; fabrication of plutonium238 ( 238 Pu) heat sources and manuf acture of radioisotopic thermoelectric generators; D&D activities; and materials developm ent. 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 a ll feedstock debris is commingled during unpackaging/shredding, sortin g, 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 th e waste stream and Hanford feedstock.

3 Pucks are 55-gallon drums of TRU waste that have be en 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

Acce p table? 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 N o Questionable Assay

TRU α <100 nCi/g?12Table 3. Example Traceability of Hanford Drums through the Advanced Mixed Waste Treatment ProjectHanford DrumNumber/WasteStreamFast ScanNDA BDRFast ScanRTR BDRAMWTPDrumNumberSDOPSilver number -No associationwith originalAMWTP orHanford DrumNumber*VE BDR(generatedduringloading ofsilver)NDA BDR(generated byNDA of silverprior topucking)Product drumnumber (100-gallon containingpucks)SHENC of 100gallon? Y/N andBDR number0026719/MPFPDD ASY10-01501RTR10-00152 10373072 10378197 10379920 VEB10-00914ASY10-01912 BN10379712 Yes,INNDAD100850030006/RLM325D ASY10-01503RTR10-00140 10369476 10378197 10379915 VEB10-00914ASY10-01912 BN10379714 No0030209/RLM325D ASY10-01474RTR10-00140 10369559 10378197 10379905 VEB10-00914ASY10-01912 BN10379716 No0037465/RLM231ZD ASY10-01474RTR10-00140 10369566 10378197 10379919 VEB10-00914ASY10-01911 BN10379718 No0044257/MPFPDD ASY10-01502RTR10-00141 10373041 10378197 10379917 VEB10-00914ASY10-01911 BN10379719 No0044837/MPFPDD ASY10-01501RTR10-00142 10373073 10378197 10379950 VEB10-00915ASY10-01916 BN10379878 No* 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 resp ect to the BN510.1 envelope and found to be adequate.

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

234 U, 238 U, and americium-241 ( 241 Am). 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 radionuc lides which may be present in feedstock debris, as indicated the BN510 AKSR, were 241 Pu, thorium-228 ( 228 Th), 231 Th, 232 Th, 234 Th, 235 U,

236 U, curium-244, and neptunium-237. The two most prevalent radionuclides by activity expected in the majority of BN510 AMWTP supercompacted debris product drums are 239 Pu and

240 Pu, while the most prevalent radionuclid es by activity will likely always include 239 Pu 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 radionuc lides. 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-gra de (WG) and heat source (HS) Pu, enriched uranium (EU), and depleted uranium (DU).

Table 4. Predominant Transuranic Radio nuclides Expected in Debris Wastes by Generator Site

Generator Site Principal Pu Type Predominant TRU Radionuclides

RF WG 239 Pu, 240 Pu
RF WG/DU/EU 239 Pu ( 235 U or 238 U) a

MD WG 239 Pu, 240 Pu

MD HS 238 Pu, 239 Pu

BC WG 239 Pu, 240 Pu RL Combination WG/Fuel-grade Pu 239 Pu ( 241 Pu or 241 Am)

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

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

EPA examined the information above against da ta 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 240 Pu, 241 Pu, 241 Am, and 238 U are expected, and 238 U may be a predominant radionuclide based on mass.

EPA also interviewed Mr. Randy Morris, AMWT P 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 th at historic AK container data, previously approved Hanford AKSRs and representative source documents were reviewed to en sure that the radiological compositions of accepted containers were well u nderstood. Mr. Morris also stated that the predominant radionuclide AK information from each AKSR was evaluated and incorporated in14 the BN510.1 AKSR “as is.” EPA’s comparison of the BN510.1 report an d individual AKSRs showed that Mr. Morris’ approach was followe d and is acceptable. EPA also interviewed
Mr. Jim Seamens to better understand the us e 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 whethe r 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 defau lt 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 radiologi cal composition of the Hanford waste streams and adequately integrated that information into the BN510.1 AKSR.

(6) Identification of physical form including wa ste 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 s upercompacted debris waste that included combustibles (e.g., rags, gloves, wipes); personal protective equipment (PPE ); plastic and rubber items; filters; leaded gloves, aprons, bricks a nd 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, di rt and sand; and noncombustible solids packaged in 55-gallon drums, supercom pacted, 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 databa se 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 Sy stem/WIPP Waste Information System RTR and VE data for 22,399 Hanford containers shippe d to WIPP between 2005 and 2009. The estimated WMPs are representative of the BN510.1 wast e stream and are summarized in Table 5.

Table 5. BN510.1 Waste Material Paramete rs 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 <115 The AKSR for BN510.1 was not updated to specifi cally include the an ticipated 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 st reams was examined to determine whether the composition would “fit” the general BN510.1 en velope. RPT-TRUW-82, Revision 2A provides WMP distributions by weight percent for each of th e four waste streams, as listed in Table 6.

Table 6. Waste Material Parameter Estima ted Percentages for Hanford Waste Streams

WMPs WMP Weight/Unit Waste (Anticip ated 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 anti cipated 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 th e Hanford waste streams compare favorably with the anticipated WMPs.

Liquid is a prohibited item that is related to EPA compliance. F eedstock debris containers that are identified as containing prohi bited items during RTR or VE are treated or rejected, as appropriate.

(7) Defense status of the new waste stream s 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 fo r disposal at WIPP if it has been generated in whole or in part by one of the atomic energy de fense activities listed in Section 10101(3) of the Nuclear Waste Policy Act of 1982 (NWPA). All feedstock to th e BN510.1 waste stream (Rocky Flats, Mound, Battelle Columbus, Hanford, and AM WTP) were generated from defense-related processes or activities. With respect to Ha nford, the waste was generated during nuclear materials production, nuclear waste and material s byproducts management, and defense research and development activities conducted at Hanford fac ilities. Hanford analytical labs or facilities may have carried out non-defens e activities concurrently with defense-related activities, but segregation of waste into defense and non-de fense subsets is not possible. The defense determination discussions specific to the RLMPFPCD, MPFPD, RLM325ZD.001, and16 RLM231SD.001 AKSRs included in RPT-TRUW-82, Re vision 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 st reams as transuranic a nd 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 sp ent nuclear fuel (SNF) and highlevel waste (HLW) as defined by the NWPA. HL W is defined by the NWPA as “the highly radioactive material resulting from the reprocessing of spent nucle ar fuel, including liquid waste produced directly in reprocessing and any solid material derived from such liquid waste that contains fission products in suffi cient concentrations, and other hi ghly radioactive material that the Commission, consistent with existing law, dete rmines by rule requires permanent isolation.” According to the NWPA, SNF is “fuel that has b een withdrawn from a nuclear reactor following irradiation, the constituent elements of which ha ve not been separated by reprocessing.” DOE Manual 435.1, Radioactive Waste Management , expands on this definition to clarify that “test specimens of fissionable materi al 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 rema ining test specimens fr om 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 reprocessi ng of constituent elements from reactor fuel, so their resulting wastes do not contain irradiated fuel elements withdrawn from a reactor, only unirradiated materials from test ing. 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 inci dental to reprocessing, as described in DOE M
435.1-1. This determination was submitted to an d 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 St ream RLM231ZD.001, the 231-Z Building converted Pu nitrate to metal, performed casting and m achining 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 invol ved with the separati on or reprocessing of
constituent elements from reactor fuel and did not manage or generate HLW.

(9) The radiological controls associated with BN510.1 feed wa ste streams designed to ensure
that the waste is transuranic were evaluated and found to be adequate.

TRU alpha contamination is composed of radionuc lides with atomic numbers greater than 92 and half-lives greater than 20 years. Drums destin ed for emplacement in WIPP must contain more than 100 nCi/g TRU alpha activity. As presente d in Figure 1 and Table 3, Hanford feedstock undergoes screening assay prior to emplacement in SDOPs. “Silvers” generated by packaging of17 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 require s 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 a ppendix, 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. Th erefore, 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 st ream was evaluated with respect to the new
Hanford feed waste streams and found to be adequate.

Load management is approved for the BN510.1 wa ste 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 em ploy load management. Specifically, individual containers in a TRU waste stream vary in th eir TRU alpha activity c oncentration, i.e., some containing more than 100 nCi/g and some c ontaining less than 100 nC i/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 w ith AK during this inspection. However, EPA raised an issue concerning in appropriate use of Hanford-CCP prepared AK information specific to the Hanford waste in tegrated 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 wa s appropriately documented and the BN510.1 waste streams were adequately defi ned, including the radi ological and physical composition of the waste streams.

Changes to AK Tiering

There are no changes to the AK T1 and T2 assign ments made during the ba seline 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-390-1 00 and -101 IWAS is not addre ssed in this report, but is addressed in detail in EPA’s baseline inspec tion report (see EPA Docket No.A-98-49; II-A4-66). This report focuses on selected operationa l 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 capab ilities of the NDA systems’ hardware and software had not changed since EPA’s last inspection

• Adequacy of the current revisions of pert inent AMWTP NDA procedures and documents

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

• Knowledge, understanding and traini ng status of AMWTP NDA personnel

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

• RPT-TRUW-03, Drum Assay Tec hnical Review Report, Advan ced Mixed Waste Treatment Project, Revision 7, December 7, 2006

• RPT-TRUW-30, Acceptable Knowledge Summar y for Supercompacted Debris Waste (BN510), Advanced Mixed Waste Treatme nt Project, Revision 6, September 11, 2008

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

• INST-TRUW-8.1.1, Drum Assay Post-Maintenan ce Calibration and Verification, Revision 11, January 5, 2010

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

• RPT-TRUW-07, Determination of Radioiso topic Content in TRU Waste Based on Acceptable Knowledge, Advanced Mixed Wast e 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 Normalizati on 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 Normalizati on Failure for the Z-390-100 IWAS NDA Unit, October 20, 201019 • Employees by Qualifications/Certificatio ns, November 18, 2010: TCNDAETR – NonDestructive Assay ETR; QCASYITR– Non-De structive Assay Independent Technical Reviewer (ITR); and FQPOT9BO – Drum Assay

• CBFO Memorandum: Approval Status Notifica tion – 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 IW AS were evaluated during this inspection:

(1) The Z-211-102 and Z-211-103 Integrated Wa ste Assay System nondestructive assay systems are the same systems that were approved previously.

The Z-211-102 and -103 IWAS systems are lo cated at AMWTP in Building WMF-634. By direct observation of the systems and their docum entation, the EPA inspection team verified that the systems have not been moved and that there ha ve been no substantive hardware or software changes to these systems since EPA’s base line 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 nonde structive 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 inspectio n. 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 pa ssive mode neutron with californium-252 Add-ASource matrix correction and the high-resolu tion gamma system with two broad energy germanium detectors. This is the same hard ware 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 nondestruc tive 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 240 Pu EFF 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

4 240 Pu EFF is defined as the mass of 240 Pu that would produce the same coin cidence response upon assay as that obtained from all the even-numbered isotopes of Pu in an actual sample. Typically, the 240 Pu EFF is 2-20% larger than
the actual 240 Pu content.20 AMWTP nonconformance process in a technical ly correct manner and were appropriately documented. Additionally, there were two K Norm alization failures: on e 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 no nconformance process in a technically correct manner and were appropriately documented. Ther e 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-21 1-102, Z-211-103, Z-390-100 and Z-390-101, had successfully participated in Drum Cycle 16A of the Carl sbad 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 a ssociated with the calibration, operation and data review and approval of the Z-211- 102, Z-211-103, Z-390-100 a nd Z-390-101 IWAS NDA systems had current training. AMWTP provided the following three training forms: Employees by Qualifications/Certifications, QCNDAETR – Non-Destructive Assa y Expert; QCASITR – Nondestructive Assay ITR; and FQPOT9B0 – Dr um Assay. All forms were dated November 18,

2010.

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

AWMTP had provided nine NDA BDRs to EP A in early October 2010. These had been requested as part of the two-st ep 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 th ese BDRs in advance of this inspection had generated a series of specific que stions regarding prep aration of the BDRs, and addressing these was the main focus of this inspection. AMWTP’ s position is that the o fficial 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 el ectronic NDA BDRs, EPA determined that they were adequate.

Nondestructive Assay Findings and Concerns

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

Nondestructive Assay Summary

The Z-211-102, Z-211-103, Z-390-100 and Z-390-101 IW AS 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 assi gnments made during the baseline inspection as a result of this inspection.

6.3 Real-Time Radiography

Real-Time Radiography for Retr ievably Stored (Legacy) Waste

EPA limited its review of RTR to ITR and S ite 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 BD R 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 assi gnments 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 pr ocedure 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 BN 510.1 waste is compacted waste in 100-gallon containers. EPA reviewed BDR Nos.VEB10-00898, VEB 10-00899, VEB10-00903, VEB10-00904, VEB10- 00905, VEB10-00906, VEB10-00909 and VEB10-00910. S ite VE personnel answered EPA’s questions with regard to WMP weight assignm ent, 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 fo r Supercompacted Debris Waste (BN510.1). EPA verified continuing qualif ication 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 assi gnments made during the ba seline 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 N ovember 17–18, 2010, the EPA inspection team
determined that the AMWTP waste characterizati on program activities con tinue 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 re sult of this inspection.24 Table 7. Tiering of Transuranic Waste Charac terization 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 Changes a

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

- Changes b 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 equipment c

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 requ ire 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

- Modification c 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 No tification 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 approv al, AMWTP will report all T2 changes to EPA at th e end of each fiscal year quarter. Note: EPA may request specific T2 change items befo re the end of a fiscal quarter.

b “Substantive changes” means changes with the potential to imp act 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 th e potential to affect NDA and/or RTR data relative to waste isolation and exclude minor changes, such as the addition of safety-related equipment.