DOCKET NO: A-98-49, II-A4-62 

DRAFT 

WASTE CHARACTERIZATION INSPECTION REPORT 

EPA BASELINE INSPECTION NO. EPA-SRS-10.05-8 

OF THE CENTRAL CHARACTERIZATION PROJECT 

WASTE CHARACTERIZATION PROGRAM AT THE SAVANNAH RIVER SITE 

October 31–November 3, 2005 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center of Federal Regulations 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

February 2006
TABLE OF CONTENTS 

Section Page

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

2.0 Purpose of Inspections........................................................................................................ 3 

3.0 Purpose of This Report ....................................................................................................... 5 

4.0 Scope of Inspection............................................................................................................. 6 

5.0 Inspection-Related Definitions........................................................................................... 7 

6.0 Personnel............................................................................................................................. 7 

6.1 EPA Inspection Team ............................................................................................. 7 

6.2 Personnel Contacted................................................................................................ 8 

7.0 Performance of the Inspection ............................................................................................ 9 

8.0 Technical Waste Characterization Areas.......................................................................... 10 

8.1 Acceptable Knowledge and Load Management ................................................... 10 

8.2 Nondestructive Assay ........................................................................................... 23 

8.3 Real-Time Radiography (RTR) ............................................................................ 41 

8.4 Visual Examination............................................................................................... 45 

8.4.1 Visual Examination Technique for Newly-generated Waste.................... 46 

8.4.2 Visual Examination as a QC Check of RTR and VE in lieu of RTR ....... 48 

8.5 WIPP Waste Information System......................................................................... 53 

9.0 Response to Comments..................................................................................................... 56 

10.0 Summary of Results.......................................................................................................... 56 

10.1 Findings................................................................................................................. 56 

10.2 Concerns ............................................................................................................... 57 

10.3 Response to Inspection Issues............................................................................... 58 

10.4 Conclusions........................................................................................................... 58 

11.0 References......................................................................................................................... 60 

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ATTACHMENTS 

Attachment A.1 Acceptable Knowledge (AK) Checklist 

Attachment A.2 Visual Examination (VE) Checklist 

Attachment A.3 Visual Examination Technique (VET) Checklist 

Attachment A.4 Real-Time Radiography (RTR) Checklist 

Attachment A.5 Nondestructive Assay (NDA) Checklist—IPAN 

Attachment A.6 Nondestructive Assay (NDA) Checklist—IQ3 

Attachment A.7 WIPP Waste Information System (WWIS) Checklist 

Attachment A.8 WIPP Waste Information System (WWIS) Data Requirements 

Attachment B.1 Replicate Testing IPAN Data for Container SR144771 

Attachment B.2 Replicate Testing IPAN Results for Container SR144771 

Attachment B.3 Replicate Testing IPAN Data for Container FBL04011 

Attachment B.4 Replicate Testing IPAN Results for Container FBL04011 

Attachment B.5 Replicate Testing IPAN Data for Container SR138868 

Attachment B.6 Replicate Testing IPAN Results for Container SR138868 

Attachment B.7 Replicate Testing IQ3 Data for Container MDL0506073 

Attachment B.8 Replicate Testing IQ3 Results for Container MDL0506073 

Attachment B.9 Replicate Testing IQ3 Data for Container MDL0506146 

Attachment B.10 Replicate Testing IQ3 Results for Container MDL0506146 

Attachment B.11 Replicate Testing IQ3 Data for Container SR123477 

Attachment B.12 Replicate Testing IQ3 Results for Container SR123477 

Attachment B.13 Replicate Testing IQ3 Data for Container SR546270 

Attachment B.14 Replicate Testing IQ3 Results for Container SR546270 

Attachment B.15 Replicate Testing IQ3 Data for Container SR611807 

Attachment B.16 Replicate Testing IQ3 Results for Container SR611807 

Attachment B.17 Replicate Testing IQ3 Data for Container MDL0506241 

Attachment B.18 Replicate Testing IQ3 Results for Container MDL0506241 

Attachment C.1 EPA Inspection Issue Tracking Form, EPA Issue No. SRS-CCP-AK-05-004

Attachment C.2 EPA Inspection Issue Tracking Form, EPA Issue No. SRS-CCP-AK-05-005 

Attachment C.3 EPA Inspection Issue Tracking Form, EPA Issue No. SRS-CCP-NDA-05-006 

Attachment C.4 EPA Inspection Issue Tracking Form, EPA Issue No. SRS-CCP-RTR-05- 

003CR 

Attachment C.5 EPA Inspection Issue Tracking Form, EPA Issue No. SRS-CCP-VE-05-001F 

Attachment C.6 EPA Inspection Issue Tracking Form, EPA Issue No. EPA SRS-CCP-VE-05-

002CR 

Attachment D Response to EPA Inspection Issues

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1.0 EXECUTIVE SUMMARY 

In accordance with 40 CFR 194.8(b), from October 31–November 3, 2005, the 

U.S. Environmental Protection Agency (EPA or the Agency) conducted Baseline Inspection 

No. EPA-SRS-10.05-8 of the Central Characterization Project’s (CCP) waste characterization 

(WC) program at the U.S. Department of Energy’s (DOE) Savannah River Site (SRS) located in 

Aiken, South Carolina. EPA conducted a baseline inspection of the site’s program to 

characterize wastes proposed for disposal in the Waste Isolation Pilot Plant (WIPP). As a result 

of our baseline inspection, EPA is proposing to approve the SRS-CCP WC program based on a 

demonstration of the site’s capabilities, with conditions and limitations discussed in this report, 

in accordance with 40 CFR 194.8(b). 

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

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

regulations for transuranic (TRU) radioactive waste (63 Federal Register (FR) 27354 and 27405, 

May 18, 1998). EPA had previously evaluated and approved WC systems at SRS-CCP (EPA 

Docket A-98-49, II-A4-29, II-A4-40, II-A4-49, and II-A4-50). SRS-CCP was approved to 

dispose of only debris waste (S5000) prior to this baseline inspection. During this baseline 

inspection EPA evaluated the SRS-CCP’s ability to characterize soils/gravel waste (S4000) for 

the first time. EPA Baseline Inspection No. SRS-10.05-8 was performed in accordance with the 

provisions of 40 CFR 194.8(b), as issued in a July 16, 2004, FR notice (Vol. 69, No. 136, pages 

42571–42583). The purpose of the SRS-CCP WC inspection was to evaluate the adequacy of 

the site’s WC programs for two TRU waste categories, debris and soils/gravel, to be disposed of 

at the WIPP. The scope of the EPA inspection did not include solid TRU waste (S3000). The 

activities examined during the inspection included the following: 

• Acceptable knowledge (AK) and load management for contact-handled (CH) retrievablystored and newly-generated TRU debris waste (S5000) and soils/gravel (S4000) 

• Visual examination technique (VET) for CH newly-generated debris waste (S5000) and 

soils/gravel (S4000) 

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

for CH retrievably-stored TRU debris waste (S5000) and soil/gravel wastes (S4000) 

• RTR for CH retrievably-stored TRU debris waste (S5000) and soil/gravel waste (S4000) 

• Nondestructive assay (NDA) and the WIPP Waste Information System (WWIS) for CH 

retrievably-stored and newly-generated TRU debris waste (S5000) and soils/gravel 

(S4000) 

Two NDA systems (Imaging Passive-Active Neutron/Gamma Energy Analysis (IPAN/GEA) 

system and MCS IQ3 gamma system) were evaluated for characterizing debris (S5000) and 

soil/gravel (S4000) wastes.1

 EPA’s inspection team identified one finding and five concerns. 

The one finding and two of the concerns required a response from DOE. All concerns and 

findings are documented on EPA Inspection Issue Tracking Forms (see Attachments C.1 through 

C.6). Personnel from the site, the Carlsbad Field Office (CBFO), and the CCP provided 

 1

 The NDA systems are not matrix-specific in the same manner as other characterization techniques. 

Specifically, any matrix within the system’s calibration parameters can be assayed.

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information regarding the finding and concerns to the EPA inspection team prior to the 

inspection closeout on site and also subsequent to the inspection (see Attachment D). The 

information provided by CBFO addressed the finding and two concerns that required a response, 

as well as one concern that did not require a response. The EPA inspection team members 

evaluated all responses for completeness and adequacy, and concluded that each had been 

resolved satisfactorily. EPA considers all concerns and the finding to be resolved, and there are 

no open issues resulting from this inspection. 

EPA’s inspection team determined that SRS-CCP’s WC program activities were technically 

adequate. EPA is proposing to approve the SRS-CCP WC program in the configuration 

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

Attachment A. This approval includes the following: 

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

soil/gravel 

(2) The IPAN and IQ3 NDA systems for assaying soil/gravel and debris waste 

(3) VE as a QC check of the RTR process for retrievably-stored soil/gravel and debris waste 

(4) The VET process for newly-generated debris and soil/gravel wastes 

(5) The nondestructive examination process of RTR for retrievably-stored soil/gravel and 

debris wastes 

(6) The WWIS process for tracking of waste contents of debris and soil/gravel wastes 

Any changes to the WC activities from the date of the baseline inspection must be reported to 

and, if applicable, approved by EPA, according to the following table. 

Proposed Tiering of TRU WC Processes Implemented by SRS-CCP

(Based on October 31–November 3, 2005, Baseline Inspection)

WC Process 

Elements 

SRS-CCP WC Process

Specific T1 Changes 

SRS-CCP WC Process 

Specific T2 Changes*

SRS-CCP General T2

Changes* 

AK including

Load Management

Any new waste category 

Changes to WWIS 

algorithms specific to load

management 

WSPFs, including updates

or additions to waste 

stream(s) within an

approved waste category 

(see Section 8.1) 

Changes in load

management status of 

approved waste stream(s) 

Changes to site procedures

requiring CBFO approvals

and other changes as

discussed in Section 8.1 of

this report 

NDA New equipment or physical 

modifications to approved 

equipment** 

Changes to approved

calibration range for 

approved equipment (see 

Section 8.2)

Changes to software for 

approved equipment (see 

Section 8.2)

Changes to operating 

range(s) upon CBFO

approval

Changes to site procedures

requiring CBFO approvals

and other changes as

discussed in Section 8.2 of

this report 

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Proposed Tiering of TRU WC Processes Implemented by SRS-CCP

(Based on October 31–November 3, 2005, Baseline Inspection)

WC Process 

Elements 

SRS-CCP WC Process

Specific T1 Changes 

SRS-CCP WC Process 

Specific T2 Changes*

SRS-CCP General T2

Changes* 

RTR N/A New equipment or changes 

to approved equipment 

Changes to site procedures

requiring CBFO approvals

and other changes as

discussed in Section 8.3 of

this report 

VE and VET Changes in vendor

performing VE and/orVET 

N/A Changes to site procedures

requiring CBFO approvals

and other changes as

discussed in Section 8.4 of

this report 

WWIS N/A N/A Changes to site procedures

requiring CBFO approvals

and other changes as

discussed in Section 8.5 of

this report 

 * Upon receiving EPA approval, SRS-CCP will report all T2 changes to EPA every three months. 

 ** Modifications to approved equipment include all changes with the potential to affect NDA data relative to

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

EPA will notify the public of the results of its evaluations of proposed Tier 1 (T1) and Tier 2 

(T2) changes through the EPA Web site and by sending e-mails to the WIPPNEWS list (see 

Section 2.0, below, for a brief discussion of tiering). All T1 changes must be submitted for 

approval before their implementation and will be evaluated by EPA. Upon approval, EPA will 

post the results of the evaluations through the EPA Web site and the WIPPNEWS list, as 

described above. EPA will post T2 changes approximately every three months beginning with 

the date of EPA’s approval of the TRU WC program implemented at SRS-CCP. EPA expects 

the first report of SRS-CCP’s T2 changes approximately three months from date of EPA’s 

approval of the TRU WC program implemented at SRS-CCP. 

The scope of the proposed site baseline compliance decision is based on EPA’s inspection 

completed on November 3, 2005. EPA will not approve any changes to the SRS-CCP program

until this proposed baseline approval is finalized by EPA. 

Based on prior approvals, SRS-CCP is currently approved to dispose of debris waste (S5000) at 

the WIPP. SRS-CCP is permitted to continue WC and disposal of debris waste while EPA 

evaluates public comment to this proposed approval and establishes a final approval. 

2.0 PURPOSE OF INSPECTIONS 

On May 18, 1998, EPA certified that the WIPP will comply with the radioactive waste disposal 

regulations at 40 CFR Part 191. In this certification, EPA also included Condition No. 3, which 

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

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

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

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set forth in §194.8.” The approval process described at 40 CFR 194.8 requires DOE to 

(1) provide EPA with information on AK2

 for waste streams proposed for disposal at the WIPP, 

and (2) implement a system of controls used to confirm that the total amount of each waste 

component that will be emplaced in the WIPP will not exceed limits identified in the WIPP 

Compliance Certification Application (CCA). 

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

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

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

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

characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes 

destined for disposal at the WIPP. An EPA inspection team conducts an onsite inspection to 

verify that the site’s system of controls is technically adequate and properly implemented. 

Specifically, EPA’s inspection team verifies compliance with 40 CFR 194.24(c)(4), which states 

the following: 

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

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

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

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

limiting value described in the introductory text of paragraph of this section.3

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

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

schemes used; and other documentation. 

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

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

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

limits. By proposing the approval of WC systems and processes at SRS-CCP, EPA has 

evaluated the capabilities of systems and processes to accomplish two tasks: (1) the 

identification and measurement of waste components (such as plutonium) that must be tracked 

 2

 As of the FR notice of July 16, 2004, EPA has replaced the term process knowledge with acceptable

knowledge. Acceptable knowledge refers to any information about the process used to generate waste, material 

inputs to the process, and the time period during which the wastes were generated, as well as data resulting from the 

analysis of waste conducted prior to or separate from the waste certification process authorized by an EPA 

certification decision to show compliance with Condition 3 of the certification decision. 3

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

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

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

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

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for compliance,4

 and (2) the confirmation that the waste in any given container has been properly 

identified as belonging to the group of approved waste streams. 

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

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

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

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

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

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

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

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

inspection or approval under 40 CFR 194.24. This will be accomplished by assigning a tier level 

to each aspect of the characterization program. Tier 1 activities have more stringent reporting 

requirements and require that DOE notify EPA, and that EPA provide approval prior to 

implementation. Tier 2 activities are reported to EPA by DOE based on the frequency 

established in the inspection report. DOE may choose to operate at risk while EPA considers the 

proposed T2 changes. If SRS CCP contemplates a change that is not identified in this report, 

EPA recommends that the site in consultation with CBFO discuss the nature of the change with 

EPA. This would minimize a possibility of EPA not approving the site-assigned tiers. The rule 

under which this baseline inspection was conducted can be found in the FR (Vol. 69, No. 136, 

pages 42571–42583, July 16, 2004). 

3.0 PURPOSE OF THIS REPORT 

This inspection report presents the results of EPA’s inspection of the WC program at SRS-CCP 

and describes the conditions that EPA is proposing for approval. This report documents the basis 

for EPA’s proposed approval decision and explains the results of Baseline Inspection No. EPASRS-10.05-8 in terms of findings or concerns. Specifically, this report does the following: 

• Describes the characterization systems proposed for approval 

• Identifies all relevant system limitations and or conditions 

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

documentation, as applicable 

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

their relevance to EPA’s proposed approval decision 

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

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

should select an NDA technique that suits such waste in order for adequate measurements to be obtained. 

Radiography and VE help both to confirm and quantify waste components, such as cellulosics, rubbers, plastics, and

metals. Once the nature of the waste has been confirmed, the assay techniques then quantify selected radionuclides

in the waste. In some cases, a TRU waste generator site may be able to characterize a wide range of heterogeneous 

waste streams or only a few. A site’s stated limits on the applicability of proposed WC processes govern EPA’s 

inspection scope.

 5
The completed checklists attached to this report reference the documents that the EPA inspection 

team members reviewed in support of the technical determination. To see or obtain copies of 

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

Quality Assurance Manager 

USDOE/Carlsbad Field Office 

P.O. Box 3090 

Carlsbad, NM 88221 

EPA’s final approval decision regarding the SRS-CCP WC program will be conveyed to DOE 

separately by letter following the consideration of public comments on this report. EPA will also

announce the decision on its Web site at http://www.epa.gov/radiation/WIPP, in accordance with 

40 CFR 194.8(b)(3). 

4.0 SCOPE OF INSPECTION 

The scope of Baseline Inspection No. EPA-SRS-10.05-8 included the technical adequacy of the 

WC systems in use at SRS-CCP to characterize TRU wastes. These systems were evaluated with 

respect to their ability to perform the following: 

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

Am, 137Cs, 

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

systems 

• Assign waste material parameters (WMPs) correctly using RTR and VE for 

CH retrievably-stored solid and debris waste, and VET for newly-generated debris and 

soil/gravel wastes 

• Perform effective waste information (data) transfer using the WWIS 

Specifically, these systems consisted of the following components: 

• The AK and load management processes that support retrievably-stored S4000 soils and 

S5000 debris wastes 

• Two NDA systems (IPAN and IQ3 systems, as described in this report) for the analysis 

of CH retrievably-stored or newly-generated S4000 soil/gravel and S5000 debris wastes 

• VE as a QC check for RTR for retrievably-stored S5000 debris and S4000 soil and gravel 

wastes 

• VET for newly-generated S5000 debris and S4000 soil/gravel wastes 

• RTR for retrievably-stored S5000 debris and S4000 soil and gravel wastes 

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

destined for WIPP emplacement 

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

responsibility of the site being evaluated during the inspection, in this case SRS-CCP. EPA 

evaluated the WC processes implemented by the site to characterize CH retrievably-stored debris 

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and soils wastes, and newly-generated debris and soil. The evaluation consists of interviewing 

personnel, observing equipment operations that comport with the site procedures, and inspecting 

records related to each of the WC processes within the inspection’s scope. An important aspect 

of this evaluation is the objective evidence that documents effectiveness of the WC processes. 

Objective evidence typically takes the form of batch data reports (BDRs); radioassay datasheets; 

AK accuracy reports; VE, VET, and RTR tapes; and WWIS printouts for specific TRU 

containers. During this inspection, EPA selected samples of each of these items, based on the 

number and variety of items each WC process produced, consistent with standard auditing 

techniques. For example, the sample of NDA BDRs that were evaluated to verify compliance 

was chosen such that it included a contribution from both operating systems, represented all 

pertinent waste matrices, and spanned each system’s operating range to the extent possible. 

Based on the evaluation of the WC processes in conjunction with the sample of objective 

evidence, EPA determined the technical adequacy of the WC processes within the inspection’s 

scope. 

5.0 INSPECTION-RELATED DEFINITIONS 

During the course of an inspection, EPA inspectors may encounter items or activities that require 

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

The two main categories relevant to WC inspections are identified below: 

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

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

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

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

response. 

Note: Concerns not requiring a response are not required to be addressed prior to program

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

issue raised in the EPA concern, EPA should be informed concurrent with implementation of the 

corrective action in response to the concern similar to a T2 issue. 

6.0 PERSONNEL 

6.1 EPA Inspection Team 

The members of the EPA WC inspection team are identified below. 

EPA Inspection Team Members

Inspection Team Member Position Affiliation

Mr. Ed Feltcorn Inspection Team Leader U.S. EPA ORIA 

Ms. Rajani Joglekar Inspector U.S. EPA ORIA 

Ms. Connie Walker Inspector S. Cohen & Associates, Inc.

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

Mr. Patrick Kelly Inspector S. Cohen & Associates, Inc.

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6.2 Personnel Contacted 

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

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

they are listed in the table below, along with their affiliation and technical area. 

Personnel Contacted During Inspection

Personnel Affiliation Area of Expertise 

Robert Thomason MCS Canberra NDA, IQ3 

Bruce Gillespie BII NDA, IQ3

Thomas Peterson BII NDA, IPAN

Alan Simpson BII NDA, IPAN

Dave Haar CCP AK, SPM

Jeff Harrison CCP AK, AKE

Kevin Peters CCP AK, AKE

Lee Smith CCP RTR, SME & Operator 

Susan Smith CCP RTR, SME & Operator 

J.R. Stroble CCP WWIS, WCO 

James Mobley CCP VE/VET, VEE

Marcus Steade CCP VE/VET, VEE

Buddy Fusel CCP VE/VET, VPM

Maurice “Chip” Hatcher CCP VE/VET, Operator

Steve Piper CCP VE/VET, Operator

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

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

qualifications and training records of these individuals to assess their WC capabilities. Based on 

this evaluation, EPA determined that SRS-CCP WC personnel responsible for characterizing 

TRU waste and certifying it as TRU waste were qualified and had received adequate training to 

perform their assigned function. EPA is not requiring that SRS-CCP provide changes in the key 

areas of expertise every three months, beginning with the date of EPA’s SRS-CCP program

approval, as a T2 change. EPA, however, can ask the site about changes in the WC personnel 

anytime after the site approval at its discretion. If the key WC personnel changes had occurred, 

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

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

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

records is similar to the evaluation done by the EPA inspection team during each inspection. 

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7.0 PERFORMANCE OF THE INSPECTION 

Site Background and History

SRS is located in South Carolina approximately 25 miles southeast of Augusta, Georgia. It 

encompasses 310 square miles and occupies portions of Aiken, Barnwell, and Allendale counties 

on the western border of South Carolina. This site has played an integral role in supporting the 

production and maintenance of nuclear materials for the nation’s weapons program since its 

inception in 1951. Its current mission focuses more on waste stabilization and management, and 

a considerable part of that waste is CH TRU materials that are slated for disposal at WIPP. SRS 

also manages significant amounts of radioactive and chemical wastes, and the site’s current 

inventory of CH TRU waste in storage is approximately 2,900 cubic meters. SRS-CCP has been 

characterizing TRU wastes for WIPP since the site’s initial approval by EPA in 2001. 

Inspection Process Overview

EPA Inspection No. EPA-SRS-10.05-8 took place from October 31 to November 3, 2005. The 

inspection had the scope described in Section 4.0, above, for the purpose of determining the 

site’s compliance with 40 CFR 194.24. The inspection was conducted in the following steps: 

 

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

(2) Reviewing the results of EPA’s and CBFO’s previous inspections and audits of SRSCCP’s WC program, including findings/concerns identified by EPA and/or CBFO and 

corrective actions 

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

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

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

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

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

recording the results on checklists 

(6) Recording all concerns on EPA issue tracking forms, which were completed and 

provided to CBFO and site personnel as they were generated 

(7) Communicating all pertinent information with CBFO and SRS-CCP personnel on site, as 

appropriate 

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

discussions with CBFO and SRS-CCP personnel 

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

personnel, as appropriate 

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8.0 TECHNICAL WASTE CHARACTERIZATION AREAS 

8.1 Acceptable Knowledge and Load Management 

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

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

retrievably-stored soils/gravel and debris waste. See Item 4 below for CCP’s assertion that all 

SRS waste received for characterization by CCP would be considered retrievably-stored 

regardless of when the waste was generated, because CCP is the characterization entity and did 

not generate the waste. EPA’s evaluation of the CCP’s argument is also presented. 

Waste Characterization Element Description

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

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

process for containers and waste streams 

• Waste-generating procedures, processes, and documentation 

• Characterization of required WMPs and radionuclides 

• AK information assembly and compilation 

• AK confirmation and associated discrepancy resolution 

• Sufficiency of AK characterization results 

• Assembly of required information and use of supplemental information 

• AK summary preparation 

• Reassignment of waste stream due to AK and discrepancy analysis 

• AK accuracy 

• Load management 

The checklist included as Attachment A.1 identifies the objective evidence reviewed by the EPA 

inspector. AK is used to provide information regarding several aspects of TRU wastes at SRSCCP, including but not limited to the following: 

• Defense waste status 

• Material parameters 

• Waste stream 

• Radionuclide composition 

• Waste matrix codes (WMCs) 

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Documents Reviewed

During the inspection, EPA inspectors examined a variety of procedures and documents related 

to AK, including the following. Please note that because CCP does not assign unique identifiers 

to AK documents, the same reference number can apply to different references in different AK 

summaries. To avoid confusion, the AK summary report applicable to the specific reference has 

been added in parenthesis before the reference number, i.e., (AK8). 

• CCP-QP-002, Revision 17, CCP Training and Qualification Plan, June 6, 2005 

• CCP TP-005, Revision 15, CCP Acceptable Knowledge Documentation, March 31, 2005 

• CCP-TP-066, Revision 3, Radiography Screening Procedure for Prohibited Items, 

effective June 14, 2005 

• Inter-Office Correspondence, from Irene Quintana to CCP Records Custodian, Savannah 

River Site Summary Category Group S5000 Specific Miscertification Rate, May 19, 

2005 

• Burial Ground Record, Drum SR98079 (debris), January 11, 1979 

• TRU Waste Package Data), Drum 570782 (debris), 1990 

• Radioactive Waste Burial Ground Record), Drum 570782 (debris), July 1990 

• Retrievable Alpha Waste for Pad and Concrete Category Drum 570782 (debris), July 

1990 

• Transuranic Waste Container Characterization Form, Drum 773A-02-0021 (debris), 

December 9, 2003 

• SW15.3-SOP-CAND-01, Revision 15, Initial Screening of Candidate Drums (u), 

December 9, 2005 

• Attachment 12, Acceptable Knowledge Re-evaluation Checklist, SR SRS-W027-FBPre86-C waste stream, October 24, 2002 

• Program Tracking System (PTS)/Container Tracking System (CTS) Data Searches for 

Containers MDL050673, MDL0506241, 773A020021, SR570782, SR98079, printed 

November 2, 2005 

• NCR-SRS 0561 from CTS Tracking System, Use of IQ3, October 20, 2004 

• NCR-SRS 0289 from CTS Tracking System, No TRU Radionuclides Measured Above 

MDA for Container SR606827, February 22, 2005 

• Go-West Database Query, Containers SR57082, MDL0506073, MDL0506241, 

773A020021, SR98079, printed November 2, 2005 

• CCP Acceptable Knowledge Confirmation Checklist for SR-MD-SOIL, October 2005 

• Inter-Office Correspondence, from C.M. Gomez to S.B. Rose, Acceptable Knowledge 

Accuracy Report: Mound Site Transuranic Waste Stored at Savannah River Site, 

SR-MD-SOIL, Lot 1, October 18, 2005 

• Waste Stream Profile Form (WSPF) SR-SRS-W027-773A-HET, March 10, 2005 

 11
• (AK7) P010, Radioactive Waste Disposal-SRL (Procedure), DPSTOM-22-30, 1981 

• (AK7) P006, Savannah River Technology Center Procedures Manual L1, Procedure 6.24, 

SRS Revision 0-6, May 18, 1998 through August 8, 2002 

• (AK7) P001, Savannah River Plant, Management of Solid Radioactive Waste/Radiation 

and Contamination Control Including DPSCP 40: Burial Container Limits, SRS Special 

Hazards Bulletin and DPSOP 40 History, 1970–1980s, undated 

• (AK7) M028, Acceptable Knowledge Payload Management Calculations for CCP-SRS 

AK Reports 1–7, November 15, 2004 

• (AK7) M024, Radiological Evaluation for 773-A, Anne K Hallman, April 12, 2004 

• (AK7) M022, W017-773A-HET, 773A-29-90 WMP calculations, David Becker, April 7, 

2004 

• (AK7) D152, TWBIR Update 2004 for Compliance Recertification Application, 2004, 

Bev Crawford and Sheila Lott, LANL, DOE/WIPP 2004-3231, March 2004 

• (AK7) D122, Citation Determination and Evaluation of Waste Incidental to 

Reprocessing, K.J. Collins, LLW-SUP-99-0060, Revision 0, April 2000 

• (AK7) D077, Savannah River Laboratory Technical Progress Report Converter Fuel 

Cycle Technology, July–September 1978 

• (AK7) D061, Production of the Transplutonium Elements at Savannah River, C.H. Ice, 

DUPONT, DP-MS-66-69, October 10, 1966 

• (AK7) D020, Savannah River Laboratory Quarterly Report(s), Waste Management 

(1975), DPST-75-125-1, E. I. du Pont de Nemours & Company, January–December 1975 

• (AK7) C003, SRS-W027-773A-HET, DWPF Canister Fill Level Detector Cf-252 Source 

Replacement Radiation Dose Rates, M.O. Whitaker, ESH-HPT-900350, February 20,

1990 

• (AK7) C019, Savannah River Laboratory Actinide Technology Division Process Incident 

Report No. PI-ATD-83-1, J.H. Gray, DPST-83-907, October 13, 1983 

• (AK7) C023, Californium-252 Wastes on TRU Pads—Reassignment to LLW and 

Disposal, A Gibbs, SWD-SWE-99-00, October 18, 1999 

• (AK7) C040, For 773A AL RE: Dried Sludge, M. Bullington, September 11, 2003 

• (AK7) C068, High Level Caves Monthly Report, December 21, 1967–January 20, 1968 

• (AK7) D001, Westinghouse Savannah River Company, WSRC-TR-2002-00001-01 

through 12, Monthly Technical Reports, January through December 2002 

• (AK7) C074, Memorandum to Steve Rose from Jeff Harrison, RE: Evaluation of 

TWBIR Waste Streams for Building 773-A, May 18, 2004 

• (AK7) D037, Safety Analysis Savannah River Laboratory Technical Area, DUPONT 

Savannah River Laboratory, DPSTSA-700-38, September 1, 1988 

 12
• CCP-AK-SRS-7, Central Characterization Project Acceptable Knowledge Summary 

Report for Savannah River Site Building 773-A, Transuranic Debris Waste Stream SRSRS-W027-773A-HET, Revision 1, December 3, 2004 

• (AK7) M025, Evaluation of the Radiological Characterization of Waste Stream SR-SRSW027-773A-HET, July 23, 2004 

• (AK7) NDA-AK Memo, Evaluation of the Radiological Characterization of Waste 

Stream SRS-W027-773A-HET, August 31, 2004 

• Manual No. 1S, SRS Waste Acceptance Criteria Manual, Appendix A-23, Revision 5,

Transuranic Waste Container Form (OSR 29-90) Instructions, April 30, 2005 

• Savannah River National Laboratory, Transuranic Waste Procedure, Procedure 6.24, 

Revision 11, August 10, 2005 

• CCP-TP-005, Attachment 1, AK Documentation Checklist for SRS-W027-773A-HET, 

October 22, 2004 

• CCP-TP-005, Attachment 4, Source Documentation Reference List for SRS-W027-

773A-HET, October 17, 2005 

• CCP-TP-005, Attachment 6, Waste Forms, Waste Material Parameters, Prohibited Items 

and Packaging for SRS-W027-773A-HET, October 19, 2004 

• CCP-TP-005, Attachment 8, Waste Containers for SRS-W027-773A-HET, October 14, 

2004 

• CCP-TP-005, Attachment 1, AK Documentation Checklist for SR-MD-SOIL, October 

15, 2005 

• CCP-TP-005, Attachment 4, Source Documentation Reference List for SR-MD-SOIL, 

October 5, 2005 

• CCP-TP-005, Attachment 6, Waste Forms, Waste Material Parameters, Prohibited Items 

and Packaging for SR-MD-SOIL, September 23, 2005 

• CCP-TP-005, Attachment 8, Waste Containers for SR-MD-SOIL, September 23, 2005 

• CCP-AK-SRS-8, Central Characterization Project Acceptable Knowledge Summary 

Report for Mound Site Transuranic Waste Stored at Savannah River Site Waste Streams 

SR-MD-HET, SR-MD-SOIL, SR-MD-HOM-A, SR-MD-HOM-B, Revision 2, September 

23, 2005 

• Rockwell International, Letter from J.K. Paynter to B.C. Barrett, RE: Radionuclide 

Information Required for TRUPACT II Shipments; WCP8-20, N/A, March 23, 1989 

• (AK8) DR005, Discrepancy Resolution for all Waste Streams in SRS-AK-8, J. Harrison, 

August 17, 2005 

• (AK8) DR006, Discrepancy Resolution for Soil with Smaller Amounts of Debris, J. 

Harrison, NA, August 17, 2005 

• (AK8) IO31, Plutonium Working Group Report on Environmental, Safety and Health 

Vulnerabilities Associated with the Departments Plutonium Storage, Volume 2, 

Appendix B, Part 7, September 1994 

 13
• (AK8) IO82, Tables of TRU Waste Packages, 1980s 

• (AK8) P028, Mound Building 38 FSAR: Pu-239 Repackaging, Phase 1, Soil, 

T. Khericha, et al., Lockheed Idaho Technologies Complex, INEL-95/0519, Revision 3, 

June 1996 

• (AK8) P040, Executive Summary of TRU Waste at Mound, Revised September 15, 1993 

• WSPF SR-MD-SOIL, October 18, 2005 

• (AK8) CCP-TP-005, Attachment 8, SR-MD-HET, Waste Containers, August 12, 2005 

(includes explanation of misidentification of waste via RTR) 

• (AK8) M064, Email Correspondence (and attached RTR Data) from S. Rose to 

J. Harrison, RE: SR-MD-SOIL, October 10, 2005 

• MDL0506073, Transuranic Waste Characterization Container Form OSR 29-90 and 

Radioactive Waste Input Form, Drum SD006073, February 2005 

• MDL0506241, Transuranic Waste Characterization Container Form OSR 29-90, 

Radioactive Waste Input Form, Drum SD006241, January/February 2005 

• (AK8) P054, Mound Site Radionuclides by Location, Issue 1-3, MD 22153, Issue 1, 

Revision 3, 95, 98, 2000 

• (AK8) P056, Decontamination and Decommissioning Projects, Findings of No 

Significant Impact for Mound, undated (possibly 1995) 

• (AK8) P058, Mound Site Waste Management Reports and Site Plans, 1977–1980, 

Mound/Monsanto, June 1, 1977 

• (AK8) P064, Mound Site Waste Management Reports and Site Plans, 1981–1989, 

Monsanto Research Corporation, November 1, 1991 

• (AK8) P086, Mound Laboratory Environmental Plutonium Study, D.R. Rogers, MLM2249, Monsanto Research Corporation, September 15, 1975 

• (AK8) P120, Radioactive Waste Procedures—Loading/Sealing Transuranic Waste 

Destined for SRS in Drums, R.S. Tuning, MD-10167, ECN No. 040131MD, Revision 2, 

November 8, 2004 

• (AK8) U018, UGL Action Memo [EE/CA] Removal Action of Soil and Underground 

Waste Transfer Lines Leading to WD Building, CH2MHill, September 2003 

• Rockwell International, Letter from J.K. Paynter to B.C. Barrett, RE: Radionuclide 

Information Required for TRUPACT II Shipments; WCP8-20, N/A, March 23, 1989 

• (AK8) SRS-8, (Soils Only) NDA-AK Memo, Part of Attachment 7, Radiological 

Characterization Form CCP-TP-005, J. Harrison, September 6, 2005 

• (AK7) CCP-TP-005, Attachment 7, Radionuclides for SRS-W027-773A-HET, May 18, 

2004 

 14
Waste Container and Batch Data Reports Reviewed

BDRs for the following waste containers (55-gallon drums) were examined: 

Drum Number VE BDR No. RTR BDR No. NDA BDR No. Load Managed? 

773A020021 - SRRTR1316 SRNDA591 No

SR570782 - SRRTR1318 SRNDA573 No

SR98079 - SRRTR1316 SRNDA576 No

MDL0506241 SRVEMS0002 - SRNDA918 Yes

MDL0506073 SRVEMS0001 - SRNDA917 No

Technical Evaluation

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

retrievably-stored debris and soil waste, and made the following observations: 

(1) Data documentation and transfer were evaluated. 

EPA examined how radiological, waste material parameter (WMP) information, prohibited 

items, and other data are assembled and transferred through various databases at SRS. 

Information generated or assembled by the SRS generators is input by SRS into the Transuranic 

Waste Characterization Database. This database is an assembly point for characterization data 

(historic analytical data, AK information, data from SRS waste analysis activities, etc.) from

SRS generator sites, including data assembled using various characterization process controls 

implemented for the time periods prior to 1986, 1986–1998, and after 1998. Radiological and 

WMP information is documented on OSR Form 29-90 for waste generated after 1998. From this 

site-wide database, the Go-West database is generated, which includes information about TRU 

waste containers potentially eligible for disposal at the WIPP. The Go-West “screen” allows the 

user to access radiological, WMP, physical form, and other relevant information from the various 

historic databases. Information from the Go-West database is used to initially populate the CCP 

project tracking system (PTS) database maintained by CCP for each site, which is continually 

updated as WIPP-required NDE and NDA are performed. Container status is tracked within this 

system with respect to WIPP readiness, and the container tracking status (CTS) database is used 

to track, among other things, noncompliance (nonconformance reports or NCRs) for each 

container. This information is ultimately used to populate the WWIS. The process used by CCP 

is consistent with that implemented at other sites; the SRS site data acquisition and input process 

was not examined because it had been adequately demonstrated by the same personnel at other 

sites recently inspected and found to be adequate. 

(2) Calculation of AK accuracy was assessed. 

The AK accuracy calculations for the soil wastes from Mound, Lot 1, waste stream SR-SDSOIL, were evaluated. The AK accuracy report was based on five drums and showed that no 

changes to the waste management codes (WMC) or radionuclide distribution were required, so 

“accuracy” was 100%. The AK accuracy report provided for review did not include analytical 

data or other information required to assess whether the determination was valid. Further, the 

report was apparently assembled after the performance of QuickScan, which showed 40 of the 53 

 15
soil containers to have been misidentified, in that the 40 containers should have been identified 

as debris (see Item 8, below). Without the use of QuickScan or other methods, the original AK 

record in this case was not accurate, i.e., misidentifying 40 of the 53 containers corresponds to an 

AK summary waste category group accuracy of 24%. EPA has allowed the use of QuickScan in 

the past for the purpose of augmenting a poor AK record, and this appears to be a prudent 

method for assessing waste content, particularly for the example cited above. This action should 

be clearly recognized in the AK accuracy calculation, as it means that the original AK was 

lacking. See Item 8 below for additional discussion of QuickScan results for soils. In addition, 

the AK confirmation checklist for SRS-W027-773A-HET was examined, which showed that 

232Th was apparently present in this lot, even though AK predicted it would occur in only a few 

containers. The site staff did not reevaluate the stream because they did not believe enough of 

the waste stream had been characterized to warrant this action. This implies that data are 

available that show 232Th to be present in more than the anticipated containers, which was 

apparently not detected in the five containers comprising Lot 1 described in the AK accuracy 

report. The AK accuracy report is of limited value, because it is not sufficiently specific with 

respect to nuclide comparisons 

(3) AK-NDA communication was assessed. 

AK-NDA communication is presented in the AK-NDA memos for the Mound Soil and 

Building 773 debris. The SRS-W027-773A-HET waste stream was generated in a facility that 

performed experimental work. While data showed that 238U and 239Pu will be the predominant 

nuclides by weight, any number of additional nuclides may be present on an individual container 

basis (252Cf, 244Cm, etc.). The memo stated that AK personnel will provide a disk to NDA 

personnel containing container-specific AK radiological information, and that the NDA 

personnel will look at AK assay data for each drum, comparing and using that information in 

conjunction with their NDA results. The NDA memo is generally sufficient, but should include 

references for the 1, 1.4, and 1.57 90Sr/137Cs ratios used; further, the specific calculation used to 

determine 234

U should be provided or referenced, as should the scaling factors used for 242Pu. 

This stream is unique in that NDA personnel will review individual drum AK data as part of 

their assessment process. 

In the case of SR-SD-SOIL, the NDA memo indicates that 238Pu and 237Np are the most 

prevalent nuclides by weight, while 238Pu and 241Am are the most prevalent nuclides by activity. 

CCP expects this waste stream to be comprised almost exclusively of heat-source 238Pu. Drumspecific radioassay data generated by Mound are available on a per-container basis, but it does 

not appear that NDA personnel will use these. The memo is generally adequate, although the 

derivation or technical basis for the derivation of the scaling factors used for 242Pu and 234U 

should be justified through reference or additional text. Further, all assumptions of 

“conservatism” must be explained. 

(4) The CCP interpretation of newly-generated waste was evaluated. 

During the EPA inspection, SRS-CCP offered an interpretation of the definition of newlygenerated vs. retrievably-stored waste. CCP stated that all waste it receives from SRS to

characterize should be considered retrievably-stored waste, regardless of when the waste was 

generated. CCP believes this is appropriate because the definition of newly-generated waste vs. 

retrievably-stored waste hinges on approval of the CCP program compliance with NQA-1. CCP 

 16
asked that the definition of newly-generated be predicated upon approvals for the 

characterization entity, noting that in the case of SRS, CCP does not generate any waste, so all 

waste received from SRS would be considered retrievably-stored. At SRS, CCP defines itself as 

a characterization entity and not a generation program. EPA agreed to assess this approach; the 

results of this assessment follow. 

The newly-generated/retrievably-stored distinction is a DOE construct. EPA’s rule does not 

identify or define newly-generated and retrievably-stored waste, and EPA’s Compliance 

Application Review Document (CARD) Nos. 22 and 24 mention this terminology only in a 

limited sense. However, DOE specifically defines newly-generated and retrievably-stored waste. 

Chapter 4 of the Compliance Recertification Application (CRA) states the following: 

Waste generated after 1970, but before implementation of [a] CBFO certified 

waste quality assurance (QA) program is referred to as retrievably-stored waste. 

Waste generated after a site’s implementation of [a] CBFO certified QA program 

is defined as newly-generated. 

Based on this, there is a clear mechanism for distinguishing newly-generated and retrievablystored waste proposed by DOE that is related to waste generation and CBFO certification of the 

site generating the waste. EPA requires that entities involved with activities that directly impact 

quality comply with the NQA requirements, which is one reason why CCP must be approved. 

However, it appears that the newly-generated/retrievably-stored distinction is keyed to DOE’s 

own approval of sites and is linked to waste generation, not characterization. Therefore, based 

upon DOE’s own documentation and EPA’s understanding that SRS still has an “approved QA 

program” related to waste generation activities, the newly-generated distinction cannot be linked 

to characterization activities, as this contradicts DOE’s own requirements. 

This distinction means that waste stream SRS-W027-773A-HET has both a newly-generated and 

retrievably-stored component. EPA’s evaluation of ongoing process controls and 

characterization activities shows that approval of both the newly-generated and retrievablystored components of this waste stream, and others similar to it, is technically valid. Therefore, 

EPA proposes to expand the scope of this proposed approval to include both newly-generated 

and retrievably-stored debris and soil waste, noting the specific exclusions stated in Tiering 

Element 1, below. 

(5) Physical waste descriptors were evaluated. 

CCP assigned the S5400 WMC to debris waste originating from the SRS laboratories in 

Building 773. S5400 is defined as follows: 

Waste that is at least 50% by volume debris materials that do not meet the criteria 

for assignment as either Inorganic (S5100) or Organic (S5300) debris. An 

example is waste that is essentially entirely debris, but is not dominant (i.e., 

estimated to be 80% by volume or more) in either inorganic or organic debris 

materials. Another example is waste that is at least 50% by volume debris 

materials, with the balance being soil (S4000) or homogeneous solids (S3000’s). 

 17
The AK summary states that waste stream SRS-W027-773A-HET is comprised of a variety of 

debris materials, with no specific material percentages provided. The content of waste generated 

after 1998 is controlled by processes documented on the OSR Form 29-90, which requires 

identification of WMPs, radionuclides, etc. The CCP AK expert (AKE) indicated that CCP 

performed an analysis of AK data obtained after 1998 to determine whether the S5400 waste 

category was accurate. This analysis showed the SRS-W027-773A-HET waste stream to be 

comprised of 82% organics and 18% inorganics [(AK7) M022]. Further, CCP personnel also 

assessed WMP AK data for waste generated from 1986–1990 and found this waste to contain 

about 78% organics. CCP rejected the use of information presented in M022 because it 

represented a “small portion” of the 773 waste streams (i.e., 89 drums of 1500). It is unknown 

how many drums were included in the 1986–1998 data analysis. When interviewed, CCP site 

personnel rejected assigning a more accurate WMC of S5300 (greater than 80% organics) 

because CCP representatives felt that SRS process/administrative controls had a very low 

reliability with respect to accurately documenting WMP content. 

Available data reviewed during the inspection showed that S5300 would be a more accurate 

WMP assignment for SRS-W027-773A-HET than S5400. By assigning the waste to the more 

general waste category, the waste is almost ensured of showing 100% accuracy with respect to 

“matching” the assigned WMC. EPA recommends that accurate WMP data be acquired, 

particularly since with 100% VE and RTR performed on waste, this information is available. 

Therefore, the misassignment of WMC, while noted, does not jeopardize WMP identification at

this time. However, should the requirement to perform VE or RTR be reduced in the future, the 

assignment and determination of WMP percentages based on the AK record will be imperative, 

and EPA would need to review for appropriateness the more general assignment because it 

would not result in an adequate AK determination of WMPs. Further, this approach invalidates 

all AK accuracy calculations performed based on WMC agreement between AK and NDE. 

(6) The inclusion of high-level waste in waste stream SRS-W027-773A-HET was assessed. 

The AK summary and several supporting documents (e.g., P001, P006, M024, D122, D077, 

C068, C040, CCP-AK-SRS-7) were reviewed to evaluate whether high-level wastes were 

generated in Building 773, and whether any of these wastes would be included in SRS-W027-

773A-HET. References examined acknowledge that high-level waste has been generated, but 

CCP removed any mention of the waste from the most recent revision (Revision 1) of CCPAK-7 (it was mentioned in the previous version, Revision 0). High-level waste is prohibited 

from disposal at the WIPP, so CCP must ensure that the AK record associated with any waste 

formerly identified as being high-level but now considered for inclusion in this or any other 

WIPP-bound waste stream must be adequately justified and supported. To document this as an 

EPA issue, we provided the following AK concern during the inspection, which did not require a 

response: 

Several AK references (e.g., C040) indicate that the Savannah River Technology 

Center generates Waste Stream SR-SRS-W027-773A-HET (debris) that may 

contain materials identified as High Level Waste (HLW). An earlier revision of 

AK-7 (SR-SRS-W027-773A-HET) included the HLW component that has since 

been removed in the latest revision of the AK summary. The AK record must 

include why this information was removed from AK-7. Also, in the future, CCP 

must adequately document and justify the inclusion of any waste in AK-7 

 18
previously or currently identified as being high level. [See EPA Issue Tracking 

Form No SRS-CCP-AK-05-005] 

(7) The definition of waste stream was evaluated. 

SRS-W027-773A-HET was created through combination of three previously identified 

individual waste streams, as presented in the 2002 Transuranic Waste Baseline Inventory Report 

(TWBIR). All three of the parent streams were described as comprising debris created by “job 

control” actions performed in Building 773, with the distinctions made based apparently upon 

chemical content of the waste. CCP reassessed this subdivision and elected to combine the 

streams because two of the streams actually contained the same chemicals, even though one 

stream identified the chemical in a certain manner, while the other waste stream did not. The 

third stream was added due to the potential presence of a metal that would warrant inclusion in 

the same chemical groupings as the other streams. 

The waste streams are also described as containing very large metal items (e.g. several feet in 

length, width, and height). These materials may originate from decontamination and 

decommissioning (D&D) activities that may not be considered normal “job control” waste, 

noting that “job control” can include size reduction of larger items, such as gloveboxes or other 

similar wastes generated when processes are changed or when equipment is upgraded, modified, 

etc. EPA expects CCP to carefully examine the definition of waste stream SRS-W027-773AHET when it considers including large objects in the future. Using EPA Issue Tracking Form

No. SRS-AK-05, EPA expressed the following concern that did not require a response during the 

inspection: 

AK reference D152 indicates that wastes in SR-SRS-W027-773A-HET include 

large items such as boxed wastes. This waste stream is classified as job control 

waste that typically excludes large metal items like those found in SR-SRS-W027-

773A-HET. The AK Summary (AK-7) does not yet address the boxed waste 

component and CCP is encouraged to assess whether the boxed waste belongs in 

SR-SRS-W027-773A-HET based on the similarity of processes, physical form and 

material type. [See EPA Issue Tracking Form No SRS-CCP-AK-05-004] 

(8) The inclusion of QuickScan and invalidated RTR information in the AK record was 

examined. 

Mound originally identified 53 containers in waste stream SR-SD-SOIL. SRS-CCP conducted 

RTR on 10 of these containers, but it was discovered that the person that conducted this 

characterization activity was not trained with respect to soil matrices, so RTR results could not 

be used as RTR data. However, information obtained indicated that the summary category group 

within the drums could have been misidentified, so SRS-CCP apparently performed QuickScan 

on all 53 containers. As a result, 40 of the 53 containers were found to technically contain 

“debris” rather than soil, noting that this distinction is based on the percentage of debris content 

within the container, not a vast misidentification of material content in the waste. Nevertheless, 

40 of the 53 containers were removed from the SR-SD-SOIL waste stream as a result of this 

action. 

 19
(9) Training was examined. 

Training records for the AKEs and site project manager (SPM) were examined. All had 

completed the assigned reading, and most had taken additional external and internal classes 

pertaining to RCRA and other technical areas. However, none appeared to have received 

training specific to 40 CFR 194.8 or 194.24 requirements, which are both pertinent to EPA’s WC

and inspection processes. Training in this area is recommended. 

(10) Sample AK summary report contents were examined, including load management. 

CCP-AK-SRS-8 and CCP-AK-SRS-7 were examined. By and large, both documents were well 

written, easy to follow, and complete. The AK summary for SR-SRS-W027-773A-HET 

included load management, and sufficient information was provided to substantiate this 

information (e.g., M024, M025). Comparison of select references with information in each of 

the documents showed that the supporting references were adequately reflected in the body of 

each AK summary. Analytical data examined as part of the traceability analysis showed that one

Mound soil container, MDL0506241, exhibited an NDA measurement less than 100 nCi/g. It is 

recommended that CCP-AK-SRS-8 be revised to address load management for this waste stream

and other Mound waste streams, if applicable. Further, it is recommended that CCP examine 

NDA-AK memos for both SR-SD-SOIL and SR-SRS-W027-773A-HET to ensure that the 

radiological discussions in each coincide. 

(11) Management of waste generation and waste contents by site process controls was 

examined. 

SRS-CCP included historic process controls (e.g., (AK7) P006, (AK7) P001) in the AK record to 

demonstrate that SRS had procedurally controlled waste content to exclude high-level wastes 

from the SR-SRS-W027-773A-HET waste stream. Further, SRS uses process controls to ensure 

that waste contents are appropriately identified, the results of which are documented on the OSR 

Form 29-90 that are one input to the Transuranic Waste Characterization Database. Note that 

current OSR Form 29-90 do not require identification of prohibited items as a line item, but the 

body of Manual No. 1S, Appendix A-23, which includes waste container form (OSR 29-90) 

instructions, does require the individuals packaging the waste to ensure that the prohibited items

are not included. The inclusion of relevant process controls in the AK record appears 

appropriate, particularly when these controls show that process controls were historically in 

place to manage waste. 

(12) Limitations and exclusions in the AK record were assessed. 

Data limitations are presented on the CCP-TP-005, Attachment 3, “Source Document 

Summary,” and are a good way to ensure that AK data are used appropriately and in context. 

Data limitations identified in the Attachment 3 samples examined were technically appropriate 

and relevant. 

 20
(13) Overall procedural technical sufficiency and scope and ability to follow the AK WC 

process for containers and waste streams were evaluated. 

CCP provided eight separate AK summaries (CCP-AK-SRS, Nos.1–8), from which two waste 

streams were randomly selected for review. AK Summary CCP-AK-SRS-7 included AK data 

for waste stream SRS-W027-773A-HET that consisted of debris waste generated through “job 

control” activities in laboratory building 773. A final WSPF for this waste stream was also 

provided, which included a completed Characterization Information Summary (CIS). A data 

traceability analysis showed that the randomly selected containers exhibited radiological and 

physical characteristics consistent with the descriptions presented in the AK summary and 

WSPF. CCP also provided AK Summary CCP-AK-SRS-8, which included AK data for waste 

stream SR-MD-SOIL, consisting of soil generated through remediation and D&D work at the 

Mound facility. A WSPF for this waste stream was also provided, including a draft CIS. A data 

traceability analysis showed that the randomly selected containers exhibited radiological and 

physical characteristics consistent with the descriptions present in the AK summary and WSPF, 

although one drum had less than 100 nCi/g TRU alpha waste, so the stream would require load 

management if this container were to be shipped to the WIPP. 

(14) Defense origin of waste was examined. 

CCP-AK-SRS-7 and CCP-AK-SRS-8 both include Section 4.2.1, which addresses defense 

determination. Information presented in this section and derived through interview of the AKEs 

indicated that while nuclides in SR-MD-SOIL may have both defense and nondefense origin, the 

nature of the waste (i.e., remediation waste) makes differentiation of nuclides by origin difficult. 

EPA expects DOE to determine the defense waste status for all waste intended for all disposal at 

the WIPP. EPA’s role is to verify that the waste identified as defense-related is properly 

characterized and complies with the regulatory limitations at 40 CFR 194.24. 

(15) AK information pertaining to radiological characteristics of waste was examined. 

Radiological information presented in each AK summary pertinent to SR-MD-SOIL and 

SRS-W027-773A-HET was examined for adequacy and supportability by references and through 

interview. Waste stream SR-MD-SOIL is thought to comprise primarily heat source 238Pu (and 

related daughter products), although because the waste originated from a waste line leak, it could 

also contain 239Pu and other nuclides. Note that AK suggests each drum from Mound underwent 

NDA prior to shipment, and this information would have been entered into the Transuranic 

Waste Characterization Database (with data apparently transferred to OSR Form 29-90 as well). 

The AK summary included isotopic distributions for heat-source, weapons-grade, and plutonium

neutron sources. A review of select references supports the premise that 238Pu will most likely 

be the predominant nuclide present in soil, but that other nuclides may be present (e.g., 

(AK8)DR005, (AK8)I082, (AK8)P028, (AK8)P040 and (AK8)P054). Note that the AK 

summary states that AK did not show any drums to be less than 100nCi/g TRU alpha, but one 

container measured by SRS-CCP had a TRU alpha concentration of less than 100nCi/g. 

Radiological data for SRS-W027-773A-HET indicates that the waste may contain any number of 

individual radionuclides because the waste was generated primarily through research and 

development. SRS-CCP expects 238U and 238Pu to be the most prevalent nuclides by mass, but 

any number of individual nuclides may be present, including several that are not TRU. Table 5-2 

 21
of CCP-AK-SRS-7 shows there could be any of 50 different radionuclides present in quantities 

varying from trace to almost 100% by weight (depending upon the nuclide). Further, the table’s 

footnotes cite several caveats and additional considerations with respect to nuclide content, 

including consideration of daughter products, identification of thorium-bearing containers, etc. 

Review of select references pertinent to nuclide content in this waste stream shows that the 

stream may indeed consist of several different radionuclides (e.g., (AK7)D152, (AK7)M024, 

(AK7)D122, (AK7)D061, (AK7)D020 and (AK7)C003). As required in “Contact-Handled 

Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant (CH-WAC),” 

Appendix E, each drum must contain measurable TRU isotopes, so this waste stream will require 

particular scrutiny in the future to ensure that each container complies with this requirement. 

 

Inspection Issues

Findings 

The EPA inspection team did not identify any findings in the areas of AK or load management 

during the inspection. 

Concerns 

The following two concerns were identified, neither of which require a response: 

EPA Inspection Issue Tracking Form, Issue No. SRS-CCP-AK-05-004C: AK reference 

D152 indicates that wastes in SR-SRS-W027-773A-HET include large items, such as boxed 

wastes. This waste stream is classified as job control waste that typically excludes large metal 

items like those found in SR-SRS-W027-773A-HET. The AK Summary (AK-7) does not yet 

address the boxed waste component and CCP is encouraged to assess whether the boxed waste 

belongs in SR-SRS-W027-773A-HET based on the similarity of processes, physical form and 

material type. 

EPA Inspection Issue Tracking Form, Issue No. SRS-CCP-AK-05-005C: Several AK 

references (e.g., C040) indicate that the Savannah River Technology Center generates Waste 

Stream SR-SRS-W027-773A-HET (debris) that may contain materials identified as High-Level 

Waste (HLW). An earlier revision of AK-7 (SR-SRS-W027-773A-HET) included the HLW

component that has since been removed in the latest revision of the AK summary. The AK 

record must include why this information was removed from AK-7. Also, in the future, CCP 

must adequately document and justify the inclusion of any waste in AK-7 previously or currently 

identified as being high-level. 

Resolution of AK Issues

Neither Issue No.SRS-CCP-AK-05-005 nor SRS-CCP-AK-05-004 required a written response 

from CCP. 

Proposed Baseline Approval

 

The AK and load management systems evaluated during this baseline inspection are approved 

for CH retrievably-stored and newly-generated debris and soil waste. 

 22
Proposed AK Tiers

Based on the inspection and the results discussed above, EPA proposes to assign the following 

tiers: 

Tier 1 AK changes that will require EPA review and approval prior to implementation and 

apply to any new waste category not evaluated during the baseline inspection include the 

following: 

• Categories of waste not approved under this baseline (e.g., solids) 

• Any waste identified outside of the waste profiles included in the 2002 TWBIR 

• Newly-generated soil or debris waste streams created through remediation or D&D 

activities 

Tier 1 changes will be reported and documentation will be submitted when SRS-CCP is ready 

for EPA review. Upon initial review, EPA will inform SRS-CCP and CBFO whether a site 

inspection is necessary. EPA may request additional information, choose to conduct a desktop 

review, and/or confer with SRS-CCP AK personnel. Upon AK evaluation with or without site 

inspection, EPA will issue a decision. Only upon receiving EPA written approval may SRS-CCP 

dispose of the new waste at the WIPP. 

Tier 2 AK changes that do not require EPA approval prior to implementation but require 

reporting and submitting documentation discussing changes by SRS-CCP include the following: 

• Changes made to AK procedure(s) that require CBFO approval 

• WSPFs, including updates or additions to WSPFs for waste streams within approved 

waste categories 

• Changes in load management status of approved waste streams 

• Revisions to AK-NDA Memos for Waste Streams SR-SD-SOIL and W027-773A-HET 

Every three months following EPA approval, SRS-CCP will provide EPA with information 

concerning T2 changes. EPA will evaluate these changes and communicate with CBFO and 

SRS-CCP as to whether the changes raise any concerns and require an SRS-CCP response, or 

whether SRS-CCP can continue to implement the changes. 

8.2 Nondestructive Assay 

EPA inspected two NDA systems to be used by SRS-CCP to characterize TRU wastes, the MCS 

IQ3 gamma system and the BII IPAN/GEA system. Both systems had been evaluated and 

approved by EPA for characterizing TRU wastes at SRS previously. As part of the inspection, 

EPA reviewed the following elements of the NDA process: 

• Capability of the measurement hardware and software to perform the required analyses 

for the radionuclides and wastes of interest

 23
• Technical adequacy of the NDA documents, procedures, and controls 

• Knowledge and understanding of the personnel involved in the NDA program

The checklists in Attachments A.4 and A.5 identify the specific pieces of objective evidence that 

were examined and used to complete the technical assessment for each of the two NDA systems 

with the inspection’s scope. 

 Documents Reviewed

The list of documents provided below, in conjunction with those listed in the NDA checklists, 

includes all documents related to NDA that were evaluated to support the assessment of the MCS 

IQ3 at SRS-CCP. The documents that pertain to both the IQ3 and IPAN/GEA NDA systems in 

general are provided following the IQ3 list. 

MCS IQ3 System

• CPP-TP-047, CCP IQ3 Gamma Scanner Operation, Revision 5 

• CCP-TP-048, Mobile IQ3 System Data Reviewing, Validating and Reporting Procedure, 

Revision 7 

• MCS-SRS-NDA-0504, Calibration and Verification Report for the Range Extension of 

the MCS IQ3 at the Savannah River Site, Revision 0, June 11, 2004. 

• MCS-SRS-NDA-0203, Calibration and Verification Report for the MCS IQ3 at the 

Savannah River Site, Revision 3, March 22, 2005 

• MCS-SRS-NDA-0203, Calibration and Verification Report for the MCS IQ3 at the 

Savannah River Site, Revision 4, September 29, 2005 

• MCS-SRS-NDA-TMU-0203, Total Measurement Uncertainty for the MCS IQ3 at the 

Savannah River Site, Revision 1, June 10, 2004 

• MCS-SRS-NDA-TMU-2003, Total Measurement Uncertainty for the MCS IQ3 at the 

Savannah River Site, Revision 1, June 10, 2004 

IPAN/GEA System

• CCP-TP-024, CCP Mobile IPAN/GEA Operating and Data Generation Level Review, 

Revision 20 

• CCP-TP-025, CCP Mobile IPAN/GEA Expert Analysis, Revision 10 

• CCP-TP-026, CCP Mobile IPAN/GEA Calibration, Revision 6 

 24
• BII-5104-QAO-001, BII Mobile Assay System Quality Assurance Objective (QAO) 

Compliance, Revision 7, January 2005 

• BII-5104-TMU-001, Total Measurement Uncertainty for the BNFL Instruments Mobile 

Assay System, Revision 1, August 2001 

• BII-5104-CTR-001, Mobile Assay System Calibration Test Report for SRS Operations, 

Revision 3, August 2001 

Documents Related to the IQ3 and IPAN/GEA NDA Systems

• CCP-AK-SRS-7, Central Characterization Project Acceptable Knowledge Summary 

Report for Savannah River Site Building 773-A, Transuranic Debris Waste Stream SRSRS-W027-773A-HET, Revision 1, December 3, 2004 

• CCP-AK-SRS-8, Central Characterization Project Acceptable Knowledge Summary 

Report for Mound Site Transuranic Waste Stored at Savannah River Site Waste Streams 

SR-MD-HET, SR-MD-SOIL, SR-MD-HOM-A, SR-MD-HOM-B, Revision 2, September 

23, 2005 

• CCP-AK-SRS-6, Central Characterization Project Acceptable Knowledge Summary 

Report for Savannah River Site Building 235-F Transuranic Debris Waste Stream SRW027-235F-HET, Revision 2 

Batch Data Reports and Waste Containers Reviewed

During the course of this inspection, NDA Batch Data Reports (BDRs) were evaluated for both 

systems. The specific BDRs that were evaluated are listed below by their SRS-CCP identifier 

followed by the system on which each was generated. 

• SRNDA683 – IQ3 

• SRNDA852 – IQ3 

• SRNDA788 – IQ3 

• SRNDA731 – IQ3 

• SRNDA715 – IQ3 

• SRS-NDA-050412 – IPAN/GEA 

• SRS-NDA-050721 – IPAN/GEA 

• SRS-NDA-050825 – IPAN/GEA 

• SRS-NDA-050912 – IPAN/GEA 

Radioassay Data Sheets for individual waste containers (drums) from the BDRs listed above 

were chosen at random and evaluated in detail, as delineated in the checklists in Attachments A4 and A-5. The numbers of the containers evaluated are listed below, preceded by the number of 

the BDR from which they originated and the system on which each was generated: 

• SRNDA683 – IQ3: HBL03103, SR513885, SR5608448, SR5608399 and SR5608415 

 25
• SRS-NDA-050721 – IPAN/GEA: SR501764, SR518613, SR519719 and SR5101102 

• SRS-NDA-050412 – IPAN/GEA: SR526637, SR173563, SR530020 and SR5546347 

Waste Characterization Element Description: MCS IQ3

The MCS IQ3 NDA system is housed in a trailer located at TRU Pad 4 of E-Area of the Solid 

Waste Management Area of SRS. This system had been evaluated previously by EPA on several 

occasions, most recently EPA Inspection No.CCP-SRS-09-04.24, EPA Docket A-98-49, II-A4-

50, and had been approved for WIPP assays prior to this inspection. The IQ3 had not been 

relocated since EPA certified it initially although there had been some system changes, 

specifically relative to the detectors’ configurations that EPA had evaluated and approved for use 

in characterizing TRU wastes for WIPP. 

The IQ3 is a multi-detector gamma detection system consisting of the following: 

• Three (3) Segmented Germanium (SeGe) coaxial detectors for direct measurement of 

radionuclides 

• Three (3) Low Energy Germanium (LEGe) detectors for isotopic determinations 

• Separate electronics and software to support each set of gamma detectors 

The system runs Canberra’s Gamma Waste Assay System (GWAS) software and is currently 

configured to quantify 238Pu, 239Pu, 233U, 235U5

, 238U, 241Am and 137Cs by direct measurement as 

well as other gamma emitting radionuclides contained in a variety of waste matrices. The 

remaining WIPP-tracked radionuclides 234U, 240Pu and 242Pu are quantified using computational 

techniques based on known or established relationships with other measured quantities. Typical 

SRS wastes are predominantly Weapons Grade Plutonium (WG Pu) or Heat Source Plutonium

(HS Pu), i.e., 239Pu or 238Pu, respectively. In some cases waste drums will contain a mixture of

both. When the activity of 238Pu dominates, radionuclides including 238Pu, 239Pu, 241Am, 233U, 

235U, 238U, 137Cs, and 237Np are quantified by direct measurement. For waste containers where 

the activity of 239Pu dominates, values for radionuclides such as 238Pu, 240

Pu, and 242Pu are 

generally obtained from measured isotopic ratios that were based on the Multi Group Analysis 

(MGA) software using LeGe data 

Technical Evaluation

(1) The design of the IQ3 was assessed. 

The IQ3 system assays the gamma-ray emitting nuclide content of a 55-gallon (208-liter) drum

by using 3 three high purity germanium (Ge) gamma-ray detectors arranged in a vertical line or

“stack” that effectively delineates three horizontal segments; the entire height of the drum is 

viewed by the three detectors. Shielded 133Ba transmission sources are located 180o opposite the 

SeGe detectors such that gamma rays from each source pass through the drum axis to its 

corresponding SeGe detector. This allows the determination of gamma radiation absorption by 

the drum matrix in the horizontal plane of the source. During the assay, the drum is rotated on a 

turntable to provide an average of radial in-homogeneities. 

 5 235U is not one of the 10 WIPP tracked radionuclides but is quantified because it contributes to a

container’s Fissile Gram Equivalent (FGE) and it is used in conjunction withal 238U in the derivation of 234

U. 

 26
Two measurement methodologies are employed in MCS IQ3 system; segmented analysis and 

summed spectrum multicurve density mode analysis. The segmented analysis applies a 

transmission source correction to account for gamma-ray attenuation in each segment, an 

approach that applies to a wide variety of waste types at SRS. However for routine assays, a 

transmission-corrected system cannot compensate for increasing matrix densities beyond a 

certain point. Therefore, in addition to the transmission-corrected component of the 

measurement, the system performs analyses in the summed spectrum multicurve density mode 

for denser materials. This analysis mode applies to waste drums with bulk densities up to a 

maximum of 2.1g/cm3

. The system had previously been approved to a maximum waste density 

of 1.7 g/cm3

, which was changed to the current limit in September 2005 based on the addition of 

calibration data from a concrete matrix drum with a density of 2 g/cm3

 to the multi-density 

calibration files. The current configuration of the IQ3 that incorporates these two operational 

modes is adequate to assay the waste matrices observed at SRS. 

(2) System calibration of the IQ3 had been performed and confirmed, and documented, as 

required. 

Several types of calibration were performed on the IQ3, all of which are described and detailed 

in CCP-TP-046. These include calibrations for energy versus channel, efficiency, transmission 

and reference peak, all of which are discussed below. All calibration-related activities are 

documented in Verification Report for the Calibration and MCS IQ3 at the Savannah River Site, 

MCS-SRS-NDA-0203, Revisions 3 and 4. Only Revision 4 of this document was reviewed 

specifically in conjunction with this inspection, because it reflected changes to the IQ3 since the 

last EPA inspection, specifically the following two major changes: 

• Extension of the mass calibration range for 238Pu and 239Pu on March 22, 2005 

• Extension of the density calibration range for 238Pu and 239Pu in Summed Spectrum

Mode on September 27, 2005 

As a result of these changes, the document was modified, most notably as follows: by adding 

sections to present new measurement data to support the proposed changes; revising the 

Calibration Qualification Summary; and, making minor editorial changes and corrections of 

Tables, as appropriate. However, some of the text in this report did not change between 

revisions. 

The calibration of the IQ3 in the extended range mode using attenuator caps is documented in 

Calibration and Verification Report for the Range Extension of the MCS IQ3 at SRS, MCS-SRSNDA-0504, Revision 0. The extended range mode calibration was evaluated by EPA during 

EPA Inspection No. EPA-CCP-SRS-09.04-24 conducted in September 2004, and subsequently 

approved. No changes relative to this operational mode were disclosed by SRS-CCP and none 

were noted by the EPA inspection team during this inspection. 

Energy Calibration: Energy calibration for the SeGe detectors was performed on February 17, 

2003, using the 241Am/

152Eu gamma mixed gamma line sources described below. The gain and 

offset for these detectors were set to nominally 0.500 keV/Ch and 0.0 keV, respectively. The 

efficiency calibration was performed at SRS in 2003 with a set of six (6) NIST-traceable 

 27
241Am/

152Eu gamma mixed gamma line sources from North American Scientific Inc. The sources 

were placed in 55-gallon drums that contained matrix materials with densities ranging from

0.015 to 1.69 g/cm3

. The certificates for these sources were examined during the inspection. 

The energies of the 241Am/

152Eu mixture are appropriate in that they cover gamma emissions 

from 59.5 to 1408 keV, which brackets the range of gamma energies of interest in SRS TRU 

wastes. 

Efficiency Calibration: The efficiency calibration of record for this instrument is based on the 

data collected by SRS on January 22, 2003, and was approved for use and installed on the IQ3 on 

January 23, 2003. The efficiency calibration technique is consistent with ASTM Standard Test 

Method C1133, which formerly described a mass versus count rate calibration only. Another 

document was needed to provide the complete technical basis for the contention that the 

efficiency calibration method is equivalent to the mass versus count rate calibration6

. However, 

ASTM Standard Test Method C1133 was recently revised and now states explicitly that the 

efficiency calibration method is equivalent to a mass calibration.7

The efficiency calibration was conducted with the six (6) NIST-traceable 241Am/

152Eu gamma 

mixed gamma line sources from North American Scientific Inc. described in this section 

previously. The drums were measured and sufficient counts were collected to permit 1% to 2% 

statistical precision for the major 241Am and 152Eu peaks. Photon emissions at the following 

energies were used: 59.5 keV, 121.8 keV, 244.7 keV, 344.3 keV, 411.1 keV, 444.0 keV, 778.9 

keV, 867.3 keV, 964.1 keV, 1085.9 keV, 1112.1 keV and 1408.0 keV. MCS-SRS-NDA-0203 

contains plots of the efficiency calibration for each of the three segments, the Summed Spectrum

calibration in Appendix 5 and a full efficiency calibration report in Appendix 6. 

Extension of the density range for the Summed Spectrum mode that was performed in September 

2005 used a set of six (6) NIST-traceable 241Am/

152Eu mixed gamma line sources from North 

American Scientific Inc. similar to those described above. Different sources were used for this 

activity because the original sources had been moved to a different SRS area and were not 

available. The certificates for these sources were examined as part of this inspection. These 

sources contain 137Cs in addition to 241Am and 152Eu that were present in the original gamma 

sources, but the gamma contribution from 137Cs was not used in order to make it compatible with 

the 2003 calibration. An additional 55-gallon drum with concrete matrix was added to the set of 

four calibration drums to provide a density range of 0.015 to 2.1 g/cm3

. The data collected from

these assays were converted to calibration parameters by the GWAS software and added to the 

previous density parameters to yield a Summed Spectrum calibration that includes data from

foam, softboard, hardboard, sand and concrete matrices. This covers a range of matrix densities 

from 0.015 to 2.1 g/cm3

. The parameters from the 2003 calibration are used for the Summed 

Spectrum mode except for those that were determined using the concrete drum. The calibration 

parameters that were determined for the 2003 calibration of the Segmented Analysis mode were 

not changed. 

 6

 MCS Letter COR-EXT-01-0017, J. G. Fleissner to Bert Rollen, Subject: Efficiency versus Mass 

Calibration for Gamma-Ray Based Counting Methods, December 5, 2001. 

7 Standard Test Method for Nondestructive Assay of Special Nuclear Material in Low density Scrap and

Waste by Segmented Passive Gamma-Ray Scanning, C 1133-03, approved July 10, 2003.

 28
Reference Peak Calibration: The initial reference peak calibration was performed on January 9, 

2003, using a pulser to provide dead time corrections for the SeGe detectors. The reference peak 

calibration is performed without a waste drum and uses a nominal pulser setting of 100 c/s for 

the segments and 300 c/s for the Summed spectrum. 

Transmission Source Calibration: The 133Ba transmission sources located 180 degrees opposite 

the SeGe detectors are used to provide a correction for the waste matrix density of the segment 

directly in front of the detector. The transmission calibration report shows the nuclide being 

used, the transmission peak energies used, peak area counts, uncertainties, and half-life. The 

initial transmission calibration was performed on January 9, 2003. 

Calibration Confirmation: The original energy calibration from 2003 was confirmed by making 

six (6) replicate measurements for each of the three mass loadings of the combustibles drum. 

Based on the criteria in DOE/WIPP-02-3122, Appendix A, a precision of 14% must be 

demonstrated; accuracy is reported as percent recovery (%R) and must be in the range of 70% to 

130%. Performance goals for precision and accuracy were met for loadings in all cases, as 

documented in MCS-SRS-NDA-0203, Revision 4. 

The extension of the 239Pu range upper limit to 2.3 times the original limit was applied to the 

238Pu range to provide a new upper limit of 2.3 g 238Pu. SRS-CCP personnel stated that this was 

acceptable because GWAS uses the same analysis method for all radionuclides and absolute 

detector efficiency as a function of energy is used along with peak count rate, energy and 

transition probability to quantify each isotope. Essentially, this means that the IQ3 analysis 

yields valid results whenever certain parameters such as dead time and transmission are 

acceptable. Since the calibration confirmation of 239Pu was acceptable, the range of 238Pu range 

was extended by the same factor to derive a new upper limit of 2.3 g 238Pu. This was not 

confirmed by measurement because certified 238Pu sources of sufficient strength were not 

available. 

Calibration Verifications: The calibration for IQ3 had been verified several times due to 

performance indicators, detector replacement, background failures and software upgrades. 

Records that documented the execution of the verification and the meeting of the performance 

goal required by DOE/WIPP-02-3122, Appendix A were examined for verifications that 

occurred on the following dates: January 31, 2005; June 30, 2005, August 26, 2005 and October 

18, 2005. All verifications were acceptable. 

(3) The calibrated range and operational range of the IQ3 had been established and 

documented. 

In the case of the IQ3 the calibrated range and the operational range are synonymous. The 

instrument’s range is expressed in MCS-SRS-NDA-0203, Revision 4 as 0 to 2.3 g 238Pu 

(administrative) and 0 to 35 g 239Pu (administrative) although the IQ3 is not mass-calibrated in 

the strict sense. Conceptually, the assay of any photon emission within the bounds of the energy 

and efficiency calibrations (discussed below) that is acceptable for the system’s performance 

parameters, such as dead time, FWHM, etc., should be valid, irrespective of nuclear material 

mass. That the range is stated in terms of mass is more of a convention due in part to the fact 

that there are other pertinent, mass-related limits, e.g., administrative and accountability limits, 

as well as functional aspects, such as system dead time and pile up. The IQ3’s true operating 

 29
range for quantitative operation is best expressed in terms of the range of the energy and 

efficiency calibrations, i.e., from 59 keV to 1408 keV. The system’s range was modified several 

times, and the EPA inspection team evaluated the technical basis for each modification and its 

documentation. Each range modification and its accompanying documentation were found to be 

acceptable, and there were no issues relative to this. The range modifications are summarized 

below. 

In June 2004 the system’s operational range was extended to 7 g 238Pu and 211 g 239Pu by adding 

a second calibration using attenuator caps as documented in MCS-SRS-NDA-0504. During data 

acquisition in support of the new calibration, it was observed that the administrative range in 

effect for the original calibration could also be extended. A calibration confirmation was 

performed to provide a demonstration of the technical basis for this range extension using a 

combustibles matrix with 23.7 g 239Pu. 

In January 2005 the upper limits of the system’s calibration range was extended from 1 to 2.3 g 

238Pu and from 15 to 35 g 239Pu, based on performance testing and a calibration confirmation to 

provide technical justification for the extension. No change was made to the system’s original 

calibration that had been performed in 2003. This range extension does not use attenuators and 

does not affect the system’s minimum detectable activity. 

 

In September 2005, SCR-CCP personnel identified a need to assay drums containing soil 

contaminated with HS Pu, i.e., high 238Pu fraction wastes. The system’s original calibration 

performed in January 2003 was valid to a maximum density of 1.7 g/cm3

 which was less than the 

2.1 g/cm3

 density expected for some of the soil drums awaiting assay. This range extension was 

performed by incorporating new measurement data from a concrete matrix drum with a density 

of 2 g/cm3

 to the multi-density calibration files. This change did not affect the Segmented 

Analysis or the Summed Spectrum calibrations for densities below 1.7 g/cm3

 and the original 

January 2003 calibration parameters for the Segmented Analysis the Summed Spectrum densities 

were unchanged. The new calibration results from the concrete drum were added to the multidensity calibration parameter set and a calibration verification of the Summed Spectrum

calibration was performed using softboard, sand, and concrete matrices. A calibration 

confirmation of both the Segmented and the Summed Spectrum calibration modes was 

performed using only 239Pu standards at the low and high ends of the calibration range. 

(4) The total measurement uncertainty (TMU) for assays performed on the IQ3 had been 

determined and documented. 

The TMU for the IQ3 system is documented in MCS-SRS-NDA-TMU-2003, Total Measurement 

Uncertainty for the MCS IQ3 at the Savannah River Site, Revision 1, June 10, 2004. This 

document includes contributions from counting statistics, calibration, isotopic ratio 

determination, matrix inhomogeneity, source self-absorption, source distribution and the effects 

of attenuator caps. The recent change in the upper limit of the system’s density range to 

2.1 g/cm3

 was not a technical concern since this change was based on previous work performed 

by MCS that had assessed the effects on the system’s TMU up to a maximum density of 

2.5 g/cm3

. The determination and documentation of TMU for the IQ3 were acceptable. 

Table 1 below shows an example of the typical TMU values for three waste matrices that 

represent a range of densities that is acceptable for routine use with the IQ3. The values used are 

 30
based on the waste container having an HS Pu content greater than approximately 0.05 gram of 

238Pu or a WG Pu content greater than approximately1 gram of 239Pu. The uncertainties are 

propagated as the square root of the sum of the squares and all individual uncertainties are shown 

as 1-sigma values. The TMU in the bottom row of the table is expressed as a 1.96-sigma limit 

and uncertainties are reported as percentages of the assay value. 

Table 1. TMU Values for a Range of Typical Waste Densities 

 

Error Source 

Matrix

Mass

Density

Steel 

(100 kg)

(0.48 g/cc) 

Graphite 

(50 kg) 

(0.24 g/cc) 

Combustibles

(25 kg) 

 (0.12 g/cc) 

Counting Statistics 1.4% 1.4% 1.4% 

Matrix Inhomogeneity 12% 12% 12% 

Source Distribution 24% 16% 11% 

Calibration 4% 4% 4%

TMU at 1.96 sigma 53% 40% 33% 

(5) The Lower Limit of Detection (LLD) of the IQ3 had been determined and documented. 

The LLD for each NDA system must be determined and documented. Additionally, NDA 

systems performing TRU/Non TRU waste discrimination must have an LLD of less than 

100nCi/g and must include contributions of site-specific environmental background and 

container-specific interferences, as applicable. In this context the LLD is defined as that level of

radioactivity, which, if present, yields a measured value greater than the critical limit with 95% 

probability, where the critical level is defined as that value which measurements of background 

will exceed with a 5% probability. 

The LLD for the IQ3 system was determined by making 6 replicate assays of a combustibles 

matrix drum without added radioactivity, i.e., radioactive sources were not present in the drum, 

for the purpose of determining the system’s minimum detectable activity (MDA). These 

activities were used to calculate the minimum detectable concentration (MDC) values based on 

the nominal weight of a combustible drum, 54.4 kg. The LLD and MDC values are calculated 

directly by the GWAS software using the Currie formula as recommended by the DOE/WIPP02-3122, Appendix A. The system’s actual capability to achieve a particular MDC can be 

estimated from these measurements. The data in Tables 2 and 3 below represent the 239Pu MDA 

and MDC values that were obtained for the combustibles drum using the segmented assay 

protocol and the multi-curve density (summed spectrum) mode, respectively, both based on a 

drum weight of 54.4 kg. 

 31
Table 2. LLD/MDC Segmented Analysis Results 

Matrix Only Drum Without Radioactive Sources 

Run # 239Pu LLD (μCi) 239Pu LLD (mg) 239Pu MDC (nCi/g) 

1 127 2.05 2.33

2 106 1.71 1.95

3 102 1.64 1.88

4 102 1.64 1.88

5 102 1.64 1.88

6 123 1.98 2.26

Average 110 1.78 2.03

These results for the segmented mode represent a best case scenario since the matrix attenuation 

is not taken into account. For an actual waste drum where the nuclear material content is treated 

as unknown prospectively, the MDC and MDA determined from the segmented results must be 

multiplied by the average matrix correction factor determined from the average transmission 

through the drum. For example, this combustible drum had an average transmission correction 

factor of approximately 1.75 at the 414 keV energy of 239Pu. This produces an MDA and MDC 

value of 3.1 mg and 3.6 nCi/g, respectively, for this drum. The data in Table 3 below represent 

the 239Pu MDA and MDC values that were obtained for the combustibles drum using the 

summed spectrum analysis mode based on a drum weight of 54.4 kg. 

Table 3. LLD/MDC Summed Spectrum Analysis Results 

Matrix Only Drum Without Radioactive Sources 

Run # 239Pu LLD (μCi) 239Pu LLD (mg) 239Pu MDC (nCi/g) 

1 284 4.58 5.22

2 255 4.11 4.69

3 240 3.87 4.41

4 251 4.05 4.61

5 254 4.09 4.67

6 292 4.71 5.37

Average 263 4.23 4.83

The system’s ability to discriminate at or below the 100 nCi/g criterion was adequately 

documented for both assay modes and the LLD values were technically acceptable and 

appropriately documented. 

(6) Replicate testing of the IQ3 was performed and evaluated. 

Replicate testing is performed in accordance with the protocol described in EPA Replicate 

Testing for WIPP Nondestructive Assay (NDA) Systems, Rev. 2, June 2002. The purpose of the 

replicate testing performed as part of this inspection was to provide EPA with an independent 

means to verify that the MCS IQ3 can provide consistent, reproducible results for the 

determination of the quantity of 10 WIPP-tracked radionuclides (241Am, 137Cs, 238Pu, 239Pu, 

240Pu, 242Pu, 90Sr, 233U, 234U, and 238U) and the TRU alpha activity concentration. This is 

 32
accomplished by reassaying drums that were previously characterized on the same system or 

instrument in order to demonstrate the following: 

• The instrument produces results consistent with the reported TMU by comparing the 

sample standard deviation for a number of replicate measurements taken over several 

hours or days to the reported TMU. 

• The instrument provides reproducible results over longer periods of time, such as weeks 

or months, by comparing the results of the replicate measurement(s) to the original 

reported values. 

As with all statistical evaluations, there are limitations inherent in this protocol. The value or 

usefulness of the results with respect to the two objectives stated above depends in large part to 

the degree to which the conditions encountered are consistent with the assumptions upon which 

the statistical tests are predicated. Our experience to date has indicated that the containers 

chosen at random do not always provide information best suited for the application of these 

statistical protocols. For example: 

• An NDA system may have been recalibrated in the time period between the original 

assay and the reassay performed during an inspection and the new calibration may have 

different values for some of the calibration algorithm’s terms 

• The containers chosen at random for replicate analysis may lack sufficient nuclear 

material content to provide useable data for all the WIPP-tracked radionuclides 

• High precision for the five replicate assays may yield an average value that differs 

slightly from the original assay value but produces results that the statistical analysis 

indicates are Significant or Highly Significant. However, these differences may be small 

variations that are inherent in the statistical protocols and do not indicate true 

measurement trends or problems 

• Since some radionuclides are quantified based on the measurement of a single other 

radionuclide, i.e., values for 238Pu and 240Pu are derived by applying an isotopic ratio to a 

measured 239Pu value, a Significant or Highly Significant indicator for the single 

measured entity will be reflected in the other two, indicating a larger potential 

measurement trend or problem than may exist 

It is important to keep these in mind when evaluating replicate data and to realize that Significant

or Highly Significant results may not in fact be representative of measurement issues. 

As part of the inspection to certify the MCS IQ3, EPA requested that SRS-CCP reassay six 

drums that EPA randomly selected from a list of drums previously assayed on the IQ3. Drum

Nos. MDL0506073, MDL0506146, MDL0506241, SR123477, SR546270 and SR611807 were 

reassayed five times, for a total of six (6) values, and the results of the five reassays were 

compared to the original assay data. Two statistical tests, a chi-squared (χ

2

) test and a t test, were 

performed. Data and results of the statistical analysis are included in Attachments B.7 through 

B.18 and are discussed in detail below. There were no issues relative to replicate testing for the 

IQ3 system at SRS-CCP. 

 33
Container Nos. MDL0506073, MDL0506146, MDL0506241 contained essentially only 238Pu. 

The χ

2

 test for all three containers showed that within the statistical limits of the test the observed 

variances in the replicate measurements are less than or equal to the reported uncertainties. The t

test for Container Nos. MDL0506073 and MDL0506146 did not show any statistically 

significant differences between the original measurement assay values and the average of the 

five replicate measurements for the activities of all reported radionuclides and the TRU Alpha 

Activity Concentration. The t test results for Container No. MDL0506241 showed a Significant

flag for the plutonium radionuclides measured (238Pu and 242Pu) but not for 241Am and this is 

reflected in the TRU Alpha Activity Concentration that also showed a Significant flag. The five 

replicates for 238Pu determination are tightly grouped and all five values are greater than the 

original measurement, although the magnitude of the difference is small. 

Container Nos. SR123477 and SR546270 contained predominantly 239Pu with small amounts of 

238Pu, 240Pu, 242Pu and 241Am, and more closely resembled the profile of WG Pu. The χ2

 test for 

both containers showed that the observed variances in the replicate measurements are less than or

equal to the reported uncertainties within the statistical limits of the test. The t test for SR123477 

showed a Highly Significant differences between the original measurement assay values and the 

average of the five replicate measurements for 240Pu, 242Pu and TRU Alpha Activity 

Concentration. The five replicates for 240Pu determination are tightly grouped and all five values 

are greater than the original measurement. The deviations in the replicate data suggest that assay 

results may vary more over long periods relative to shorter time periods. While this is not 

entirely unexpected due to fluctuations in environmental backgrounds, the observed deviations 

that are greater than the reported TMU also suggest that the TMU for these analyses may be 

somewhat underestimated. The t test for SR546270 showed no statistically significant 

differences between the original measurement assay values and the average of the five replicate 

measurements for all individual radionuclides but did show a Highly Significant difference for 

TRU Alpha Activity Concentration. The exact reason for this flag is not clear. 

Container No. SR611807 contained predominantly 238Pu as well as small amounts of 239Pu, 242Pu 

and 241Am. The χ

2

 test for this container showed that the observed variances in the replicate 

measurements are less than or equal to the reported uncertainties within the statistical limits of

the test. The t test for this container showed no statistically significant differences between the 

original measurement assay values and the average of the five replicate measurements. 

Waste Characterization Element Description: IPAN System

The IPAN-GEA NDA system is housed in a trailer located at TRU Pad 4 of E-Area of the Solid 

Waste Management Area of SRS adjacent to the MCS IQ3 described previously. This system

had been evaluated previously by EPA on several occasions, most recently EPA Inspection 

No.CCP-SRS-09-04.24, EPA Docket A-98-49, II-A4-50, and had been approved for WIPP 

assays prior to this inspection. The IPAN had not been relocated since EPA certified it initially 

although there had been some system changes all of which had been evaluated and approved for 

use in characterizing TRU wastes for WIPP. The IPAN is a multi-detector system that consists 

of the following: 

 34
• A shielded assay chamber that surrounds the waste container on all four sides, top, and 

bottom; one side of the enclosure contains a 14 MeV neutron generator located inside a 

moderator assembly 

• Shielded detector packages comprising a number of 3

He neutron detectors embedded 

within blocks of polyethylene 

• Individual electronic counting units consisting of pre-amplifiers, amplifiers, 

discriminators and other supporting hardware 

• An internal HP Ge detector for the determination of isotopic distribution 

The system operates in both active and passive modes, and provides values for 239Pu effective 

mass (239PuEff) and 240Pu effective mass (240PuEff), respectively. The IPAN/GEA is currently 

configured to measure one of these two quantities depending on the nuclear material (plutonium) 

loading of a specific container. Values for other WIPP-tracked are quantified based on known or 

established relationships with the measured quantity or by using computational techniques as in 

the case of 242Pu. Typical SRS wastes assayed on the IPAN/GEA consist predominantly of WG 

Pu, and containers with significant contribution from HS Pu are not amenable to the IPAN/GEA 

at this time. 

Technical Evaluation

(1) The design of the IPAN was assessed. 

The IPAN/GEA system uses active and passive mode determinations to provide two independent 

measures of the plutonium content of a waste container. The active mode result is expressed in 

terms of 239PuEff and the passive mode result is expressed in terms of 240PuEff. The system makes 

a selection to use the active or passive results based primarily on the number of measured 

coincidence neutrons and the magnitude of the absorber and/or moderator correction factors, i.e., 

the MOD and/or ABS-MOD indices discussed below. 

The system’s single gamma-ray detector collects data over its calibrated range, i.e., 

approximately 50 to 1500 keV. The container is rotated during the assay interval to reduce the 

error associated with different locations of nuclear material within the container and corrections 

for detector efficiency and gamma-ray attenuation are container and assay event specific. 

Gamma data are correlated to active and/or passive mode neutron data. 

(2) The calibration of the IPAN/GEA was evaluated.

The IPAN/GEA calibration of record was unchanged from previous EPA Inspections (see EPA 

Inspection No. EPA-SRS-CCP-10-03.24 of the Central Characterization Program as 

Implemented at the Savannah River Site, EPA Docket A-98-49, II-A4-40). The system’s 

calibration is documented in the BII report Mobile Assay System Calibration Test Report for SRS 

Operations, BII-5104-CTR-001, Revision 3, August 2001. This calibration continues to be 

appropriate for the wastes the IPAN/GEA has assayed since that time until the time of this 

 35
inspection. There are no technical issues with the IPAN/GEA’s calibration or the documentation 

thereof. 

(3) The calibrated range and operational range of the IPAN had been established and 

documented. 

The IPAN/GEA is calibrated for assays of WIPP containers from the system detection limit to a 

maximum of 120g of WG Pu. The calibration in the active mode is valid for matrices with 

ABSMOD (absorber-moderator) indices between 11.96 and 341.65. The ABSMOD index is a 

measure of the neutron absorption and moderation properties of the waste matrix and is a 

function of both the matrix mass and the elemental composition of the waste material itself. For 

a given matrix composition, the ABSMOD index is expected to increase with increasing matrix 

mass. In the passive mode, the calibration is valid for matrices with MOD (moderator) indices 

between 1.89 and 13.94, where the MOD index is a measure of the neutron moderation 

properties of the waste matrix. The system’s calibration range is documented in the BII report 

Mobile Assay System Calibration Test Report for SRS Operations, BII-5104-CTR-001, Revision 

3, August 2001. For the IPAN/GEA the calibrated and operational ranges are synonymous. 

There are no issues relative to the calibrated or operational range of the IPAN/GEA from this 

inspection. 

(4) The TMU for assays performed on the IPAN had been determined and documented. 

The TMU for the IPAN/GEA system was found to be unchanged from the previous EPA 

inspections when it was evaluated. TMU is documented in the BII report Total Measurement 

Uncertainty for the BNFL Instruments Mobile Assay System, BII-5104-TMU-001, Revision 1, 

August 2001. There are no issues relative to TMU for the IPAN/GEA from this inspection. 

(5) The Lower Limit of Detection (LLD) of the IPAN/GEA had been determined and 

documented. 

The LLD for the IPAN/GEA had been evaluated previously during EPA Inspection No. EPACCP-SRS-09.04-24 during which a concern was raised regarding the use of the IPAN/GEA for 

assays below 100 nCi/g. Because of the manner in which the IPAN/GEA determined the LLD, 

EPA was concerned about the technical basis for assays of lower matrix mass drums with low 

ABSMOD indices where the differences in the MDC were not primarily due to differences in the 

MDA, but resulted from differences when the MDA was divided by the net weight of the drum. 

Originally, SRS CCP estimated the minimum detectable activity (MDA) and minimum 

detectable concentration (MDC) for three surrogate waste matrices and assigned the MDC of 

each surrogate container to the three regions of the ABSMOD range assuming it was 

representative of all containers and matrices within that range. In addition to the three original 

measurements, SRS CCP included data from an additional eight (8) surrogate waste matrices, 

divided the ABSMOD range into four regions and assigned the highest of the observed MDCs to 

that part of the ABSMOD range. SRS-CCP made these changes in response to the EPA concern 

to better characterize this region of the system’s operating range. These changes adequately 

addressed EPA’s concern and are reflected in the report BII Mobile Assay System Quality 

Assurance Objective Compliance, BII-5104-QAO-001, Revision 7, from January 2005 and the 

operating procedure CCP Mobile IPAN/GEA Expert Analysis Procedure, CCP-TP-025, Revision 

 36
10, from September 7, 2005. There are no issues relative to the LLD for the IPAN/GEA from

this inspection. 

(6) Replicate testing of the IPAN/GEA was performed and evaluated. 

Replicate testing is performed in accordance with the protocol described in EPA Replicate 

Testing for WIPP Nondestructive Assay (NDA) Systems, Rev. 2, June 2002. The purpose of the 

replicate testing performed as part of this inspection was to provide EPA with an independent 

means to verify that the IPAN/GEA can provide consistent, reproducible results for the 

determination of the quantity of 10 WIPP-tracked radionuclides (241Am, 137Cs, 238Pu, 239Pu, 

240Pu, 242Pu, 90Sr, 233U, 234U, and 238U) and the TRU alpha activity concentration. This is 

accomplished by reassaying drums that were previously characterized on the same system or 

instrument in order to demonstrate the following: 

• The instrument produces results consistent with the reported TMU by comparing the 

sample standard deviation for a number of replicate measurements taken over several 

hours or days to the reported TMU. 

• The instrument provides reproducible results over longer periods of time, such as weeks 

or months, by comparing the results of the replicate measurement(s) to the original 

reported values. 

As with all statistical evaluations, there are limitations inherent in this protocol. The value or 

usefulness of the results with respect to the objectives stated above depends in large part to the 

degree to which the conditions encountered are consistent with the assumptions upon which the 

statistical tests are predicated. Our experience to date has indicated that the containers chosen at 

random do not always provide information best suited for the application of these statistical 

protocols. For example: 

• An NDA system may have been recalibrated in the time period between the original 

assay and the reassay performed during an inspection and the new calibration may have 

different values for some of the calibration algorithm’s terms. 

• The containers chosen at random for replicate analysis may lack sufficient nuclear 

material content to provide useable data for some or all the WIPP tracked radionuclides. 

• High precision for the five replicates assays may yield an average value that differs 

slightly from the original assay value but produces results that the statistical analysis 

indicates are Significant or Highly Significant. However, these differences may be small 

variations that are more a function of the statistical protocols and do not indicate true 

measurement trends or problems. 

• Since some radionuclides are quantified based on the measurement of a single other 

radionuclide, i.e., values for 238Pu and 240Pu are derived by applying an isotopic ratio to a 

measured 239Pu value, a Significant or Highly Significant indicator for the single 

measured entity will be reflected in the other three, indicating a larger potential 

measurement trend or problem than may exist. 

 37
It is important to keep these in mind when evaluating replicate data and to realize that Significant

or Highly Significant results may not in fact be representative of measurement issues. 

As part of the inspection to certify the IPAN/GEA system, EPA requested that SRS-CCP reassay 

three drums that EPA randomly selected from a list of drums previously assayed on the IPAN. 

Drum Nos. FBL04011, SR144771 and SR138868 were reassayed five times and the results were 

compared to the original assay data. Two statistical tests, a chi-squared (χ

2

) test and a t test, were 

performed. Data and results of the statistical analysis are included in Attachments B.1 through 

B.6 and are discussed below. There were no issues relative to replicate testing for the 

IPAN/GEA system at SRS-CCP. 

 

The χ

2

 test for all three containers assayed on the IPAN/GEA system indicated that the observed 

variances in the replicate measurements are less than or equal to the reported uncertainties within 

the statistical limits of the test. Additionally, the t tests for these containers did not show any 

statistically significant differences between the original measurement assay values and the 

average of the five replicate measurements. 

Inspection Issues

Findings 

The EPA inspection team did not identify any findings relative to the MCS IQ3 or the 

IPAN/GEA systems during this inspection. 

Concerns 

The EPA inspection team identified one concern that did not require a response in the area of 

NDA during this inspection; however subsequent to the inspection, CBFO supplied information 

addressing this concern, as described below. 

EPA Inspection Issue Tracking Form, Issue No. SRS-CCP-NDA-05-006CR: Default 

isotopics based on AK are documented on a waste stream basis and are contained in the 

appropriate AK-NDA Memorandum for each waste stream. However, there is no formal 

instruction for the NDA Expert Analysts (EA) regarding the use of AK based default isotopics. 

Additionally, CCP Procedure CCP-TP-048 does contain directions to the EA regarding other 

aspects of the radioaassay process. Examination of NDA BDRs by the EPA inspection team

indicates that on several occasions the NDA EA has applied AK-based isotopics. 

Resolution of NDA Issue

A step was added to CCP-TP-048, Section 4.1.2 to clarify that the EA shall refer to the 

appropriate NDA/AK memorandum when assigning default isotopic values. A copy of the 

changed page from the procedure is included in the CBFO response in Attachment D. 

Proposed Baseline Approval

The baseline conditions that the EPA inspection team evaluated during this baseline inspection 

consist of the two NDA systems described in this report: 

 38
• MCS IQ3 Gamma Ray System used for gamma–based determinations of isotopic 

distributions and quantitative assays as described above and detailed in the IQ3 checklist 

(Attachment A.6) over the calibrated energy and efficiency ranges of photon emission 

from 59 keV to 1,408 keV. 

• IPAN/GEA system used for neutron–based assays of fissile radionuclides using active 

and/or passive mode measurements consistent with the system’s operating range 

expressed in ABS and ABS-MOD indices, respectively, as represented in the IPAN 

Calibration Test Report and reflected in the IPAN/GEA checklist (Attachment A.5) with 

gamma or AK–based isotopics, as appropriate. 

Each system, along with its range of applicability for disintegration rate (activity) and matrix, 

and any limitations, is approved as described in this report and detailed in the NDA checklists 

(Attachment A5 and A.6). Each system is currently configured to assay retrievably-stored or 

newly-generated soil/gravel (S4000) and debris (S5000) wastes. 

Proposed NDA Tiers

Based on the inspection and the results discussed above, EPA proposes to assign the following 

tiers: 

Tier 1 NDA changes that will require EPA review and approval prior to implementation are the 

following: 

• New NDA equipment;8

• Physical modifications to approved equipment;9

 and 

• Extension or changes of an approved calibration range(s) for approved equipment 

For purposes of clarification, the last bullet above refers to the extension of a system’s approved 

calibration range with respect to determination of disintegration rate (activity) or physical 

characteristics (matrix) of any of the three NDA systems proposed for approval during this 

inspection During an EPA technical inspection, several characteristics of a measurement system

are evaluated. A key characteristic is the range of conditions for which the instrument is capable 

of producing technically defensible data with respect to two aspects: 

• Activity – the nuclear disintegration rate of specific radiations types (neutron or gamma), 

typically Special Nuclear Material or Transuranic radionuclides; units of activity and 

mass are interchangeable; 

 8 New NDA equipment refers to a system or component not previously evaluated by EPA. Specifically, this

is defined as a physically distinct or different system or apparatus; an assay system that is reported to be the 

equivalent of or identical to a previously approved system but which has not been formally inspected and approved 

by EPA is a new system and must be approved by EPA prior to implementation to characterize WIPP wastes. 

9

 Changes to existing NDA equipment include all changes and or modifications to approved equipment that

have the potential to affect the quality of NDA data used for the purposes of waste characterization and/or waste 

isolation. This does not include minor changes or safety-related changes (e.g., addition of hand rails) that do not 

have the potential to affect waste characterization data. 

 39
• Physical Characteristics – the physical attributes of waste matrices as they relate to a 

radiometric system, i.e., how the matrix’s physical properties interact with the radiations 

that originate within the sample and affect the system’s ability to detect them. Examples 

include attenuation of photons (gamma), and moderation and absorption of neutrons. 

During the inspection, the system’s technical capabilities that are evaluated represent the 

conditions observed and they define the operational envelope in which WIPP measurements will 

occur. Changes to a system’s calibrated range with respect to disintegration rate and/or matrix 

may represent an essentially different set of conditions from those evaluated during the 

inspection. For this reason, a change to a system’s calibrated range is considered a Tier 1 

change. A system’s operating range is generally, although not always, a subset of a calibration 

range, i.e., systems that are calibrated to make valid measurements from 0 to 200 grams of WG 

Pu or Total Pu typically operate in a smaller range, the system’s LLD to <200 g for WIPP. 

Provided the system’s calibrated range is valid, a site is free to designate a different operating 

range(s) within the calibrated range as a Tier 2 change. 

Similarly, for physical characteristics NDA systems are often calibrated with respect to a range 

of sample attributes, e.g., a matrix density range upper limit of 2.2 g/cm3 for the IQ3 system

discussed in this report. This range may include materials that are commonly referred to using 

terms such as debris (S5000) and soils & gravels (S4000), both of which are within the calibrated 

density range. Actual waste assays may be restricted to a portion or subset of this range, i.e., 

debris only, for a variety of technical and/or administrative reasons. Changing the calibrated 

range by extending it beyond 2.2 g/cm3

 for the IQ3 system would constitute a Tier 1 change. 

Provided the original density range is valid, changing the operational range(s) of an approved 

NDA system is a Tier 2 change, as discussed below. 

Tier 1 changes will be reported and documentation will be submitted when SRS-CCP is ready 

for EPA review. In case of the first two T1 NDA changes listed above, DOE should assume that 

an EPA inspection is likely. In the case of a last T1 NDA change, EPA will inform SRS-CCP 

and CBFO whether a site inspection is necessary. EPA may request additional information, 

choose to conduct a desktop review, and/or confer with SRS-CCP NDA personnel. Upon 

evaluation (with or without site inspection), EPA will issue an approval letter and only upon 

receiving the EPA approval can SRS-CCP continue to use the equipment affected by the change. 

Tier 2 NDA Changes that do not require EPA approval prior to implementation but require 

reporting and submitting documentation discussing changes by SRS-CCP are: 

• Changes to software for approved equipment; and 

• Changes to approved operating range(s) of approved NDA systems upon CBFO approval 

(see discussion, above) 

• Changes to procedures that require CBFO approval 

For purposes of clarification, examples of the first bullet above would include: 

• Changing a system’s operating system, e.g., first use of Canberra NDA 2000 

 40
• Identification of a systematic problem with a software package and subsequent 

modifications to address the problem, e.g., use of an incorrect value for a radionuclide’s 

transition probability in NDA 2000 

• Introduction of a new version of an existing software package beyond what is in current 

use 

Regarding the second bullet above, reducing a system’s operating range because of performancerelated problems or equipment failures would be Tier 2 changes. For example, if, the IQ3 were 

to not pass a PDP cycle for a specific matrix or activity range and its use for those were formally 

restricted by the site or CBFO, this would be a Tier 2 change. 

Every three months from the date of EPA approval, SRS-CCP will provide information 

concerning T2 changes. EPA will evaluate changes and communicate with SRS-CCP whether 

changes raise any concerns and SRS-CCP response is necessary or whether SRS-CCP can 

continue to implement changes. 

8.3 Real-Time Radiography (RTR) 

Waste Characterization Element Description

At the time of the inspection, only one mobile RTR unit (RTR#1) was on site. 

As part of the inspection of the RTR activities, the team reviewed the elements of the RTR 

process listed below: 

 

• Documentation of RTR activities through use of an approved procedure 

• Proper execution of RTR activities 

• Management oversight and independent review of RTR activities 

• Statistical verification of RTR activities through VE (see Section 8.4.2) 

• Training of RTR personnel 

Emphasis was placed on overall procedural technical adequacy and implementation, as well as 

the identification of WMPs and prohibited items. 

The RTR facility uses radiography to help determine the following aspects of TRU WC: 

• Types and amounts of WMP 

• Presence or absence of prohibited items 

• Testing for new operators on the RTR system using specifically placed items 

Documents Reviewed

The following documents were among those examined to assess whether all RTR operations 

follow the appropriate approved procedures: 

• CCP-TP-011, Revision 16, Radiography Inspection Operating Procedure, May 2, 2005 

 41
• CCP-TP-028, Revision 2, CCP Radiographic Test and Training Drum Requirements, 

February 4, 2005 

• CCP-QP-002, Revision 16, Training & Qualification Plan, June 6, 2005 

• CCP-PO-002, Revision 13, CCP Transuranic Waste Certification Plan, effective May 9, 

2005 

• RTR BDRs: SRRTR1724, SRRTR1728, SRRTR1732 (S5000, debris waste) 

• Training records for RTR operator/ITR/TS/FQAO and RTR subject matter expert (SME) 

Technical Evaluation

During the inspection, the following elements of the RTR process were investigated using the 

checklist contained in Attachment A.3: 

(1) Overall procedural technical adequacy and implementation were evaluated. 

Prior to the inspection, the RTR procedure was reviewed for technical adequacy. The procedure, 

documented in CCP-TP-011, contains specific instructions for performing nonintrusive 

radiography, including operational setup and checkout, identification of prohibited items, 

assignment of WMPs and estimation of weights and volumes, confirmation of WMCs, input of 

data, issuance of NCRs, and technical review of radiography results. No technical adequacy 

issues were identified for this procedure. 

QC examinations were performed as required. For example, in batch SRRTR1278, an

independent observation was performed on container SR85815 and a replicate scan was 

performed on container SR506717. In batch SRRTR1732, an independent observation was 

performed on container 235F01073 and a replicate scan was performed on container SR519787. 

Both of the QC samples were performed by a different operator from the original. 

Corrective action is implemented as needed. NCR-SRS-1273-05 was initiated for drum 

SR118958, batch SRRTR1728, because it contained greater than 1 inch of liquid. In the same

batch, containers 772F020054, FBL03144, and SR529802 contained greater than 20% inorganic 

waste. The disposition for these containers was documented in NCR-SRS-1272-05 as “use as 

is.” The verification of NCRs associated with specific drums is a checklist item in the FQAO 

checklist for each BDR. 

(2) Characterization of WMPs and prohibited items were evaluated. 

WMPs and their estimated weights, the presence or absence of prohibited items, and 

confirmation of the WMC were recorded in the BDRs and audio/visual tapes reviewed. The 

following process is used to perform the RTR examination of containers at SRS-CCP. At the 

beginning of a shift, and prior to examining any waste containers, the operator performs a linespair (LP) resolution test to ensure that images are clearly visible. The procedure requires an 

image resolution of at least 5 LP/cm, and the result of the test image is documented in 

Attachment 8, “CCP Radiography Measurement Control Report.” 

 42
For each RTR event, two audio/video recordings are simultaneously made. The first notations 

on the audio/video recording, made by the operator, are the container number and the 

examination date and time. The examination begins at the top of the drum, where the operator 

determines if a rigid liner is present and if this liner is vented. The drum is rotated through 

360 degrees so that all objects can be viewed from all sides. The operator has the ability to zoom

both in and out and increase or decrease the scan energy in order to compensate for varying 

densities of the waste material examined. During the examination, the operator also rocks the 

drum from side to side to determine the presence of free liquids. A second operator 

electronically records items identified by the operator scanning the container on Attachment 3 to 

the procedure. 

During examination of the container, the operator determines the presence or absence of 

prohibited items, and this determination is documented on Attachment 3, as well as on the 

audio/visual recording. Standardized weights for WMPs are contained in the RTR procedure 

(Tables 1 and 2) and are used by the operators, in conjunction with an operator aid that also 

contains standardized WMP weights, to calculate WMP weights immediately after the scan is 

completed. Layers of confinement and volume utilization of the drum are also recorded on 

Attachment 3. 

During the onsite inspection, EPA observed the RTR event for a debris (S5000) drum, number 

SR515960 (batch SRRTR1749). The demonstration took place on Pad 4 of SRS. Performance 

of the LP resolution test, as well as the operator’s systematic examination of the subject drum, 

was observed. RTR data, including WMP description and estimated weights, and the presence 

or absence of prohibited items were electronically entered into the data sheet (Attachment 3 of 

procedure CCP-TP-011). 

Through interviews with operational personnel, review of BDRs, and observation of an RTR 

event, EPA determined that SRS-CCP successfully characterizes WMPs and prohibited items for 

debris waste. 

(3) Documentation of radiography activities was examined. 

EPA reviewed both the written record (BDR) and audio/visual recording for containers 

SR100137 and SR118958. The data recorded in the BDR and on the tape were consistent. 

During the RTR demonstration, EPA observed that data were recorded on the audio/visual tape 

and in Attachment 3. RTR data are entered electronically into Attachments 3 and 8 of procedure 

CCP-TP-011. The review of the audio/visual recordings and BDRs demonstrated that 

documentation of RTR events by SRS-CCP was complete.

(4) Training of radiography personnel was adequate. 

During the inspection, EPA reviewed documentation of the capability demonstration for 

radiography personnel. The test drum tapes and associated documentation for one operator and 

one SME were reviewed: 

• Training drum (SRS-NDE-TEST-12B) audio/video recording for SME, August 25, 2005 

 43
• Training drum (SRS-NDE-TEST-13B) audio/video recording for operator, October 19, 

2005 

Although the drum inventory included a horsetail, the SME did not identify this and the SME 

reviewing the tape did not recognize this omission. EPA Concern SRS-CCP-RTR-05-003CR 

was written because the review process used by CCP did not identify this problem and provide 

adequate training feedback to RTR personnel. 

The training records reviewed indicate that only trained personnel were operating the RTR 

equipment. RTR operators are required to review the results of the RTR/VE comparisons, and 

significant issues are discussed. Training documentation was complete and filed correctly for 

viewing and reference. The documents reviewed include the following: 

• Training records for RTR operator (ITR/TS/FQAO) and SME 

• VE/RTR comparison report, May 25, 2005 

Inspection Issues

Findings 

The EPA inspection team did not identify any findings in the area of RTR during this inspection. 

Concerns 

The EPA inspection team identified one concern in the area of RTR during this inspection. 

EPA Inspection Issue Tracking Form, Issue No. SRS-CCP-RTR-05-003CR: In the process 

of RTR training in accordance with CCP-TP-028, Revision 2, an operator did not identify a 

required item in the training drum. Although a qualified RTR operator reviewed this training 

tape, it appears that the CCP NDE Test Drum Inventory Sheet, CCP-TP-028-A1, Revision 0, was 

not used as a basis for this review because the reviewer did not document that a required item

was missed. The process in place results in a lack of identification of problems associated with 

the re-qualification of RTR operators and does not provide the opportunity for feedback to the 

operator undergoing RTR operator re-qualification. 

Resolution of Issue: This issue was discussed with CCP management during the on-site 

inspection and CCP provided documented evidence that the issue had been appropriately 

addressed. The documentation that supported the successful implementation of appropriate 

corrective action consisted of a written description of training provided to the RTR operators and 

a signed attendance sheet demonstrating that the training was given to the applicable personnel. 

This issue was successfully resolved, during the on-site inspection, by CCP. 

Proposed Baseline Approval

The baseline conditions that the EPA inspection team evaluated during this baseline inspection 

consisted of the following: 

 44
• Trained personnel: operator/ITR/TS/FQAO and SME 

• Approved and controlled operating procedures: CCP-TP-011, CCP-TP-028, and CCPQP-002

• CCP Mobile RTR Unit No. RTR 1 

• RTR records and supporting data: CCP-TP-011, Revision 16, Attachments 3 and 8, and 

RTR BDRs 

This system is approved for RTR of S5000 (debris) wastes.

Proposed RTR Tiers 

Based on the inspection and the results discussed above, EPA proposes to assign the following 

tiers. 

Tier 1 RTR changes: none at this time. 

Tier 2 RTR changes that do not require EPA approval prior to implementation but require 

reporting and submission of documentation discussing changes by SRS-CCP include the 

following: 

• New RTR equipment or changes to approved equipment 

• Changes made to RTR procedure(s) that require CBFO approval 

Every three months from the date of EPA approval, SRS-CCP will provide information 

concerning T2 changes. If new RTR equipment is in use, EPA inspection may be necessary. 

EPA will evaluate changes and communicate with SRS-CCP whether the changes raise any 

concerns and require SRS-CCP response, or whether SRS-CCP can continue to implement the 

changes. 

8.4 Visual Examination 

Waste Characterization Element Description

Three VE processes were assessed as part of the inspection activities: 

(1) VET for newly-generated waste 

(2) VE in lieu of RTR for retrievably-stored waste 

(3) VE as a QC check for RTR for retrievably-stored waste 

The two VE processes are combined in the same section of this report because the operational 

processes used are the same. These processes are discussed in Sections 8.4.1 and 8.4.2, 

respectively, below. 

As part of the inspection of the VE activities, the inspector reviewed the elements of the VE 

processes listed below: 

 45
• Characterization of WMPs and prohibited items 

• Technical adequacy of VE procedures 

• Documentation of VE activities 

• Training of VE personnel 

Emphasis was placed on overall procedural technical adequacy and implementation, as well as 

the identification of WMPs and prohibited items. 

8.4.1 Visual Examination Technique for Newly-generated Waste 

Waste Characterization Element Description

The VET process for newly-generated waste consists of removing the waste from the container 

in order to determine the following aspects of TRU WC:

• Confirmation of WMPs and WMC 

• Confirmation of presence or absence of prohibited items

Documents Reviewed

The following documents were among those reviewed to assess whether VET operations follow 

the appropriate approved procedures and meet VET requirements: 

• CCP-TP-113, Revision 3, CCP Standard Waste Visual Examination, January 25, 2005 

• CCP-QP-002, Training & Qualification Plan, Revision 16, June 6, 2005 

• Training records for VEE and VE operator/ITR/TS/FQAO 

• BDRs: SRVETXxxx1, SRVETXxxx2, S5000, debris (Note: these BDRs were generated 

by SRS-CCP for demonstration purposes only)

Technical Evaluation

During the inspection, the technical elements of CCP’s VET process were evaluated using the 

checklist contained in Attachment A.2. These aspects are summarized below: 

(1) Overall procedural technical adequacy was evaluated. 

Prior to the onsite inspection, procedure CCP-TP-113 was reviewed for technical adequacy and 

no issues were identified. The procedure contains specific instructions for performing VET in 

Section 4.2, including identification of prohibited items and WMPs, and confirmation of WMCs. 

(2) Characterization of WMPs and prohibited items was evaluated. 

VET for newly-generated waste does not require generation of an audio/visual recording of the 

VET event. The contents of the container are removed and sorted by WMP. Bags are 

sequentially numbered and opened, and the contents identified and weighed. Both of the 

containers in the demonstration BDRs contained numerous bags and a variety of WMPs. 

 46
Operators receive training on specific waste generating processes, typical packaging 

configurations, and WMPs expected to be found in each WMC. After the waste has been 

identified, weighed, and documented, it is loaded into a preweighed drum and the volume 

utilization percentage of the output container is estimated. The final weight of the loaded drum

is determined after the drum has been closed. 

Section 5 of Attachment 1 is used to record the presence or absence of prohibited items. If

found, an NCR is initiated and the prohibited item is processed in accordance with the 

disposition specified in the NCR or as directed by the VE technical supervisor. 

Through interviews with operational personnel, review of BDRs, and observation of a VET 

event, it was determined that SRS-CCP successfully characterizes WMPs and prohibited items

by this technique for debris waste. 

(3) Implementation of the procedure and documentation of VET activities were examined. 

Section 1 of Attachment 1 records general information for the container undergoing VET 

examination. Section 2 records WMC and layers of confinement, Section 3 records waste 

packaging data, and Section 4 records packaging material and WMPs. Section 5 records the 

presence or absence of prohibited items. In both of the BDRs reviewed, all of the required 

information was entered into Attachment 1. 

During the onsite demonstration, two operators worked in a glovebox and a VEE was outside of 

the radiation containment area recording all VET data as they were generated. Data entry is 

made by hand. All drum contents are removed, sorted by WMP, and weighed. The scale 

calibration verification was observed by EPA and correctly documented by the VEE. To 

facilitate operations, the operators use Operator Aid No. E-03-0006 when they are working 

inside the glovebox. This aid documents the scale identification number and calibration date. 

The demonstration drum SR233850 contained a hut that was tightly packed in the drum. The 

operators cut the hut into pieces to remove it from the drum. The drum also contained two 

prohibited items, and the VEE initiated an NCR as required by the procedure. 

By interviews with VE personnel, observation of the demonstration VET event, and review of 

the demonstration BDRs, it was determined that the VET procedure for debris waste was 

implemented and documented as required. 

(4) Calculation of miscertification rates is not applicable because all newly-generated waste 

will undergo VET. 

(5) Training of VET personnel was evaluated. 

The site maintains a list of qualified individuals, which is used to ensure that all training is 

current. CCP uses qualification cards to document training received by CCP personnel. The 

appointment of VEEs by the SPM is documented in a letter that is included in the VEE’s 

qualification card. Training on specific waste-generating processes, typical packaging 

configurations, and WMPs expected to be found in each WMC is provided to VE personnel. 

 47
During the inspection, the qualification cards for a VE operator/ITR/TS/FQAO were reviewed 

and found to be complete and current. Also, the qualification card for a VEE was reviewed and 

found to be complete and current, and contained the letter appointing him as a VEE. 

The following documents were reviewed: 

• Qualification card for VEE/SME 

• Qualification card for VE operator 

Training documentation was complete and filed correctly for viewing and reference. 

8.4.2 Visual Examination as a QC Check of RTR and VE in lieu of RTR

Waste Characterization Element Description

The operational VE process used for VE as a QC check of RTR is the same as that for VE in lieu 

of RTR; hence, these two VE processes are reported together. Both types of VE are performed 

in a glovebox located on Area 4, Pad 6, at SRS. The EPA inspector observed VE in lieu of RTR 

for container SR597472 (S4000, soil/gravel), BDR SRVEP60162. The drum was from waste 

stream SR-W027-221H-HET. Although the EPA inspector did not observe VE as QC check of 

RTR, two BDRs, SRVEP60037 and SRVEP60132, were reviewed. Additionally, EPA reviewed 

the audio/visual recording for VE of drum SR100052, BDR SRVEP60037. The drums in both 

BDRs contained S5000, debris waste. 

Documents Reviewed

The following documents were among those reviewed to assess whether VE as a QC check of 

RTR and VE in lieu of RTR operations follow the appropriate approved procedures and meet the 

appropriate technical requirements: 

• CCP-TP-113, Revision 3, CCP Standard Waste Visual Examination, effective January 

25, 2005 

• CCP-QP-002, Revision 17, Training & Qualification Plan, June 6, 2005 

• Training records for VEE and VE operator/ITR/TS/FQAO 

• VE as a QC check of RTR BDRs SRVEP60037, SRVEP60132 (S5000, debris waste)

• VE in lieu of RTR BDRs SRVEP60019, SRVEP60029 (S5000, debris), SRVEMS0001, 

SRVEMS0002, SRVEMS0003 (S4000, soil/gravel waste) 

• Posted Operator Aid No. E-03-0006 

• VE/RTR comparison email and report, May 25, 2005 

 48
Technical Evaluation

During the inspection, the technical elements of the VE process as a QC check of RTR and VE 

in lieu of RTR were evaluated using the checklist contained in Attachment A.2. These areas are 

summarized below: 

(1) Overall procedural technical adequacy was evaluated 

The VE procedure, CCP-TP-113, is well defined, and the document is controlled. The procedure 

contains complete and detailed instructions for performing VE as a QC check of RTR and VE in 

lieu of RTR. These two types of VE are performed in exactly the same manner, and both are 

included in Section 4.1 of the procedure. The procedure requires identification of WIPP 

prohibited items, a description of layers of confinement, determination of WMPs and their 

weights, and confirmation of the WMC. Table 4 in the procedure provides standard weights for 

items, and Attachment 1 is used to record all VE data. 

(2) Characterization of WMPs and prohibited items was evaluated. 

For each container undergoing examination, an audio/video recording of the event is made. For 

VE as a QC check of RTR and VE in lieu of RTR for S5000 debris waste, the operators remove 

all of the waste items from the drum, open packages, sort and identify the WMPs, and weigh the 

packages. The VEE documents the items and their weights on Attachment 1 and makes voice 

entries of the same on the audio/visual recording.

 

When performing VE in lieu of RTR for S4000 soil/gravel waste, only the top of the waste is 

investigated. Any WMPs found are inventoried and weighed, but only if they are contained in 

the top 6–8 inches of the waste. EPA Concern SRS-CCP-VE-05-001F was written in response to 

this limited VE process. 

Section 5 of Attachment 1 is used to record the presence or absence of prohibited items. If

found, an NCR is initiated and the prohibited item is processed in accordance with the 

disposition specified in the NCR or as directed by the VE technical supervisor. 

Through interviews with operational personnel, review of BDRs, and observation of a VE in lieu 

of RTR event, EPA determined that SRS-CCP successfully characterizes WMPs and prohibited 

items by this technique and VE as a QC check for RTR for S4000 (soil/gravel) and S5000 

(debris) waste. 

(3) Documentation of VE activities was examined. 

Section 1 of Attachment 1 records general information for the container undergoing VET 

examination. Section 2 records WMC and layers of confinement, Section 3 records waste 

packaging data, and Section 4 records packaging material and WMPs. Section 5 records the 

presence or absence of prohibited items. In the BDRs reviewed, all of the required information 

was entered into Attachment 1. 

 49
The EPA inspector reviewed four audio/video recordings for VE in lieu of RTR: 

SRVEMS0001, SRVEMS0002, SRVEMS0003 (S4000, soil/gravel), and SRVEP60029 (S5000, 

debris). The information contained in the BDRs corresponded to that recorded on the 

audio/visual tapes. 

One audio/video recording for VE as a QC check of RTR was reviewed and compared to the 

written information in BDR SRVEP60132. The audio/visual record did not match the written 

record in the BDR for drum SR100052. Changes had been made to the written record, and the 

original record was not retained as required. EPA concern SRS-CCP-VE-06-002CR was 

initiated to address this issue. 

During the inspection, EPA observed VE in lieu of RTR for debris (S5000) drum SR597472, 

BDR SRVEP60162. The drum was from waste stream SR-W027-221H-HET. During the 

demonstration, two operators worked inside a glovebox, and the VEE was outside of the 

radiation containment area recording all VE data as they were generated. Data entry is made by 

hand. All drum contents are removed, sorted by WMP, and weighed. The scale calibration 

verification was observed by EPA and correctly documented by the VEE. To facilitate 

operations the operators use Operator Aid No. E-03-0006 when working inside the glovebox. 

This aid documents the scale identification number and calibration date. The demonstration 

drum, SR597472, contained a hut that was tightly packed in the drum. The operators cut the hut 

into pieces to remove it from the drum and weigh the individual pieces. The drum also contained

two prohibited items, and the VEE initiated an NCR as required by the procedure. 

(4) Calculation of miscertification rates was examined. 

At the time of the inspection, SRS-CCP had calculated a miscertification rate for Category 

Group S5000 (debris). Inter-office memorandum “Savannah River Site Category Group S5000 

Specific Miscertification Rate,” reports the miscertification rate calculations and results. Sixteen 

drums were selected and visually examined between October 4, 2004, and May 3, 2005. These 

drums were added to the 141 drums processed in previous years, and a miscertification rate of 

3% was calculated. The algorithm used for the calculation was appropriate. 

(5) Training of VE personnel was evaluated. 

The site maintains a list of qualified individuals, which is used to ensure that all training is 

current. CCP uses qualification cards to document training received by CCP personnel. The 

appointment of VEEs by the SPM is documented in a letter that is included in the VEE’s 

qualification card. Training on specific waste-generating processes, typical packaging 

configurations, and WMPs that are expected to be found in each WMC is provided to VE 

personnel. 

During the inspection, the qualification cards for a VE operator/ITR/TS/FQAO were reviewed 

and found to be complete and current. Also, the qualification card for a VEE was reviewed and 

found to be complete and current, and contained the letter appointing him as a VEE. 

 50
The following documents were reviewed: 

• Qualification card for VEE/SME 

• Qualification card for VE operator 

Training documentation was complete and filed correctly for viewing and reference. 

Inspection Issues

Findings 

VE for Newly-generated Waste: The EPA inspection team did not identify any findings in the 

area of VE of newly-generated waste during this inspection. 

VE as a QC Check of RTR: The EPA inspection team identified one finding, summarized 

below, in the area of VE as QC check of RTR. 

EPA Inspection Issue Tracking Form, Issue No. SRS-CCP-VE-05-001F: When performing 

VE on S4000 soils drums from the Mound soil waste stream described in AK-8 for BDRs 

SRVEMS0001 through SRVEMS0003, operators conducted visual inspection that was not 

consistent with procedure CCP-TP-113, Revision 3. The VE event did not assess the drums’ 

contents but focused solely on the top layer of waste. The BDRs reported that no prohibited 

items were found, but this could not be ascertained based on the VE that was performed. 

Resolution of Issue: This issue was discussed at length with CCP’s management and was 

resolved based on the following information: 

• Only 19 containers of this waste were at SRS, including 14 drums. Of these drums, only 

2 had not been investigated by a WC technique at the time of the inspection. 

• All of the WC activities for these drums did not result in any prohibited items being 

identified. 

• The AK record for the waste did not indicate the presence of prohibited items in 

containers. 

• CBFO approved procedure CCP-TP-113, Revision 3, section 4.1.4, Note below [D], 

allows for limited VE, “For containers whose contents are to larger or heavy to move

(e.g., solidified mass or sludge), the VE may be performed with the material in place”. 

• ALARA concerns associated with removal of sludge/soil matrices for full VE. 

EPA accepted CCP’s explanation for the limited VE for these specific containers and the issue 

was successfully resolved during the on-site inspection. 

VE in Lieu of RTR: The EPA inspection team did not identify any findings in the area of VE in 

lieu of RTR. 

 51
Concerns 

VET for Newly-generated Waste: The EPA inspection team did not identify any concerns in the 

area of VET for newly-generated waste during this inspection. 

VE as a QC Check of RTR: The EPA inspection team did not identify any concerns in the area 

of VE as a QC check of RTR during this inspection. 

VE in Lieu of RTR: The EPA inspection team identified one concern, summarized below, in the 

area of VE in lieu of RTR during this inspection. 

EPA Inspection Issue Tracking Form, Issue No. SRS-CCP-VE-06-002CR: The Waste 

Visual Examination Data Form (Attachment 1) from procedure CCP-TP-113 contains data that 

does not match what actually transpired during VE of Drum SR100052. The videotape record 

shows a problem with the VE data for this drum that was initially recorded in the hard-copy 

record. Subsequently, the original record was discarded and replaced with one that does not 

match the videotaped event. Consequently, the hard-copy record that remains does not represent 

what transpired during VE of this drum. 

Resolution of Issue: The cause of this concern was that the VE operator did not recognize the 

original record as an in-process quality assurance record and discarded it. The corrective action 

that CCP implemented consisted of providing VE operators with Lessons Learned CCP-LL-QA0001-06. This training described how records may be corrected and required operators to retain 

all in-process records. This issue was successfully resolved, during the on-site inspection, by 

CCP. 

Proposed Baseline Approval

VET for Newly-generated Waste: The VET system for newly-generated waste that the EPA 

inspection team evaluated during this baseline inspection consisted of the following: 

• Trained personnel: operators, VEEs, SPM, and SPQAO 

• Approved and controlled operating procedures: CCP-TP-113, Revision 3, and CCP-QP002, Revision 17

• VET records and supporting data: CCP-TP-113, Revision 3, Attachment 1, and VET 

BDRs 

This VET process is approved for characterization of S5000 debris wastes. 

VE as a QC Check of RTR and VE in lieu of RTR: The system for VE as a QC check for RTR 

and VE in lieu of RTR that the EPA inspection team evaluated during this baseline inspection 

consisted of the following: 

• Trained personnel: operators, VEE, SPM, and SPQAO 

 52
• Approved and controlled operating procedures: CCP-TP-113, Revision 3, and CCP-QP002, Revision 17

• VE records and supporting data: CCP-TP-113, Revision 3, Attachment 1, and VE BDRs 

This system is approved for VE as a QC check of RTR and VE in lieu of RTR for S4000 

(soil/gravel) and S5000 (debris) wastes. 

Proposed VE and VET Tiers 

Based on the inspection and the results discussed above, EPA proposes to assign the following 

tiers. 

• Changes in vendor performing VE and/or VET 

Tier 2 VE and VET changes that do not require EPA approval prior to implementation but 

require reporting and submitting documentation include the following: 

• Changes made to VE or VET procedure(s) that require CBFO approval. 

Every three months from the date of EPA approval, SRS-CCP will provide information 

concerning T2 changes. EPA will evaluate changes and communicate with SRS-CCP whether 

the changes raise any concerns and require SRS-CCP response, or whether SRS-CCP can 

continue to implement the changes. 

8.5 WIPP Waste Information System 

Waste Characterization Element Description

SRS-CCP has successfully submitted data, for both characterization and certification, from

numerous containers to the WWIS in the past. The CCP procedures, practices, and personnel 

who process container data are the same as those used at other approved sites. 

Documents Reviewed

The following documents were reviewed prior to or during the inspection to guide investigation 

and questions: 

• CCP-TP-030, Revision 16, TRU Waste Certification and WWIS Data Entry, April 22, 

2005 

• CCP-TP-086, Revision 8, TRUPACT-II Shipping Payload Assembly, July 11, 2005 

• CCP-PO-002, Revision 13, CCP Transuranic Waste Certification Plan, May 9, 2005 

• CCP-QP-002, Revision 17, Training and Qualification Plan, June 6, 2005 

• Waste Container Data Report for Containers SR544742 and SRTP01413 

 53
• WWIS Data Entry Summary—Characterization and Certification for Drum

MDL0506073 

Technical Evaluation

During the inspection, the technical elements of the SRS-CCP WWIS process (see Attachments 

A.8 and A.9) were evaluated: 

(1) Overall procedural technical adequacy was evaluated. 

The WWIS procedure, documented in CCP-TP-030, Revision 16, is well defined and controlled 

and contains complete instructions for entering, reviewing, and transmitting data. Adequate 

reviews are incorporated into the WWIS data entry procedure to minimize the transmittal of 

noncompliant or incorrect data. The Excel spreadsheet, used for data entry, was also adequate 

and controlled. No adequacy issues were identified for the procedure or spreadsheet.

(2) Implementation and documentation of WWIS activities were examined. 

Personnel entering data into the WWIS can only do so after being granted access by the WWIS

Administrator, and access is password protected. After the data have been through every level of 

review and approval, they are compiled into a drum file and entered into a controlled Excel 

spreadsheet by the waste certification assistant (WCA). The waste certification official (WCO) 

reviews the data to ensure that they are WIPP complaint and signs the spreadsheet to accept the 

data. At this point, data are converted into ASCII format files and transmitted to the WWIS. 

The information contained in the drum file is subsequently used for transportation activities. 

Data storage and retrieval were demonstrated. CCP personnel were able to retrieve and print 

requested records, including WWIS access requests and waste container data reports for 

containers SR544742 and SRTP01413.

(3) Training of WWIS personnel was reviewed. 

The actual job performance of a WCO was observed to verify training and qualification. 

Training and qualifications packages were reviewed for WCA (data entry personnel) and the 

WCO who performed the data entry demonstration. Required training included use of the 

WWIS User’s Manual, and the required reading list included the WIPP Waste Analysis Plan 

(WAP) and DOE/CBFO Quality Assurance Program Document (QAPD). Training 

documentation was complete and filed correctly for viewing and reference. 

(4) Load management was evaluated. 

The following documents were reviewed prior to or during the inspection to guide investigation 

and questions: 

• CCP-TP-030, Revision 16, TRU Waste Certification and WWIS Data Entry, April 22, 

2005 

• CCP-PO-002, Revision 13, CCP Transuranic Waste Certification Plan, May 9, 2005 

 54
• DOE/WIPP-02-3122, Revision 3.0, Contact-Handled Transuranic Waste Acceptance 

Criteria for the Waste Isolation Pilot Plant, April 25, 2005 

Attachment 8 of the certification plan (CCP-PO-002, Revision 13) and procedure CCP-TP-030, 

Revision 16, contain the same requirements for load management as those found in Appendix E 

of the CH-WAC. CCP-TP-030 and CCP-TP-086, containing CCP’s load management 

procedures and practices, are approved procedures. SRS-CCP had previously been approved for 

load management of debris waste. The process used is the same as that successfully 

implemented at other sites. 

The SPM assesses drums for load management, ensuring that all candidate drums are from the 

same waste stream. For the purpose of demonstration, a WCO entered data into the WWIS test 

module as if drums were candidates for load management. The demonstration included the 

WCO trying to include a container from a different waste stream into a payload container. The 

WWIS rejected the container and the software gave an error message. The WCO also added 

containers to a payload to demonstrate that the WWIS recalculates the average TRU activity as 

new drums are added to the payload. The WWIS also recalculated other criteria that must be met 

for shipping, i.e., requirements from the U.S. Nuclear Regulatory Commission document 

“Contact-Handled Transuranic Waste Authorized Methods for Payload Control (CHTRAMPAC)”. The weight used to calculate the TRU alpha activity of the drums in the payload 

includes drums, waste, and liners. SRS-CCP will use approved 10-drum overpacks or SWBs as 

load-managed containers. 

The EPA inspector verified that the procedure and process used by SRS-CCP for load 

management conform to the requirements contained in Appendix E of the CH-WAC. 

Inspection Issues

Findings 

The EPA inspection team did not identify any findings related to the WWIS during this 

inspection. 

Concerns 

The EPA inspection team did not identify any concerns related to the WWIS during this 

inspection. 

Proposed Baseline Approval

The system used for container certification and load management that was evaluated during this 

baseline inspection consisted of the following: 

• Trained personnel: WWIS WCA (formerly data entry personnel) and WCO 

• Approved and controlled operating procedures: CCP-TP-030, Revision 16, and CCP-QP002, Revision 17 

 55
• Approved and controlled Excel spreadsheet: WWIS Data Entry Summary—

Characterization and Certification 

This system is approved for submitting data to the WWIS for container characterization, 

certification, and payload management for waste summary category groups S4000 and S5000. 

Proposed WWIS Tiers 

Based on the inspection and the results discussed above, EPA proposes to assign the following 

changes. 

Tier 1 WWIS changes that require EPA review and approval prior to implementation include 

the following: 

• Changes to WWIS algorithms specific to load management 

This Tier 1 change will be reported and documentation will be submitted when SRS-CCP is 

ready for EPA review. Upon review, EPA may request additional information, choose to inspect 

or conduct a desktop review, and/or confer with SRS-CCP WWIS personnel. Upon evaluation, 

EPA will issue an approval letter. Only upon receiving the EPA approval can SRS-CCP use the 

changed algorithms. 

Tier 2 WWIS changes that do not require EPA approval prior to implementation but require 

reporting and submitting documentation discussing changes by SRS-CCP include the following: 

• Changes made to WWIS procedure(s) that require CBFO approval 

• Changes in load management status of approved waste category(s) 

Every three months from the date of EPA approval, SRS-CCP will provide information 

concerning T2 changes to EPA. EPA will evaluate the changes and will inform SRS-CCP 

whether the changes raise any concerns and require SRS-CCP response, or whether SRS-CCP 

can continue to implement the proposed changes. 

9.0 RESPONSE TO COMMENTS 

This section is reserved for comments in response to the EPA’s proposed approval decision. 

10.0 SUMMARY OF RESULTS 

10.1 Findings 

During this inspection of SRS-CCP, the EPA inspection team identified one finding in the area 

of VE as QC check of RTR. This is contained on the EPA Inspection Issue Tracking Form

(Attachment C.5) and is summarized below. 

EPA Inspection Issue Tracking Form, Issue No. SRS-CCP-VE-05-001F: When performing 

VE on S4000 soils drums from the Mound soil waste stream described in AK-8 for BDRs 

 56
SRVEMS0001 through SRVEMS0003, operators conducted visual inspection that was not 

consistent with procedure CCP-TP-113, Revision 3. The VE event did not assess the drums’ 

contents but focused solely on the top layer of waste. The BDRs reported that no prohibited 

items were found, but this could not be ascertained based on the VE that was performed. 

10.2 Concerns 

During this inspection of SRS-CCP, the EPA inspection team identified five concerns: two in 

the area of AK, one in the area of NDA, one in RTR, and one in the area of VE. All concerns are 

addressed on the Inspection Issue Tracking Forms (Attachments C.1 through C.4 and C.6) and 

are summarized below. 

The EPA inspection team identified two concerns in the area of AK during this inspection. 

EPA Inspection Issue Tracking Form, Issue No. SRS-CCP-AK-05-004C: AK reference 

D152 indicates that wastes in SR-SRS-W027-773A-HET include large items, such as boxed 

wastes. This waste stream is classified as job control waste that typically excludes large metal 

items like those found in SR-SRS-W027-773A-HET. The AK Summary (AK-7) does not yet 

address the boxed waste component and CCP is encouraged to assess whether the boxed waste 

belongs in SR-SRS-W027-773A-HET based on the similarity of processes, physical form and 

material type. 

EPA Inspection Issue Tracking Form, Issue No. SRS-CCP-AK-05-005C: Several AK 

references (e.g., C040) indicate that the Savannah River Technology Center generates Waste 

Stream SR-SRS-W027-773A-HET (debris) that may contain materials identified as High-Level 

Waste (HLW). An earlier revision of AK-7 (SR-SRS-W027-773A-HET) included the HLW

component that has since been removed in the latest revision of the AK summary. The AK 

record must include why this information was removed from AK-7. Also, in the future, CCP 

must adequately document and justify the inclusion of any waste in AK-7 previously or currently 

identified as being high-level. 

The EPA inspection team identified one concern in the area of NDA during this inspection. 

EPA Inspection Issue Tracking Form, Issue No. SRS-CCP-NDA-05-006CR: Default 

isotopics based on AK are documented on a waste stream basis and are contained in the 

appropriate AK-NDA Memorandum for each waste stream. However, there is no formal 

instruction for the NDA Expert Analysts (EA) regarding the use of AK based default isotopics. 

Additionally, CCP Procedure CCP-TP-048 does contain directions to the EA regarding other 

aspects of the radioaassay process. Examination of NDA BDRs by the EPA inspection team

indicates that on several occasions the NDA EA has applied AK-based isotopics. 

The EPA inspection team identified one concern in the area of RTR during this inspection. 

EPA Inspection Issue Tracking Form, Issue No. SRS-CCP-RTR-05-003CR: In the process 

of RTR training in accordance with CCP-TP-028, Revision 2, an operator did not identify a 

required item in the training drum. Although a qualified RTR operator reviewed this training 

tape, it appears that the CCP NDE Test Drum Inventory Sheet, CCP-TP-028-A1, Revision 0, was 

not used as a basis for this review because the reviewer did not document that a required item

 57
was missed. The process in place results in a lack of identification of problems associated with 

the re-qualification of RTR operators and does not provide the opportunity for feedback to the 

operator undergoing RTR operator re-qualification. 

The EPA inspection team identified one concern in the area of VE in lieu of RTR during this 

inspection. 

EPA Inspection Issue Tracking Form, Issue No. SRS-CCP-VE-06-002CR: The Waste 

Visual Examination Data Form (Attachment 1) from procedure CCP-TP-113 contains data that 

does not match what actually transpired during VE of Drum SR100052. The videotape record 

shows a problem with the VE data for this drum that was initially recorded in the hard-copy 

record. Subsequently, the original record was discarded and replaced with one that does not 

match the videotaped event. Consequently, the hard-copy record that remains does not represent 

what transpired during VE of this drum. 

10.3 Response to Inspection Issues 

Personnel from the site and the Carlsbad Field Office (CBFO) provided information relative to 

the one finding and two of the concerns that required a response to the EPA inspection team

prior to the inspection closeout on site. The finding and two concerns that required a written 

response were also addressed by a formal submittal provided by CBFO to EPA on November 22, 

2005, included as Attachment D. CBFO’s submittal included information related to the NDA 

concern that did not require a written response. The EPA inspection team members evaluated 

the responses for completeness and adequacy, and concluded that each had been resolved 

satisfactorily. As a result of the information provided by these two sources, all issues identified 

by EPA during the inspection were adequately addressed. EPA considers all concerns and 

findings to be resolved, and there are no open issues resulting from this inspection. 

10.4 Conclusions 

EPA’s inspection team determined that SRS-CCP’s WC program activities were technically 

adequate. EPA is proposing to approve the following scope of WC activities for SRS-CCP: 

• Acceptable knowledge (AK) and load management for contact-handled (CH) retrievablystored and newly-generated TRU debris waste (S5000) and soils/gravel (S4000) 

• Visual examination technique (VET) for CH newly-generated debris waste (S5000) and 

soils/gravel (S4000) 

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

for CH retrievably-stored TRU debris waste (S5000) and soil/gravel wastes (S4000) 

• RTR for CH retrievably-stored TRU debris waste (S5000) and soil/gravel waste (S4000) 

• Nondestructive assay (NDA) and the WIPP Waste Information System (WWIS) for CH 

retrievably-stored and newly-generated TRU debris waste (S5000) and soils/gravel 

(S4000) 

 58
Any changes to the WC activities from the date of the baseline inspection must be reported to 

and, if applicable, approved by EPA according to the following table. 

Proposed Tiering of TRU WC Processes Implemented by SRS-CCP

(Based on October 31–November 3, 2005, Baseline Inspection)

WC Process 

Elements 

SRS-CCP WC Process 

Specific T1 Changes 

SRS-CCP WC Process

Specific T2 Changes*

SRS-CCP General T2

Changes* 

AK including

Load Management

Any new waste category 

Changes to WWIS 

algorithms specific to load

management 

WSPFs, including updates

or additions to waste 

stream(s) within an

approved waste category 

(see Section 8.1) 

Changes in load

management status of 

approved waste stream(s) 

Changes to site

procedures requiring 

CBFO approvals 

and other changes as

discussed in Section 8.1 

of this report 

NDA New equipment or physical 

modifications to approved 

equipment** 

Changes to approved

calibration range for 

approved equipment (see 

Section 8.2)

Changes to software for 

approved equipment (see 

Section 8.2)

Changes to operating 

range(s) upon CBFO

approval

Changes to site

procedures requiring 

CBFO approvals 

and other changes as

discussed in Section 8.2 

of this report 

RTR N/A New equipment or

changes to approved

equipment

Changes to site

procedures requiring 

CBFO approvals 

and other changes as

discussed in Section 8.3 

of this report 

VE and VET Changes in vendor

performing VE and/orVET 

N/A Changes to site

procedures requiring 

CBFO approvals 

and other changes as

discussed in Section 8.4 

of this report 

WWIS N/A N/A Changes to site

procedures requiring 

CBFO approvals 

and other changes as

discussed in Section 8.5 

of this report 

* Upon receiving EPA approval, SRS-CCP will report all T2 changes to EPA every three months. 

 ** Modifications to approved equipment include all changes with the potential to affect NDA data relative to

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

 59
11.0 REFERENCES 

U.S. Department of Energy, Carlsbad Area Field Office, “Contact-Handled Transuranic Waste 

Acceptance Criteria for the Waste Isolation Pilot Plant (CH-WAC),” Revision 3, DOE/WIPP-02-

3122, Carlsbad, New Mexico, April 25, 2005. 

New Mexico Environment Department, Waste Isolation Pilot Plant Hazardous Waste Facility 

Permit, NM48901 139088-TSDF, Santa Fe, New Mexico, 1989. 

U.S. Environmental Protection Agency, “Criteria for the Certification and Recertification of the 

Waste Isolation Pilot Plant’s Compliance with the Disposal Regulations: Certification Decision; 

Final Rule,” Federal Register, Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405. 

U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 191, “Environmental 

Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level 

and Transuranic Radioactive Wastes.” 

U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 194, “Criteria for the 

Certification and Re-Certification of the Waste Isolation Pilot Plant’s Compliance with the 

40 CFR Part 191 Disposal Regulations.” 

U.S. Department of Energy, Title 40 CFR Part 191, Compliance Certification Application for the 

Waste Isolation Pilot Plant, DOE/CAO 1996-2184, Carlsbad, New Mexico, 1996. 

U.S. Department of Energy, Title 40 CFR Part 191, SUBPART D AND C, Compliance 

Recertification Application 2004, DOE/WIPP/2004-3231. 

U.S. Department of Energy, Carlsbad Area Field Office, “Quality Assurance Program

Description (QAPD)”, DOE/CBFO-94-1012, Revision 7, Carlsbad, New Mexico, July 2005. 

U.S. Nuclear Regulatory Commission, “Contact-Handled Transuranic Waste Authorized 

Methods for Payload Control (CH-TRAMPAC).” 

 60
 

Attachments A.1 through A.8

 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

General AK-1Is the waste TRU by definition as presented in the LWA?(P.L.102-579) 

CCP-TP-005, Revision 15; CHWAC Rev. 3; P.L. 102-579 Yes CCP-AK-S

Rev.2. Nobeing perfanalytical for SRS-8 

AK-2Do the presented volumes comport with LWA capacity restrictions?(P.L.102-579) 

CCP-TP-005, Revision 15; CHWAC Rev. 3; P.L. 102-579 Yes CCP-AK-S

Rev.2; CCSRS-2 Rev CCP-AK-SRev 2, CC2004 for Sexamined to waste v

AK-3Are any wastes considered (or previously considered) HLW? HLW are prohibited.(P.L.102-579) 

CCP-TP-005, Revision 15; CHWAC Rev. 3; P.L. 102-579 Partial Verification; see Objective Evidence CCP-AK-

AK-SRS-8 D020; C06(rev.0) indat the facilwaste subsstreams doHLW. 

AK-4Are any wastes considered (or previously considered) Spent Nuclear Fuel?(P.L.102-579) 

CCP-TP-005, Revision 15; CHWAC Rev. 3; P.L. 102-579 Yes CCP-AK-S

Rev.2; D1above. 

AK-5Are these defense wastes?(P.L.102-579) 

CCP-TP-005, Revision 15; CHWAC Rev. 3; P.L. 102-579 Yes CCP-AK-S

Rev.2; P0Waste appupon consreferenced 

Revision No.: 1 AK-1 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

AK-6What is the scope of authorization sought (i.e., SCG, newly generated vs. retrievably stored, other site-specific breakdowns)

CCP-TP-005, Revision 15; CRA 2002

Partial Verification; see 

Objective Evidence 

CCP-AK-Rev.2; TWprovided a that did noin the CRAscope of ththe scope nnewly genretrievably 

AK-7Is AK being used that was assembled prior to an EPA approved QA program (retrievably stored). If so, whatqualification process is used? Is this waste undergoingconfirmation as per the CCA/CRA (100% sampling) [194.24(c)(2)-(5), 194.22(a)]

CCP-TP-005, Revision 15; CHWAC Rev. 3; P.L. 102-579 Yes CCP-AK-S

Rev.2; BDSR570782MDL0506NDA and 

AK-8Is AK being assembled as waste is generated after EPAapproval of the QA program (newly generated)? Is thiswaste undergoing confirmation as per the CCA/CRA(100% sampling)?[194.24(c)(2)-(5)]

CCP-TP-005, Revision 15; CHWAC Rev. 3; P.L. 102-579 Partial Verification; see Objective Evidence CCP-AK-

Rev.2; BDSR570782MDL0506issue, item waste (retrgenerated)being 100% CCA/CRA

Personnel Training Requirements AK-9Procedures require staff to be qualified to assemble, compile and confirm AK data, including but not limitedto: Identification of required reading list and successfulcompletion of all required reading including, but not 

CCP-TP-005, Revision 15; CCP-QP-002 

Partial Verification, see 

Objective Evidence 

CCP-AK-Rev.2; TraKevin PeteRCRA traitraining wwas observrequiremen

Revision No.: 1 AK-2 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

limited to: 

• Applicable portions of the WIPP WAP and TSDF 

WAC

• WIPP Compliance Certification Decision Conditions 

2 and 3 

• State and Federal RCRA regulations associated with

solid and hazardous waste characterization 

• Discrepancy resolution and reporting processes • Site-specific procedures associated with waste 

characterization using acceptable knowledge 

• Successful completion of testing to demonstrate 

understanding of required reading list

• Completion of internal and/or external training

programs pertinent to AK 

• Participation in internal audits to assess AK program• Other methodologies for demonstrating AK

proficiency as developed on a site-specific basis 

(WAP B4, B4-3a)

be includeprograms. testing or tpersonnel 

Procedure Scope AK-10a. Are procedures adequate to encompass the spectrum

of wastes for which authorization is sought?

b. Are there different procedures for newly generated vs. 

retrievably stored waste? Are there differentprocedures for solid, debris, or soil waste? Should there be?

c. For newly generated waste, have adequate procedures

CCP-TP-005, Revision 15; CCP-TP066, SW13.3-SOP-CAND-01,Manual IS Rev. 5;SRS Procedure 6.24;

Partial Verification; see 

Objective Evidence 

CCP-AK-Rev.2; DRInformatioidentified FastScan oof the 53) does not approcedures generated (i.e., SRS-

Revision No.: 1 AK-3 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

been developed and implemented to characterize waste using acceptable knowledge prior to packaging?

(WAP B4, B4-3b)

the waste astored. Nopackaging newly genwere examthat this inthey did noinstead pereach conta

Assembling AK Information and Compiling AK Documentation into an auditable record AK-11What is the breakdown of the types and quantities ofTRU waste generated/stored at the site?(WAP B4, B4-2a)

CCP-TP-005, Revision 15 Yes CCP-AK-

Rev.2; CCSRS-2 Rev CCP-AK-SRev.2, CC2004 for Sin the abovbreakdown generated/

AK-12Do procedures call for AK information to be collected for: a. 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 

90Sr, 137Cs + unexpected radionuclides

b. ferrous metals (in containers)c. cellulosics, plastics, rubber d. nonferrous metals (in containers) (CRA/CCA Ch 4 and Attachments/Appendices) 

CCP-TP-005, Revision 15; ManualIS Rev. 5; SRS Procedure 6.24 

Partial Verification; see 

Objective Evidence 

CCP-AK-Rev.2; WSSR-SD-SOC019, M0773A-HET C074, M07, and 8 foSOIL; P02Radionuclassembledlittle confipertaining not includother detaiincluding 

Revision No.: 1 AK-4 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

AK-13Do procedures require documentation of radionuclide process origin?Are the facility and TRU waste management operationscorrelated to specific waste stream information?(Attachment B4; CH WAC Appendix A.2.2)

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2; M0D020, C00P028, P04P120. Radadequately generation was noted assigning wItem AK-3

AK-14Are correlations between waste streams, with regard to time of generation, waste generating processes, and sitespecific facilities clearly described? For newly generatedwastes, the rate and quantity of waste to be generatedshall be defined. (Attachment B4, B4-3c; CH WAC Appendix A, Section A.2) 

CCP-TP-005, Revision 15 Partial Verification, see 

Objective Evidence 

CCP-AK-Rev.2; TWHET and SW027-773three separthe TWBIRdata/informsite identifwithin the CCP had nnewly gendone). Se

AK-15Are wastes streams appropriately identified and are wastes characterized on a waste stream basis?Are wastes grouped on a waste stream basis using Acceptable Knowledge and are they characterized in the same manner (i.e., by visual examination) as a newly generated waste if a waste does not have all mandatoryAK documentation requirements?(Attachment B4, Section B-1a) 

CCP-TP-005, Revision 15 Partial Verification, see 

Objective Evidence 

CCP-AK-Rev.2; TWHET and Sfor discusscombinatioidentified TWBIR dethis waste items. It iwould be cmust carefto ensure iinclusion i

Revision No.: 1 AK-5 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

AK-16Do procedures demonstrate a logical progression fromgeneral facility information to more detailed waste stream-specific information?

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2; D1U018. Daprogramm

AK-17Does the process include review of AK information toevaluate and document AK-AK information discrepancies?(CH WAC Section A.2.2.3, Attachment B4, Section B4-3) 

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2; DRdiscrepancincorrect imound debsoil was prFastScan sbe compriprepared to 

AK-18Do procedures require collection of information regardinghow waste is tracked and managed at the generator site (including historical and current operations)?(Ch WAC Section A.2; Attachment B4 Section B4-2a)

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2; G-WTransuranDatabase, printouts. (i.e., historTransuranDatabase, obtain the informatioto assign wdata obtainCTS/PTS Data entry was not ex

AK-19Is AK information compiled in an auditable record, including a road map for all applicable information?

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2; CCwaste streaSOIL. Attprogram awith refere

Revision No.: 1 AK-6 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

determinatreference l

AK-20Has a reference list been provided that identifies documents, databases, Quality Assurance protocols, andother sources of information that support AKinformation?(Attachment B4, Section B4-3c) 

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2; AttW027-773Reference recommenunique idereference iapplies to, numbers aidentify dilead to con

AK-21Have the following mandatory information requirements been identified?Map of the site that identifies the areas and facilities involved in TRU waste generation, treatment, and storage Facility mission description related to TRU waste generation and managementDescription of the operations that generate TRU waste at the site and process information, including:

• Area(s) or building(s) from which the waste stream

was or is generated 

• Estimated waste stream volume and time period of 

generation 

• Waste generating process description for each 

building or area 

• Process flow diagrams, if appropriate • Generalized material inputs or other information that 

CCP-TP-005, Revision 15 CCP-AK-

Rev.2; P00D077, D06M025, SCP054, P05Informatiospecific prinformatioThe physiccould affethoroughly for waste sSR-MD-Smade. Isoavailable fwaste (e.gbe presentexperimenHET). Fowere used distributiowere also u

Revision No.: 1 AK-7 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

identifies the radionuclide content of the waste streamand the physical waste form

• Types and quantities of TRU waste generated,

including historical generation through futureprojections 

• Physical/chemical waste composition that could

affect isotopic distribution (i.e., processes to remove ingrown 241Am)

• Statement of all numerical adjustments applied to

derive the material’s isotopic distribution, e.g.,scaling factors, decay/ingrowth corrections and secular equilibrium considerations

• Specification of isotopic ratios for the 10 WIPPtracked radionuclides and, if applicable, the 

radionuclides that comprise 95% of the hazard 

(CH WAC Section A.2.2; Attachment B4, B4-2a, B4-2b) 

nuclides pand by actthere were presented AK-NDA nuclides idthe site rev

AK-22Does the site have procedures for the collection of supplemental information? Examples of supplementalinformation, from CH WAC, include: 

• Safeguards and security and other material control

systems/programs

• Reports of nuclear safety or criticality • Accidents involving SNM waste packaging and waste 

disposal

• Building or nuclear material management area logs or 

inventory records 

• Site databases that provide SNM or nuclear material 

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2; BurP006, P00C003, C01D037, IO3P058, P06Database pGround dasupplemenare exampprovided t

Revision No.: 1 AK-8 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

information test plans 

• Research project reports, or laboratory notebooks that 

describe the radionuclide content of materials used inexperiments 

• Information from site personnel • Historical analytical data relevant to isotopic 

distribution in the waste stream 

(CH-WAC Section A.2.2.2; Attachment B4 Section B4-2c) 

AK-23Is all necessary supplemental information assembled andhas it been appropriately used?(Section B4-2c) 

CCP-TP-005, Revision 15 Partial Verification, see 

Objective Evidence 

CCP-AK-Rev.2; Godata informbe noted thassignmencorrect basM022, etca WMC of correct, banot choose confidence identificatthat the accorrectly iS5400 cateelected to calculationthey are nothe actual 

Revision No.: 1 AK-9 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

AK-24a. Are waste categorization schemes presented and are

they appropriate?

b. Are waste identification/categorization schemes 

relevant to the isotopic composition of waste?

(Attachment B4 Section B1, CH-WAC page ix, AppendixA.2) 

CCP-TP-005, Revision 15; CHWAC Rev. 3 Partial, see Objective Evidence CCP-AK-

Rev.2; M0With respeassociated neither of were segredistributioattempting stream prewaste had character. 

AK-25Have data uses and limitations been assembled and arethey technically adequate?(CRA/CCA; CH-WAC Appendix A, Section A.2.2.3) 

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2; CCAcceptablSummary. and placed attachmensource docdocumente

Generating an AK Summary/AK Document AK-26Site documents/procedures require the facility prepare an AK summary document that summarizes all information collected, including the basis for all waste streamdesignations. Is the AK Summary of sufficient scope and detail?(CH-WAC Appendix A Section A.2.2; Attachment B4Section B4-2b)

CCP-TP-005, Revision 15 Yes CCP-AK-

Rev.2; CCSRS-2 RevCCP-AK-SRev.2, CCdetail of thadequate. 

AK-27Are conclusions and interpretations presented in the AKSummary technically sound and supported by referenced

CCP-TP-005, Revision 15 Partial Verification, see 

Objective Evidence 

CCP-AK-Rev.2. Doupdated to discussion 

Revision No.: 1 AK-10 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

mandatory and supplemental information? data (e.g., 

radionucliidentificatand the ND

AK-28If AK data discrepancy is identified, site will evaluate the source of the discrepancy to determine if discrepantinformation is credible. Information that is not credible will be identified as such and reasons for dismissing will be justified in writing. Limitations concerninginformation will be documented in the AK record andsummarized in the AK report. If a discrepancy cannot beresolved, the site will perform direct measurements for the impacted population. (CH WAC Appendix A.2, Section A.2.2.3) 

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2; DRpresented Mound drushowed diidentificatadequately Mound anBurial GroAKEs. It expressed measurembut the AKHET expliinformatiomeasuremmemos do

AK-29Is load management being proposed? Does the AKSummary include the following from the CH WAC,Rev. 3 Appendix E?Each TRU waste stream selected for payload management must include in its acceptable knowledge summary report an estimate of the total waste volume andthe percentage of the waste volume that is above and below 100 nCi/g. (It should be noted that thisinformation, although based on the best available AKinformation, is preliminary and subject to the performance of WIPP-certified NDA measurements and cannot and will not be used as a measure of AK

CCP-TP-005, Revision 15 Partial Verification, see 

Objective Evidence 

CCP-AK-Rev.2., M0Summary anticipate measurembe at least require loathe AK Sumanagemeused. 

Revision No.: 1 AK-11 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

accuracy.) (Reference E3) (CH-WAC, Appendix E) Identifying Management Controls For Discrepant Items/Containers/Waste Streams and Data Management/Tracking AK-30Are nonconforming wastes segregated? Are NCRs disposition in an appropriate and technically defensible manner?(Attachment B4, Section B4-3b, Attachment B3, Section B3-13) 

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2; NCCTS databin the CCP NCRs are addressed. be segrega

AK-31Do site procedures require that additional information becollected before waste may be shipped if the required AK information is not available for a waste stream or if available AK is poor or unacceptable?(Attachment B4, Section B1) 

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2. Se

Confirming AK Information with Other Analytical Results AK-32Do these procedures facilitate the mandatory traceability analysis performed for each Summary Waste CategoryGroup examined during the audit, noting that EPA will determine whether the available waste streams adequately demonstrate the full characterization process for the proposed scope?(Attachment B4, Section B4-2) 

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2; BG Package Ddrum 5707Pad and CWaste ConDrum 773containers MDL0506PTS/CTS 773A0200MDL0506Traceabili

Revision No.: 1 AK-12 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

AK-33If AK was used (i.e., data collected prior to QA program), what method was employed to qualify the information?Approved methods or peer review, corroborating data, confirmatory testing, and QA program equivalency? If confirmatory testing is used, has the following beenconsidered (from CH WAC) At a minimum, to confirm existing AK data, it is necessary to compare ratios of the two most prevalentradionuclides in the isotopic mix a. For 238 Pu, 239Pu, 240Pu, 241Pu, 242 Pu and 241Am:

Confirmation can be accomplished via comparison ofmeasured and AK values for 239 Pu/ 240 Pu for 

weapons grade plutonium; 238Pu/ 239Pu for heat source 

Measured 241Am can be used to calculate 241Pu (for 

subsequent AK comparison) if time of chemical separation is known (no 241Am at time of separation 

assumed) 

241Pu can be compared (by ratio) to confirm AK of 

any Pu isotope associated with WG/RG (i.e., 239Pu or 

240 Pu) 238Pu from AK for wg/rg Pu is assumed to be valid if

the AK values of 239Pu and 240Pu have been confirmed 

by measurement 

242Pu calculated by correlation techniques, since it 

can’t be measured 

b. For 235U, 233U, 238U, 234U:

Were they tracked or measured in AK information?If no valid AK exists, data generated can only be usedto detect or calculate, or confirm absence ratios for 

CCP-TP-005, Revision 15, CHWAC Rev. 3 Partial Verification, see Objective Evidence CCP-AK-

Rev.2 NDW027-773SRS-W02

states “...radionucliSavannah W027-773

followed b

this stream specific coisotopic diheat sourca drum by AK-NDA waste strearatios... Abheat sourc

238Pu. Ove

weight) 239

over 99% ratios vary stream. Isdrum-by-dprovided b

value is ca

239Pu weig

present, th

by a scalin

values. If the measur

multi-grou

242Pu value

distributiospecific m

measured 

multiplied 

Revision No.: 1 AK-13 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

234U calculated from 235U enrichment 

If valid AK exists can confirm with certified systems 

234U calculated by 235U enrichment, because 234U 

can’t be measured 

c. For 137 Cs and 90 Sr:

Confirmed by WIPP-certified system (direct measurement or comparison of 241Am peak at 662 

keV to other 241Am peaks (disproportionate 241Am

peak at 662 keV could mean presence of 137Cs) 

90 Sr calculated from 137Cs using scaling factors 

Other radionuclides – must identify via NDA and should identify via AK 

(40 CFR 149.22(b), CH WAC, Appendix A, Section A.2.1) 

The NDA quantified provide or used. The that “quan

previous a

values can daughter.” to note tha

present in AK will be containers relies heavcontents, ball nuclideSR-MD-S

“The pred% are 238P

radionucli

241Am (dec

memo prodistributio(weapons plutoniumused by N“Radioassthis waste analysis usspectrosconeeded, by Mobile IPAmemo goeis calculat

weight %. mass of th

scaling fac

242Pu mass

Revision No.: 1 AK-14 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

the measur

scaling facanalysis (Mdetermine 

contains a war reservscale 242Pu

conservatioverestimamight resuas TRU. T

234U value 

and/or 239P

present, th

by a scalin

238Pu) to c

reserve Pu 

239Pu is us

by the mulisotopic so

mass. If a of plutoniucompositio

The quanti

using the d

value in th

determined 

137Cs /90Sr 1:1 activity  Summary

in NDA mscaling facFor W027

should be “conservataccount re

Revision No.: 1 AK-15 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

AK-34If waste is generated after an EPA approved QA program, are radioassay and NDE results compared to the data assembly process as a cross reference to verify implementation of the as-generated characterization program?(194.24 (c)(3); 194.22(b))

CCP-TP-005, Revision 15 CCP-AK-

Rev.2; TWNumber 1AK-6, abolittle confinewly genprocess at interpreted 

AK-35This procedure requires a reevaluation of AK if NDEidentifies it to be a different waste matrix code. This procedure describes how the waste must be reassigned, based on the AK reevaluation.(Attachment B4, Section B4-3d) 

CCP-TP-005, Revision 15 Yes CCP-AK-

Rev..2; Mthe misideperformed (FastScan, discrepancNDE deterproceduralimpression actuality pidentify th

AK-36Does the generator site have written procedures for newly generated waste to document the confirmation ofacceptable knowledge information with visual examination prior to or during waste packaging? Dothese procedures address the required elements in 3.4-3d? (Attachment B4, Section B4-3d)

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2. CCincluding nstored was

AK-37Procedures require the following steps to be followed if wastes are reassigned to a different waste matrix codebased on NDE:

• Review existing information based on the container 

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2. No provided; 

Revision No.: 1 AK-16 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

identification number and document all differences 

• Reassess and document all analytical data associated 

with the waste 

• Reevaluate waste material parameter determinations

and document any changes 

• Reevaluate the radionuclide content and document

any changes 

• Verify and document that the reassigned waste matrix 

code was generated within the specified time period, area and buildings, waste generating process, and that the process material inputs are consistent with the waste material parameters identified duringradiography or visual examination 

• Record all changes to acceptable knowledge records • If discrepancies exist in the acceptable knowledge 

information for the reassigned waste matrix code, complete a nonconformance report, document the segregation of this container, and define the corrective actions necessary to fully characterize the waste 

(Attachment B4, Section B4-3d) 

AK-38Has the acceptable knowledge expert calculated the percent changes in matrix parameter categories (MPCs) based on AK and NDE/VE? Were accuracy evaluationsassigned? Are these acceptable?(Attachment B4, Section B4-3e; CH-WAC Appendix A, Section A.6.5)

CCP-TP-005, Revision 15 Partial Verification, see 

Objective Evidence 

CCP-AK-Rev.2; MiM022, CCMound waCalculatioadequate, no supportAccuracy because thto nuclide accuracy fdebris was 

Revision No.: 1 AK-17 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

technique and a too-bassigned b

NDA-AK Data Sharing and Communication/Proceduralization AK-39Are the following bullets addressed with respect to AKNDA communication and use of AK data by NDApersonnel?Do procedures require the identification of AK data limitations?Are AK data and associated limitations communicated to NDA personnel and is this required by procedure?How is AK used by NDA?Do AK and NDA personnel communicate and agree about the use of AK?Is this agreement proceduralized?(CH-WAC, Appendix A)

CCP-TP-005, Revision 15. Section 4.4.20

Yes CCP-AK-S

Rev.2; AKSR-MD-SCCP has pNDA and respect to personnel. limitations NDA pers

Auditing of AK Records and AK Discrepancy Identification/Resolution AK-40Have internal audits been performed?(Attachment B4, Section B4-3e) 

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2; SRReport. Inthis audit arather than an internal respect to 

Revision No.: 1 AK-18 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

AK-41Has a waste stream been revoked based either on AKinformation or reassessment as part of reconfirmation? If so, was the procedure(s) followed?(Attachment B4, Section B4-4) 

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2. No 

AK-42If data consistently indicate discrepancies with acceptable knowledge information, the site increases sampling,reassesses the materials and processes that generate the waste, and resubmits waste stream profile information. (CH-WAC Section A.2.2.3; Attachment B4, Sections B4-3b, B4-3d)

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2. No 

QA Objectives for AK and Other Elements AK-43Are acceptable knowledge processes consistently applied among all generator sites, and does each generator sitecomply with the following data quality requirements for acceptable knowledge documentation: a. Precision - Precision is not applicable to AK (see 

Attachment B4) 

b. Accuracy - Accuracy is the degree of agreement 

between an observed sample result and the true value. The percentage of waste containers which require reassignment to a new waste matrix code based on thereevaluation of acceptable knowledge and sampling and analysis data will be reported as a measure of acceptable knowledge accuracy. Accuracy based on radionuclide content is typically assessed bycomparing measured results with AK data. 

c. Completeness - Completeness is an assessment of the 

CCP-TP-005, Revision 15 Partial Verification, see 

Objective Evidence 

CCP-AK-Rev.2. AcReport, Mcalculationrequiremento be usefucomparisorespect to compromiwaste streawas broadon availabAccuracy that every FastScannBecause eRTR/VE awastes are characteriz

Revision No.: 1 AK-19 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

number of waste streams or number of samples collected to the number of samples determined to beuseable through the data validation process. The acceptable knowledge record must contain 100 percent of the information specified in Section B4-2. The usability of the acceptable knowledge information will be assessed for completeness duringaudits. 

d. Comparability - Data are considered comparable 

when one set of data can be compared to another set of data. Comparability is ensured through sites meeting the training requirements and complyingwith the minimum standards outlined for procedures that are used to implement the acceptable knowledgeprocess. CH-WAC Section A.6.5: Additionally, comparison of measured data with AK-derived or -based values, as applicable, provides a means toassess comparability on a waste stream basis. 

e. Representativeness - Representativeness expresses the 

degree to which sample data accurately and precisely represent characteristics of a population. Representativeness is a qualitative parameter that will be satisfied by ensuring that the process of obtaining,evaluating, and documenting acceptable knowledge information is performed in accordance with the minimum standards established in Section B3. Sites also must assess and document the limitations of the acceptable knowledge information used to assign waste parameters. 

(Attachment B4, Section B4-3e) 

miscalcularespect to 

AK-44Does the generator site address quality control bytracking its performance with regard to the use of acceptable knowledge by: 1) assessing the frequency of 

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2; AK (Attachmemound AK identificat

Revision No.: 1 AK-20 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

inconsistencies among information, and 2) documentingthe results of acceptable knowledge confirmation through radiography or visual examination? In addition, the acceptable knowledge process and waste streamdocumentation must be evaluated through internal assessments by quality assurance organizations andassessments by auditors or observers external to the organization (i.e., CBFO, NMED, EPA).(Section B4-3e) 

performed assessmen40, above)

AK-45Did the generator site implement, or does it currently implement, process controls to ensure that prohibited items are documented and managed in accordance withsite-specific certification plans and that the following minimum site specific controls: 

• Identify the organization(s) responsible for 

compliance with administrative controls 

• Identify the oversight procedures and frequency of

actions to verify compliance with administrative controls

• Develop on-the-job training specific to administrative 

control procedures 

• Ensure that personnel may stop work if

noncompliance with administrative controls isidentified

• Develop a nonconformance process that complies 

with the requirements in Section B3-13 of the WAP to document and establish corrective actions

• Address controlled changes to WAP-related plans or

procedures as part of the nonconformance and 

CCP-TP-005, Revision 15 Partial Verification, see 

Objective Evidence 

CCP-AK-Rev.2; SRSRS ProceCAND-01P006, P01generator to control in waste as historically control waprocedures waste contAK portiorecognized characterizperform “Fto quickly consider thcontrol. Aprocedures which are Further, thitems detenot examindrums consegregated population 

Revision No.: 1 AK-21 
ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Required Technical Elements Procedure Location/Adequacy Verification of Activity Exam

corrective action process 

• As part of the corrective action process, assess the 

potential time frame of the noncompliance, the potentially affected waste population(s), and the reassessment and recertification of those wastes 

(Attachment B4, Section B4-3b) 

treatment)the WAP Aadministraand better where prohistorically being gene

AK-46Does the generator site document, justify, and consistently delineate waste streams... based on sitespecific permit requirements or state-enforced agreements? How do these agreements impact waste characterization?(Section B4-4) 

CCP-TP-005, Revision 15 Yes CCP-AK-S

Rev.2; TWTWBIR desometimes assigning No state-erequiremeninspection determinat

Revision No.: 1 AK-22 
ATTACHMENT A.2: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Ev

VE-1Site procedures identify required training and qualifications for VE personnel.

CCP-QP-002,Revision 17

Visual Examination Expert’s (VEE) explanation of job duties was consistent with applicable procedures. VE personnel’s training was consistent with applicable procedures. VE personnel’s certification is current. VE personnel are re-qualified every two years. • VE personnel received training on specific 

waste generating processes, typical packaging configurations, WMPs expected to be found in each Waste Matrix Code 

Y CCP uses Qualification Card

training received by CCP perManager appoints Visual Exais documented in a letter that training file. Training on spetypical packaging configuratfound in each Waste Matrix Cpersonnel.The site maintains a List of Qused to ensure all training is During the inspection, the Quoperator/ITR/TS/FQAO was complete and current. Also, was reviewed and found to bcontained the letter appointin

Objective evidence reviewed

VE operator Qualification CaVEE Qualification CardList of Qualified Individuals 

VE-2Procedures and technical guidance documents provide complete instructions for performing VE. 

CCP-TP-113, Revision 3 

• The site uses AK to identify the waste 

matrix code category and to estimate waste material parameters present 

• Procedures are sufficiently detailed to

enable the operator to determine if a waste container meets the criteria of '194.24 with regard to identifying applicable parameters with waste limits 

• Establish standard nomenclature, based on

current site practice, so that all staff recognize waste by the same descriptors 

Y Two types of VE were assess

CCP, namely VE in lieu of RRTR. Procedure CCP-TP-113 continstructions for performing VVE in lieu of RTR. These twexactly the same manner and of the procedure. The procedprohibited items, a descriptiodescription of Waste Materiatable for waste item weights, used to record some of the V

Revision No.: 1 VE-1 
ATTACHMENT A.2: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Ev

When a new AK summary bereceive documented training and packaging configuration

VE-3 CCP-TP-113, 

Revision 3, s.3.2.3 

Prior to starting the VE, the VEE reviews all documented data related to the waste container and its contents to ensure that there are no safety hazards for the VE operators 

All drums go through fast sca

informed by the VPM if theridentified in the drums. AK summaries for the waste available to the VEE and VE VE takes place. Objective evidence reviewed

1. VE in lieu of RTR BDRs

SRVEP60019, SRVEP60SRVEMS0001, SRVEM

2. VE as a QC check of RT

SRVEP60037, SRVEP60

VE-4Procedure requires an audio/visual recording of the VE event to be made.

CCP-TP-113, Revision 3, s.4.1.2 

• VEE/operator’s explanation of how to

operate the data recording system was consistent with applicable procedures 

• The video camera was focused prior to the

start of VE 

An audio/videotape is made of the waste container exam and maintained as a nonpermanent record • Data on the audio/visual recording is 

consistent with documentation

Y During the inspection, EPA o

debris (S5000) drum. The drBDR # was SRVEP60162. TSR-W027-221H-HET. At thoperations were operating on The VE event took place in bVE was performed by 2 operdata and controlling which cavisual recordings. An RCT icontainment area and is respocamera. Other cameras are in Two tapes are made of the Vobserved that the required au

performed as required. The E

Revision No.: 1 VE-2 
ATTACHMENT A.2: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Ev

scale check. For this VE event, the drum cdrum, sorted in accordance winto a new drum. All data arcandidate drum is sealed and BDR SRVEP60029, VE in lidrum # SR557498 and audioduring the on-site inspectionSRVEMS0002, and BDR SRwaste and their associated aureviewed. In all cases, the wthe tape record. During the inspection of VE reviewed BDR SRVEP60037 audio/visual tape for BDR SRperformed VE as a QC check procedure. The drums in botwaste. The written record foSR100052 and the audio/visuinformation and EPA InspectSRS-CCP-VE-06-002CR waConcern SRS-CCP-VE-06-00The Waste Visual Examinatifrom procedure CCP-TP-113match what actually transpireDrum No. SR100052. The vwith the VE data for this drum the hard copy record. Subseqdiscarded and replaced with ovideotaped event. Consequeremains does not represent wdrum. 

Revision No.: 1 VE-3 
ATTACHMENT A.2: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Ev

Objective evidence reviewed

VE in lieu of RTR BDRs: 

SRVEP60019, SRVEP60

SRVEMS0001, SRVEM

VE as a QC check of RTR B

SRVEP60037, SRVEP60

VE-5There is a procedure for handling instances when the VE Expert is unable to see through the inner plastic bags/packages/containers ofwaste. 

CCP-TP-113, Revision 3, s.3.2, 4.1.4, [F3], (b) 

The VEE has decision making criteria for assessing the need to open the bags/packagesin order to identify all of their contents. If the bags are not opened, a brief writtendescription of the contents of the bags isprepared with estimates of the amount of each waste type in the bags.

Y It is CCP’s policy to open all 

For VE as a QC check of RTdrums in the reviewed BDRsFor the drums containing soiperformed and documented iCCP-Waste Visual ExaminatBDRs. The top of the waste soil/ gravel was not removed Issue Tracking Form No. SRinitiated to address this issueFinding SRS-CCP-VE-05-00When performing VE on S40soil waste stream described iSRVEMS0001 through SRVvisual inspection that was noCCP-TP-113, Revision 3. Thdrums’ contents but focused The BDRs reported that no pthis could not be ascertained performed. Objective evidence reviewed

VE in lieu of RTR BDRs: 

Revision No.: 1 VE-4 
ATTACHMENT A.2: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Ev

SRVEP60019, SRVEP60

SRVEMS0001, SRVEM

VE as a QC check of RTR BD

SRVEP60037, SRVEP60

VE-6The VE procedure requires verification of Waste Matrix Code and WMP weights.

CCP-TP-113, Revision 3,Attachment 1, Tables 1-4 

• If an automated data entry system is used, 

data entry VE personnel could navigatethrough the various screens 

• A VE data form is used to document the 

waste matrix code and estimated WMP weights of the waste 

• VE staff have access to standardized charts 

or tables to aid in the consistentestimation/assignment of weights, waste material parameters, and waste matrixcodes 

• The estimated or weighed WMP weights 

are determined by compiling an inventoryof waste items, residual materials and packaging materials 

• The items on the inventory list are sorted

by WMP and combined with a standard weight look-up table to provide an estimate of WMP weights 

• References tables are updated as site gains 

information from VE 

• VEE verifies Waste Matrix Code and 

recommends changes as needed 

Y All data sheets are completed 

data sheets for each drum prothe end of the day (they do ncontainment area as each druThe waste matrix code is recon the CCP Waste Visual Exare recorded in section 3 of thExamination Data Form and form. Procedure CCP-TP-113, Revprohibited items, a descriptiodescription of Waste Materiatable for waste item weights, used to record some of the VFor soil drums, WMPs weighof the soil/gravel is calculatedrum minus the estimated weWhen performing VE as a Qby WMP and actual weights The waste matrix code is recon the CCP Waste Visual ExThe VEE interviewed had neWMP reference table. Occasare not contained in the referfrequency to require updating 

Revision No.: 1 VE-5 
ATTACHMENT A.2: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Ev

Objective evidence reviewed

VE in lieu of RTR BDRs: 

SRVEP60019, SRVEP60

SRVEMS0001, SRVEM

VE as a QC check of RTR B

SRVEP60037, SRVEP60

VE-7Procedure provides instructions for processing of containerswith prohibited items. 

CCP-TP-113, Revision 3, s.4.3, Attachment1, s. 5 

VE expert could name prohibited items. VE expert’s explanation of required actions ifprohibited items were encountered was consistent with procedure. The VEE describes any liquids found, including a description of their location in the container and estimated volume. Other prohibited items, including sealed containers are identified and segregated. 

Y EPA interview of a VEE dem

to identify prohibited items afound. The process describeprocedure CCP-TP-113, Revare either remediated or remocontinued. If an item is founthis way, the VE event would initiated and the VPM would inspection no drum had been processed. Volume utilization is recorde1, CCP Waste Visual Examinweight of the container in quThis information was present Objective evidence reviewed

VE in lieu of RTR BDRs: 

SRVEP60019, SRVEP60

SRVEMS0001, SRVEM

VE as a QC check of RTR B

SRVEP60037, SRVEP60

Revision No.: 1 VE-6 
ATTACHMENT A.2: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Ev

VE-8 CCP-TP-113, 

Revision 3, s.4.1.4, [C.1] & [C.8]Attachment 1, s. 2 

The gross weight of the waste container 

(container plus contents) is recorded on the VE data form.

Volume utilization of the container is 

documented. 

Y Volume utilization is recorde

1, CCP Waste Visual Examinweight of the container in quThis information was present Objective evidence reviewed

1. VE in lieu of RTR BDRs

SRVEP60019, SRVEP60

SRVEMS0001, SRVEM

2. VE as a QC check of RT

SRVEP60037, SRVEP60

VE-9 CCP-TP-113, 

Revision 3, s.4.3.2 CCP-QP-005,Revision 10

The procedure is adequately implemented • Corrective actions are taken when

necessary 

Y The demonstration observed 

performed in accordance with Revision 3. The BDRs and tcontained all of the required SRS-CCP-VE-06-002CR). NCRs NCR-SRS-0901-05 anreviewed during the inspectiobecause the waste in drums Fmatch the waste stream descrthe drums was “use as is” and responsible manager and the Officer / Facility Quality AssObjective evidence reviewed

1. VE in lieu of RTR BDRs

SRVEP60019, SRVEP60

SRVEMS0001, SRVEM

2. VE as a QC check of RT

SRVEP60037, SRVEP60

3. NCRs NCR-SRS-0901-0

Revision No.: 1 VE-7 
ATTACHMENT A.2: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Ev

VE-10 Site procedure(s) require data generation and project levelreviews of Batch Data Reports (BDRs). 

CCP-TP-113, Revision 113, s. 4.6-4.8,Attachments 2-4 CCP-TP-001, Revision 11,Attachment 2 &5 

• BDRs contain all required information (see 

table below)

• Data generation and project level reviews

are complete 

Y The BDRs reviewed for VE i

check of RTR contained all oBDRs contained completed areview checklists (IndependeTechnical Supervisor, Facilitand completed and signed pr(Site Project Manager and SiOfficer). Objective evidence reviewed

VE in lieu of RTR BDRs: 

SRVEP60019, SRVEP60

SRVEMS0001, SRVEM

VE as a QC check of RTR B

SRVEP60037, SRVEP60

VE-11 The site has a procedure for using the data obtained fromVE as a QC check of RTR to calculate the percentage of miscertified waste containers. The facility has a procedure for randomly selecting waste containers. 

CCP-TP-113, Revision 113, s. 4.1 CCP-TP-003, Revision 14, s.4.9 - 4.10, 4.12, Table 1 

The number of waste containers to undergoVE is appropriately calculated. The site uses an initial miscertification rate of 11%. Miscertification rate is calculated for each applicable Summary Category Group after 6months or 50% of the SCG have undergone RTR. Site uses 1% miscertification rate if calculatedvalue is <1%. Rate is reassessed annually using a drumweighed average.

An inter-office memorandum 

Group S5000 Specific MisceS5000 (debris) miscertificatioSixteen drums were selected October 4, 2004 and May 3, to the 141 drums processed in miscertification rate of 3% wwaste containers to undergo VObjective evidence reviewed

VE as a QC check of RTR B

SRVEP60037, SRVEP6

Inter-office memo, “Savanna

S5000 Specific Miscerti

Inter-office memo, “Waste M

Comparison Report for S2004 through May 2005 Comparison Report for RExamination”

Revision No.: 1 VE-8 
ATTACHMENT A.2: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Ev

VE-12 The site has a documented stratagem for selecting replacement waste containers. 

CCP-TP-003, Revision 14, s 4.12 & 4.13

If fewer containers were visually examined 

than were sampled, the reason for excluding the containers is documented 

The replacement stratagem is restricted to

containers from the same waste stream

VE is performed on the replacement

containers 

Y Containers used for calculati

chosen randomly, by Excel sare documented in a “VE RanReport”. This report also docontainer replacement from treport is generated for selectisampling. Objective evidence reviewed

VE as a QC check of RTR B

SRVEP60037, SRVEP60

Inter-office memorandum, “2

Containers for Solids SamSite” 

VE-13 The calculation used for the miscertification rate is documented. 

CCP-TP-003, Revision 14, s.4.9 

After the required number of containers have

been visually examined, the UCL90 for the

proportion miscertified is calculated

The site has used the appropriate distribution 

for the UCL90 calculation to determine N. 

Y An inter-office memorandum 

Group S5000 Specific MisceS5000 (debris) miscertifcatioSixteen drums were selected October 4, 2004 and May 3, to the 141 drums processed in miscertification rate of 3% wdetermining the number of coduplicate of that in WAP, TaObjective evidence reviewed

VE as a QC check of RTR B

SRVEP60037, SRVEP60

Inter-office memo, “Savanna

S5000 Specific Miscertif

Inter-office memo, “Waste M

Comparison Report for S2004 through May 2005 Comparison Report for RExamination”

Revision No.: 1 VE-9 
ATTACHMENT A.2: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Ev

VE-14 Results of VE as a QC check of RTR are forwarded to the radiography facility. 

RTR operators receive results of RTR/VE

comparison 

Y RTR personnel are required t

Comparison Reports as are thavailable electronically for thissues are discussed with the 

Objective evidence reviewed

1. Inter-office memo, “Wa

Comparison Report for S2004 through May 2005 Comparison Report for RExamination”

Information Included in BDR – VE in Lieu of RTR, Soils and Debris 

Required Testing Batch Content Present Y or N Required Testing Batch Content Present Y or N Required Testing Ba

Batch Date Y Description of liners Y Verification of Waste MReport date Y Layers of confinement Y Reference to or copies Waste container number Y Indication of vented rigid liners Y VEE decisions Waste Matrix Code Y Description of container contents Y Operator signature and Implementing procedure name or # Y Indication of sealed containers >4L Y VEE signature and test Videotape reference Y Amount of free liquid Y Completed data generaQC documentation Y Container gross weight Y Completed project leveVerification that waste matches waste stream description 

Y Waste Material Parameters weights Y 

Revision No.: 1 VE-10 
ATTACHMENT A.2: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Information Included in BDR – VE as a QC Check for RTR, Debris 

Required Testing Batch Content Present Y or N Required Testing Batch Content Present Y or N Required Testing Ba

Batch Date Y Description of liners Y Verification of Waste MReport date Y Layers of confinement Y Reference to or copies oWaste container number Y Indication of vented rigid liners Y VEE decisions Waste Matrix Code Y Description of container contents Y Operator signature and tImplementing procedure name or # Y Indication of sealed containers >4L Y VEE signature and test dVideotape reference Y Amount of free liquid Y Completed data generatiQC documentation Y Container gross weight Y Completed project level Verification that waste matches waste stream description 

Y Waste Material Parameters weights Y 

Revision No.: 1 VE-11 
ATTACHMENT A.3: VISUAL EXAMINATION TECHNIQUE (VET) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of 

Required Technical 

Elements in Procedures

Y/N 

Location Execution of Procedures Y/N Objective Evide

VET-1Site procedures identify required training and qualifications for VET personnel.

CCP-QP-002,Revision 17

VE personnel’s training was consistent with applicable procedures. VE personnel’s certification is current. VE personnel are re-qualified every two years. • VE personnel received training on specific 

waste generating processes, typical packaging configurations, WMPs expected to be found in each Waste Matrix Code 

Y CCP uses Qualification Cards to doc

personnel. The letter from Site ProjExamination Expert (VEE) is includCard. Training on specific waste gepackaging configurations, WMPs exMatrix Code is provided to the VE pThe site maintains a List of Qualifieensure all training is current. During the inspection, the Qualificaoperator/ITR/TS/FQAO was reviewcurrent. Also, the Qualification Carfound to be complete, current, and cas a VEE. 

Objective evidence reviewed:

 VE operator Qualification Card 

VEE Qualification Card

 List of Qualified Individuals for V

VET-2Procedures and technical guidance documents provide complete instructions for performing VET. 

CCP-TP-113, Revision 3, s.4.2 

• Two trained operators perform VET • Procedures are sufficiently detailed to

enable the operator to determine if a waste container meets the criteria of '194.24 with regard to identifying applicableparameters with waste limits 

• Establish standard nomenclature, based on

current site practice, so that all staff recognize waste by the same descriptors 

Y Procedure CCP-TP-113 contains com

for performing VET. The procedure prohibited items, a description of layof Waste Material Parameters (WMweights, and a table explaining the cVE data. During the on-site inspection EPA oSR233850 (S5440, debris) from wasTwo operators performed the VET a

generated. The drum contained a huoperators had to cut the hut out of thamount of residual liquid was found Operator aid # E-03-0006, Revision scale ID #, calibration date, and is uinspector observed the calibration ch

Revision No.: 1 VET-1 
ATTACHMENT A.3: VISUAL EXAMINATION TECHNIQUE (VET) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of 

Required Technical 

Elements in Procedures

Y/N 

Location Execution of Procedures Y/N Objective Evide

WMPs. Two cans (prohibited itemscans were removed, after weighing, An NCR was initiated as required. Ndemonstration purposes only and the SRS/CCP. Two BDRs were generated by SRS/demonstration during the inspectionsubject drums, SR545235 and SR50characterization. Objective evidence reviewed:

BDRs (S5000, debris): SRVETXxxx1, SRVETXxxx2 

VET-3The VET procedure requires verification of the physical form of the waste and presence or absence ofprohibited items. 

CCP-TP-113, Revision 3,Attachment 1 

• A VET data form is used to document

verification of the physical form of the waste and the Waste Matrix Code 

• Packaging configuration, type and number 

of filters, and rigid liner vent hole (presence and diameter) are documented for each container 

• Presence or absence of prohibited items is

documented on the VET data form

• VET operators explanation of required 

actions if prohibited items were encountered was consistent withprocedure 

• If an automated data entry system is used, 

data entry VET personnel could navigatethrough the various screens 

• A calibrated scale is used to weigh WMPs VET staff have access to standardized charts

or tables to aid in the consistentestimation/assignment of WMP weights 

Y Attachment 1 from procedure CCP-

data, which includes Waste Matrix Crigid liner vent hole (presence and dof prohibited items. Data are entereVEE, as the data are generated. The weighed and recorded. After weighthe output waste container. Prior to calibration is checked and recorded. provides standard weights for waste demonstration BDRs provided for reweighed. It is optional for the VET audio/visual tape. Objective evidence reviewed:1. BDRs (S5000, debris): SRVETXxxx1, SRVETXxxx2 

Revision No.: 1 VET-2 
ATTACHMENT A.3: VISUAL EXAMINATION TECHNIQUE (VET) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of 

Required Technical 

Elements in Procedures

Y/N 

Location Execution of Procedures Y/N Objective Evide

VET-4 CCP-TP-113, 

Revision 3,Attachment 1 

The gross weight of the waste container (container plus contents) is recorded on the VE data formVolume utilization of the container is documented 

Y The forms used to record VET data 

as a QC check of RTR and VE in lieTP-113). Volume utilization is recoAttachment 1, CCP Waste Visual Exgross weight of the container in queinformation was present in all the BObjective evidence reviewed:1. BDRs (S5000, debris):

 SRVETXxxx1, SRVETXxxx2 

VET-5Procedures and technical guidance documents provide complete instructions for performing VET. 

CCP-TP-113, Revision 3CCP-QP-005 

The procedure is adequately implemented • Corrective actions are taken when

necessary 

Y During the demonstration VET even

prohibited items were found in the dNCRs NCR-SRS-0901-05 and NCRduring the inspection. These NCRs in drums FBL01216 and SR544842 description. The final disposition of the NCRs were correctly signed by tSPQAO/FQAO. Although these NCVET, they demonstrated that VE perNCRs as required and were familiar Objective evidence reviewed:1. NCRs NCR-SRS-0901-05 and N

VET-6Site procedure(s) require data generation and projectlevel reviews of BatchData Reports (BDRs). 

CCP-TP-113, Revision 3,Attachments 2-4 CCP-TP-001, Revision 11,Attachments 2 &5

• Data generation level reviews are 

performed and documented 

• Project level reviews are performed and 

documented 

Y The two BDRs reviewed contained 

and contained completed and signed checklists (ITR, TS, and FQAO) and level review checklists (SPM and SPObjective evidence reviewed:1. BDRs (S5000, debris): SRVETXxxx1, SRVETXxxx2 

Revision No.: 1 VET-3 
ATTACHMENT A.4: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements 

in Procedures

Y/N 

Location Execution of Procedures Y/N Objective 

RTR-1 Site procedures identify required training and qualifications for RTR personnel

CCP-TP-011, Revision 16,s. 3.3 CCP-QP-002,Revision 17CCP-TP-028, Revision 2,CCP-TP-028-A1, Revision 0

Operator training was consistent with applicable procedures. Operator certification is current. OJT was documented for each operator. Operators are re-qualified every two years.RTR operators passed a training drum test thatincludes items common to the waste streams examined at the site (biannually). Training drum contains all required items. RTR operators receive training on the waste matrix parameters and typical packagingconfigurations expected to be found in each waste stream. 

Y CCP uses Qualification 

training received by CManager appoints RTR and this appointment iin the SME’s training fgenerating processes, tWMPs expected to be is provided to the RTR receive training for eacand have AK summarireference.The site maintains a Liwhich is used to ensure time of the inspection, qualified for RTR. Alqualified on unit RTR During the inspection, operator/ITR/TS/FQAcomplete and current. an SME was reviewed current, and contained SME. EPA reviewed the latetape and documentatioan RTR operator. The and drum used was SRno problems identified EPA also reviewed the tape and documentatioperformed on 8/25/05 TEST-12B. Although horsetail, the SME did reviewing the tape did 

Revision No.: 1 RTR-1 
ATTACHMENT A.4: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements 

in Procedures

Y/N 

Location Execution of Procedures Y/N Objective 

following concern was process used by CCP dprovide adequate trainSRS-CCP-RTR-05-003training in accordance an operator did not idetraining drum. Althoureviewed this training NDE Test Drum InvenRevision 0 was not usebecause the reviewer ditem was missed. The of identification of prorequalification of RTR the opportunity for feeRTR Operator requalif

Objective evidence rev

RTR operator QualificRTR SME QualificatioCompetency demonstr

associated docume

List of Qualified Indiv

RTR-2 Site procedure(s) provide completeinstructions for operators toperform the RTR examination and completion of the associated documentation

CCP-TP-011, Revision 16

• RTR operator adequately explained the process 

followed for examining a drum and entering datainto data forms (whether hard copy or electronic data entry is used). 

Y During the on-site insp

event for a debris (S50(batch SRRTR1749) odemonstration took plaoperator had a copy of TP-011) available in thperformed the RTR evprocedure instructionsentered into the data fo

Revision No.: 1 RTR-2 
ATTACHMENT A.4: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements 

in Procedures

Y/N 

Location Execution of Procedures Y/N Objective 

CCP-TP-011). An opestandard weights that aRadiography Data Sheweight is used to check scale. A tolerance of ± the Lines Pair Resolutiand documented on AtTwo audio/visual tapes RTR event. 

Objective evidence rev

BDRs, debris, S5000:

SRRTR1724, SRR

Audio/visual recording

SRRTR1732

RTR-3 The RTR procedure(s) require an image quality check to beperformed 

CCP-TP-011, Revision 16, s.4.6 

• Operator adequately explained how the 

acceptability of an image is determined 

• Image quality check is performed once per day • Performance of the image quality check is 

documented and recorded

Y The operator was able 

worked and what actioThe image quality chethe demonstration RTR each of the BDRs reviewas documented on At(Radiography Measure

Objective evidence rev

BDRs, debris, S5000:

SRRTR1724, SRR

RTR-4 The procedure allows the operator to adjust the RTR to accommodate the physical properties of the waste and waste containers likely to be 

CCP-TP-011, Revision 16, s.4.7.4 

• Operator could identify applicable policies and 

procedures governing the operation of RTR equipment

• The RTR system could be adjusted 

Y During the demonstrat

adjusted the Kv of the densities of the materiaSRS-CCP undergo Fasapproved process for Wprohibited items prior 

Revision No.: 1 RTR-3 
ATTACHMENT A.4: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements 

in Procedures

Y/N 

Location Execution of Procedures Y/N Objective 

encountered at the site • High-density material was examined with the 

x-ray device set on the maximum voltage and low density material at a lower voltage

• Operator adequately explained what is done if an 

image is unacceptable (e.g., the waste is solidified or the container is lead-lined) 

RTR process. If prohiare returned to SRS fothe containers are sent does not identify the pcontainer is subjected tCCP-TP-011. For this identified, they are remCCP-TP-136. ContainRTR due to the presenlead lined gloves. If a it will be examined by (CCP-TP-113). 

Objective evidence rev

BDRs, debris, S5000:

SRRTR1724, SRR

RTR-5 CCP-TP-011, 

Revision 16, s.4.3 

RTR tape is high quality, the sound track is audible, and the required information is contained on the audible portion of the tape. The RTR tape is consistent with the data package for the same drum. 

Y As part of the inspectio

#s SR100137 (BDR # (BDR SRRTR1728) won the audio/visual tapwere consistent. The aand of good quality. 

Objective evidence rev

BDRs, debris, S5000:

SRRTR1724, SRR

RTR-6 There is a procedure for determining whether the waste matches the waste streamdescription and Waste MatrixCode, and for determining Waste 

CCP-TP-011, Revision 16, s.4.7.12 [P] & [Q],Attachment 1-3 

The procedure is adequately implemented Operators verify that the waste matches the waste stream description. Waste Matrix Code is verified. If not, corrective action is taken. 

Y Attachment 3, CCP-TP

documents that the phythe waste stream descrDuring the RTR event weights are estimated contains standard weig

Revision No.: 1 RTR-4 
ATTACHMENT A.4: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements 

in Procedures

Y/N 

Location Execution of Procedures Y/N Objective 

Material Parameters and Weights WMP weights are estimated by compiling an 

inventory of waste items and residual/packagingmaterials.Does the RTR operator use a standard weightlookup table to provide an estimate of WMP weights? If so, has the table been updated toreflect additional information gained through previous RTR/VE exams or updated AKinformation?

critical when assigning and 2 of procedure CCstandard weights for co

Objective evidence rev

BDRs, debris, S5000:

SRRTR1724, SRR

RTR-7 The RTR procedure providesinstructions for identifyingprohibited items and for processingdrums containing prohibited 

CCP-TP-011, Revision 16, s.4.7.12, [J],Attachment 3 

Operator could name prohibited itemsOperator adequately explained how the presence of free liquids is determined Operator’s explanation of required actions if prohibited items were encountered was consistentwith procedureCorrective actions are taken when necessary 

Y The operator was able 

demonstrated how the determined (rocking thWhen a prohibited item Liquid greater than 1” batch SRRTR1728 and initiated. This drum wbatch, containers 772FSR529802 contained gThe disposition for theNCR # NCR-SRS-127

Objective evidence rev

BDRs, debris, S5000:

SRRTR1724, SRR

RTR-8 RTR procedures include the required QC examinations, evaluation accuracy and reproducibility of the RTR process 

CCP-TP-011, Revision 16, s.4.9 & 4.10

• An independent replicate scan is performed on

one waste container per day or on one containerper testing batch (whichever is less frequent)

• An independent observation of one scan (not the 

replicate) is performed, by a qualified RTRoperator (anyone but the initial RTR operator) 

Y In batch SRRTR1278, 

performed on containewas performed on contSRRTR1732, an indepperformed on containewas performed on contoperator from the origisamples. The replicate 

Revision No.: 1 RTR-5 
ATTACHMENT A.4: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements 

in Procedures

Y/N 

Location Execution of Procedures Y/N Objective 

observation for batch Sbatch SRRTR1723. 

Objective evidence rev

BDRs, debris, S5000: SRRTR1728, SRR

RTR-9 Procedure(s) contain standardized forms for recording RTR data

CCP-TP-011, Revision 16,Attachment 3 

• RTR operator adequately explained the process 

followed for examining a drum and entering datainto data forms (whether hard copy or electronic data entry is used). 

• Direct data entry into an electronic form is done

by the RTR operator using a computer while the operator is still in the RTR booth.

• The electronic data file undergoes the same

quality control (QC) checks used for hand-writtendata entries 

Y During the on-site insp

event for a debris (S50(batch SRRTR1749) odemonstration took plaoperator had a copy of TP-011) available in thperformed the RTR evinstructions contained electronically entered iof procedure CCP-TP-available for WMP stacompleting the RadiogThe BDRs are subject project level reviews. reviewed were comple

Objective evidence rev

BDRs, debris, S5000:

SRRTR1724, SRR

RTR-10Site procedures require review of Batch Data Reports (BDRs) at the data generation and project level

CCP-TP-011, Revision 16,Attachment 4-7 CCP-TP-001, Revision 11

Data generation level reviews are performed anddocumented Project level reviews are performed and documented 

Y BDRs SRRTR1724, SR

were reviewed during tcontained complete anreview checklists (IndeTechnical Supervisor, Officer). The BDRs alsigned Site Project Qua

Revision No.: 1 RTR-6 
ATTACHMENT A.4: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements 

in Procedures

Y/N 

Location Execution of Procedures Y/N Objective 

checklists. The Site Prsummary for these BDtime of the inspection. 

Objective evidence rev

BDRs, debris, S5000:

SRRTR1724, SRR

RTR-11RTR operators receive the results of the VE/RTR comparison 

RTR operators receive the results of the VE/RTR 

comparison RTR operators receive lessons learned information based on the comparison of RTR and VE data

Y RTR personnel are req

Parameter Comparison operators can access thsignificant issues are d

Objective evidence rev

Inter-office memo, “WComparison Report fo2004 through May 200Comparison Report foExamination”, dated M

Revision No.: 1 RTR-7 
ATTACHMENT A.4: REAL-TIME RADIOGRAPHY (RTR) CHECKLIST 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Information Included in BDR 

Required Testing Batch Content Present Y or N Required Testing Batch Content Present Y or N Required Testing Bat

Batch Date Y Description of liners Y Verification of Waste MaReport date Y Layers of confinement Y Reference to or copies of Waste container number Y Indication of vented rigid liners Y Operator signature and teWaste Matrix Code Y Description of container contents Y Data generation checklistImplementing procedure name or # Y Indication of sealed containers >4L Y Project level checklists Videotape reference Y Amount of free liquid Y QC documentation Y Container gross weight Y Verification that waste matches waste stream description 

Y Estimated weights for Waste 

Material Parameters 

Y 

Revision No.: 1 RTR-8 
ATTACHMENT A.5: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IPAN 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

System Description Identify the NDA system by name, locationand number, as appropriate. 

Y CCP-PO-002, Revision 13 The IPAN/GE system addressed in this

checklist is identified and described.

Y T

AEsShwoB

Describe the system’s operational historyincluding deployment at other DOE sites. 

NA Not Applicable The system’s operational history for 

TRU wastes for WIPP is restricted to SRS. 

NA F

cWo

For systems that have been deployed atmultiple DOE sites document pertinent aspects of each system’s development, e.g., installation of new or different detectors,software or other relevant features. 

NA Not Applicable This system has not been deployed at

other DOE sites for assaying TRU wastes for WIPP. 

NA T

da

System Performance Identify the period of performance relevant tothis inspection and if this NDA system has prior EPA approval(s). 

NA EPA Inspection Notification

Letter for EPA-SRS-10.05-8 and Inspection Report for EPA-CCP-SRS-09.04.24 

This inspection focuses on IPAN/GEA operations over the past year. Prior IPAN/GEA approvals are those determined by EPA. 

Y T

ToIIt

Revision No.: 1 NDA-IPAN-1 
ATTACHMENT A.5: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IPAN 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

Identify the number of waste containers thissystem assayed during the period ofperformance. Of these, indicate how many Batch Data Reports (BDRs) were assembled, and how many have been promoted throughProject Level Review and are available for evaluation during this inspection. 

NA Not Applicable CCP documents indicate the number of 

IPAN/GEA assays, the number of completed BDRs and how many BDRshave been promoted through Project Level Review and are available for evaluation during this inspection. 

Y A

a2rB

General Reporting Requirements Assay systems must report quantitative values and uncertainties for 238Pu, 239Pu,240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr, and 137Cs. 

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10; CCP-TP-026, Revision 6 

The IPAN/GEA provides quantitative values and uncertainties for all 10WIPP-tracked radionuclides. 

Y T

n(mv

22

aFR0

Each container characterized and intendedfor disposal at WIPP must contain TRU waste. 

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10; CCP-TP-026, Revision 6 

Containers to be disposed of at WIPP meet the definition of TRU waste. 

Y S

R0

NDA instruments and procedures areappropriate for the waste streams being assayed. 

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10; CCP-TP-024, Revision 20

The IPAN/GEA and associated procedures are appropriate for the waste matrices being assayed. 

Y T

fcm0Q

NDA instruments and procedures result inunbiased values for the cumulative activity of the WIPP radionuclide inventory.

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10; CCP-TP-024, Revision 20

The IPAN/GEA operation results inunbiased values for the cumulative activity of the WIPP radionuclide inventory.

Y S

R0

Revision No.: 1 NDA-IPAN-2 
ATTACHMENT A.5: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IPAN 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

Some radionuclides are derived by the application of scaling factors or correlation techniques. Identify all radionuclides that are quantified in this manner. 

Y CCP-PO-002, Revision 13;

CCP-TP-024, Revision 20; CCP-TP-025, Revision 10

All radionuclides derived by the application of scaling factors orcorrelation techniques are identified.

Y V

b

92

Ad5B

Assess the technical adequacy of thecalculations involving the application ofscaling factors and/or correlation techniques. 

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10

The technical adequacy of the calculations involving the application ofscaling factors and/or correlationtechniques is appropriate and documented. 

Y T

ctdCQ5WR

Identify the procedures that govern this function and where the results of these calculations are documented. 

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10

The CCP procedures that govern the application of scaling factors are identified and results of these calculations are documented. 

Y C

ptcI

Acceptable Knowledge (AK) If isotopic ratios based on AK are used the values are qualified by confirmatory testing.

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10

Isotopic ratios used in quantifying radionuclides are qualified byconfirmatory testing when AK is used. 

Y C

dbd

Revision No.: 1 NDA-IPAN-3 
ATTACHMENT A.5: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IPAN 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

Do NDA personnel use AK derived isotopicvalues to calculate radionuclide values? If so, is this function performed according to a formal procedure? Assess the technicaladequacy of this process(s). 

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10

NDA personnel using AK derived isotopic values to calculate radionuclide values do so according to a formal procedure the technical adequacy of which is acceptable. 

Y A

wC2Spu

Identify the procedure and where the results of these calculations are documented. 

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10

The procedure for AK relatedcalculations and where the results of these calculations are recorded are documented. 

Y C

Cdi

Isotopic Determination Identify the radionuclides that are measured directly and the specific radiation type (", AN or PN) that is measured. 

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10

The radionuclides that the IPAN/GEAmeasures directly and the specific radiation type (AN, PN of gamma) thatis measured are documented. 

Y T

gm

22

Identify the method(s) used to derive the isotopic contribution for the unmeasuredradionuclides, e.g., MGA, PC FRAM orother technique. 

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10

The IPAN/GEA methods used to derivethe isotopic contribution for the unmeasured radionuclides areidentified. 

Y E

(SR0

Lower Level of Detection (LLD) The LLD for each NDA system must be determined. For multi modal systems this may require a separate determination for eachmode, i.e., active neutron, passive neutron and gamma. 

Y CCP-PO-002, Revision 13;

CCP-TP-026, Revision 6 

The LLD for the IPAN/GEA has beendetermined for both operational modes (active neutron and passive neutron)over a range of waste-related indices, i.e., ABS/MOD & MOD indices. 

Y T

eDvdcpdi

Revision No.: 1 NDA-IPAN-4 
ATTACHMENT A.5: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IPAN 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

ib5

Site-specific environmental backgrounds and container-specific interferences must be accounted for in LLD determinations. 

Y CCP-PO-002, Revision 13;

CCP-TP-026, Revision 6 

Site-specific environmental backgrounds and container specific interferences are considered.

Y S

R0

NDA instruments performing TRU/NonTRU waste discrimination measurements arerequired to have a LLD no greater than 100nCi/g. 

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10; CCP-TP-026, Revision 6 

The IPAN/GEA performs TRU/NonTRU waste discrimination and has aLLD of less than 100 nCi/g for all pertinent operational modes. 

Y T

sTnC5

The technical basis and derivation for LLDsmust be adequate and appropriately documented. 

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10; CCP-TP-026, Revision 6 

The technical basis and derivation for the IPAN/GEA’s LLDs are adequate and appropriately documented.

Y T

Ioims4 2

For radionuclides that are not determined primarily by measurement an LLD analog, i.e., a reporting threshold must be used whenit is technically feasible. Identify all instances when this occurs and the form ofthe documentation of these activities. 

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10

For all radionuclides that are notdetermined primarily by measurement an LLD analog is used when it is technically feasible. All instances when this occurs are documented appropriately. 

Y L

t

2

Ic

Identify any/all instances where an LLD value for a non-measured radionuclide is not 

provided basis on a lack of technicalfeasibility. 

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10

There are no instances where an LLD value (analog) for a non-measuredradionuclide is not provided based on a lack of technical feasibility. 

Y C

ta

Revision No.: 1 NDA-IPAN-5 
ATTACHMENT A.5: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IPAN 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

Are LLD values container/assay event specific or are typical LLD values applied to a class or type of wastes, i.e., those with similar attributes? If LLD values are notcontainer/assay event specific identify the attributes or characteristics whereby waste containers are grouped. 

Y CCP-PO-002, Revision 13;

CCP-TP-025, Revision 10

The technical basis for the IPAN/GEA’s LLD values has been determined and isdocumented appropriately.

Y I

dgaActcBB

Total Measurement Uncertainty (TMU) The method used to calculate the TMU for all required quantities must be documented and technically justified.

Y CCP-PO-002, Revision 13 The method used to calculate the TMU

for all required quantities is documentedand technically justified.

Y T

d0dEa

TMU determination accounts for all sources of uncertainty, specifically: 

• Random errors• Calibration• Isotopic determination • Matrix inhomogeneity • Difference between calibration 

assumptions and actual waste 

• Non uniform source distribution • End effects • Self absorption • Transmission source • Self shielding• Neutron multiplication

Y CCP-PO-002, Revision 13 The TMU determination accounts for 

the following sources of uncertainty: 

• Random errors• Calibration• Isotopic determination • Matrix effects • Presence of neutron & gamma

interferents 

• Source distribution • Self shielding• Neutron multiplication

Y S

R

Revision No.: 1 NDA-IPAN-6 
ATTACHMENT A.5: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IPAN 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

Methods to determine TMU must bedocumented, reviewed and approved byCBFO for each NDA instrument.

Y CCP-PO-002, Revision 13 Methods to determine TMU have been

reviewed and approved by CBFO for each NDA instrument. 

Y B

Ja

System Calibration Each NDA instrument must be calibrated before its initial use. Determine the date of the system’s calibration of record and where this is documented. 

Y CCP-PO-002, Revision 13;

CCP-TP-026, Revision 6 

The IPAN/GEA was calibrated beforeits initial use and the system’s calibration of record has been determined and documented.

Y T

d0Q

The range of applicability of the system ‘s calibration(s) must be specified in site procedures or other formal documentation.Identify the manner in which the range is expressed, i.e., curies or Pu/SNM mass for activity and salient physical characteristics for matrix. 

Y CCP-PO-002, Revision 13;

CCP-TP-026, Revision 6 

The range of applicability for the IPAN/GEA’s calibrations has been specified and is documented appropriately. 

Y T

eAaMaot0

Any matrix/source surrogate waste combinations must be representative of the activity ranges and relevant waste matrixcharacteristics currently in use or planned for use by the system. The system must be calibrated to 100% recovery.

Y CCP-PO-002, Revision 13 ;

CCP-TP-026, Revision 6 

Matrix/source surrogate waste combinations used are representative of the activity ranges and relevant physical characteristics (matrices) of the waste containers currently measured by theIPAN/GEA. The system is calibrated to100% recovery. 

Y T

uipcspMB

The use of consensus standards for calibration is required, when such standards exist. If consensus standards do not exist, the calibration technique must be approved byCBFO. Identify the specific consensus standards that were used for the systemcalibration or, in their absence, the alternate 

Y CCP-PO-002, Revision 13;

CCP-TP-026, Revision 6 

A consensus standard has been used for the IPAN/GEA’s calibration and is citedin the CCP documentation.

Y B

cTAWND

Revision No.: 1 NDA-IPAN-7 
ATTACHMENT A.5: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IPAN 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

calibration technique. Evaluate the CBFO approval of the alternate technique. 

TtdcecD

Primary standards must be obtained fromsuppliers maintaining a nationally accredited measurement program. Identify the nationally accredited measurement program.

Y CCP-PO-002, Revision 13;

CCP-TP-026, Revision 6 

Primary standards have been obtained from suppliers maintaining a nationally accredited measurement program. Theprogram has been identified and appropriately documented. 

Y T

lRsv

List the standards used for calibration and verify the pedigree of each standard. 

Y CCP-PO-002, Revision 13;

CCP-TP-026, Revision 6 

The calibration standards are listed and the pedigree of each has been verified. 

Y C

P

SC

Calibration Verification & ConfirmationVerification of an NDA instrument’s calibration must be performed after any of the following occurrences: major systemrepairs and/or modifications, replacement of the system’s components, significant changes to the system’s software, and relocation ofthe system. 

Y CCP-PO-002, Revision 13;

CCP-TP-026, Revision 6 

Verification of the instrument’s calibration has been performed anddocumented as required. 

Y T

evf

Recalibration of the system must occur if the calibration verification demonstrates that the system’s response has significantly changed. 

Y CCP-PO-002, Revision 13;

CCP-TP-026, Revision 6 

Recalibration of the IPAN/GEA systemhas not been required within the lastyear. 

NA C

rh

The system calibration must be confirmed byperforming replicate measurements of a noninterfering matrix. 

Y CCP-PO-002, Revision 13;

CCP-TP-026, Revision 6 

The calibration has been confirmed byperforming replicate measurements of a non-interfering matrix. 

Y S

R

Revision No.: 1 NDA-IPAN-8 
ATTACHMENT A.5: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IPAN 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

Replicate measurements must be performed with containers of the same nominal size andaccording to the same procedures used for actual waste assays. 

Y CCP-PO-002, Revision 13;

CCP-TP-026, Revision 6 

Replicate measurements have been performed with containers of the samesize using the same procedures as thoseused for actual waste assays. 

Y S

R

Replicate measurements must be performed using nationally recognized standards orstandards derived from nationally recognizedstandards that span the range of use of the instrument with respect to disintegration rateand/or matrix effects. Identify all standards that were used and indicate their application (verification or confirmation). 

Y CCP-PO-002, Revision 13;

CCP-TP-026, Revision 6 

Replicate measurements have been performed using nationally recognizedstandards that span the range of use ofthe instrument with respect todisintegration rate and/or matrix effects. All standards that were used have beenidentified and their specific application documented. 

Y S

R5

Identify the nationally accredited measurement program. List the standards used for verification/confirmation and verifythe pedigree of each standard. 

Y CCP-PO-002, Revision 13 The nationally accredited measurement 

programs for the three types ofstandards used are identified allowingthe pedigree of each standard to beverified. 

Y S

AttTAP

The standards used for calibration confirmation must not be the same sources as those used for the system’s calibration of record. 

Y CCP-PO-002, Revision 13;

CCP-TP-026, Revision 6 

The standards used for calibration confirmation are different from those used for the IPAN/GEA’s calibration ofrecord. 

Y I

u

smuC5

Requirements for accuracy, expressed as %R, and precision, expressed as %RSD, must bemet as specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for precision and "30% for accuracy. 

Y CCP-PO-002, Revision 13;

CCP-TP-026, Revision 6 

Requirements for accuracy and precision have been met as specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for precision and "30% for accuracy. 

Y C

raC5

Revision No.: 1 NDA-IPAN-9 
ATTACHMENT A.5: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IPAN 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

Quality Control All radioassay and data validation must be performed by appropriately trained and qualified personnel.

Y CCP-PO-002, Revision 13;

CCP-QP-002 

Review and validation of IPAN data areperformed by appropriately trained and qualified personnel.

Y T

dpQ

Identify the name, title and function of all personnel performing NDA data validation.

Y CCP-PO-002, Revision 13;

CCP-QP-002 ; CCP-TP024, Revision 20; CCP-TP025, Revision 10 

The name, title and function of all personnel performing IPAN/GEA datavalidation are documented. 

Y T

apL

Requalification of personnel must be based on evidence of continued satisfactory performance and must be performed at least every two years. 

Y CCP-PO-002, Revision 13;

CCP-QP-002 ; CCP-TP024, Revision 20; CCP-TP025, Revision 10 

Requalification of personnel is based onevidence of continued satisfactoryperformance is performed at least every two years. 

Y T

IpI

All computer programs, includingspreadsheets used for data reduction oranalysis, must meet the applicable requirements in the CBFO QAPD. 

NA This aspect was not 

evaluated during the inspection.

This aspect was not evaluated during the inspection.

NA T

d

The site must participate in relevantmeasurement comparison programssponsored or approved by CBFO, including the NDA PDP. 

Y CCP-PO-002, Revision 13 The IPAN/GEA has participated 

successfully in the CBFO sponsored NDA PDP. 

Y T

Nsm

“NJK

Revision No.: 1 NDA-IPAN-10 
ATTACHMENT A.5: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IPAN 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

Background and Performance Checks Assay system background measurements must be taken daily, unless otherwise approved by CBFO. Determine the form ofthe documentation of CBFO’s approval, if applicable. Contributions to backgrounds from nearby radiation sources must be carefully controlled, or more frequentbackgrounds must be measured. 

Y CCP-PO-002, Revision 13;

CCP-TP-024, Revision 20; CCP-TP-025, Revision 10

Daily background measurements havebeen taken and recorded over the appropriate periods of performance. Contributions to background fromnearby radiation sources and waste handling activities are controlled. 

Y T

idI0SN

Assess how often background radiation was problematic to the extent that measurement personnel had to make adjustments. 

Y CCP-TP-002, Revision 13;

CCP-TP-024, Revision 20

Control charts that document the system’s performance over time are maintained. 

Y E

at

Identify the criteria used to evaluate instrument backgrounds and assess thetechnical adequacy of this criterion, i.e., statistical or administrative. 

Y CCP-TP-002, Revision 13;

CCP-TP-024, Revision 20

Backgrounds have been evaluated and the results of these evaluations have been documented. 

Y S

ABN0

System performance checks must be performed at least once per operational day.

Y CCP-TP-002, Revision 13;

CCP-TP-024, Revision 20

Performance checks have beenperformed at least once per operationalday and all checks have beendocumented in IPAN/GEA BDRs. 

Y S

N0S

System performance checks must include, asapplicable, efficiency, matrix correction checks, and systems peak position and resolution for spectrometric systems. 

Y CCP-TP-002, Revision 13;

CCP-TP-024, Revision 20

Performance checks include: No-Source Backgrounds, Imaged Active Mass, Corrected Passive Multiplicity Mass, 

137Cs Energy & Resolution (FWHM) 

Y T

acS0S

At a minimum of once per operational weekan interfering matrix must be assayed toassess the long term stability of the NDA instrument and its matrix corrections. How is this performance documented?

Y CCP-TP-002, Revision 13;

CCP-TP-024, Revision 20

An interfering matrix is used to assess the long term stability of the IQ3 and its matrix corrections at least once per operational week. This activity is reviewed and documented at the 

Y T

tit(

Revision No.: 1 NDA-IPAN-11 
ATTACHMENT A.5: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IPAN 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

required intervals M

S5SIR(

Interfering surrogate waste matrices must beconstructed in a way that the salient matrixcharacteristics do not change over time. 

Y CCP-TP-002, Revision 13 Interfering surrogate waste matrices 

have been constructed such that the salient matrix characteristics do not change over time. 

Y S

tdf

The radionuclide sources used for performance checks must be long-lived andof sufficient strength (activity) to provide statistically sufficient results over a short measurement time. 

Y CCP-TP-002, Revision 13;

CCP-TP-024, Revision 20

The radionuclide sources used for performance checks are long-lived and are of sufficient strength (activity) toprovide statistically sufficient results over a short measurement time. 

Y R

pcac

a

Radioactive sources are decay corrected as a function of their physical half life, as appropriate, specifically133Ba, 252Cf, 137Cs, 75Se and 109Cd. 

Y CCP-TP-002, Revision 13;

CCP-TP-024, Revision 20

Documentation exists to indicate that radioactive sources are decay corrected as a function of their physical half life, as appropriate. 

Y T

dwDC

Performance checks must be quantitative andbased on 2 and 3 sigma limits. 

Y CCP-TP-002, Revision 13;

CCP-TP-024, Revision 20

Performance checks are quantitative andbased on 2 and 3 sigma limits. 

Y C

p3 l

Identify how many data points are used for the initial evaluation of Weekly InterferingMatrix Checks and at what interval(s) new limits are calculated. 

NA CCP-TP-002, Revision 13 The acceptance criterion is not 

calculated using a collection of data points, therefore this question is not applicable. 

Y T

atTe

Revision No.: 1 NDA-IPAN-12 
ATTACHMENT A.5: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IPAN 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

Data Management All radioassay data must be reviewed andapproved by qualified personnel before being reported to WWIS. 

Y CCP-PO-002, Revision 13;

CCP-TP-024, Revision 20; CCP-TP-025, Revision 10

IPAN/GEA data have been reviewedand approved by qualified personnel before being reported to WWIS. 

Y T

crI0SNo

Identify the name, title and function of the individual(s) performing technical review and approval of NDA BRDs. 

Y CCP-PO-002, Revision 13;

CCP-TP-024, Revision 20; CCP-TP-025, Revision 10

The name, title and function of the individual(s) performing technicalreview and approval of IPAN/GEA BRDs are documented.

Y S

N0SL

Radioassay BDRs must consist of the following elements: 

• Testing facility name, testing batch

number, container numbers, and signature of the Site Project Officer (SPO) or designee(s) 

• Table of Contents• Background and performance check data

or control charts for the relevant timeperiod. 

• Data validation per the QAPD and site 

procedures 

• Separate testing report sheets for each 

container. 

Y CCP-PO-002, Revision 13;

CCP-TP-024, Revision 20; CCP-TP-025, Revision 10

IPAN/GEA BRDs consist of the following elements, at a minimum: 

• Testing facility name, testing batch

number, container numbers, andsignature of the Site Project Officer (SPO) or designee(s)

• Table of Contents• Background and performance check 

data or control charts for the relevant time period. 

• Data validation per the QAPD and

site procedures

• Separate testing report sheets for 

each container. 

Y S

N0S

Revision No.: 1 NDA-IPAN-13 
ATTACHMENT A.5: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IPAN 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

Radioassay data sheets must include: 

• Title “Radioassay Data Sheet” • Method/procedure used• Date of radioassay• Activities and associated TMU for 

individual radionuclides 

• TRU alpha concentration and its 

associated TMU 

• Operator signature • Reviewer signature 

Y CCP-PO-002, Revision 13;

CCP-TP-024, Revision 20; CCP-TP-025, Revision 10

Radioassay data sheets included, at aminimum:

• Title “Radioassay Data Sheet” • Method/procedure used• Date of radioassay• Activities and associated TMU for 

individual radionuclides 

• TRU alpha concentration and its 

associated TMU 

• Operator signature • Reviewer signature 

Y T

r(wSFSFSS

The following nonpermanent records must be maintained at the radioassay-testing facility or forwarded to the site project office:

• Testing batch reports • All raw data, including instrument

readouts, calculation records, and radioassay QC results 

• All applicable instrument calibration

reports 

Y CCP-PO-002, Revision 13;

CCP-QP-008 

The following nonpermanent records are maintained at the radioassay-testing facility or forwarded to the site project office: 

• Testing batch reports • All raw data, including instrument

readouts, calculation records, and radioassay QC results 

• All applicable instrument calibration

reports 

Y I

oIro

Revision No.: 1 NDA-IPAN-14 
ATTACHMENT A.6: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IQ3 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

System Description Identify the NDA system by name, locationand number, as appropriate. 

Y CCP-PO-002, Revision 13 The NDA system addressed in this

checklist is the MCS IQ3 gamma system housed in a trailer that is locatedat the Savannah River Site, Area E, Pad 4. 

Y Ph

emArtrasam

Describe the system’s operational historyincluding deployment at other DOE sites. 

NA Not Applicable The MCS IQ3 has been deployed only

at SRS with respect to WIPP relatedassays. 

NA Th

at ass

For systems that have been deployed atmultiple DOE sites document pertinent aspects of each system’s development, e.g., installation of new or different detectors,software or other relevant features. 

NA Not Applicable Not applicable; the MCS IQ3 has only 

been deployed at SRS for WIPP assayssince approximately March 2003. 

NA No

beesin

System Performance Identify the period of performance relevant tothis inspection and if this NDA system has prior EPA approval(s). 

Y EPA Inspection Notification

Letter for EPA-SRS-10.05-8 and Inspection Report for EPA-CCP-SRS-09.04.24 

This inspection focuses on IQ3operations over the past year. Prior IQ3 approvals are those determined by EPA. 

Y Th

concurIQwa

Identify the number of waste containers thissystem assayed during the period ofperformance. Of these, indicate how many Batch Data Reports (BDRs) were assembled. Of the assembled BDRs, indicate how manyhave been promoted through Project Level Review and are available for evaluation during this inspection. 

Y Not Applicable The number of waste containers this

system assayed during the period ofperformance is identified. Of these, the number of BDRs that were assembled and how many BDRs have been promoted through Project Level Reviewand are available for evaluation during this inspection are documented.

Y Th

assthe 06BD

Revision No.: 1 NDA-IQ3-1 
ATTACHMENT A.6: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IQ3 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

General Reporting Requirements Assay systems must report quantitative values and uncertainties for 238Pu, 239Pu,240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr, and 137Cs. 

Y CCP-PO-002, Revision 13;

CCP-TP-047, Revision 6;CCP-TP-048, Revision 7 

Quantitative values and uncertainties for 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 

233U, 234U, 238U, 90Sr, and 137Cs are 

reported. 

Y Th

for as 02SR

Each container characterized and intendedfor disposal at WIPP must contain TRU waste. 

Y CCP-PO-002, Revision 13;

CCP-TP-047, Revision 6;CCP-TP-048, Revision 7 

Containers to be disposed of at WIPP meet the definition of TRU waste. 

Y Se

Re05

NDA instruments and procedures areappropriate for the waste streams being assayed. 

Y CCP-PO-002, Revision 13; The IQ3 operation and procedures are

appropriate for the waste streams being assayed. 

Y Th

wadesRe05

NDA instruments and procedures result inunbiased values for the cumulative activity of the WIPP radionuclide inventory.

Y CCP-PO-002, Revision 13; The IQ3operation results in unbiased 

values for the cumulative activity of the WIPP radionuclide inventory.

Y Th

opin & 0; Re

Some radionuclides are derived by the application of scaling factors or correlation techniques. Identify all radionuclides that are quantified in this manner. 

Y CCP-PO-002, Revision 13;

CCP-TP-048, Revision 7 

All radionuclides derived by the application of scaling factors orcorrelation techniques are identified.

Y 234U

the corNDTP04

Assess the technical adequacy of thecalculations involving the application ofscaling factors and/or correlation techniques. 

Y CCP-PO-002, Revision 13;

MCS-SRS-NDA-0203, Revisions 3 &4; CCP-TP048, Revision 7 

The technical adequacy of the calculations involving the application ofscaling factors and/or correlationtechniques is appropriate and documented. 

Y MC

4 pder

Revision No.: 1 NDA-IQ3-2 
ATTACHMENT A.6: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IQ3 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

Identify the procedures that govern this function and where the results of these calculations are documented. 

Y CCP-PO-002, Revision 13;

CCP-TP-048, Revision 7 

The procedures that govern the application of scaling factors are identified and results of these calculations are documented. 

Y Th

for7. sam

Acceptable Knowledge (AK) If isotopic ratios based on AK are used the values are qualified by confirmatory testing.

Y CCP-PO-002, Revision 13;

CCP-TP-048, Revision 7 

Isotopic ratios used in quantifying radionuclides are qualified byconfirmatory testing when AK is used. 

Y Se

chethe 

Do NDA personnel use AK derived isotopicvalues to calculate radionuclide values? If so, is this function performed according to a formal procedure? Assess the technicaladequacy of this process(s). 

N CCP-PO-002, Revision 13;

CCP-TP-048, Revision 7 

NDA personnel using AK derived isotopic values to calculate radionuclide values do not execute this taskaccording to a formal procedure. 

N Ap

strSRSRHoinsAnbasdoregradBDisoNDTra05

Identify the procedure and where the results of these calculations are documented. 

Y CCP-PO-002, Revision 13;

CCP-TP-048, Revision 7 

The procedure for AK relatedcalculations and where the results of these calculations are recorded are documented. 

Y CC

appgenthe 

Isotopic Determination Identify the radionuclides that are measured directly and the specific radiation type (γ, ANor PN) that is measured. 

Y CCP-PO-002, Revision 13;

CCP-TP-048, Revision 7 

The radionuclides that the IQ3 measures directly are listed, all are photon (gamma) emitters. 

Y Al

emmame

239P

Revision No.: 1 NDA-IQ3-3 
ATTACHMENT A.6: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IQ3 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

MCand Re

Identify the method(s) used to derive the isotopic contribution for the unmeasuredradionuclides, e.g., MGA, PC FRAM orother technique. 

Y CCP-PO-002, Revision 13;

CCP-TP-048, Revision 7 

The method(s) used to derive the isotopic contribution for the unmeasured radionuclides for the IQ3 are identified. 

Y MG

medetmeuseapp

Lower Level of Detection (LLD) The LLD for each NDA system must be determined. For multi modal systems this may require a separate determination for eachmode, i.e., active neutron, passive neutron and gamma. 

Y CCP-PO-002, Revision 13;

CCP-TP-048, Revision 7 

The LLD for each NDA system has been determined, including alloperational gamma (transmissioncorrected and sum-of-segments) modes and detector configurations (use of end caps). 

Y Th

detSymuconMCand Re

Site-specific environmental backgrounds and container-specific interferences must be accounted for in LLD determinations. 

Y CCP-PO-002, Revision 13; Site-specific and container specific 

backgrounds and interferences are addressed in LLD the determinations for all the IQ3’s operational modes. 

Y Th

acccon02

NDA instruments performing TRU/NonTRU waste discrimination measurements arerequired to have a LLD no greater than 100nCi/g. 

Y CCP-PO-002, Revision 13 The IQ3 does perform TRU/Non-TRU 

waste discrimination measurements and does have an LLD less than 100 nCi/g. 

Th

supassrepND

The technical basis and derivation for LLDsmust be adequate and appropriately documented. 

Y CCP-PO-002, Revision 13;

CCP-TP-047, Revision 6;CCP-TP-048, Revision 7 

The technical basis and derivation for IQ3 LLDs are adequate and appropriately documented. 

Y Th

tecdoRe

For radionuclides that are not determined primarily by measurement an LLD analog, i.e., a reporting threshold must be used when

Y CCP-PO-002, Revision 13;

CCP-TP-047, Revision 6;CCP-TP-048, Revision 7 

For radionuclides that are notdetermined primarily by measurement an LLD analog, i.e., a reporting 

Y No

rep

and 

Revision No.: 1 NDA-IQ3-4 
ATTACHMENT A.6: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IQ3 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

it is technically feasible. Identify all instances when this occurs and the form ofthe documentation of these activities. 

threshold is used when it is technically feasible. All instances when this occurs for the IQ3 are documented appropriately. 

239P

tha

ThNDpro

Identify any/all instances where an LLD value for a non-measured radionuclide is not 

provided on the basis of a lack of technicalfeasibility. 

Y CCP-PO-002, Revision 13;

CCP-TP-047, Revision 6;CCP-TP-048, Revision 7 

Any/all instances where an LLD valuefor a non-measured radionuclide is not provided based on a lack of technicalfeasibility for the IQ3 are documented.

Y A r

det

basas TedoReTP

Are LLD values container/assay event specific or are typical LLD values applied to a class or type of wastes, i.e., those with similar attributes? If LLD values are notcontainer/assay event specific identify the attributes or characteristics whereby waste containers are grouped. 

Y CCP-PO-002, Revision 13;

CCP-TP-047, Revision 6;CCP-TP-048, Revision 7 

The nature of LLD values has beendetermined and is documented appropriately for the IQ3. 

Y LL

evefor expLL02ND

Total Measurement Uncertainty (TMU) The method used to calculate the TMU for all required quantities must be documented and technically justified.

Y CCP-PO-002, Revision 13 The method used to calculate the TMU

for all required quantities is documented and technically justifiedfor the IQ3. 

Y TM

detMCRe

TMU determination accounts for all sources of uncertainty, specifically 

• Random errors• Calibration• Isotopic determination • Matrix inhomogeneity • Difference between calibration 

assumptions and actual waste 

Y CCP-PO-002, Revision 13 The TMU determination accounts for 

all sources of uncertainty, specifically: 

• Random errors• Calibration• Isotopic determination • Matrix inhomogeneity • Difference between calibration 

assumptions and actual waste 

Y Th

and 20unand meconcoustrdet

Revision No.: 1 NDA-IQ3-5 
ATTACHMENT A.6: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IQ3 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

• Non uniform source distribution • End effects • Self absorption • Transmission source • Attenuator caps 

• Non uniform source distribution • End effects • Self absorption • Transmission source • Attenuator caps 

madiscaperrrep1-s

Methods to determine TMU must bedocumented, reviewed and approved byCBFO for each NDA instrument.

Y CCP-PO-002, Revision 13 Methods to determine TMU for the IQ3 

have been reviewed and approved byCBFO. 

Y Th

fro

System Calibration Each NDA instrument must be calibrated before its initial use. Determine the date of the system’s calibration of record and where this is documented. 

Y CCP-PO-002, Revision 13;

CCP-TP-047, Revision 6 

The IQ3 has been calibrated before itsinitial use and the system’s calibrationof record has been determined and documented. 

Y Th

doRe05ND

The range of applicability of the system ‘s calibration(s) must be specified in site procedures or other formal documentation.Identify the manner in which the range is expressed, i.e., curies or Pu/SNM mass for activity and salient physical characteristics for matrix. 

Y CCP-PO-002, Revision 13;

CCP-TP-047, Revision 6 

The ranges of applicability of the IQ3’s calibrations have been specified and aredocumented appropriately.

Y MC

proin 

35 

thecalter59 05extof 

for 

thr

Revision No.: 1 NDA-IQ3-6 
ATTACHMENT A.6: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IQ3 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

Any matrix/source surrogate waste combinations must be representative of the activity ranges and relevant waste matrixcharacteristics currently in use or planned for use by the system. The system must be calibrated to 100% recovery.

Y CCP-PO-002, Revision 13; Matrix/source surrogate waste 

combinations used are representative of the activity ranges and relevantphysical characteristics of the matrices currently measured or planned for use.The IQ3 is calibrated to 100% recovery. 

Y Ma

comMCand Re

The use of consensus standards for calibration is required, when applicable. If consensus standards do not exist, CBFO must approve the calibration technique. 

Y CCP-PO-002, Revision 13 A consensus standard has been used for 

calibrating the IQ3.

Y Th

an nex

Identify the specific consensus standards thatwere used for the system calibration or, in their absence, the alternate calibration technique. Evaluate the CBFO approval ofthe alternate technique. 

Y CCP-PO-002, Revision 13 The specific consensus standard that

was used for the IQ3’s calibration is identified and documented.

Y Th

StaNoNuScrPaC-in effASoncal

Primary standards must be obtained fromsuppliers maintaining a nationally accredited measurement program. Identify the nationally accredited measurement program.

Y CCP-PO-002, Revision 13 Primary standards have been obtained 

from suppliers maintaining a nationally accredited measurement program. Theprogram has been identified and appropriately documented. 

Y Ca

ENNoCeweacc02and Ap

List the standards used for calibration and verify the pedigree of each standard. 

Y CCP-PO-002, Revision 13 The calibration standards are listed and 

the pedigree of each has been verified. 

Y Mo

gamwh

Revision No.: 1 NDA-IQ3-7 
ATTACHMENT A.6: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IQ3 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

indMCAp241A

souAp

Calibration Verification & ConfirmationVerification of an NDA instrument’s calibration must be performed after any of the following occurrences: major systemrepairs and/or modifications, replacement of the system’s components, significant changes to the system’s software, and relocation ofthe system. 

Y CCP-PO-002, Revision 13;

CCP-TP-048, Revision 7 

Verifications of the IQ3’s calibrationhave been required, performed anddocumented as required. 

Y Th

verdatof to3 fol18detaccwadowhins

Recalibration of the system must occur if the calibration verification demonstrates that the system’s response has significantly changed. 

NA CCP-PO-002, Revision 13;

CCP-TP-048, Revision 7 

Recalibration of the system has not been required in the time periodrelevant to this inspection. 

NA Re

of tha

Revision No.: 1 NDA-IQ3-8 
ATTACHMENT A.6: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IQ3 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

The system calibration must be confirmed byperforming replicate measurements of a noninterfering matrix. 

Y CCP-PO-002, Revision 13 The IQ3’scalibration was confirmed by

performing replicate measurements of a non-interfering matrix, as required. 

Y Th

contypof 

the Thcon

stavalCoExperand 239P

alsfol(no

staMC4 a

Replicate measurements must be performed with containers of the same nominal size andaccording to the same procedures used for actual waste assays. 

Y CCP-PO-002, Revision 13 Replicate measurements have been

performed with containers of the samenominal size and according to the sameprocedures as those used for actual waste assays on the IQ3. 

Y Al

usisouaboSRand 

Replicate measurements must be performed using nationally recognized standards orstandards derived from nationally recognizedstandards that span the range of use of the instrument with respect to disintegration rateand/or matrix effects. Identify all standards that were used and indicate their application (verification or confirmation). 

Y CCP-PO-002, Revision 13 Replicate measurements have been

performed using nationally recognizedstandards or standards derived fromnationally recognized standards thatspan the range of use of the instrumentwith respect to disintegration rate and/or matrix effects. All standards that were used have been identified andtheir application documented.

Y Al

anawiconspato maSRand 

Revision No.: 1 NDA-IQ3-9 
ATTACHMENT A.6: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IQ3 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

Identify the nationally accredited measurement program. List the standards used for verification/confirmation and verifythe pedigree of each standard. 

Y CCP-PO-002, Revision 13 The nationally accredited measurement 

program has been identified and the pedigree of the each of standards usedfor verification/confirmation has beenverified. 

Y Plu

LAproRe05

The standards used for calibration confirmation must be different from the sources that were used for the system’s calibration of record. 

Y CCP-PO-002, Revision 13 The standards used for calibration 

confirmation are not the same sources as those used for the IQ3’s calibration of record. 

Y Th

weiniNDSR

Requirements for accuracy, expressed as %R, and precision, expressed as %RSD, must bemet as specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for precision and "30% for accuracy. 

Y CCP-PO-002, Revision 13;

CCP-TP-048, Revision 7 

Requirements for accuracy and precision have been met as specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for precision and "30% for accuracy. 

Y Ac

meSe3 aRe

Quality Control All radioassay data review and validation must be performed by appropriately trained and qualified personnel. 

Y CCP-PO-002, Revision 13;

CCP-QP-002 

All IQ3 data review and validation have been performed by appropriatelytrained and qualified personnel.

Y A l

proInd

Identify the name, title and function of all personnel performing NDA data validation.

Y CCP-PO-002, Revision 13;

CCP-QP-002 

The name, title and function of all personnel performing IQ3 datavalidation are documented. 

Y A l

proInd

Requalification of personnel must be based on evidence of continued satisfactory performance and must be performed at least every two years. 

Y CCP-PO-002, Revision 13;

CCP-QP-002 

Requalification of personnel is based on evidence of continued satisfactory performance and has been performed atleast every two years. 

Y Th

Ind

tra

All computer programs, includingspreadsheets used for data reduction oranalysis, must meet the applicable requirements in the CBFO QAPD. 

NA CCP-PO-002, Revision 13 This activity was not assessed during

the inspection.

NA Th

the 

Revision No.: 1 NDA-IQ3-10 
ATTACHMENT A.6: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IQ3 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

The site must participate in relevantmeasurement comparison programssponsored or approved by CBFO, including the NDA PDP. 

Y CCP-PO-002, Revision 13 The site has participated successfully in

the CBFO sponsored NDA PDP. 

Y Th

NDcomPu 

Pu CyJulWa

Background and Performance Checks Assay system background measurements must be taken daily, unless otherwise approved by CBFO. Determine the form ofCBFO approval documentation of the alternate approach to backgrounds, if applicable. Contributions to backgrounds from nearby radiation sources must be carefully controlled, or more frequentbackgrounds must be measured. 

Y CCP-PO-002, Revision 13;

CCP-TP-047, Revision 6 

Daily background measurements havebeen taken and recorded over the appropriate periods of performance. Contributions to background fromnearby radiation sources are controlled. 

Y Ba

daisesBain secthe bac

Assess how often background radiation was problematic to the extent that measurement personnel had to make adjustments. 

Y CCP-PO-002, Revision 13;

CCP-TP-047, Revision 6 

Background records that document the IQ3’s performance over time are maintained by CCP measurement personnel.

Y A 

on bacCCNDsig

Identify the criteria used to evaluate instrument backgrounds and assess thetechnical adequacy of this criterion, i.e., statistical or administrative. 

Y CCP-PO-002, Revision 13;

CCP-TP-047, Revision 6;CCP-TP-048, Revision 7 

Backgrounds for the IQ3 have beenevaluated against a technically appropriate acceptance criterion, and the nature and results of these evaluations have been documented. 

Y Da

reli.efla(B

Revision No.: 1 NDA-IQ3-11 
ATTACHMENT A.6: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IQ3 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

Identify the number of data points required toderive the initial control limit. At what interval(s) will new limits be calculated?

Y CCP-PO-002, Revision 13 The number of data points required to

derive the initial control limit and the interval(s) at which will new limits becalculated are documented. 

Y Re

perRoperAudowe

an2/1

Thbaslim

System performance checks must be performed at least once per operational day.

Y CCP-PO-002, Revision 13;

CCP-TP-047, Revision 6 

Performance checks have beenperformed at least once per operationalday and have been documented. 

Y Th

exeche

System performance checks must include, asapplicable, efficiency, matrix correction checks, and systems peak position and resolution for spectrometric systems. 

Y CCP-PO-002, Revision 13;

CCP-TP-047, Revision 6 

Performance checks for the IQ3 include peak centroid at 81 & 353 keV, peakFWHM at 81 &356 keV, and 137Cs 

efficiency 

Y Th

exeche

At a minimum of once per operational weekan interfering matrix must be assayed toassess the long term stability of the NDA instrument and its matrix corrections. How is this performance documented?

Y CCP-PO-002, Revision 13;

CCP-TP-047, Revision 6 

An interfering matrix is used to assess the long term stability of the IQ3 andits matrix corrections at least once per operational week. This activity is reviewed and documented at the required intervals. 

Y Th

execheWefor Riv05 05 

Interfering surrogate waste matrices must beconstructed in a way that the salient matrixcharacteristics do not change over time. 

Y CCP-PO-002, Revision 13 Interfering surrogate waste matrices 

have been constructed such that the salient matrix characteristics do not change over time. 

Y Su

equare app

Revision No.: 1 NDA-IQ3-12 
ATTACHMENT A.6: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IQ3 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

The radionuclide sources used for performance checks must be long-lived andof sufficient strength (activity) to provide statistically sufficient results over a short measurement time. 

Y CCP-PO-002, Revision 13 The radionuclide sources used for 

performance checks are long-lived and are of sufficient strength (activity) toprovide statistically sufficient results over a short measurement time. 

Y Ra

percomsta

sta

Radioactive sources are decay corrected as a function of their physical half life, as appropriate, specifically133Ba, 252Cf, 137Cs, 75Se and 109Cd. 

Y CCP-PO-002, Revision 13 Documentation exists to indicate that

radioactive sources are decay corrected as a function of their physical half life, as appropriate, or that limits are adjusted to compensate for decliningsource strength. 

Y Th

declimcomhal

corSR5/3

Performance checks must be quantitative andbased on 2 and 3 sigma limits. 

Y CCP-PO-002, Revision 13 Performance checks are quantitative 

and based on 2 and 3 sigma limits forall statistical parameters. Nonstatistical parameters are established byderived limits.

Y De

doSR5/3

Identify how many data points are used for the initial evaluation and at what interval(s) new limits are calculated. 

Y CCP-PO-002, Revision 13 The number of data points used for the

initial evaluation and at what interval(s) new limits are calculated aredocumented as required. 

Y At 

estperevemaRe2/1

Data Management All radioassay data must be reviewed andapproved by qualified personnel before being reported to WWIS. 

Y CCP-PO-002, Revision 13;

CCP-TP-048, Revision 7 

All radioassay data have been reviewedand approved by qualified personnel before being reported to WWIS. 

Y Th

revappSRSRSRSR

Revision No.: 1 NDA-IQ3-13 
ATTACHMENT A.6: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IQ3 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

Identify the name, title and function of the individual(s) performing technical review and approval of NDA BRDs. 

Y CCP-PO-002, Revision 13;

CCP-TP-048, Revision 7 

The name, title and function of the individual(s) performing technicalreview and approval of NDA BRDs are documented. 

Y Th

conof funSRSRSRSR

Radioassay BDRs must consist of the following elements: 

• Testing facility name, testing batch

number, container numbers, and signature of the Site Project Officer (SPO) or designee(s) 

• Table of Contents• Background and performance check data

or control charts for the relevant timeperiod. 

• Data validation per the QAPD and site 

procedures 

• Separate testing report sheets for each 

container. 

Y CCP-PO-002, Revision 13;

CCP-TP-048, Revision 7 

Radioassay BRDs consisted of thefollowing elements, at a minimum: 

• Testing facility name, testing batch

number, container numbers, andsignature of the Site Project Officer (SPO) or designee(s)

• Table of Contents• Background and performance check 

data or control charts for the relevant time period. 

• Data validation per the QAPD and

site procedures

• A separate testing report sheet for 

each container. 

Y Th

revall SRSRSR

Radioassay data sheets must include: 

• Title “Radioassay Data Sheet” • Method/procedure used• Date of radioassay• Activities and associated TMU for 

individual radionuclides 

• TRU alpha concentration and its 

associated TMU 

• Operator signature • Reviewer signature 

Y CCP-PO-002, Revision 13 Radioassay data sheets include:

• Title “Radioassay Data Sheet” • Method/procedure used• Date of radioassay• Activities and associated TMU for 

individual radionuclides 

• TRU alpha concentration and its 

associated TMU 

• Operator signature • Reviewer signature 

Y Th

datlistBDSRSRBDMDBDMD

Revision No.: 1 NDA-IQ3-14 
ATTACHMENT A.6: NONDESTRUCTIVE ASSAY (NDA) CHECKLIST—IQ3 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date

Required Technical Elements Y/N Location Verification of Activity Y/N 

The following nonpermanent records must be maintained at the radioassay-testing facility or forwarded to the site project office:

• Testing batch reports • All raw data, including instrument

readouts, calculation records, and radioassay QC results 

• All applicable instrument calibration

reports 

Y CCP-PO-002, Revision 13;

CCP-QP-008 

The following nonpermanent records are maintained at the radioassay-testing facility or forwarded to the site project office: 

• Testing batch reports • All raw data, including instrument

readouts, calculation records, and radioassay QC results 

• All applicable instrument calibration

reports 

Y IQ

eleFooff

Revision No.: 1 NDA-IQ3-15 
ATTACHMENT A.7: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLI

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

WWIS-1: WWIS and Data Entry Personnel must be trained to assess data and properly enter data into the WWIS.

CCP-QP-002,R. 17CCP-TP-030, R.16

WCO and Data Entry Personnel are trained to assess data and properly enter and transfer alldata in the WWIS. Training for Data Entry Personnel and datareviewers/verifiers include the WIPP Waste Information System User’s Manual and the applicable site procedures. Training records are available for review and are complete. 

Y Training for data en

waste certification aWaste Information Sapplicable site procein Carlsbad, NM and SRS to demonstrate All CCP data entry iCarlsbad. The trainpersonnel QualificatWCA were revieweThe training was comthese positions. 

The WCO and/or WCcharacterization data entered into WWIS. Batch Data Report (Bcontainer from the PT

System) and uses thiidentify characterizatObjective evidence r

Qualification Card foQualification Cards fAssistant (WCA) 

WWIS-2: Security measures for ensuring data integrity and accessing WWIS are sufficient. 

CCP-TP-030, R.16, s. 4.1 

Access to WWIS is controlled. WWIS access requests are recorded in an access log, however named, that is available for review. 

Y The WWIS Data Adm

WWIS. CCP requesapproval and passwomail. The WWIS DaNew Mexico, maintaObjective evidence r

E-mail, dated 7/27/05WCA

Revision No.: 1 WWIS-1 
ATTACHMENT A.7: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLI

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

WWIS-3: There are adequateprocedures for entering data into the WWIS and transmitting data to WIPP. 

CCP-TP-030, R.16, s. 4.0 

Employee’s explanation of job duties was consistent with applicable procedures. WWIS and Data Entry Personnel adequately explained howdata are assessed, input, and transferred intoWWIS.

Y Data entry for all CC

NM. For the purpose was present at SRS fData Entry Summary Certification, which to enter characterizatcompletion, the spreareviewed. By signinaccepts the data for sAfter the spreadsheet the WCO, ASCII, tabgenerated and then suThe Excel spreadsheQA. All NCRs must be clMooney verifies NCR WCO of containers tinto WWIS. After acceptance by Wcan be accessed by thReport.  Objective evidence r

WWIS Data Entry SuCertification for contWaste Container DatSR544742 E-mail, dated 9/1/05, regard to NCR/CAR 537 List of containers and 

Revision No.: 1 WWIS-2 
ATTACHMENT A.7: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLI

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

WWIS-4: Procedures require that only verified and validated data are entered into WWIS. 

CCP-TP-030, R.16, Table 1 

Data generation and project level reviews ofcontainer data for WWIS entry have beenperformed and review checklists are complete. 

Y When all reviews hav

Project Manager (SPthat a lot evaluation i(container informatioadministrative controonly containers that hof review are availabAs part of this inspecreviewed RTR and Vcontained complete rObjective evidence r

Inter-office memoranCharacterization InfoSW026-772F-HET W(CIS) 

WWIS-5: Procedures include instructions for submission of data into the Characterization and theCertification module of WWIS. 

CCP-TP-030, R.16, s. 4.3 &4.4 

To enable Waste Stream Profile Form approval Data are entered into the Characterization module of WWIS on a container basis.To obtain shipping certification of a container data are entered into the Certification module of WWIS.

Y Characterization data 

Characterization MoStream Profile Form data fields in the Chasubset of those in the characterization data transferred into the Cchecks of electronicabut 100% of manuallaccuracy. The checkand the WCO/WCA the data. Any changBDR. An Excel spreadshee–Characterization anensure that all data arto uploading to WWImany of the same daWWIS submission th

Revision No.: 1 WWIS-3 
ATTACHMENT A.7: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLI

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

by signing the Excel Objective evidence rWWIS Data Entry SuCertification for contWaste Container DatSR544742 

WWIS-6: Procedures include a requirement for review of data prior to submission to WWIS.

CCP-TP-030, R.16, s. 4.8-4.12 

There is an independent review of data prior tosubmission to WIPP via the WWIS. Procedures for resolution/correction of nonconforming data are adequately implemented. 

Y Characterization data 

Characterization MoStream Profile Form data fields in the Chasubset of those in the characterization data transferred into the Cchecks of electronicabut 100% of manuallaccuracy. The checkand the WCO/WCA the data. Any changBDRs. The WCO acsubmission by signinWWIS contains checor unusable data to brejected by WWIS, ainforming the WCO/rejected. CCP issues corrects it, and resubObjective evidence r

E-mail, dated 12/6/04for container SR5131NCRs NCR-SRS-050772F020030 and SR

Revision No.: 1 WWIS-4 
ATTACHMENT A.7: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLI

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

WWIS-7: There are adequateprocedures for entering data into the WWIS and transmitting the data toWIPP. 

CCP-TP-030, R.16, s. 4.0 

The site has successfully submittedcharacterization and certification data to WIPP via WWIS. 

Y CCP at SRS has succ

characterization and containers to WIPP vable to access to muldemonstrate CCP’s pObjective evidence r

WWIS Data Entry SuCertification for contWaste Container DatSR544742 WWIS Data Entry SuCertification for contFile for container MDanalytical BDRs 

WWIS-8: Procedures provide instructions for data correction if data are rejected by WWIS. 

CCP-TP-030, R.16, s. 4.4.12 CCP-QP-005,R. 10

e-mail notifications from WWIS (acceptance/modification/rejection of data) If data are rejected by the WWIS Data Administrator, processes for datareconciliation/correction are implemented

Y WWIS contains chec

or unusable data to brejected by WWIS, ainforming the WCO/rejected. CCP issues corrects it and resubmObjective evidence r

E-mail, dated 12/6/04for container SR5131NCRs NCR-SRS-050772F020030 and SR

WWIS-9: Procedures for waste container characterization/certification data submittal to WWIS require the appropriate records to be retained. 

CCP-TP030, R. 16, s. 5.1.1

WWIS data approval/rejection reports WWIS Data Spreadsheets Waste container data reports WWIS access requests 

Y The WCO demonstra

was able to retrieve a

Objective evidence r

E-mail, dated 12/6/04for container SR5131

Revision No.: 1 WWIS-5 
ATTACHMENT A.7: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLI

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

WWIS Data Entry SuCertification for contWaste Container DatSR544742 WWIS Data Entry SuCertification for contE-mail, dated 7/27/05WCA 

WWIS-10 CCP-TP-030, 

R.16, s. 4.7-4.13 CCP-TP-086, R. 8CCP-PO-002,R.13, Attachment 8 

Plans and procedures for payload managementhave been approved by CBFO.CBFO informed EPA prior to approving the site to payload manage containers. TRU alpha activity concentration is > 100 nCi/gfor the entire waste stream. Only waste containers from the same waste stream are payload managed in the same payload container. Each waste container selected for payload management contains at least one TRU isotope. TRU alpha activity concentration of the payload container is determined and reported. 

Y The Certification Pla

procedure CCP-TP-0requirements for payfound in Appendix E 030 and CCP-TP-086management practiceapproved proceduresThe procedures and pmanagement, at SRS other approved CCP At the time of the insapproved to payload CBFO will notify EPsoils/gravel waste to The Site Project Manfor load managementdrums are from the sthe demonstration, thdrum from a differendemonstration payloaso by WWIS. The Averify that each drum stream. For the purpose of dethe data from SRS (s

Revision No.: 1 WWIS-6 
ATTACHMENT A.7: WIPP WASTE INFORMATION SYSTEM (WWIS) CHECKLI

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Dat

Establishment of Required

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Y/N Objective 

WWIS test module, trecalculates average added to the payloadother criteria that muTRAMPAC requiremWWIS does not allow waste streams to be pThe weight used to cthe drums in the payland liners. CCP uses SWBs as payload conCertification Official transportation modulassembled are WIPP the WCO. Containerfor shipment until theWWIS. WWIS checmanagement, containqualify as TRU wastThe waste container SRTP01413 lists all payload (ten drum ovObjective evidence rWaste Container Repten-drum overpack. 

Revision No.: 1 WWIS-7 
ATTACHMENT A.8: WIPP WASTE INFORMATION SYSTEM (WWIS) 

DATA REQUIREMENTS 

EPA Inspection No.: EPA-SRS-10.05-8 Inspection Date: 10/31/2005–11/03/2005

 

WWIS Data Requirements 

Characterization Module Data Fields 

(not a complete list) 

Container ID - present 239Pu equivalent activity - present 

Generator EPA ID – present 239Pu fissile gram equivalent - present

Site ID - present 239Pu FGE uncertainty - present 

Waste Stream Profile Number - present Radionuclide name - present 

Waste Matrix Code - present Radionuclide activity - present 

Waste Matrix Code Group - present Radionuclide activity uncertainty - present 

Waste Material Weight - present Radionuclide mass - present

Waste Material Parameter - present Radionuclide mass uncertainty - present 

Hazardous Code - present Radioassay method - present 

Layers of packaging - present Assay date - present

Liner exists - present Characterization method - present

Filter model - present Characterization method date – present 

Number of filters installed - present Alpha surface concentration - present 

TRUCON code - present Dose rate - present 

Decay heat – present Sample ID - present 

Decay heat uncertainty - present Sample type - present 

TRU alpha activity - present Sample date - present 

TRU alpha activity uncertainty - present Analyte - present 

TRU alpha activity concentration - present Analyte concentration - present 

TRU alpha activity concentration uncertainty - 

present Analyte detection method - present

Waste type code - present Analyte detection method - present

Certification Module Data Fields 

Container ID - present Container Certification date - present

Container Type - present Container Closure date - present

Container weight - present Handling Code - present

Contact DoseRate - present

Revision No.: 1 WWIS-8 Date of Revision: 11/01/05 
Attachments B.1 through B.18
B-1 

ATTACHMENT B.1 REPLICATE TESTING IPAN DATA FOR CONTAINER SR144

Instrument: IPAN/GEA - SRSContainer: SR144771

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative ReporInterest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Valu233U Activity (Ci) 6.61E-05 #VALUE! NA 6.67E-05 #VALUE! NA 7.07E234U Activity (Ci) 3.51E-05 #VALUE! NA 3.95E-05 #VALUE! NA 6.94E238U Activity (Ci) 1.10E-05 #VALUE! NA 7.31E-06 #VALUE! NA 4.85E238Pu Activity (Ci) 1.55E-04 1.10E-04 7.09E-01 1.37E-04 1.17E-04 8.54E-01 1.53E239Pu Activity (Ci) 1.39E-03 9.80E-04 7.07E-01 1.23E-03 1.05E-03 8.53E-01 1.37E240Pu Activity (Ci) 3.16E-04 2.32E-04 7.35E-01 2.81E-04 2.46E-04 8.76E-01 3.13E242Pu Activity (Ci) 3.55E-08 2.51E-08 7.09E-01 3.15E-08 2.69E-08 8.54E-01 3.52E241Am Activity (Ci) 9.43E-05 #VALUE! NA 1.34E-04 2.28E-04 1.71E+00 8.90E90Sr Activity (Ci) 0.00E+00 N/A NA 0.00E+00 N/A NA 0.00E+137Cs Activity (Ci) 0.00E+00 N/A NA 0.00E+00 N/A NA 0.00E+TRU Alpha Conc. (nCi/g) 1.12E+02 8.75E+01 7.80E-01 1.03E+02 9.44E+01 9.21E-01 1.11E

Replicate #3 Replicate #4 Replicate #5 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Absolute Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value Uncertainty 233U Activity (Ci) 8.77E-07 #VALUE! NA 8.43E-05 #VALUE! NA 5.72E-05 #VALUE! 234U Activity (Ci) 3.90E-04 #VALUE! NA 5.57E-05 #VALUE! NA 6.16E-05 #VALUE! 238U Activity (Ci) 4.13E-08 #VALUE! NA 9.54E-06 #VALUE! NA 5.84E-06 #VALUE! 238Pu Activity (Ci) 1.60E-04 1.24E-04 7.73E-01 1.66E-04 1.27E-04 7.67E-01 1.68E-04 1.23E-04 239Pu Activity (Ci) 1.44E-03 1.11E-03 7.71E-01 1.49E-03 1.14E-03 7.65E-01 1.50E-03 1.10E-03 240Pu Activity (Ci) 3.28E-04 2.61E-04 7.97E-01 3.39E-04 2.68E-04 7.91E-01 3.43E-04 2.61E-04 242Pu Activity (Ci) 3.68E-08 2.85E-08 7.73E-01 3.80E-08 2.92E-08 7.67E-01 3.85E-08 2.83E-08 241Am Activity (Ci) 9.32E-05 8.09E-05 8.69E-01 2.02E-04 3.85E-04 1.91E+00 4.06E-04 5.34E-04 90Sr Activity (Ci) 0.00E+00 N/A NA 0.00E+00 N/A NA 0.00E+00 N/A 137Cs Activity (Ci) 0.00E+00 N/A NA 0.00E+00 N/A NA 0.00E+00 N/A TRU Alpha Conc. (nCi/g) 1.16E+02 9.06E+01 7.80E-01 1.26E+02 1.10E+02 8.74E-01 1.39E+02 1.16E+02 
B-2 

ATTACHMENT B.2 REPLICATE TESTING IPAN RESULTS FOR CONTAINER SR14

Instrument: IPAN/GEA - SRSContainer: SR144771

Original Measurement 

Quantity of Reported Absolute Interest Value Uncertainty

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <|χ2|) 

233U Activity (Ci) 6.61E-05 #VALUE! 4.32E-05 3.72E-05 8.61E-01 #VALUE! #VALUE234U Activity (Ci) 3.51E-05 #VALUE! 1.23E-04 1.50E-04 1.21E+00 #VALUE! #VALUE238U Activity (Ci) 1.10E-05 #VALUE! 4.65E-06 4.21E-06 9.07E-01 #VALUE! #VALUE238Pu Activity (Ci) 1.55E-04 1.10E-04 1.57E-04 1.23E-05 7.81E-02 5.01E-02 1.00E+0239Pu Activity (Ci) 1.39E-03 9.80E-04 1.41E-03 1.10E-04 7.81E-02 5.03E-02 1.00E+0240Pu Activity (Ci) 3.16E-04 2.32E-04 3.21E-04 2.51E-05 7.81E-02 4.66E-02 1.00E+0242Pu Activity (Ci) 3.55E-08 2.51E-08 3.60E-08 2.81E-09 7.81E-02 5.01E-02 1.00E+0241Am Activity (Ci) 9.43E-05 #VALUE! 1.85E-04 1.32E-04 7.13E-01 #VALUE! #VALUE90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUETRU Alpha Conc. (nCi/g) 1.12E+02 8.75E+01 1.19E+02 1.41E+01 1.19E-01 1.04E-01 9.99E-0Quantity of Interest χ2 Test t Test 233U Activity (Ci) #VALUE! Not Significant 234U Activity (Ci) #VALUE! Not Significant 238U Activity (Ci) #VALUE! Not Significant 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Not Significant Not Significant 241Am Activity (Ci) #VALUE! Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) #VALUE! Not Significant 
B-3 

ATTACHMENT B.3 REPLICATE TESTING IPAN DATA FOR CONTAINER FBL04

Instrument: IPAN/GEA - SRS Container: FBL04011 

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative ReporteInterest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) 1.79E-04 #VALUE! NA 1.64E-04 #VALUE! NA 1.73E234U Activity (Ci) 2.13E-05 1.02E-05 4.77E-01 1.82E-05 8.83E-06 4.85E-01 1.19E238U Activity (Ci) 4.87E-06 #VALUE! NA 4.34E-06 #VALUE! NA 4.32E238Pu Activity (Ci) 1.51E-02 1.43E-02 9.52E-01 8.96E-03 1.59E-02 1.77E+00 9.83E239Pu Activity (Ci) 1.74E-01 7.76E-02 4.47E-01 1.68E-01 7.52E-02 4.47E-01 1.69E240Pu Activity (Ci) 3.86E-02 3.46E-02 8.97E-01 6.15E-02 3.13E-02 5.09E-01 5.14E242Pu Activity (Ci) 1.14E-05 5.12E-06 4.50E-01 1.03E-05 4.62E-06 4.50E-01 1.08E241Am Activity (Ci) 4.86E-02 2.95E-02 6.06E-01 4.36E-02 2.63E-02 6.03E-01 4.63E90Sr Activity (Ci) 0.00E+00 N/A NA 0.00E+00 N/A NA 0.00E+137Cs Activity (Ci) 0.00E+00 N/A NA 0.00E+00 N/A NA 0.00E+TRU Alpha Conc. (nCi/g) 5.55E+03 3.14E+03 5.65E-01 5.68E+03 2.99E+03 5.27E-01 5.56E+

Replicate #3 Replicate #4 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 1.78E-04 #VALUE! NA 1.71E-04 #VALUE! NA 1.64E-0234U Activity (Ci) 1.55E-05 8.10E-06 5.22E-01 1.63E-05 8.33E-06 5.12E-01 1.69E-0238U Activity (Ci) 4.38E-06 #VALUE! NA 4.41E-06 #VALUE! NA 4.27E-0238Pu Activity (Ci) 1.25E-02 5.64E-03 4.50E-01 1.18E-02 5.31E-03 4.50E-01 1.18E-0239Pu Activity (Ci) 1.72E-01 7.71E-02 4.47E-01 1.74E-01 7.77E-02 4.47E-01 1.72E-0240Pu Activity (Ci) 5.17E-02 2.67E-02 5.16E-01 5.42E-02 2.77E-02 5.11E-01 6.50E-0242Pu Activity (Ci) 1.14E-05 5.14E-06 4.50E-01 1.09E-05 4.90E-06 4.50E-01 1.22E-0241Am Activity (Ci) 4.89E-02 2.95E-02 6.03E-01 4.68E-02 2.82E-02 6.03E-01 5.18E-090Sr Activity (Ci) 0.00E+00 N/A NA 0.00E+00 N/A NA 0.00E+0137Cs Activity (Ci) 0.00E+00 N/A NA 0.00E+00 N/A NA 0.00E+0TRU Alpha Conc. (nCi/g) 5.75E+03 2.79E+03 4.86E-01 5.77E+03 2.80E+03 4.85E-01 6.05E+0
B-4 

ATTACHMENT B.4 REPLICATE TESTING IPAN RESULTS FOR CONTAINER FBL0

Instrument: IPAN/GEA - SRS Container: FBL04011 

Original Measurement

Quantity of Reported Absolute Interest Value Uncertainty

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <|χ2|) 

233U Activity (Ci) 1.79E-04 #VALUE! 1.70E-04 5.88E-06 3.46E-02 #VALUE! #VALUE! 234U Activity (Ci) 2.13E-05 1.02E-05 1.58E-05 2.38E-06 1.51E-01 2.19E-01 9.94E-01 238U Activity (Ci) 4.87E-06 #VALUE! 4.34E-06 5.58E-08 1.28E-02 #VALUE! #VALUE! 238Pu Activity (Ci) 1.51E-02 1.43E-02 1.10E-02 1.51E-03 1.38E-01 4.45E-02 1.00E+00 239Pu Activity (Ci) 1.74E-01 7.76E-02 1.71E-01 2.43E-03 1.42E-02 3.93E-03 1.00E+00 240Pu Activity (Ci) 3.86E-02 3.46E-02 5.68E-02 6.15E-03 1.08E-01 1.27E-01 9.98E-01 242Pu Activity (Ci) 1.14E-05 5.12E-06 1.11E-05 7.37E-07 6.62E-02 8.28E-02 9.99E-01 241Am Activity (Ci) 4.86E-02 2.95E-02 4.75E-02 3.08E-03 6.48E-02 4.36E-02 1.00E+00 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! TRU Alpha Conc. (nCi/g) 5.55E+03 3.14E+03 5.76E+03 1.80E+02 3.13E-02 1.32E-02 1.00E+00 

Quantity of Interest χ2 Test t Test 233U Activity (Ci) #VALUE! Not Significant 234U Activity (Ci) Not Significant Not Significant 238U Activity (Ci) #VALUE! Highly Significant 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Not Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
B-5 

ATTACHMENT B.5 REPLICATE TESTING IPAN DATA FOR CONTAINER SR138

Instrument: IPAN/GEA - SRS Container: SR138868 

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 3.16E-04 #VALUE! NA 1.21E-04 #VALUE! NA 1.53E-234U Activity (Ci) 2.94E-04 #VALUE! NA 1.67E-04 #VALUE! NA 1.89E-238U Activity (Ci) 5.18E-05 #VALUE! NA 1.05E-05 #VALUE! NA 1.24E-238Pu Activity (Ci) 1.20E-03 6.59E-04 5.49E-01 1.30E-03 7.66E-04 5.90E-01 1.23E-239Pu Activity (Ci) 2.87E-02 1.60E-02 5.57E-01 2.68E-02 1.59E-02 5.92E-01 3.07E-240Pu Activity (Ci) 6.93E-03 4.04E-03 5.83E-01 6.85E-03 5.18E-03 7.56E-01 6.77E-242Pu Activity (Ci) 1.11E-06 6.12E-07 5.49E-01 1.23E-06 7.25E-07 5.90E-01 1.13E-241Am Activity (Ci) 2.80E-03 2.57E-03 9.18E-01 6.14E-03 4.49E-03 7.32E-01 1.59E-90Sr Activity (Ci) NA #VALUE! NA 0.00E+00 N/A NA 0.00E+137Cs Activity (Ci) 2.12E-07 #VALUE! NA 0.00E+00 N/A NA 0.00E+TRU Alpha Conc. (nCi/g) 2.25E+03 1.32E+03 5.87E-01 2.33E+03 1.49E+03 6.40E-01 2.29E+

Replicate #3 Replicate #4 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 1.40E-04 #VALUE! NA 1.33E-04 #VALUE! NA 1.37E-0234U Activity (Ci) 1.81E-04 #VALUE! NA 2.06E-04 #VALUE! NA 1.87E-0238U Activity (Ci) 1.11E-05 #VALUE! NA 1.09E-05 #VALUE! NA 1.08E-0238Pu Activity (Ci) 1.11E-03 6.60E-04 5.93E-01 1.41E-03 8.10E-04 5.74E-01 1.19E-0239Pu Activity (Ci) 2.75E-02 1.64E-02 5.96E-01 2.91E-02 1.67E-02 5.75E-01 2.80E-0240Pu Activity (Ci) 6.27E-03 3.87E-03 6.18E-01 6.47E-03 5.22E-03 8.07E-01 6.96E-0242Pu Activity (Ci) 1.02E-06 6.05E-07 5.93E-01 1.34E-06 7.67E-07 5.74E-01 1.11E-0241Am Activity (Ci) 1.72E-03 2.03E-03 1.18E+00 6.96E-03 5.03E-03 7.24E-01 3.74E-090Sr Activity (Ci) 0.00E+00 N/A NA 0.00E+00 N/A NA 0.00E+0137Cs Activity (Ci) 0.00E+00 N/A NA 0.00E+00 N/A NA 0.00E+0TRU Alpha Conc. (nCi/g) 2.07E+03 1.30E+03 6.29E-01 2.50E+03 1.58E+03 6.33E-01 2.27E+0
B-6 

ATTACHMENT B.6 REPLICATE TESTING IPAN RESULTS FOR CONTAINER SR13

Instrument: IPAN/GEA - SRS Container: SR138868 

Original Measurement

Quantity of Reported Absolute Interest Pr(x <|χ2 Value |) Uncertainty Sample Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 

233U Activity (Ci) 3.16E-04 #VALUE! 1.37E-04 1.16E-05 8.52E-02 #VALUE! #VALUE! 234U Activity (Ci) 2.94E-04 #VALUE! 1.86E-04 1.43E-05 7.67E-02 #VALUE! #VALUE! 238U Activity (Ci) 5.18E-05 #VALUE! 1.11E-05 7.24E-07 6.50E-02 #VALUE! #VALUE! 238Pu Activity (Ci) 1.20E-03 6.59E-04 1.25E-03 1.13E-04 9.00E-02 1.17E-01 9.98E-01 239Pu Activity (Ci) 2.87E-02 1.60E-02 2.84E-02 1.53E-03 5.39E-02 3.67E-02 1.00E+00 240Pu Activity (Ci) 6.93E-03 4.04E-03 6.66E-03 2.86E-04 4.30E-02 2.01E-02 1.00E+00 242Pu Activity (Ci) 1.11E-06 6.12E-07 1.17E-06 1.21E-07 1.04E-01 1.56E-01 9.97E-01 241Am Activity (Ci) 2.80E-03 2.57E-03 4.03E-03 2.47E-03 6.13E-01 3.68E+00 4.50E-01 90Sr Activity (Ci) NA #VALUE! 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 137Cs Activity (Ci) 2.12E-07 #VALUE! 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! TRU Alpha Conc. (nCi/g) 2.25E+03 1.32E+03 2.29E+03 1.51E+02 6.60E-02 5.24E-02 1.00E+00 

Quantity of Interest χ t Test 2 Test 233U Activity (Ci) #VALUE! Highly Significant 234U Activity (Ci) #VALUE! Highly Significant 238U Activity (Ci) #VALUE! Highly Significant 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Not Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
B-7 

ATTACHMENT B.7 REPLICATE TESTING IQ3 DATA FOR CONTAINER MDL0506

Instrument: SRS IQ3 Container: MDL0506073 

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238Pu Activity (Ci) 7.92E-02 4.61E-02 5.82E-01 8.62E-02 4.87E-02 5.65E-01 7.24E-239Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+240Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+242Pu Activity (Ci) 4.55E-08 2.64E-08 5.80E-01 4.94E-08 2.79E-08 5.65E-01 4.16E-241Am Activity (Ci) 6.23E-05 3.30E-05 5.30E-01 5.98E-05 3.17E-05 5.30E-01 6.30E-90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+TRU Alpha Conc. (nCi/g) 3.11E+02 1.81E+02 5.82E-01 3.38E+02 1.91E+02 5.65E-01 2.84E+

Replicate #3 Replicate #4 Replicate 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238Pu Activity (Ci) 3.67E-02 1.97E-02 5.37E-01 7.70E-02 4.31E-02 5.60E-01 3.80E-239Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+240Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+242Pu Activity (Ci) 2.10E-08 1.13E-08 5.38E-01 4.42E-08 2.47E-08 5.59E-01 2.18E-241Am Activity (Ci) 5.88E-05 3.12E-05 5.31E-01 6.12E-05 3.24E-05 5.29E-01 6.00E-90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+TRU Alpha Conc. (nCi/g) 1.44E+02 7.71E+01 5.35E-01 3.02E+02 1.69E+02 5.60E-01 1.49E+
B-8 

ATTACHMENT B.8 REPLICATE TESTING IQ3 RESULTS FOR CONTAINER MDL05

Instrument: SRS IQ3 Container: MDL0506073 

Original Measurement

Quantity of Reported Absolute Interest

Relative 

Value Uncertainty 

Sample 

Mean 

Sample 

Standard 

Deviation 

Standard 

Deviation χ2 Pr(x <|χ2|) 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238Pu Activity (Ci) 7.92E-02 4.61E-02 6.21E-02 2.31E-02 3.72E-01 1.00E+00 9.09E-01 239Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 240Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 242Pu Activity (Ci) 4.55E-08 2.64E-08 3.56E-08 1.33E-08 3.73E-01 1.01E+00 9.08E-01 241Am Activity (Ci) 6.23E-05 3.30E-05 6.06E-05 1.61E-06 2.66E-02 9.51E-03 1.00E+00 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! TRU Alpha Conc. (nCi/g) 3.11E+02 1.81E+02 2.43E+02 9.06E+01 3.72E-01 1.00E+00 9.10E-01 

Quantity of Interest χ2 Test t Test 233U Activity (Ci) #VALUE! Not Applicable234U Activity (Ci) #VALUE! Not Applicable238U Activity (Ci) #VALUE! Not Applicable238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) #VALUE! Not Applicable240Pu Activity (Ci) #VALUE! Not Applicable242Pu Activity (Ci) Not Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable137Cs Activity (Ci) #VALUE! Not ApplicableTRU Alpha Conc. (nCi/g) Not Significant Not Significant 
B-9 

ATTACHMENT B.9 REPLICATE TESTING IQ3 DATA FOR CONTAINER MDL0506

Instrument: SRS IQ3Container: MDL0506146

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Reported Absolute Relative Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+238Pu Activity (Ci) 3.16E-02 1.70E-02 5.38E-01 3.16E-02 1.70E-02 5.38E-01 3.12E-239Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+240Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+242Pu Activity (Ci) 1.82E-08 9.77E-09 5.37E-01 1.82E-08 9.98E-09 5.48E-01 1.79E-241Am Activity (Ci) 5.33E-05 2.87E-05 5.38E-01 5.54E-05 2.98E-05 5.38E-01 5.41E-90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+TRU Alpha Conc. (nCi/g) 1.05E+02 5.62E+01 5.35E-01 1.04E+02 5.62E+01 5.40E-01 1.03E+

Replicate #3 Replicate #4 Replicate #

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238Pu Activity (Ci) 3.30E-02 1.78E-02 5.39E-01 3.39E-02 1.83E-02 5.40E-01 3.28E-0239Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0240Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0242Pu Activity (Ci) 1.90E-08 1.02E-08 5.37E-01 1.95E-08 1.05E-08 5.38E-01 1.88E-0241Am Activity (Ci) 5.53E-05 2.97E-05 5.37E-01 5.36E-05 2.88E-05 5.37E-01 5.48E-090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0TRU Alpha Conc. (nCi/g) 1.09E+02 5.87E+01 5.39E-01 1.12E+02 6.03E+01 5.38E-01 1.08E+0
B-10 

ATTACHMENT B.10 REPLICATE TESTING IQ3 RESULTS FOR CONTAINER MDL0

Instrument: SRS IQ3Container: MDL0506146

Original Measurement

Quantity of Reported Absolute Interest Value Uncertainty

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <|χ2|) 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238Pu Activity (Ci) 3.16E-02 1.70E-02 3.25E-02 1.10E-03 3.37E-02 1.66E-02 1.00E+00 239Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 240Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 242Pu Activity (Ci) 1.82E-08 9.77E-09 1.87E-08 6.38E-10 3.42E-02 1.71E-02 1.00E+00 241Am Activity (Ci) 5.33E-05 2.87E-05 5.46E-05 7.77E-07 1.42E-02 2.93E-03 1.00E+00 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! TRU Alpha Conc. (nCi/g) 1.05E+02 5.62E+01 1.07E+02 3.70E+00 3.45E-02 1.74E-02 1.00E+00 

Quantity of Interest χ2 Test t Test 233U Activity (Ci) #VALUE! Not Applicable 234U Activity (Ci) #VALUE! Not Applicable 238U Activity (Ci) #VALUE! Not Applicable 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) #VALUE! Not Applicable 240Pu Activity (Ci) #VALUE! Not Applicable 242Pu Activity (Ci) Not Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
B-11 

ATTACHMENT B.11 REPLICATE TESTING IQ3 DATA FOR CONTAINER SR1234

Instrument: SRS IQ3Container: SR123477

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238Pu Activity (Ci) 5.44E-02 5.62E-02 1.03E+00 7.06E-02 1.65E-02 2.34E-01 8.26E-0239Pu Activity (Ci) 1.97E+00 3.65E-01 1.85E-01 1.89E+00 3.49E-01 1.85E-01 1.89E+0240Pu Activity (Ci) 8.17E-01 2.23E-01 2.73E-01 4.88E-01 9.21E-02 1.89E-01 4.46E-0242Pu Activity (Ci) 3.23E-05 3.38E-05 1.05E+00 8.27E-06 2.01E-06 2.43E-01 7.67E-0241Am Activity (Ci) 3.90E-01 7.42E-02 1.90E-01 3.78E-01 7.23E-02 1.91E-01 3.36E-090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0TRU Alpha Conc. (nCi/g) 1.04E+05 1.40E+04 1.35E-01 9.05E+04 1.18E+04 1.30E-01 8.83E+0

Replicate #3 Replicate #4 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 6.60E-02 1.57E-02 2.38E-01 7.07E-02 1.65E-02 2.33E-01 6.75E-02 239Pu Activity (Ci) 1.80E+00 3.34E-01 1.86E-01 1.88E+00 3.48E-01 1.85E-01 1.87E+00 240Pu Activity (Ci) 4.49E-01 8.48E-02 1.89E-01 5.16E-01 9.74E-02 1.89E-01 4.46E-0242Pu Activity (Ci) 7.49E-06 1.89E-06 2.52E-01 8.35E-06 2.06E-06 2.47E-01 7.40E-06 241Am Activity (Ci) 3.62E-01 2.48E+00 6.85E+00 3.65E-01 9.28E-02 2.54E-01 3.73E-090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 8.59E+04 8.02E+04 9.34E-01 9.07E+04 1.20E+04 1.32E-01 8.83E+04 
B-12 

ATTACHMENT B.12 REPLICATE TESTING IQ3 RESULTS FOR CONTAINER SR12

Instrument: SRS IQ3Container: SR123477

Original Measurement

Quantity of Reported Absolute Interest Value Uncertainty 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <|χ2|) 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238Pu Activity (Ci) 5.44E-02 5.62E-02 7.15E-02 6.54E-03 9.14E-02 5.41E-02 1.00E+00 239Pu Activity (Ci) 1.97E+00 3.65E-01 1.87E+00 3.78E-02 2.03E-02 4.29E-02 1.00E+00 240Pu Activity (Ci) 8.17E-01 2.23E-01 4.69E-01 3.17E-02 6.77E-02 8.10E-02 9.99E-01 242Pu Activity (Ci) 3.23E-05 3.38E-05 7.84E-06 4.44E-07 5.67E-02 6.91E-04 1.00E+00 241Am Activity (Ci) 3.90E-01 7.42E-02 3.63E-01 1.63E-02 4.48E-02 1.92E-01 9.96E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! TRU Alpha Conc. (nCi/g) 1.04E+05 1.40E+04 8.87E+04 1.96E+03 2.21E-02 7.85E-02 9.99E-01 

Quantity of Interest χ2 Test t Test 233U Activity (Ci) #VALUE! Not Applicable 234U Activity (Ci) #VALUE! Not Applicable 238U Activity (Ci) #VALUE! Not Applicable 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Highly Significant 242Pu Activity (Ci) Not Significant Highly Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Highly Significant 
B-13 

ATTACHMENT B.13 REPLICATE TESTING IQ3 DATA FOR CONTAINER SR5462

Instrument: SRS IQ3Container: SR546270

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238Pu Activity (Ci) 3.85E-01 8.36E-02 2.17E-01 3.59E-01 6.76E-02 1.88E-01 4.16E-0239Pu Activity (Ci) 3.63E+00 7.68E-01 2.12E-01 3.68E+00 6.68E-01 1.82E-01 3.60E+0240Pu Activity (Ci) 9.43E-01 2.01E-01 2.13E-01 9.12E-01 1.68E-01 1.84E-01 9.07E-0242Pu Activity (Ci) 2.61E-05 5.94E-06 2.28E-01 2.42E-05 4.80E-06 1.98E-01 2.31E-0241Am Activity (Ci) 5.75E-01 1.09E-01 1.90E-01 6.34E-01 1.18E-01 1.86E-01 6.25E-090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0TRU Alpha Conc. (nCi/g) 2.74E+05 3.99E+04 1.46E-01 3.07E+05 3.86E+04 1.26E-01 3.05E+0

Replicate #3 Replicate #4 Replicate #

Quantity of Reported Absolute Relative Reported Relative Absolute Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 3.54E-01 9.71E-03 2.74E-02 3.63E-01 6.77E-02 1.87E-01 3.53E-0239Pu Activity (Ci) 3.74E+00 6.78E-01 1.81E-01 3.62E+00 6.58E-01 1.82E-01 3.66E+00 240Pu Activity (Ci) 9.70E-01 1.78E-01 1.84E-01 8.88E-01 1.63E-01 1.84E-01 9.01E-0242Pu Activity (Ci) 2.49E-05 7.03E-06 2.82E-01 2.30E-05 4.48E-06 1.95E-01 2.42E-05 241Am Activity (Ci) 5.59E-01 1.02E-01 1.82E-01 5.45E-01 9.91E-02 1.82E-01 5.44E-090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 3.09E+05 3.93E+04 1.27E-01 2.98E+05 3.78E+04 1.27E-01 3.00E+05 
B-14 

ATTACHMENT B.14 REPLICATE TESTING IQ3 RESULTS FOR CONTAINER SR54

Instrument: SRS IQ3Container: SR546270

Original Measurement

Quantity of Reported Absolute Interest Value Uncertainty

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <|χ2|) 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238Pu Activity (Ci) 3.85E-01 8.36E-02 3.69E-01 2.66E-02 7.20E-02 4.04E-01 9.82E-01 239Pu Activity (Ci) 3.63E+00 7.68E-01 3.66E+00 5.48E-02 1.50E-02 2.03E-02 1.00E+00 240Pu Activity (Ci) 9.43E-01 2.01E-01 9.16E-01 3.17E-02 3.46E-02 9.95E-02 9.99E-01 242Pu Activity (Ci) 2.61E-05 5.94E-06 2.39E-05 8.11E-07 3.39E-02 7.45E-02 9.99E-01 241Am Activity (Ci) 5.75E-01 1.09E-01 5.81E-01 4.44E-02 7.64E-02 6.64E-01 9.56E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! TRU Alpha Conc. (nCi/g) 2.74E+05 3.99E+04 3.04E+05 4.66E+03 1.53E-02 5.45E-02 1.00E+00 

Quantity of Interest χ2 Test t Test 233U Activity (Ci) #VALUE! Not Applicable 234U Activity (Ci) #VALUE! Not Applicable 238U Activity (Ci) #VALUE! Not Applicable 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Not Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Highly Significant 
B-15 

ATTACHMENT B.15 REPLICATE TESTING IQ3 DATA FOR CONTAINER SR6118

Instrument: SRS IQ3Container: SR611807

Original Measurement Replicate #1 

Quantity of Reported Absolute Relative Reported Absolute Relative Reported 

Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value U233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 1.86E+01 3.11E+00 1.67E-01 1.83E+01 3.05E+00 1.67E-01 1.86E+01 239Pu Activity (Ci) 1.45E-02 2.43E-03 1.68E-01 1.61E-02 2.61E-03 1.62E-01 1.56E-02 240Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 242Pu Activity (Ci) 5.69E-06 9.52E-07 1.67E-01 5.59E-06 9.34E-07 1.67E-01 5.68E-06 241Am Activity (Ci) 5.34E-02 8.93E-03 1.67E-01 5.51E-02 9.25E-03 1.68E-01 5.31E-02 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 1.47E+06 2.45E+05 1.67E-01 1.44E+06 2.41E+05 1.67E-01 1.47E+06 

Replicate #3 Replicate #4 Replicate #5

Quantity of Reported Absolute Relative Reported Absolute Relative Reported Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 1.87E+01 3.11E+00 1.66E-01 1.86E+01 3.10E+00 1.67E-01 1.87E+01 239Pu Activity (Ci) 1.59E-02 2.58E-03 1.62E-01 1.48E-02 2.45E-03 1.66E-01 1.60E-02 240Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 242Pu Activity (Ci) 5.71E-06 9.52E-07 1.67E-01 5.69E-06 9.49E-07 1.67E-01 5.73E-06 241Am Activity (Ci) 5.30E-02 9.41E-03 1.78E-01 4.41E-02 7.48E-03 1.70E-01 3.46E-02 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 1.48E+06 2.45E+05 1.66E-01 1.47E+06 2.44E+05 1.66E-01 1.48E+06 
B-16 

ATTACHMENT B.16 REPLICATE TESTING IQ3 RESULTS FOR CONTAINER SR61

Instrument: SRS IQ3Container: SR611807

Original Measurement

Quantity of Interest Reported Value Absolute Uncertainty Sample Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <|χ2|) 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 238Pu Activity (Ci) 1.86E+01 3.11E+00 1.86E+01 1.64E-01 8.84E-03 1.12E-02 1.00E+00 239Pu Activity (Ci) 1.45E-02 2.43E-03 1.57E-02 5.26E-04 3.36E-02 1.88E-01 9.96E-01 240Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 242Pu Activity (Ci) 5.69E-06 9.52E-07 5.68E-06 5.39E-08 9.48E-03 1.28E-02 1.00E+00 241Am Activity (Ci) 5.34E-02 8.93E-03 4.80E-02 8.61E-03 1.79E-01 3.71E+00 4.46E-01 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE! TRU Alpha Conc. (nCi/g) 1.47E+06 2.45E+05 1.47E+06 1.64E+04 1.12E-02 1.80E-02 1.00E+00 

Quantity of Interest χ2 Test t Test 233U Activity (Ci) #VALUE! Not Applicable 234U Activity (Ci) #VALUE! Not Applicable 238U Activity (Ci) #VALUE! Not Applicable 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) #VALUE! Not Applicable 242Pu Activity (Ci) Not Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
B-17 

ATTACHMENT B.17 REPLICATE TESTING IQ3 DATA FOR CONTAINER SR6118

Instrument: SRS IQ3Container: MDL0506241 

Original Measurement Replicate #1 

Quantity of Interest 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0238Pu Activity (Ci) 3.22E-02 1.77E-02 5.50E-01 3.66E-02 2.02E-02 5.52E-01 3.74E-0239Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0240Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0242Pu Activity (Ci) 1.85E-08 1.02E-08 5.51E-01 2.10E-08 1.16E-08 5.52E-01 2.14E-0241Am Activity (Ci) 5.67E-05 3.12E-05 5.50E-01 5.93E-05 3.26E-05 5.50E-01 5.89E-090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 0.00E+00 N/A 0.00E+0137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+0TRU Alpha Conc. (nCi/g) 9.34E+01 5.13E+01 5.49E-01 1.06E+02 5.83E+01 5.50E-01 1.08E+0

Replicate #3 Replicate #4 

Quantity of Interest 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 238Pu Activity (Ci) 3.74E-02 2.08E-02 5.56E-01 3.59E-02 2.01E-02 5.60E-01 3.86E-02 239Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 240Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 242Pu Activity (Ci) 2.14E-08 1.19E-08 5.56E-01 2.06E-08 1.15E-08 5.58E-01 2.21E-08 241Am Activity (Ci) 5.75E-05 3.16E-05 5.50E-01 5.72E-05 3.14E-05 5.49E-01 5.95E-05 90Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A 0.00E+00 0.00E+00 TRU Alpha Conc. (nCi/g) 1.08E+02 6.02E+01 5.57E-01 1.04E+02 5.82E+01 5.60E-01 1.12E+02 
B-18 

ATTACHMENT B.18 REPLICATE TESTING IQ3 RESULTS FOR CONTAINER SR61

Original Measurement 

Quantity of Interest 

Reported 

Value 

Absolute 

Uncertainty Pr(x <|c2|) 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation c2 

233U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE234U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE238U Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE238Pu Activity (Ci) 3.22E-02 1.77E-02 3.72E-02 1.01E-03 2.72E-02 1.30E-02 1.00E+0239Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE240Pu Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE242Pu Activity (Ci) 1.85E-08 1.02E-08 2.13E-08 5.57E-10 2.61E-02 1.19E-02 1.00E+0241Am Activity (Ci) 5.67E-05 3.12E-05 5.85E-05 1.06E-06 1.81E-02 4.61E-03 1.00E+090Sr Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUE137Cs Activity (Ci) 0.00E+00 N/A 0.00E+00 0.00E+00 N/A #VALUE! #VALUETRU Alpha Conc. (nCi/g) 9.34E+01 5.13E+01 1.08E+02 2.97E+00 2.76E-02 1.34E-02 1.00E+0Quantity of Interest 2 Test t Test233U Activity (Ci) #VALUE! Not Applicable 234U Activity (Ci) #VALUE! Not Applicable 238U Activity (Ci) #VALUE! Not Applicable 238Pu Activity (Ci) Not Significant Significant 239Pu Activity (Ci) #VALUE! Not Applicable 240Pu Activity (Ci) #VALUE! Not Applicable 242Pu Activity (Ci) Not Significant Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Applicable137Cs Activity (Ci) #VALUE! Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Significant 
Attachments C.1 through C.6
ATTACHMENT C.1: EPA INSPECTION ISSUE TRACKING FORM, 

EPA ISSUE No. SRS-CCP-AK-05-004C 

 Page 1 of 1

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

Inspection No. EPA-SRS-CCP-10-05.8 Issue Number: SRS-CCP-AK-05-004C 

Date: 11-01-05 

Inspector: Connie Walker 

Attachments? YES NO 

Sample Size: One Waste Stream

Population size (if known): NA 

A. Description of Issue: AK reference D152 indicates that wastes in SR-W027-773A-HET include 

large items such as boxed wastes. This waste stream is classified as job control waste that typically 

excludes large metal items like those found in SR-W027-773A-HET. The AK Summary (AK-7) does not 

yet address the boxed waste component and CCP is encouraged to assess whether the boxed waste belongs 

in SR-W027-773A-HET based on the similarity of processes, physical form and material type. 

B. Regulatory Reference: 

40 CFR 194.24 (c)(3) 

C. Site requirement(s): 

CCP-TP-005, Revision 15 

D. Discussed with: 

 Site Personnel: Kevin Peters, Jeff Harrison 

 DOE/CTAC Personnel: Wayne Ledford 

 Other Personnel: 

E. Additional Comments: 

 None 

F. Site Response Information:

 Site Response Required? YES NO 

 Site Response Due Date: N/A 

C-1 
ATTACHMENT C.2: EPA INSPECTION ISSUE TRACKING FORM, 

EPA ISSUE No. SRS-CCP-AK-05-005C 

 Page 1 of 1

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

Inspection No. EPA-SRS-CCP-10-05.8 Issue Number: SRS-CCP-AK-05-005C 

Date: 11-01-05 

Inspector: Connie Walker 

Attachments? YES NO 

Sample Size: One Waste Stream

Population size (if known): NA 

A. Description of Issue: Several AK references (e.g., C040) indicate that the Savannah River 

Technology Center generates Waste Stream SR-W027-773A-HET (debris) that may contain materials 

identified as High Level Waste (HLW). An earlier revision of AK-7 (SR-W027-773A-HET) included the 

HLW component that has since been removed in the latest revision of the AK summary. The AK record 

must include why this information was removed from AK-7. Also, in the future, CCP must adequately 

document and justify the inclusion of any waste in AK-7 previously or currently identified as being high 

level. 

B. Regulatory Reference: 

40 CFR 194.24 (c)(3) 

C. Site requirement(s): 

CCP-TP-005, Revision 15 

D. Discussed with: 

 Site Personnel: Kevin Peters, Jeff Harrison 

 DOE/CTAC Personnel: Wayne Ledford 

 Other Personnel: 

E. Additional Comments: 

 None 

F. Site Response Information:

 Site Response Required? YES NO 

 Site Response Due Date: N/A 

C-2 
ATTACHMENT C.3: EPA INSPECTION ISSUE TRACKING FORM, 

EPA ISSUE No. SRS-CCP-NDA-05-006C 

 Page 1 of 1

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

Inspection No. EPA-SRS-CCP-10-05.8 Issue Number: SRS-CCP-NDA-05-006C 

Date: 11-01-05 

Inspector: Patrick Kelly 

Attachments? YES NO 

Sample Size: NA 

Population size (if known): NA 

A. Description of Issue: Default isotopics based on AK are documented on a waste stream basis and are 

contained in AK-NDA Memoranda. There is no formal instruction for the NDA Expert Analysts (EA) 

regarding the use of AK based default isotopics. CCP-TP-048 does contain directions to the EA regarding 

other aspects of the radioassay process. Examination of NDA BDRs indicates that AK-based isotopics have 

been applied by the NDA EA. 

B. Regulatory Reference: 

40 CFR 194.24 (b)(2) 

C. Site requirement(s): 

CCP-TP-048 

D. Discussed with: 

 Site Personnel: Rich Thomason, Bruce Gillespie, 

 DOE/CTAC Personnel: Joe Harvill, David Drehr 

 Other Personnel: 

E. Additional Comments: 

None 

F. Site Response Information:

 Site Response Required? YES NO 

 Site Response Due Date: 

C-3 
ATTACHMENT C.4: EPA INSPECTION ISSUE TRACKING FORM, 

EPA ISSUE No. SRS-CCP-RTR-05-003CR 

 Page 1 of 1

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

Inspection No. EPA-SRS-CCP-10-05.8 Issue Number: SRS-CCP-RTR-05-003CR 

Date: 10-31-05 

Inspector: Dorothy Gill 

Attachments? YES NO 

Sample Size: Two (2) 

Population size (if known): Four (4) 

A. Description of Issue: In the process of RTR training in accordance with CCP-TP-028, Revision 2, an 

operator did not identify a required item in the training drum. Although a qualified RTR operator reviewed 

this training tape, it appears that the CCP NDE Test Drum Inventory Sheet CCP-TP-028-A1, Revision 0 was 

not used as a basis for this review because the reviewer did not document that a required item was missed. 

The process in place results in a lack of identification of problems associated with the requalification of

RTR Operators and does not provide the opportunity for feedback to the operator undergoing RTR Operator 

requalification. 

B. Regulatory Reference: 

40 CFR 194.24 (b)(2) 

C. Site requirement(s): 

CCP-TP-028, Revision 2 

D. Discussed with: 

Site Personnel: Lee Smith & James Mobley 

 DOE/CTAC Personnel: Annabelle Axinn, Wayne Ledford 

 Other Personnel: 

E. Additional Comments: 

None 

F. Site Response Information:

 Site Response Required? YES NO 

 Site Response Due Date: 11-21-05 

C-4 
ATTACHMENT C.5: EPA INSPECTION ISSUE TRACKING FORM, 

EPA ISSUE No. SRS-CCP-VE-05-001F 

 Page 1 of 1

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

Inspection No. EPA-SRS-CCP-10-05.8 Issue Number: SRS-CCP-VE-05-001F 

Date: 10-31-05 

Inspector: Dorothy Gill 

Attachments? YES NO 

Sample Size: Three (3) 

Population size (if known): Five (5) 

A. Description of Issue: When performing VE on S4000 soils drums from the Mound soil waste stream

described in AK-8 for BDRs SRVEMS0001 through SRVEMS0003, operators conducted visual inspection 

that was not consistent with Procedure CCP-TP-113, Revision 3. The VE event did not assess the drums’ 

contents but focused solely on the top layer of waste. The BDRs reported that no prohibited items were 

found but this could not be ascertained based on the VE that was performed. 

B. Regulatory Reference: 

40 CFR 194.24 (b)(2) 

C. Site requirement(s): 

CCP-TP-113, Revision 3 

D. Discussed with: James Mobley, CCP, Visual Examination Expert 

Site Personnel: 

 DOE/CTAC Personnel: Annabelle Axinn 

 Other Personnel: 

E. Additional Comments: 

None 

F. Site Response Information:

 Site Response Required? YES NO 

 Site Response Due Date: 11-21-05 

C-5 
ATTACHMENT C.6: EPA INSPECTION ISSUE TRACKING FORM, 

EPA ISSUE No. SRS-CCP-VE-05-002CR 

 Page 1 of 1

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

Inspection No. EPA-SRS-CCP-10-05.8 Issue Number: SRS-CCP-VE-05-002CR 

Date: 10-31-05 

Inspector: Dorothy Gill 

Attachments? YES NO 

Sample Size: One 

Population size (if known): One 

A. Description of Issue: The Waste Visual Examination Data Form (Attachment 1) from procedure 

CCP-TP-113 contains data that does not match what actually transpired during visual examination of Drum

No. SR100052. The videotape record shows a problem with the VE data for this drum that was initially 

recorded in the hard copy record. Subsequently, the original record was discarded and replaced with one 

that does not match the videotaped event. Consequently, the hard copy record that remains does not 

represent what transpired during VE of this drum. 

B. Regulatory Reference: 

 40 CFR 194.24 (b)(2) 

C. Site requirement(s): 

CCP-TP-113, Revision 3 

D. Discussed with: James Mobley, CCP, Visual Examination Expert 

 Site Personnel: 

 DOE/CTAC Personnel: Annabelle Axinn 

 Other Personnel: 

E. Additional Comments: 

None 

F. Site Response Information:

 Site Response Required? YES NO 

 Site Response Due Date: 11-21-05 

C-6 
Attachment D: Response to EPA Inspection Issues
APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

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APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

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APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

D-3 
APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

D-4 
APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

D-5 
APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

D-6 
APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

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APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

D-8 
APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

D-9 
APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

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APPENDIX D: RESPONSE TO EPA INSPECTION ISSUES 

Inspection No. EPA-SRS-CCP-10-05.8 Inspection Date: 10/31/05-11/03/2005 

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