EPA DOCKET NO. A-98-49; II-A4-173

WASTE CHARACTERIZATION INSPECTION

CONTINUED COMPLIANCE REPORT

EPA INSPECTION OF THE CENTRAL CHARACTERIZATION PROJECT

WASTE CHARACTERIZATION PROGRAM

AT THE ADVANCED MIXED WASTE TREATMENT PROJECT

October 30 – November 1, 2012 February 26, 2013

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

April 2013ii TABLE OF CONTENTS

Acronyms and Abbreviations .................................................................................................... .... iii

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

2.0 Purpose of Continued Compliance Inspections .................................................................. 4

3.0 Purpose of This Report ....................................................................................................... 4

4.0 Scope of This Continued Compliance Inspection ............................................................... 4

5.0 Inspection Personnel .......................................................................................................... . 5

6.0 Technical Evaluation .......................................................................................................... 5

6.1 Acceptable Knowledge ........................................................................................... 5

6.2 Nondestructive Assay ........................................................................................... 16

6.3 Real-Time Radiography ........................................................................................ 19

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

7.0 Findings and Concerns ...................................................................................................... 23

8.0 Conclusions ................................................................................................................... .... 23

LIST OF TABLES

Table 1. Tiering of CH TRU Waste Characterization Processes Implemented by AMWTP ......... 3 Table 2. Key AMWTP Waste Management a nd Acceptable Knowledge Procedures ................. 10 Table 3. Batch Data Reports ................................................................................................... ...... 14

LIST OF FIGURES

Figure 1. AMWTP and INL-CCP Char acterization Relationship .................................................. 6 Figure 2. AMWTP Waste Ma nagement Process ............................................................................ 8 Figure 3. Document Hierarchy and Informati on Flow for AMWTP Acceptable Knowledge ..... 12

ATTACHMENTS

Attachment A Tiering of CH TRU Waste Characterization Processes Implemented by AMWTP – Superseded
Attachment B Approval Summary for AMWT P CH Waste Characterization Program

Attachment C List of Documents Revi ewed by EPA during Continued Compliance Inspection

Attachment D Inspection Personnel

Attachment E.1 Nondestructiv e Assay Inspection Checklist
Attachment E.2 Real-Time Radiography Inspection Checklist

Attachment E.3 Visual Examination Inspection Checklist

Attachment F EPA Inspection Issue Track ing Form, Issue No. AMWTP-CH-CC-AK-12- 001CR, Final

Attachment G EPA Inspection Issue Track ing Form, Issue No. AMWTP-CH-CC-RTR-12- 002CR, Finaliii ACRONYMS AND ABBREVIATIONS

AK acceptable knowledge

AKE Acceptable Knowledge Expert

AKSR acceptable knowledge summary report

Am americium

AMWTP Advanced Mixed Waste Treatment Project

ANLE Argonne National Laboratory-East

BC Battelle Columbus

BDR batch data report

Bechtel BWXT Bechtel BWXT Idaho, LLC

BN Battelle Northwest

CBFO Carlsbad Field Office

CCP Central Characterization Project

CFR Code of Federal Regulations

CH contact-handled

CIS characterization information summary

Cs cesium

CTAC Carlsbad Technica l Assistance Contractor

DEQ Department of Environmental Quality

DOE U.S. Department of Energy

EPA U. S. Environmental Protection Agency

FGE fissile gram equivalent

HLW high-level waste

HSG headspace gas

HWN hazardous waste number

IDC item description code

INL Idaho National Laboratory

ITG Idaho Treatment Group, LLC

ITR Independent Technical Reviewer

IWAS Integrated Waste Assay System

IWTS Integrated Waste Transfer System

LLD lower limit of detectioniv LOQI list of qualified individuals

LWA Land Withdrawal Act

m 3 cubic meters

MD Mound Site

MDC minimum detectable concentration

MFC Materials and Fuels Complex

NCR nonconformance report

NDA nondestructive assay

NDE nondestructive evaluation

OJT on-the-job training

Pu plutonium

QA quality assurance

QC quality control

RCRA Resource Conservation and Recovery Act

RF Rocky Flats

RFETS Rocky Flats Envir onmental Technology Site

RH remote-handled

RL Richland Laboratory

RTR real-time radiography

SCG Summary Category Group

SME subject matter expert

SNF spent nuclear fuel

SOP standard operating procedure

SQS small quantity site

Sr strontium

T1 Tier 1

T2 Tier 2

TMU total measurement uncertainty

TRAMPAC Transuranic Waste Authori zed Methods for Payload Control

TRU transuranic

TRUCON Transuranic Waste Content Code

U uranium

VE Visual Examinationv VEE Visual Examination Expert

VET Visual Examination Technique

WAC waste acceptance criteria

WAP Waste Analysis Plan

WDS Waste Data System

WIPP Waste Isolation Pilot Plant

WMC Waste Matrix Code

WMP waste material parameter

WSPF waste stream profile form

WTS Waste Tracking System1 1.0 EXECUTIVE SUMMARY

In accordance with Title 40 of the Code of Federal Regulations (40 CFR) 194.24(h), the U.S. Environmental Protection Agency (EPA) conducted a continued compliance inspection of the waste characterization program for contact-ha ndled (CH) transuranic (TRU) wastes at the U.S. Department of Energy’s (DOE’s) Advanced Mixed Waste Treatment Project (AMWTP) at Idaho National Laboratory (INL) in Idaho Falls , Idaho. Specifically, EP A conducted a continued compliance inspection of the site’s program to characterize CH TRU wastes proposed for disposal at the Waste Isolation Pilot Plant (WIPP). This inspec tion took place over two visits to AMWTP: (1) acceptable knowledge (AK), real-time radiography (R TR) and visual examination (VE) were evaluated October 30–November 1, 2012, and (2) nondestructive assay (NDA) was evaluated February 26, 2013. As a result of this continue d compliance inspection, EPA

confirmed that the AMWTP TRU waste characteri zation program continues to characterize CH

TRU waste consistent with the conditions and li mitations that are disc ussed in the baseline inspection report (see EPA Dock et No. A-98-49; II-A4-66).

In October 2011, Idaho Treatment Group (ITG) , a DOE Carlsbad Field Office (CBFO) contractor, took over AMWTP’s TRU waste char acterization program from the previous contractor. During this transition, ITG a dopted “as is” the existing CH TRU waste characterization program that had been implemen ted by the previous contractor [see Item (2), section 6.1 of this report], which EPA had appr oved via a baseline inspection in October 2006 (See EPA Report A-98-49; II-A4-66 in EPA Air Do cket). ITG also adapted relevant CH TRU waste characterization documents, which serve as a basis for the conti nued characterization of CH waste containers from the Idaho Cleanup Project and other DOE TRU sites with small quantities of CH TRU wastes such as Bettis, Ar gonne National Laboratory East (ANLE) and the Materials and Fuel Complex (MFC). The contin ued compliance inspection discussed in this report, therefore, was necessary to determin e technical adequacy of the ITG-implemented processes, procedures, equipment and trai ning of personnel involved. AMWTP routinely repackages and supercompacts waste containers, using an overpack that can contain up to 10 compacted drums.

EPA identified two concerns during the October/November 2012 continued compliance inspection, one related to AK and the other relate d to RTR. Both concer ns were adequately resolved and ITG provided supporting documentati on in February 2013. In Item (2) of section 6.3, this report discusses three items related to RT R that were relatively minor in nature or onetime occurrences which EPA brought to the at tention of AMWTP personnel and management during the inspection. These relate to the reporting of containe r weight, reporting of prohibited items in a nonconformance report and an incomp lete inventory of waste items in a drum subjected to RTR. During the inspection, EP A asked that AMWTP consider these minor observations and make changes to current prac tices. EPA requires CBFO to notify EPA of how

AMWTP has addressed these issues when subm itting AMWTP’s Tier 2 changes for the current

quarter.

Although this continued compliance inspection did not generate any modifications to the Tier 1 (T1) and Tier 2 (T2) designations from the Oc tober 2006 baseline inspecti on, the original T1 and T2 designations were modified as a result of two T1 change requests EPA approved in January2 2013. 1 Table 1 provides the current tiering re quirements for AMWTP (see footnote 1). Attachment A provides the origin al tiering table, dated Octobe r 2006, that was current during the AK, RTR and VE continued compliance ev aluations in October/November 2012.

Based on the results of this inspection, EPA conf irms its original appr oval of the AMWTP CH TRU waste characterization program, now implem ented by ITG, in the configuration observed during this continued compliance inspection consistent with the limitations described in the baseline inspection report cited above and subs equent EPA T1 approvals. Attachment B provides a table listing all of EPA’s a pprovals of the AMWTP CH TRU wa ste characterization program.

This report serves as EPA’s public notification of the results of the continued compliance inspection. This information wi ll be provided through the EPA website and by sending emails to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3).

1 The tiering modifications were published in the EPA T1 approval report for the “Addition of ContactHandled Transuranic Waste to the Advanced Mixed Waste Treatment Project Approved Program: S3000 and S5000 Waste from Argonne National Laboratory-East and S5000 Waste from Idaho National Laboratory Materials and Fuels Complex,” EPA Docket No. A-98-49; II-A4-169, published January 29, 2013.3Table 1. Tiering of CH TRU Waste Characterization Processes Implemented by AMWTP(Based on March 28–30 and April 11–13, 2006, Baseline Inspectionand Subsequent T1 Evaluations, Updated January 2013)Process ElementsAMWTP CH Waste Characterization Processes – T1 ChangesAMWTP CH Waste Characterization Processes – T2 Changes*Acceptable Knowledge,including LoadManagementAny new waste categoryAny waste from sources other than Mound, RFETS, BattelleColumbus, Bettis, ANLE and MFCLoad management of any new or unapproved waste streamNotification to EPA upon completion of or substantive modification** to:Site procedures requiring CBFO approvalLoad management status of approved waste streamsAll final WSPFs with related attachments (e.g., CIS), including updates oradditions to waste streams within approved SCGs and summaries ofradiological data for those containers included on the CIS drum listAK accuracy reports (annually, at a minimum)All new and revised AKSRs and generator-site-specific summary AKreports (e.g., RPT-TRUW-79 and RPT-TRUW-89)Any waste identified outside of the waste profiles included in the 2002TWBIR, when applicableImplementation of procedures and related documentation that formalizeNDA-AK communication requirementsRPT-TRUW-05, RPT-TRUW-07 and RPT-TRUW-12Nondestructive Assay New equipment or physical modifications to approved equipment***Extension or changes to approved calibration range for approvedequipmentNotification to EPA upon substantive modification** to:Site procedures requiring CBFO approvalSoftware for approved equipmentOperating ranges upon CBFO approvalReal-Time Radiography None Notification to EPA upon substantive modification** to:Site procedures requiring CBFO approvalNew equipment or physical modifications to approved equipment***Visual Examination andVisual ExaminationTechniqueChanges in vendor performing VE and/or VET Notification to EPA upon:Substantive modification** to site procedures requiring CBFO approvalAddition of new waste categoryAddition of new procedure or site equipment identifierWIPP Waste Data System Changes to WDS algorithms specific to load management Notification to EPA upon substantive modification** to:Site procedures requiring CBFO approvalLoad management status of approved waste streamsNew T1s, T2s and significant modifications to existing T1s or T2s would be inboldtext; T1s or T2s that were only revised for style are not shown in bold.* AMWTP will report all T2 changes to EPA every three months.** “Substantive modification” refers to a change with the potential to impact AMWTP’s CH wastecharacterization processes or documentation thereof, excluding changes thatare solely related to environment, safety and health; nuclear safety; or the Resource Conservationand Recovery Act, or that are editorial in nature orare required to addressadministrative concerns. New references that are included as part of the document revision may be requested by EPA.*** Modifications to approved equipment include all changes with the potential to affect data relative to waste isolation and exclude minor changes, such as the addition ofsafety-related equipment.4 2.0 PURPOSE OF CONTINUED COMPLIANCE INSPECTIONS

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, Federal Register notice, EPA must perform a single ba seline inspection of a TRU waste generator site’s waste characterization program (Vol. 69, No. 136, pages 42571–42583, July 16, 2004). The purpose of EPA’s baseline inspection is to approve the s ite’s waste characteriza tion program, based on a demonstration that the program’s components, w ith 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.

Following EPA’s baseline approval, EPA has th e authority to conduct continued compliance inspections to verify that the site (1) conti nues to use only the approve d waste characterization processes to characterize the waste and (2) remains in compliance with all regulatory requirements. EPA is also authorized to evaluate and approve changes, if necessary, to the site’s approved waste characterization program by conducting additional inspections under the authority of 40 CFR 194.24(h).

3.0 PURPOSE OF THIS REPORT

This report documents the basis for EPA’s deci sion to maintain the approval of the AMWTP waste characterization program for CH TR U wastes. Specifically, this report:

 Describes the sample of the AMWTP waste characterization systems evaluated during this inspection.

 Identifies all areas in which waste characterization systems have changed relative to what was approved during the baseline inspection and other subsequent EPA T1 evaluations and assesses the impact, if any, of those changes.

 Provides objective evidence to support the basis for EPA’s continued approval of all waste characterization systems.

 Describes any tests or demonstrations comple ted during the course of the inspection and

their relevance to EP A’s approval decision.

The DOE documents that EPA reviewed for this evaluation are cited in throughout the report and are listed in Attachment C. Any of these documen ts can be requested from the following address:

Carlsbad Field Office Manager, National TRU Program

P.O. Box 3090 Carlsbad, NM 88221-3090

4.0 SCOPE OF THIS CONTINUED COMPLIANCE INSPECTION

The scope of this continued compliance inspecti on included the evaluation of selected elements of the waste characterization systems in use at AMWTP to characterize CH TRU wastes that were approved during the base line inspection and subseque nt T1 evaluations. Waste5 characterization activities ev aluated included AK for Summ ary Category Group (SCG) S3000 and S5000 CH waste streams, NDA systems repr esented by Integrated Waste Assay System (IWAS) units Z-390-100 and Z-390-101 and IW AS units Z-211-102 and Z-211-103, and RTR

and VE for SCG S5000 CH waste.

5.0 INSPECTION PERSONNEL

EPA and its support personnel c onducted interviews with AM WTP waste characterization personnel in several disc iplines. The personnel contacted repr esented a sample of the CH TRU waste characterization staff. The EPA insp ection team and AMWTP personnel contacted are listed in Attachment D, with their affilia tions and areas of expertise or function.

6.0 TECHNICAL EVALUATION

Sections 6.1 through 6.4 of this report detail the four technica l areas assessed during this inspection: AK, NDA, RTR and VE. Completed inspection checklists for NDA, RTR and VE are

included in Attachment E.

6.1 Acceptable Knowledge

EPA evaluated AMWTP’s continued compliance with EPA-approved AK procedures for CH

waste characterization.

Technical Evaluation

(1) Overall Advanced Mixed Waste Treatmen t Project waste management flow and characterization processes were examined and found to be adequately explained.

EPA interviewed AMWTP personnel to understa nd the waste characterization and waste management processes performed by AMWTP. Th e Central Characteriza tion Project (CCP) at INL and the ITG program at AMWT P are both authorized to charac terize CH TRU waste at INL,

with some activities shared between the two entiti es. Legacy waste in storage at the INL complex is managed by both INL-CCP and AMWTP dependi ng on the waste origin and storage location. In addition, AMWTP also operates a small-quantit y-generator program that accepts CH waste from offsite sources (e.g., Hanford, ANLE, Bettis , Mound) for characterization and shipment to the WIPP. All remote-handled (RH) waste at INL, regardless of origin, is managed by INL-CCP. All necessary Resource Conservation and Recove ry Act (RCRA) sampling and analysis for CH and RH waste managed by INL-CCP is sent to AMWTP, but INL-CCP performs all other characterization activities, incl uding VE, RTR, NDA and radiol ogical characterization. AMWTP does not generate an AMWTP wa ste profile form for any of the INL-CCP managed waste. Figure 1 presents the AMWTP and IN L-CCP characterization relationship.6 Figure 1. AMWTP and INL-CCP Char acterization Relationship Yes INL-CCP Program: INL Legacy Waste (RH and CH) and SQS Offsite Waste (CH only)

Retained

Under INLCCP Program? See Figure 2 No

INL-CCP writes AKSR p er CCP-TP-005 a

INL-CCP performs NDE and NDA

INL-CCP prepares Form 1900 and sends

waste to AMWTP

AMWTP performs RCRA characterization (HSG or solid sampling)

INL-CCP takes waste back as fully

characterized INL-CCP waste stream and prepares CCP WIPP WSPF

AMWTP assembles payload, which is shipped under CCP’s approved transportation program as an INL-CCP waste stream

a Central Characterization Project, “CCP Acceptable Knowledge Documentation,” CCP-TP-005,
Revision 24, November 28, 2011.7 Figure 2 presents the AMWTP waste acceptance a nd waste characterization processes for waste profiled under the AMWTP program, incl uding AMWTP newly generated waste, 2 legacy waste, 3

offsite waste 4 and waste generated at INL but outsi de of the AMWTP facility [e.g., waste generated at the Materials and Fuels Complex (MFC)]. 5 AMWTP typically requires specific manifests and reports to be in place prior to accepting wastes origina ting outside of AMWTP. Upon arrival, AMWTP conducts fingerprint analyses of these wastes to ensure that the waste accepted matches the waste manifests. Wastes th at are AMWTP-generated or originate within AMWTP (i.e., legacy waste) do not require this ma nifest process. INL waste is tracked using the Integrated Waste Tracking System (IWTS), and AMWTP waste characteri zation data are input into the AMWTP Waste Tracking System (WTS). These systems track waste movement and characterization, as well as many AMWTP-sp ecific forms as the waste is moved through shipment to AMWTP, acceptance, characterizatio n and other processes. Item (4) addresses the shipment and management of these wastes as part of EPA’s traceability analyses.

The waste transfer, management and profiling pr ocess at AMWTP can be complex and may vary based on the type of waste being managed (see Figure 2). For example, offsite profiling and other information must be compiled prior to AMWTP acceptance for waste generated at the Hanford Site that is shipped to AMWTP. This profiling is not requir ed for waste generated within AMWTP, including legacy waste in st orage at INL. Once waste is accepted, AMWTP performs the same general waste characterization processes for all waste acc ording to the type of waste managed (i.e., solid or debris) and whethe r the waste is to be supercompacted. INL-CCP packages and ships AMWTP-profiled and-charac terized waste under separate procedures and

controls.

EPA found that, while the waste management process at AMWTP is complex, AMWTP personnel adequately described the waste management processes.

2 “For the purposes of AK, AMWTP newly-generated wast e includes waste that is generated as a result of repackaging, treatment (e.g. supercomp action), retrieval, characterization, a nd/or handling of retrieved or accessibly stored primary waste or as a result of conducting ma intenance activities” (MP-TRUW-8.13, Revision 24).

3 “Historically stored waste containers th at comprise the 65,000 cubic meters (m 3 ) of waste outlined in the agreement with the State of Idaho (i.e., the ‘Batt Agreement’)” (MP-TR UW-8.13, Revision 24). This includes waste that originated from various waste generators across the DOE complex, including the Rocky Flats Environmental Technical Site and the Mound Site. Waste was shipped to INL for storage over the course of several decades. MFC (as Argonne National Laboratory-West) contributed waste to the legacy waste population and continues to generate

waste that is now considered INL waste.

4 “Mixed contact-handled transurani c waste received from an offsite wa ste generator. [An] offsite waste generator [is] a non-INL generator such as Hanford, Los Alamos, CCP, etc.” (MP-TRUW-8.41, Revision 3).

5 “Waste generated by operations outside of the Tran suranic Storage Area on the INL and received at the Transuranic Storage Area after September 11, 1991. [A n] INL waste generator [is] a non-AMWTP INL waste generator” (MP-TRUW-8.40, Revision 9).8 Figure 2. AMWTP Waste Management Process  Legacy Waste

 AMWTP newly generated waste a  Non-AMWTP INL waste

 Offsite waste a

Submit Form 1900 AMWTP Offsite Waste Stream

Profile or other information as needed to AMWTP for acceptance consideration

Yes AMWTP AKE revises an existing generator-site-specific AK summary report or writes a new one

No Is waste to be supercompacted? AMWTP AKE develops or revises

waste streams, AKSRs and other AK reports per procedure

MP-TRUW-8.13

AMWTP characterizes waste (NDA, NDE, RCRA HSG sampling/analysis) per AMWTP

procedures and prepares AMWTP WIPP

WSPF

AMWTP assembles payload, which is shipped under CCP’s approved transportation program as an AMWTP waste stream AMWTP AKE identifies containers and population groups with acceptable IDCs

AMWTP AKE adds waste to IDC BN 508 or other approved feed IDC for supercompacted

Waste Stream BN510.1

AMWTP AKE revises AKSR and other AK reports as necessary per procedure

MP-TRUW-8.13

AMWTP processes waste as necessary and

performs NDE per AMWTP procedures

AMWTP packages waste in silvers and performs NDA per AMWTP procedures

AMWTP supercompacts the silvers and packages pucks into 100-gallon drums per AMWTP procedures

AMWTP performs RCRA HSG sampling/analysis per AMWTP procedures and prepares AMWTP WIPP WSPF

AMWTP assembles payload, which is shipped under CCP’s approved transportation program as an AMWTP waste stream SCG S3000 or S5000 for direct shipment SCG S5000 only

a INL-CCP may occasionally identify CH waste to be included in categories managed by AMWTP9 (2) The Idaho Treatment Group program document integration process was examined and found to be adequate. Waste shipment status was also ascertained.

Bechtel BWXT Idaho, LLC (Bechtel BWXT) tr ansferred operation of AMWTP to Idaho Treatment Group, LLC (ITG) as of October 1, 2011, and ITG began shipping waste under its program a few days after the transfer (Refer ence Advanced Mixed Waste Treatment Project website). AMWTP procedures implemented by Bechtel BWXT were accepted by ITG via a Blue Sheet process in which the contents were re viewed and accepted without major changes, although many procedures were later revised to address ongoing program modifications and updates. The Blue Sheet process allowed rela tively smooth transition of activities between contractors and is still in pr ogress. ITG uses previous Bech tel BWXT procedures without

revision until the Blue Sheet review is completed. EPA agrees that the process is satisfactory and that Bechtel BWXT successfully transitioned pr ocedures previously examined by EPA to the ITG program.

AMWTP currently ships both compacted and uncom pacted waste to the WIPP. AMWTP shreds and repackages CH debris waste in its pres upercompaction process lines, creating about 500

silvers 6 each week. The silvers are supercompacted into pucks, 7 and three to seven pucks are packaged in a 100-gallon drum. Approximately 90 100-gallon drums of supercompacted waste are generated weekly. INL currently makes approxi mately eight waste shipments per week, with six of these originating from the supercompacted debris stream and the others from approved AMWTP direct-ship streams and INL-CCP-managed streams.

In October 1995, the state of Idaho, U.S. Navy a nd DOE reached an agreement (referred to as the “Batt Agreement”) that included a requirement th at DOE ship all transuranic waste located at INL (estimated to be 65,000 m 3 in 1995) to WIPP by a target date of December 31, 2015, but no later than December 31, 2018. The Batt Agreement also included provisions for removal of targeted waste from the Subsurface Disposal Area (Reference 1995 Settlement Agreement). When asked about shipments pertaining to th e Batt and other agreements, AMWTP personnel stated that INL has shipped 40,000 m 3 of low-level and TRU waste to date, noting that the precompacted waste volume counts toward the calculated waste volume. AMWTP representatives also stated that ITG has contr act-required shipment volumes but did not disclose the specific volume to EPA. ITG shipped approximately 3,200 m 3 of supercompacted and directship waste between October 2011 and October 2012.

(3) Selected Advanced Mixed Waste Treatment Pr oject waste management procedures were examined and are adequately implem ented by Idaho Treatment Group, LLC.

Table 2 presents the selected key procedur es that EPA examined during the continued compliance inspection. EPA determined that these procedures were adequately transitioned to the ITG program. AMWTP maintains upper leve l procedures that address WIPP waste characterization requirements, AK characteri zation, AMWTP waste acceptance requirements for onsite and offsite waste, and pro cedures associated with readying waste for shipment to WIPP.

6 “Silvers” are 55-grallon drums that contai n shredded or repackaged debris waste.

7 “Pucks” are the crushed drums resulting from the supercompaction process.10 Table 2. Key AMWTP Waste Management and Acceptable Knowledge Procedures

Procedure Title Contents

MP-TRUW-8.1, Revision 22 Certification Plan for INL Transuranic Waste,

Advanced Mixed Waste Treatment Project Summarizes the methods and procedures used by AMWTP to demonstrate compliance with the WIPP

WAC. a

MP-TRUW-8.2, Revision 16 Quality Assurance Project Plan, Advanced Mixed Waste Treatment Project Summarizes the methods and procedures used by AMWTP to demonstrate compliance with the WIPP

WAP. b

MP-TRUW-8.5, Revision 28 TRU Waste Certification,

Advanced Mixed Waste Treatment Project Present methods to comply with MP-TRU-8.1, CCPPO-003 Payload Control Methods, and the CCP CH Transuranic Waste Authorized Methods for Payload Control (TRAMPAC). c

MP-TRUW-8.11, Revision 24 Data Reconciliation,

Advanced Mixed Waste Treatment Project Presents procedures to reconcile data quality objectives following data validation and verification by the Site Project Office.

MP-TRUW-8.13, Revision 24 Collection, Review, and Management of Acceptable Knowledge Documentation,

Advanced Mixed Waste Treatment Project Presents methods and procedures for AMWTP personnel and/or subcontractors performing acceptable knowledge collection, review, compilation, evaluation and management of AK

documents in accordance with the WIPP WAP.
MP-TRUW-8.14, Revision 12 Preparation of Waste Stream Profile Forms, Advanced

Mixed Waste Treatment Project Provides procedures to prepare the waste stream profile form and associated characterization information summary and th e waste characterization package in accordance with the WIPP WAP.
MP-TRUW-8.40, Revision 9 INL Waste Acceptance,

Advanced Mixed Waste Treatment Project Presents requirements for the acceptance of waste from INL waste generators such as MFC and the Sludge Repackaging Project.

MP-TRUW-8.41, Revision 3 Offsite DOE CH-TRU Waste Acceptance, Advanced

Mixed Waste Treatment Project Requirements for acceptance of offsite waste from offsite waste generators, such as INL-CCP or the

Hanford Site.

a DOE CBFO, “Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant,” DOE/WIPP-02-3122, Revision 7.2, Carlsbad, NM, June 13, 2011.

b Waste Isolation Pilot Plant Hazardous Wa ste Facility Permit, New Me xico Environment Departme nt, Waste Analysis Plan, Santa Fe, NM, June 29, 2010.

c U.S. Department of Energy, “Contact-Ha ndled Transuranic Waste Authorized Methods for Payload Control (CH-TRAMPAC),” Carlsbad, NM [n.d.].

All of the examined procedures reference dozens of different forms that are used to document the results of procedural requirements. EPA examin ed several example completed forms, including Form 1066 (“TRU Waste Management AK Checklist”), Form 1070 (“Acceptable Knowledge Resolution Checklist”), Form 1727 (“Non-AMWT P Generator Shipping Request”), Form 1736 (“AMWTP Safety Basis Radioact ive Material Waste Acceptance Criteria Calculator”), Form 1084 (“AK Source Document Reference List”), Form 1900 (“AMWTP Offsite Waste Stream Profile”), Form 1901 (“Non-AMWTP Generator Waste Fingerprinting”), and Form 1905 (“Offsite Waste Receipt Payloa d Verification Checklist”). The examined forms supported the associated procedural references and demonstrated that procedures were adequately implemented

and documented. The forms also demonstrated cont ainer traceability, as addressed in Item (4).11 Additionally, EPA examined implementati on of AK procedure MP-TRUW-8.13, Revision 24.

The review included the source document assemb ly and review process, preparation of AKrelated documents, subsequent preparation of the AK summary repor t (AKSR), and final preparation of the waste stream profile form . Figure 3 shows the document hierarchy as presented in MP-TRUW-8.13, Revision 24. AMWT P manages wastes from various sources, including offsite wastes, IN L wastes and AMWTP-generate d wastes. AMWTP assembles AK data for all of these sources and writes ge nerator-site-specific AK su mmary reports for each waste facility of origin. AMWTP also typically prepares AKSRs for each waste stream but may not require AKSRs for a waste popul ation that is to be included in the supercompacted waste stream. Instead, AMWTP integrates the wast e into the BN510.1 AKSR by acceptable item description codes (IDCs) and updates the “A cceptable Knowledge Baseline Document for AMWTP Waste” (RPT-TRUW-06) and “Acceptable Knowledge Summary for Supercompacted Debris Waste (BN510.1)” (RPT-TRUW-83) accordingly.

AMWTP’s AK approach is adequate because it serves the broad scope of the AMWTP mission. Notable AMWTP AK elements include the following:

 Acceptable Knowledge Experts (AKEs) are no t required to maintain drum lists that document initial waste stream populations. Dr ums are identified individually and placed into existing waste streams, but upon request AMWTP can determine candidate populations that are assi gned to waste streams.

 AMWTP prepares an AK resolution ledger that documents AK measurement and other discrepancies and the resolution of those issues.

 AMWTP does not generate generator-sit e-specific summary AK reports (AMWTP sometimes refers to these reports as “baselin es”) for waste characterized but not profiled by AMWTP, such as INL-CCP waste transferred to AMWTP for RCRA characterization. However, AK information about the waste st ream is included in an “AMWTP Offsite Waste Stream Profile” (Form 1900) create d by the generator site (e.g., Reference P861A).

 AMWTP divides AK information into differe nt documents rather than include all information in a single document. As s hown in Figure 3, AMWTP prepares RPT-TRUW05, “Waste Matrix Code Reference Ma nual”; RPT-TRUW-06, “AMWTP Baseline AK for Newly Generated Waste”; RPT-TRUW-07, “Determination of Radioisotopic Content in TRU Waste Based on Accep table Knowledge”; and RPT-TRUW-12, “AMWTP Waste Stream Designations.” For the evaluation of th e history of a given dr um or waste stream, any of these documents may include pertinen t information and all provide information

included in waste stream AKSRs. For ex ample, RPT-TRUW-83 is the AKSR for the BN510.1 waste stream, which is supporte d by the site summary AMWTP AK Report

RPT-TRUW-06.

EPA determined that the procedures examin ed continue to adequately address waste management. Procedure MP-TRUW-8.13, Revision 24, adequately documents the AMWTP AK waste characterization process.12 Figure 3. Document Hierarchy and Informatio n Flow for AMWTP Acceptable Knowledge Collect, Review and Summarize

Documents for AK Record Published (P) Unpublished (U) Correspondence (C)

Discrepancies (D) AK Resolutions (AKRs)

Evaluate and Compile into AK Baseline Documents (by Generator) RPT-TRUW-04 (BC) RPT-TRUW-06 (BN) RPT-TRUW-13 (MD) RPT-TRUW-56 (RF) RPT-TRUW-79 (MFC)

RPT-TRUW-82 (RL)

RPT-TRUW-12, Waste Stream Designations Documents WIPP-approved

waste streams, identifies chemical constituents, and documents HWN assignment. RPT-TRUW-07,

Determination of Radioisotopic Content Based

on AK Provides radioisotopic information per generator. Used

for validation and reconciliation. RPT-TRUW-05,

WMC Reference Manual Assigns waste to summary categories, WMC groups, and WMCs. Provides physical form

and packaging descriptions.

Includes TRUCON Code assignments. Used by validators and operators.

AK Summary for Waste Stream of AK Summary for Sufficiency Determination Requests

Prepared by AMWTP

Waste Stream

Profile/Characterization Information Summary

Prepared by AMWTP Review and

Evaluation

Characterization

Data

Source: Reproduced from MP-TRUW-8.13, Revision 24, Figure 1.13 (4) Waste traceability was ad equately demonstrated.

EPA evaluated the traceability of supercompact ed waste stream BN510.1 drums as well as the traceability of two cemented wastewater sludge drums (BN-836) that or iginated at the Mound Site and were direct shipped by AMWTP to the WIPP (References RPT-TRUW-63, Revision 6, and RPT-TRUW-83, Revision 2). EPA intended to trace containers from the MFC and Argonne National Laboratory-East (ANLE) waste populati ons that were the subject of an ongoing T1 evaluation (T1 approved January 29, 2013; see EP A Docket No. A-98-49, II-A4-169). However, AMWTP representatives indicated they were no t prepared to provide complete information

about these wastes at the time of the AK con tinued compliance inspection held in October 2012. EPA agreed to accept traceability informa tion for the BN510.1 and BN-836 waste streams because they represent ongoing supercompacted and uncompacted waste populations that are being characterized and shipped from AMWTP.

EPA asked whether drum-specific data are avai lable on a container ba sis, including waste travelers or other information generated pr ior to AMWTP waste characterization. AMWTP representatives do not have ready access to any original waste trav elers or similar container data created by the generator site, but information from these data sources ar e input into the IWTS database. The IWTS is readily accessible and is the starting point for waste characterization. AMWTP provided IWTS printouts that present hi storical waste information (Reference IWTS Drum Screen Shots). AMWTP AKEs use the IWTS to identify containers or waste groupings by

IDC. The AKEs then evaluate the IDCs to determ ine if the containers ar e associated with an identified generator-site-specific summary AK report or waste stream AKSR or if the containers may be added to BN510.1 (only debris waste ar e eligible for supercompaction). AKEs input

container data into the WTS at the start of the waste management process, and AMWTP personnel update the WTS as characterization progresses.

As indicated in Item (3), container management and movement from storage or a generator site

to AMWTP is documented on several forms that ar e specific to the origin and type of waste being transferred to AMWTP. EPA examined several examples of drum traceability through

review of IWTS data and AMWTP forms that documented drum history to and through the AMWTP. The following example presents the tr ansfer of ANLE waste (shipment AEIN1101) to and through AMWTP, as documented on various forms that were completed in the order listed.

 Form 1904, “Offsite Waste Generato r Container Certification.” Each container of waste is accompanied by a Form 1904, insuring that:

o Each drum (55-gallons or larger) to be received at AMWTP contains at most 200 fissile gram equivalent (FGE) plutonium-239 (Pu 239 ), including at least one

standard deviation error level.

o Each crate or box to be received at AMWTP contains at most 325 FGE Pu 239

, including at least one standard deviation.

 Form 1905, “Offsite Waste Receipt Payload Verification Checklist.” Payload shipments

from offsite facilities to AMWTP are documented on Form 1905. Accompanying the checklists are many forms documenting tran sportation equipment inspections, land14 disposal restriction manifests, and othe r inter-site shipment and transportation requirements. These may include a package receipt checklist.

 Form 1901, “Non-AMWTP Generato r Waste Fingerprinting.” Waste that is shipped to AMWTP from off site and accompanied by a Form 1900, “AMWTP Offsite Waste Stream Profile,” may be randomly selected per the AMWTP Waste An alysis Plan (WAP) to undergo waste fingerprinting by non-WIPP pr ogram RTR to verify waste contents. Completion of adequate fingerprin ting is documented on a Form 1901.

 Form 1915, “Offsite Waste Generator Shipment Acceptance Checklist.” Form 1915 is completed prior to waste acceptance at AMWT P. The form verifies that the accepted waste is certified by the offsite generator a nd that he necessary forms and checks were performed.

EPA examined several example forms to ev aluate waste transfer and management documentation. Although the use of forms is very complex, the traceability examples examined by EPA show that drums and shipments can be traced from the generator to AMWTP.

Table 3 lists the waste characte rization batch data reports (BDR s) provided to EPA for review.

Table 3. Batch Data Reports

Drum RTR BDR No. VE BDR No. NDA BDR No.

Waste Stream BN 510.1 BN10421829 (puck drum), containing: 10422232, 10422344, 10422345,

10422354 Not applicable VEB11-00835

VEB11-00837 ASY11-02056

ASY11-02060

Waste Stream BN510.1 BN10430658 (puck drum), containing:
10430617, 10430671, 10430674, 10430681, 10430685, 10430686 Not applicable VEB12-00021

VEB12-00020 ASY12-00076

ASY12-00077

ASY12-00078

Waste Stream BN510.1 BN10452423 (puck drum), containing: 10452385, 10452372, 10452244,

10452162 Not applicable VEB12-00649

VEB12-00650

VEB12-00651

VEB12-00649 ASY12-02195

ASY12-02201

Waste Stream BN836

10123139 RTR06-00548 Not applicable ASY06-03161

Waste Stream BN836

10059943 RTR06-00062 Not applicable ASY06-08194

EPA also examined IWTS information for select containers in Table 3 (Reference IWTS Drum Screen Shots). WTS screen shots show that information for both the feed drums and supercompacted waste is included in the IWTS database, as well as information for individual

BN-836 containers. The BDRs and IWTS inform ation adequately demonstrate that waste movement is adequately captured in the IWTS database. AMWTP has adequately demonstrated container traceability.15 (5) The waste defense determination and exclusion of spent nuclear fuel and high-level waste was examined and found to be adequate.

AMWTP provided generator-site-specific summary AK reports (e.g., RPT-TRUW-06, RPTTRUW-13) and AKSRs that addressed defense de termination and the absence of high-level waste (HLW) and spent nuclear fuel (SNF). However, AMWTP adds waste by IDC to the BN510.1 waste stream, and there were no documen tation or procedures ensuring that AMWTP representatives reviewed the IDCs to confirm that the waste was defense in origin and excluded

HLW and SNF. EPA documented this as a concern requiring a res ponse, AMWTP-CH-CC-AK12-001CR (see Attachment F).

EPA requires that AMWTP document additional anal yses or evaluations performed to ensure

that the IDCs to be included in the BN510.1 wa ste stream meet the Land Withdrawal Act (LWA) requirements of being defense in origin and ex cluding HLW and SNF. EPA discussed options to accomplish this with AMWTP AK personnel, who acknowledged EPA’s concern about the need

for additional documentation that the waste in question meets LWA restrictions on a case-bycase basis.

AMWTP proposes to have the AK group prepar e a memorandum documenting the evaluation performed on each new IDC to be included in the BN510.1 waste stream. The memo to file will document that the IDCs meet the requirements of the LWA restrictions wi th respect to defense waste, SNF and HLW. The memo to file will be submitted to AMWTP document control records and will be included as a reference suppor ting the AKSR for the BN510.1 waste stream.

The new evaluation requirement was included in Procedure LST-RTQP-03-IM, Revision 0, December 2010. The response to the concern is adequate.

(6) Acceptable knowledge personnel training was examined and found to be adequate.

EPA examined AK training records for Steve Carpenter, Tim Venneman and Randy Morris. AMWTP provided information from the AMWTP training database, specifically, the field printout titled “QCAKE01A – Acceptable Know ledge Expert, Employees by Qualifications / Certifications.” The training database is used to document individual training status and to ensure that each individual is up to date on require d training and reading. AMWTP and EPA examined

the online database and verified that the AKEs were up to date on critical reading, including AKSRs such as RPT-TRUW-83, Revision 2 (W aste Stream BN510.1), as well as MP-TRUW8.1, Revision 22, and MP-TRUW-8.2, Revision 16. The database did not indicate that training specifically about the WIPP WAP and WI PP Waste Acceptance Criteria (WAC) 8 was conducted, but AKEs are required to be up to date with MP-TRUW-8.1 and MP-TRUW-8.2, which contain WAC and WAP requirements, resp ectively. Therefore, EPA determined that training to these important documents is taking pl ace. Training was up to date at the time of the AK portion of the continued compliance inspection.

8 DOE CBFO, “Transuranic Waste A cceptance Criteria for the Waste Isolation Pilot Plant,” DOE/WIPP02-3122, Revision 7.2, Carlsbad, New Mexico, June 13, 2011.16 Summary of Acceptable Knowledge Findings and Concerns

EPA did not identify any findings for AK at AMWTP. EPA generated a concern requiring a response, AMWTP-CH-CC-AK-12-001CR (reproduced in full in Attachment F), for verification of IDC-specific LWA compliance within the s upercompacted waste stream, Waste Stream BN510.1. AMWTP adequately addressed this concern on February 21, 2013.

Acceptable Knowledge Approval

Based on the results of this evaluation and the data examined, EPA determines that AMWTP

demonstrated continued AK ch aracterization compliance.

6.2 Nondestructive Assay

EPA had approved the four IWAS NDA systems initially during the ba seline inspection and again at an unannounced continued compliance inspection in 2010. The systems’ abilities to perform the required analyses had been demonstr ated during the baseline and confirmed by the continued compliance inspection. Accordingly, this inspection focused on the following:

 Confirming that the design and technical cap abilities of both NDA systems’ hardware and software had not changed since EPA’s last inspection.

 Adequacy of the current revisions of th e AMWTP NDA procedures and documents.

 Operational and maintenance history of the NDA systems since the last EPA inspection.

 Knowledge, understanding and training status of AMWTP NDA personnel.

Technical Evaluation

EPA inspected four AMWTP NDA systems used to characterize TRU wastes: two Z-211 systems, Units 102 and 103 located in Buildi ng 634; and two Z-390 systems, Units 100 and 101 located in Building 676. All four systems are essentially identical, although there are important operational distinctions between the Z-211 and the Z-390 systems. EPA evaluated and approved all four systems for characterizing TRU wastes at AMWTP previously (see Docket No.A-98-49, Item A4-53), although the approvals for the tw o Z-211 systems included SCG S5000 debris and S3000 solids, while the two Z-390 systems were approved for S5000 debris only. Because these systems were extensively evaluate d during previous EPA inspections , the focus of this inspection emphasized operational aspects that occurred with in the last year. Specifically, EPA reviewed the following elements of the NDA process for all four IWAS units:

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

for the radionuclides and wastes of interest.

 Technical adequacy of the NDA docum ents, procedures and controls.

 Knowledge and understanding of the pe rsonnel involved in the NDA program.

 Performance indicators relevant to the past year’s operation.17 The modified NDA checklist used for this evalua tion is included as Attachment E.1 to this report. This checklist cont ains specific details that supplement the text below.

(1) The design and operational history of IWAS Units Z-211- 102, Z-211-103, Z-390-100 and

Z-390-101 were assessed and were found to not have changed since previous EPA

evaluations.

The IWAS Units Z-390-100 and Z-390-101 systems are identically designed NDA systems that combine passive-active neutron assay techniques with gamma spectrometry in a single system. The active neutron assay mode for each IWAS ha d been disabled in 2010 for operational reasons

and EPA confirmed that this was stillo the case fo r all four systems. These systems are designed to quantify the radiological components of TRU waste in 55-gallon drums, and the Z-211 systems also assay 55-gallon and 83-gallon overpack s. All four systems are capable of assaying a variety of waste matrices, including, but not limited to, combustibles, glass, organic and inorganic sludge, and metals. However, the Z-390 systems are limited to assaying only debris (SCG S5000) wastes, while the Z-211 systems a ssay debris and solids (SCG S3000). Because of the multimodal system design and the ability to correct for matrix effects on both the gamma and neutron measurement elements independently, thes e systems are essentially matrix-independent within the range of demonstrated app licability for each measurement technique.

There were no substantive changes in the opera tional aspects of the four AMWTP IWAS NDA

systems.

(2) System calibrations for IWAS Units Z-211-102, Z-211-103, Z- 390-100 and Z-390-101 had been performed and documented as required.

Canberra Industries calibrated all four IWASs prior to their shipment to AMWTP. The calibration of each system was verified and documented in the site acceptance reports, CI-IDA-NDA-0051 through CI-IDA-NDA-0054. There we re no substantive changes to the

calibrations of the four IWAS NDA systems.

(3) The total measurement uncertainty of assays performed on IWAS Units Z-211-102, Z-211-103, Z-390-100 and Z-390-101 has been determined and documented.

The determination of total measurement uncertainty (TMU) for all four IWAS units is documented in CI-IDA-NDA-0055, “Total Measuremen t Uncertainty for the AMWTP Integrated Waste Assay Systems,” Revision 1, July 30, 2003. Th is document was evaluated in detail during previous EPA inspections and has not been changed or modified; it addresses all major components of TMU. Uncertainties for the pa ssive neutron mode included those due to calibration, counting statistics, matrix/source distribution effect s and elevated backgrounds due to high Z matrices. For the active neutron m ode, uncertainties due to calibration, counting statistics, matrix/source distribution effects, ne utron multiplication and self-shielding were also included. Uncertainties for the gamma-ray mode included those due to calibration, counting statistics, self-absorption, matrix heterogeneit y and source heterogeneity. The uncertainty due to the measurement of isotopic ratios was also included.18 (4) The lower limit of detection, including the mi nimum detectable con centration, of IWAS Units Z-211-102, Z-211-103, Z-390-100 and Z- 390-101 has been determined and

documented.

The lower limit of detection (LLD) is defined as that level of radioactivity th at, if present, yields a measured value greater than the critical level with a 95% probability, wh ere the critical level is

defined as that value which measurements of the background will exceed with 5% probability. The LLD is a strong function of both the backgr ound and the efficiency of the system. The

NDA-2000 software calculates the LLD and the mi nimum detectable concentration (MDC) for each assay based on the background and efficiency a ssociated with that particular measurement.

AMWTP determined nominal LLDs and MDCs for a variety of matrices for the active neutron, passive neutron and gamma mode s by assaying surrogate drums of those matrices with no radioactive sources present. Ma trices used for the active and passive neutron modes included combustibles, metals, glass, and inorganic a nd organic sludge. For th e gamma mode, the LLD

and MDC were estimated for four matrices va rying in density from 0.0284 to 1.58 grams per

cubic centimeter. The nominal values were reported in the site acceptance reports, CI-IDA-NDA-0053 through CI-IDA-NDA-0054, and EPA inspection team personnel confirmed that they were unchanged since the previous EPA inspection.

(5) Several nondestructive assay batch data re ports generated by the Z-211 and Z-390 IWAS systems were reviewed and were found to be adequate.

Attachment E.1 provides a list of specific BDRs that EPA evaluated for each assay system. EPA found that radioassay data sheets for the BDRs generally contained all of the necessary information, i.e., radionuclide c ontent, uncertainty, to tal TRU alpha activit y, other calculated (derived) quantities, proper identification of me asurement system and technique, and the use of measured isotopic ratios or defa ult isotopic ratios. Using a hand-he ld calculator that had been programmed prior to the inspec tion, the EPA inspector spot-checked several aspects of the radionuclide information provided on all of the ra dioassay data sheets in each BDR, specifically, the following items:

 Conversion from activity in curies to mass in grams for americium-241 ( 241 Am), 238 Pu,

239 Pu and 240 Pu, based on the stated specific activity of each radionuclide.

 TRU alpha activity concentrati on (curies per gram), based on a simple arithmetic sum divided by the container’s ne t weight in kilograms.

 Correlation of cesium-137 ( 137 Cs) and strontium-90 ( 90 Sr), when applicable, evaluated relative to AMWTP’s stated approach for de riving these quantities as documented in AMWTP-RPT-TRUW-03, Revision 8, Section 3.1.

 Correlation of uranium-234 ( 234 U) to 238 U and/or 235 U, when applicable, evaluated relative to AMWTP’s stated approach for de riving these quantities as documented in AMWTP-RPT-TRUW-03, Revision 8, Section 3.1.

No errors were found in any of these calculations.19 Summary of Nondestructive Assay Findings and Concerns

EPA did not identify any findings or concerns for NDA at AMWTP.

Nondestructive Assay Approval

Based on the results of this evaluation and the data examined, EPA determines that AMWTP demonstrated continued NDA complian ce for all four IWAS NDA systems.

6.3 Real-Time Radiography

EPA evaluated AMWTP’s continued compliance with EPA-approved RTR procedures for CH

waste characterization.

Technical Evaluation

(1) Real-time radiography examination of a drum was observed and found to be adequate.

On October 30, 2012, EPA observed the RTR examination of Drum No. 10306633 from BDR

No. RTR12-00136 9 during the onsite visit to the AMWTP facility. The operator performed the necessary equipment checks prior to EPA’s arriva l. EPA observed the entire RTR examination of the drum, including generation of the written and audiovisual record s. Waste items were identified by the operator on the audiovisual reco rding and entered electronically into RTR data sheets. The operator used Procedure INST-OI- 12 to guide the examination. This procedure includes detailed operational instructions and ta bles for waste item weights and prohibited items. The EPA inspector determined the procedure to be adequate and effective for generation of compliant RTR data. EPA reviewed a list of qua lified individuals and determined that the operator performing the demonstrated RT R examination was pr operly qualified.

(2) Real-time radiography operating records we re examined and found to be adequate.

EPA reviewed written and audiovisual RTR data generated by AMWTP for waste drums reported in BDR Nos. RTR11-00414, RTR12-00 029 and RTR12-00127. The waste described in these three BDRs was debris of various type s with Waste Matrix Codes of S5112, S5123, S5300, S5410, S5490 and S5900. EPA reviewed in detail th e recordings and writ ten records for the following containers:

 Container Nos. 10371838, 10368990, 10006014 and 10006114 from BDR No. RTR11-

00414.

 Container No. 10104637 from BDR No. RTR12-00127.

EPA found that changes to written RTR BDRs th at the Independent Tech nical Reviewer (ITR) identifies as necessary are not always made by the original RTR operator. For example, the original RTR operator for Container No.10006001 (from BDR No. RTR11-00414) was Cindy

9 EPA did not examine BDR No. RTR12-00136 during this inspection because AMWTP is still compiling

the record.20 Tiegs, but a different RTR opera tor (Edwin Oldham) revised the BDR as requested by the ITR. The operator making the changes requested by the IT R is not required to review the RTR records (including the DVD) before making the changes. EP A asserts that changes to original records should be made by the original operator whenever po ssible and that this step should be integrated into an applicable procedure. If changes are ma de by a different operator, that operator should be required to review the original da ta to ensure that he or she co ncurs with the requested change for which he or she is taking responsibility. EPA discussed the issue with AMWTP personnel and formalized it as a concern requiring a res ponse on EPA Inspection Is sue Tracking Form No. AMWTP-CH-CC-RTR-12-002CR, part (a) (s ee Attachment G). AMWTP responded by proposing a “tail gate training” fo r all RTR operators to reinforce the expected ways to process changes and the importance and meaning of signing certification information. EPA found AMWTP’s response to adequate ly address the concern.

EPA also identified three items that were minor in nature or one-time occurrences and brought them to the attention of AMWTP personne l and management during the inspection:

 Weights of containers are recorded on da ta sheets to three decimal places (e.g., 169.285 pounds). It is unlikely that the scale used to weigh containers can achieve this level of accuracy; therefore, EPA asked AMWTP pers onnel to investigate this practice and change how weights are recorded if necessary.

 A nonconformance report (NCR) is written agai nst RTR operators who fail to identify a prohibited item during normal operations. AMWT P’s procedure allows an operator three separate misses of prohibited items in a year before a corrective acti on request is written and a complete root cause analysis is perfor med. At the end of each year, the counter is restarted at zero for the next year. EPA considers any miss of a prohibited item as a potentially serious occurrence and will refer this matter to EPA quality assurance for

further consideration. 10

 A single occurrence of an operator not making a complete inventory of waste items in a drum (BDR No. RTR11-00414, Container No. 10371838) was identified. This

occurrence was not written as a concern beca use the final waste material parameters recorded by the operator were correct even though waste items were not identified individually.

EPA asked AMWTP to consider the above when reviewing RTR operations or making changes to current practices. EPA requires that CBF O notify EPA how AMWTP has addressed these three minor issues as part of AMWTP’s submi ssion of T2 changes for the current quarter.

EPA’s review determined that appropriate AMWTP RTR personnel had performed the required quality control examinations (i.e., an independent observation and replicate scan) for the BDRs examined by EPA. The BDR also provided documen tation that the data were reviewed at the data generation and Site Projec t Manager levels; the reviews we re recorded on the appropriate

10 Zeroing the count annually is a minor issue. EPA considers it a major issue that AMWTP’s quality assurance program allows operators to miss up to three pr ohibited items before taking action. This issue will be referred to EPA’s quality a ssurance program for further consideration because AMWTP’s quality assurance program is outside the scope of this continued compliance evaluation.21 forms from MP-TRUW-8.8 and 8.9. In general, pr ohibited items found in the BDR containers were properly identified, recorded and processed.

AMWTP initiated NCRs as required in response to prohibited items and the presence of lead

liners in containers. EPA review ed several NCRs, including:

NCR No. Nonconformance

14196 Lead-lined container 70583 Sealed container greater than four liters 67219 Impenetrable object

67218 Lead-lined container 67188 Liquids

EPA found all NCRs to be acceptable.

(3) Real-time radiography training records were examined and found to be adequate.

EPA reviewed training records, both written a nd audiovisual, for the operator performing the RTR demonstration and one other operator. EPA found that RTR operators are not required to identify all waste items in CH test containers for the biannual demonstration of capability. Test containers include items required by the WIPP WAC plus other material added to fill the

container. The success of this demonstration of capability is based on identification of WACrequired items only. While this demonstrati on may be sufficient for WAC compliance,

identification of 100% of the c ontainer’s inventory is required to demonstrate an operator’s ability to determine the cellulosics, plastic and rubber content of waste to be emplaced in the repository. This step should be integrated into the training criteria for RTR operators. EPA discussed the issue with AMWTP personnel and fo rmalized it as a concern requiring a response on EPA Inspection Issue Tracking Form No. AMWTP-CH-CC-RTR-12-002CR, part (b) (see Attachment G). AMWTP agreed to revise pr ocedure MP-TRUW-8.39 to incorporate estimation of waste material parameters (WMPs) a nd to revise the AMWTP RTR Bi-Annual Drum Qualification Package to inco rporate estimation of WMPs. EPA found AMWTP’s response to adequately addre ss the concern.

EPA determined that operators were trained in accordance with AMWTP procedures and that training records were readily available for review.

Summary of Real-Time Radiography Findings and Concerns

EPA did not identify any findings for RTR at AMWTP. EPA generated a concern requiring a response, AMWTP-CH-CC-RTR-12-002CR, parts (a ) and (b) (reproduced in full in Attachment G), for RTR training and operati ons. AMWTP adequately addresse d this concern on February 26, 2013. EPA also raised three minor issues disc ussed in Item (2) above. EPA requires CBFO to notify EPA of how AMWTP has addressed these three minor issues as part of AMWTP’s submission of T2 changes for the current quarter.22 Real-Time Radiography Approval

Based on the results of this evaluation and the data examined, EPA determines that AMWTP demonstrated continued RTR compliance with 40 CFR Part 194 for all evaluated systems.

6.4 Visual Examination

EPA evaluated AMWTP’s continued compliance with EPA-approved VE procedures for CH

waste characterization.

Technical Evaluation

(1) Box-to-drum visual examination operations were observed and found to be adequate.

On October 30, 2012, EPA observed box-to-drum VE operations in Room 231, north box-line, of Building WMF-676. Two VE operators sorted waste from Container No. 10212582, IDC RF 481, for packaging in 55-gallon drums. EPA observ ed packaging and VE of a cellulosics drum, No. 10467335, from BDR No. VEB12-00983. The VE was performed in accordance with Procedure INST-FOI-17, “Facility Visual Examin ation Operations.” One operator controlled the Brokk arm and manipulated the waste while the othe r operator electronically entered data into the WTS. At the end of packaging, both operato rs verified the data entry and electronically signed off the data sheet. The VE operations were adequately performed according to procedure.

(2) Visual examination operating records were examined and found to be adequate.

VE at AMWTP is performed by two operators, and no audiovisual reco rd is required. EPA reviewed paper BDR Nos. VEB12-00732, VEB1 2-00758 and VNC12-00156. Data sheets were completed as required and signed by two operators. All BDRs had been reviewed by appropriate VE personnel at the data generati on and project level, and review checklists were completed as required. There were no NCRs associated with these BDRs. EPA found these BDRs to be appropriately prepared

(3) Visual examination training records were examined and found to be adequate.

EPA reviewed QPVE0001, “Visual Examiner, Empl oyees by Qualificatio ns/Certifications,” dated October 16, 2012, and verified that the VE operators perf orming the demonstration were qualified. Both operators were included on the lis t of qualified individual s. EPA reviewed the “QCITR0VE – Level 1 Validation ITR VE” list to ve rify that ITRs performing review of BDRs VEB12-00732, VEB12-00758 and VNC12-00156 were qualified. The EPA inspector also reviewed requalification packages for two VE operators and determ ined that the packages were complete and signed as required.

Summary of Visual Examination Findings and Concerns

EPA did not identify any findings or concerns for VE at AMWTP.23 Visual Examination Approval

Based on the results of this evaluation and the data examined, EPA determines that AMWTP demonstrated continued VE compliance with 40 CFR Part 194 for all evaluated systems.

7.0 FINDINGS AND CONCERNS

There were no findings identified during this continued compliance inspection. The EPA inspection team identified one concern relate d to AK and one concern related to RTR as performed by AMWTP. These concerns are di scussed in sections 6.1 and 6.3 above and are provided in Attachments E and G, respectively.

8.0 CONCLUSIONS

Changes to Tiering

There are no changes to the T1 or T2 designations in any waste characterization area as a result of this inspection.

Approval

The EPA inspection team determined that the AMWTP waste characterization program activities continue to be technically ad equate. EPA is not proposing an y changes to the AMWTP waste characterization program at this time. The scope of the compliance decision is based on EPA’s inspection completed October 30–N ovember 1, 2012, and February 26, 2013.

Section 6.3, Item (2), discusses th ree items related to RTR that we re minor in nature or one-time occurrences which EPA brought to the attenti on of AMWTP personnel and management during the inspection. These relate to the reporting of c ontainer weight, reporting of prohibited items in a nonconformance report and an incomplete invent ory of waste items in a drum subjected to RTR. During the inspection, EPA asked that AMWTP consider these minor observations and make changes to current practices. EPA re quires CBFO to notify EPA of how AMWTP has

addressed these three minor issues when s ubmitting AMWTP’s quarterly T2 change for the

current quarter.A-1ATTACHMENT ATiering of Transuranic Waste Characterization Processes Implemented by theAdvanced Mixed Waste Treatment Project(Based on March 28–30, 2006, Baseline Inspection, Revised February 2011)Process ElementsAMWTP T1 ChangesAMWTP T2 ChangesaAK includingLoad ManagementAny new waste categoryChanges to WDS algorithms specific to loadmanagementNotification to EPA upon the following:-Changes in load management status of approved waste stream(s)-Availability of WSPFs, including updates or additions to waste stream(s)within an approved waste category-Changesbto site procedures requiring approvals by CBFO and otherchanges as discussed in Section 8.1 of the baseline reportNDA New equipment or physical modifications to approvedequipmentcChanges to approved calibration range for approvedequipmentNotification to EPA upon completion of changes to software for approvedequipment, operating range(s), and site procedures that require CBFO approvaland other changes as discussed in Section 8.2 of the baseline reportRTR There are no T1 changes at this timeNotification to EPA upon the following:-Implementation of new equipment-Modificationcto approved equipment-Changes to site procedures requiring CBFO approvals and other changes asdiscussed in Section 8.3 of the baseline reportVE Performance of VE by a different vendor Notification to EPA upon the following:-Addition of new waste category-Addition of new procedure or site equipment identifier-Changes to site procedures requiring CBFO approvals and other changes asdiscussed in Section 8.4 of the baseline reportWWIS/WDS There are no T1 changes at this time Notification toEPA upon changes to site procedures requiring CBFO approvalsand other changes as discussed in Section 8.5 of the baseline reportaUpon receiving EPA approval, AMWTP will report all T2 changes to EPA at theend of each fiscal year quarter. Note: EPA may request specific T2 change items before theend of a fiscal quarter.b“Substantive changes” means changes with the potential to impact the site’s waste characterization activities or documentationthereof, excluding changes that are solely relatedto ES&H, nuclear safety, RCRAor are editorial in nature.cModifications to approved equipment include all changes with thepotential to affect NDA and/or RTR data relative to waste isolation and exclude minor changes, such as theaddition of safety-related equipment.B-1 ATTACHMENT B

APPROVAL SUMMARY FOR AMWT P CONTACT-HANDLED WASTE

CHARACTERIZATION PROGRAM

Specific AMWTP CH Approval Date EPA Docket Number

AMWTP CH Baseline Approval October 2006 A-98-49; II-A4-66

T1 Change – Addition of Four Hanford Legacy Debris Waste Streams to the BN510 Super-Com pacted Debris Waste Stream June 2010 A-98-49; II-A4-127

Unannounced Continued Compliance Inspection March 2011 A-98-49; II-A4-143

T1 Change – Addition of ANLE-generated SCG S3000 and S5000 CH Waste and MFC-generated SCG S5000 CH Waste January 2013 A-98-49; II-A4-169C-1 ATTACHMENT C

LIST OF DOCUMENTS REVIEWED BY EPA DURING CONTIN UED COMPLIANCE

INSPECTION

1995 Settlement Agreement: Overview & FAQs, Id aho Department of Environmental Quality, http://www.deq.idaho.gov/inl-oversight/oversight -agreements/1995-settlement-agreement.aspx, accessed February 15, 2013

Acceptable Knowledge Ledger, Advanced Mixed Waste Treatment Project, printed October 9,

2012

Advanced Mixed Waste Treatment Project webs ite, http://amwtp.inl.gov, ac cessed February 15,

2013

AMWTP Form 1066, TRU Waste Management AK Checklist Mound Laboratory (Draft), printed October 10, 2012

AMWTP Form 1070, Acceptable Knowledge Reso lution (AKR) Checklist, ICD RF-337, AKR12-735, January 4, 2012

AMWTP Form 1084, AK Source Document Re ference List, printed October 10, 2012

AMWTP Form 1727, Non-AMWTP Ge nerator Shipping Request, ID-ICP-MFC-Gloves, March
20, 2011

AMWTP Form 1736, AMWTP Safety Basis Radio active Material Waste Acceptance Criteria Calculator, ANLE Inorga nic Sludge, April 13, 2011

AMWTP Form 1900, AMWTP Offsite Waste Stream Profile, ID-ICP-MFC-Gloves, Revision 0, February 21, 2011

AMWTP Form 1901, Non-AMWTP Generator Waste Fingerprinting, Argonne National Laboratory AEIN1101, October 12, 2011

AMWTP Form 1904, Offsite Waste Ge nerator Container Ce rtification, Containers for Shipment AEIN1101, September 28, 2011

AMWTP Form 1905, Offsite Waste Receipt Payload Verification Checklist, AEIN1101, October
2, 2011

AMWTP Form 1915, Offsite Waste Generator Shipment Acceptance Checklist, Argonne National Laboratory AEIN1101, approved May 9, 2012

AMWTP Non-conformance Re port, dated October 1, 2012

BDR No. RTR11-00414, December 6, 2011

BDR No. RTR12-00029, March 5, 2012

BDR No. RTR12-00127, September 28, 2012C-2 BDR No. VEB12-00732, August 25, 2012

BDR No. VEB12-00758, August 31, 2012

BDR No. VNC12-00156, September 5, 2012

INST-FOI-01, In-Plant Drum Assay Operations , Advanced Mixed Waste Treatment Project, Revision 25, August 9, 2012

INST-FOI-17, Facility Visual Examination Op erations, Advanced Mixed Waste Treatment Project, Revision 25, July 11, 2012

INST-OI-12, Real-Time Radiography Operations (Drum), Advanced Mixed Waste Treatment Project, Revision 48, July 3, 2012

INST-OI-14, Drum Assay Operations, Advanced Mixed Waste Treatment Project, Revision 31, August 10, 2012

INST-OI-34, Non-Facility Visual Examination Operations, Advanced Mixed Waste Treatment Project, Revision 27, December 29, 2011

INST-OI-81, Real-Time Radiography Operations (F or WIPP Certification of Boxes), Advanced Mixed Waste Treatment Project, Revision 10, August 6, 2012

INST-TRUW-8.1.1, Drum Assay Post-Maintenan ce Calibration and Verification, Advanced Mixed Waste Treatment Project, Revision 11, January 5, 2010

IWTS Drum Screen Shots, Historic and O ngoing Waste Characterization, Advanced Mixed Waste Treatment Project, printed October 31, 2012

MP-Q&SI-5.3, Corrective Action, Revision 12, September 13, 2012

MP-Q&SI-5.4, Identification of Nonconformi ng Conditions, Revision 21, September 17, 2012

MP-TRUW-8.1, Certification Plan for INL Tr ansuranic Waste, Advanced Mixed Waste Treatment Project, Revision 22, September 12, 2012

MP-TRUW-8.11, Data Reconciliation, Advanced Mi xed Waste Treatment Project, Revision 24, September 25, 2012

MP-TRUW-8.12, Waste Receipt and Shipping Insp ection, Advanced Mixed Waste Treatment Project, Revision 22, March 30, 2010

MP-TRUW-8.13, Collection, Review, and Ma nagement of Acceptable Knowledge Documentation, Advanced Mixed Waste Treat ment Project, Revision 24, December 12, 2011

MP-TRUW-8.14, Preparation of Waste Stream Profile Forms, Advanced Mixed Waste Treatment Project, Revision 12, December 15, 2010

MP-TRUW-8.2, Quality Assurance Project Pl an, Advanced Mixed Waste Treatment Project, Revision 16, June 4, 2012C-3 MP-TRUW-8.34, WIPP Sample Transfers, Adva nced Mixed Waste Treatment Project, Revision 8, June 20, 2012

MP-TRUW-8.39, RTR Operator Proficie ncy Program, Revision 7, April 26, 2012

MP-TRUW-8.40, INL Waste Acceptance, Adva nced Mixed Waste Treatment Project, Revision 9, October 1, 2012

MP-TRUW-8.41, Offsite DOE CH-TRU Waste Accep tance, Advanced Mixed Waste Treatment Project, Revision 3, March 9, 2009

MP-TRUW-8.5, TRU Waste Certification, Adva nced Mixed Waste Treatment Project, Revision 28, September 10, 2012

MP-TRUW-8.8, Level I Data Validation, Adva nced Mixed Waste Treatment Project, Revision 32, April 25, 2012

MP-TRUW-8.9, Level II Data Validation, Adva nced Mixed Waste Treatment Project, Revision 24, August 25, 2011

Non-Conformance Report Nos. 67187, 67188, 67173, 67218, 67219, 70583, 14196, 14195 and

70586

P861A, Non-AMWTP Generator Waste Pr ofile for ID-MFC-S5490, MFC CH-TRU Heterogeneous Debris (AW-167), Roy P. Grant, AMWTP ID-MFC-S5490, April 20, 2010

QCAKE01A – Acceptable Knowle dge Expert, Employees by Qualifications/Certifications, Training Database Screenshot, October 16, 2012

QCITR0VE – Level 1 Validation ITR VE, Employ ees by Qualifications/Certifications, Training Database Screenshot, October 16, 2012

QPOT034A0 – Real-Time Radiography, Employees by Qualifications/Cer tifications, Training Database Screenshot, October 16, 2012

QPVE0001 – Visual Examiner, Employees by Qualif ications/Certifications , Training Database Screenshot, October 16, 2012

Requalification Package QPOT3A, Real Time Radiography, for two operators

Requalification Package, Visual Examination, for two operators

RPT-TRUW-03, Drum Assay Tec hnical Review Report, Advan ced Mixed Waste Treatment Project, Revision 8, June 27, 2012

RPT-TRUW-05, Waste Matrix Code Reference Manual, Advanced Mixed Waste Treatment Project, Revision 30, September 26, 2012

RPT-TRUW-06, Acceptable Knowledge Baseline Document for AMWTP Waste, Advanced Mixed Waste Treatment Project, Revision 14, July 5, 2012C-4 RPT-TRUW-07, Determination of Radioiso topic Content in TRU Waste Based on Acceptable Knowledge, Advanced Mixed Wast e Treatment Project, Revision 17, June
23, 2011

RPT-TRUW-12, AMWTP Waste Stream De signations, Advanced Mixed Waste Treatment Project, Revision 18, August 31, 2011

RPT-TRUW-13, Acceptable Knowledge Document for INL Stored Transuranic Waste – Mound Plant Waste, Advanced Mixed Waste Treat ment Project, Revision 7, July 5, 2012

RPT-TRUW-63, Acceptable Knowledge Summary for Cemented Sludge (BN836), Advanced Mixed Waste Treatment Project, Revision 6, June 27, 2012

RPT-TRUW-83, Acceptable Knowledge Summary of Supercompacted Debris Waste (BN510.1),

Advanced Mixed Waste Treatment Pr oject, Revision 2, January 31, 2012

RPT-TRUW-87, Documentation of QAPjP Test C ontainers, Advanced Mixed Waste Treatment Project, Revision 0, January 27, 2011

RTR Bi-Annual Drum Written and DVD Recor d, RTR Test Drum # 3, for one operatorD-1ATTACHMENT DINSPECTION PERSONNELNameAffiliation and Area of Expertise/FunctionOpeningMeeting10/23/12Close-outMeeting10/25/12OpeningMeeting2/26/13Close-outMeeting2/26/13InterviewedRajani Joglekar Inspector-Team Leader, EPAEd Feltcorn Inspector, EPAPatrick Kelly Technical Evaluator – NDA, SC&A, Inc.Dorothy Gill Technical Evaluator – VE/RTR, SC&A, Inc.Connie Walker Technical Evaluator – AK, SC&A, Inc.Denise Lee RTR Operator & ITR – ITG/TRU ProgramBill Huggins RTR Operator – ITG/TRU ProgramAaron Buckskin Characterization ShiftSupervisor – ITG/TRU ProgramRhett Bradford Observer – CBFO/CTACTom Morgan Observer – DOE/CBFOGina Tedford TRU Program Manager – ITG/TRU ProgramSue Peterman TRU Program Manager – ITG/TRU ProgramDenny Gaspar VE Expert, ITR – ITG/TRU ProgramNolan Jacobs VE Operator – ITG/TRU ProgramJeff Bailey VE Operator – ITG/TRU ProgramRandy Morris AK Expert – ITG/TRU ProgramTim Venneman AK Expert – ITG/TRU ProgramSteve Carpenter Site Project Manager – ITG/TRU ProgramMichael Hall Observer – CBFO/CTACMark Doherty Observer – CBFO/CTACDavid Haar Manager – ITG/TRU ProgramMark Sorenson Lead RTR ITR – ITG/TRU ProgramAngie Morse ITG QA– ITG/TRU ProgramBruce Larue DEQ INLJerry Wells DOE-IDSteve Tallman RTR SME – ITG/TRU ProgramJames Seamans NDA SME – ITG/TRU ProgramSteve Turner Engineer – ITG/TRU ProgramDavey Sumners NDA Operator – ITG/TRU ProgramCorey Boland NDA Operator – ITG/TRU ProgramE-1ATTACHMENT E.1NONDESTRUCTIVE ASSAY INSPECTION CHECKLISTEPA Inspection No.: EPA-AMWTP-10.12-24Inspection Date: February 26, 2013Technical ElementsObjective Evidence/CommentIdentify the NDA systems by name, location and numberand determine if these are the same systems in the samelocations as EPA had approved previously.The two In-Plant IWAS NDA Units Z-390-100 and Z-390-101 are located in Building 676. The twoIWAS Retrieval Units Z-211-102 and Z-211-103 are located in Building WMF-634 at AMWTP. EPAhad previously approved all four IWASNDA systems in their current locations.Establish the current operational status of all IWASs forassaying TRU waste.All four IWAS NDA systems were operational.Confirm any substantive changes to the four IWASs in thelast year with respect to activity or density operating ranges.There were no substantive changesto the four IWAS NDA systems.Identify all NDA personnel who have operated the IWASunits, performed data review or validation, or served as anExpert Analyst for the last year. Confirm that all personnelwere current on the LOQI as appropriate.AMWTP provided a comprehensive listing of all personnel qualified for drum assay operations, experttechnical review and independent technical review that was current as of February 26, 2013. This isthe AMWTP equivalent of an LOQI.Determine what maintenance events or repairs wereperformed to the four IWASs over the last year asdocumented in AMWTP records.Work Order No. 411486 documented a detector gain adjustment of the Z-390-100 IWAS on July 11,2011. Work Order No. 427738 documented a detector gain adjustment of the Z-211-103 IWAS onSeptember 11, 2011. Work Order No. 400148 documented a detector replacement on the gainadjustment of the Z-211-102 IWAS on March 6, 2012. Work Order No. 402556 documented adetector replacement on the Z-390-100 IWAS on May 10, 2012.Identify the number of waste containers that have beenassayed using the four IWAS units. Indicate how manyBDRs were assembled and indicate how many of theseBDRs have been promoted through Project-Level Review.Confirm the sample types that all four IWASs have assayedin the past year (debris and solids).For calendar year 2012, there were30,816 assay events on all fourIWAS NDA systems, which werecompiled in a total of 3,734 NDA BDRs.Confirm that the four IWAS units are able to reportquantitative values and uncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr and137Cs.All four IWAS NDA systems report quantitative values and uncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr and137Cs, as evidenced by NDA BDRs reviewed during inspection. Thefollowing BDRs were reviewed: ASY11-02568, ASY12-00374, ASY12-00642, ASY12-00776,ASY12-01969, ASY12-01595, ASY12-00915, ASY12-01508, ASY12-01434, ASY12-02030 andASY13-00110.Identify any sample conditions, interferences, radionuclidesor other aspects that are potentially problematic or requirespecific corrections forthe four IWAS units.There are no potentially problematic sample conditions or interferences that the IWASs and theAMWTP NDA personnel were not able to adequately address.Determine how many calibration verification have beenperformed on each IWASunit over the last year.Z-390-100 and Z-390-101Z-211-102 and Z-211-103E-2EPA Inspection No.: EPA-AMWTP-10.12-24Inspection Date: February 26, 2013Technical ElementsObjective Evidence/CommentIdentify any changes to the methods used to derive theisotopic contribution for the unmeasured radionuclides forthe four IWASs.There have been no changes in the manner in which the unmeasured radionuclides are quantified forthe four IWAS NDA systems.Confirm the AMWTP procedures for operation, datareduction, review and validation and expert analysis ofNDA data for all four IWASs. Establish the currentrevisions of all procedures cited.Current revisions of all procedures are as follows: INST-OI-14, Revision 31, August 10, 2012; INSTTRUW-8.1.1, 4, Revision 11, January 5, 2010; MP-TRUW-8.1, Revision 22, September 12, 2012;MP-TRUW-8.8, Revision 33, November 10, 2012; RPT-TRUW-03, Revision 8, June 27, 2012; RPTTRUW-07, Revision 17, June 23, 2011.E-3ATTACHMENT E.2REAL-TIME RADIOGRAPHY INSPECTION CHECKLISTEPA Inspection No.: EPA-AMWTP-10.12-24Inspection Date: October 30 – November 1, 2012Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentRTR-1:Site procedures identifyrequired training andqualifications for RTRpersonnelQPOT34A0RPT-TRUW-87MP-TRUW-8.39MP-TRUW-8.1Operator training was consistent with applicableprocedures.Operator certification is current.OJT was documented for each operator.Operators are requalified every two years.RTR operators passed a training drum test thatincludes items common to the waste streamsexamined at the site (biannually).Training drum contains all required items.RTR operators receive training on the wastematrix parameters and typical packagingconfigurations expectedto be found in eachwaste stream.EPA reviewed demonstration of capability RTR examinationrecordings, written records and records of requalification forselected operators. A concernrequiring a response was writtenbecause RTR operators are not required to identify all items inthe test drums, only those specified by the WAC (AMWTP-CHCC-RTR-12-002CR, part (b)).Objective evidence:1.Requalification Package QPOT3A, Real TimeRadiography, for two operators.2.RTR Biannual drum written and DVD record, RTR TestDrum No. 3, for one operator.3.QPOT034A0, Real Time Radiography, Employees byQualifications/Certifications, 10/16/12.4.RPT-TRUW-87, Documentation of QAPjP TestContainers, Revision 0, 1/27/11.5.MP-TRUW-8.39, RTR Operator Proficiency Program,Revision 7, 04/26/12.6.Concern AMWTP-CH-CC-RTR-12-002CR.RTR-2:Site procedures providecomplete instructions foroperators to perform theRTR examination andcompletion of theassociated documentationINST-OI-12,Revision 48(drums)INST-OI-81,Revision 10(boxes)RTR operator adequately explained the processfollowed for examining a drum and entering datainto data forms (whether hard copy or electronicdata entry is used).EPA observed an operator perform an RTR examination duringthe onsite inspection. The EPA inspector also reviewed theDVD recordings of various RTRexaminations that had alreadybeen through project-level review.Objective evidence:1.Container Nos. 10371838, 10368990, 10006014 and10006114 from BDR No. RTR11-00414.2.Container No. 10104637 from BDR No. RTR12-00127.E-4EPA Inspection No.: EPA-AMWTP-10.12-24Inspection Date: October 30 – November 1, 2012Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentRTR-3:The RTR proceduresrequire an image qualitycheck to be performedINST-OI-12,Revision 48(drums)INST-OI-81,Revision 10(boxes)Operator adequately explained how theacceptability of an image is determined.Image quality check is performed once per day.Performance of the image quality check isdocumented and recorded.The image quality test had already been performed at the timeof the EPA demonstration. However, the BDRs reviewed hadbeen through data generation and project-level reviews and noissues were identified for image quality.Objective evidence:1.BDR Nos. RTR11-00414, RTR12-00029 and RTR12-00127.RTR-4:The procedure allows theoperator to adjust the RTRto accommodate thephysical properties of thewaste and wastecontainers likely to beencountered at the siteINST-OI-12,Revision 48(drums)INST-OI-81,Revision 10(boxes)Operator could identify applicable policies andprocedures governing the operation of RTRequipment.The RTR system could be adjusted.High-density material was examined with the Xray device set on the maximum voltage and lowdensity material at a lower voltage.Operator adequately explained what is done if animage is unacceptable (e.g., the waste issolidified or the container is lead-lined).During the demonstration, the operator followed ProcedureINST-OI-12 to achieve a compliant examination. EPA reviewedseveral audiovisual recordings to verify operator performanceand data record generation. All ofthe recordings reviewed wereclear and easy to understand and follow.Objective evidence:1.Container Nos. 10371838, 10368990, 10006014 and10006114 from BDR No. RTR11-00414.2.Container No. 10104637 from BDR No. RTR12-00127.RTR-5:The procedures requirethat the RTR recording beof high quality, audible,complete, and accurate.INST-OI-12,Revision 48(drums)INST-OI-81,Revision 10(boxes)RTR recording is high quality, the sound track isaudible, and the required information iscontained on the audible portion of the tape.The RTR recording is consistent with the datapackage for the same drum.EPA reviewed several audiovisual recordings to verify operatorperformance and data record generation. All of the recordingsreviewed were clear and easy to understand and follow.The RTR system now has an electronic cursor on the screen thatthe operator can use to point out certain items in the container.This system appeared to workcorrectly and did not introduceany prejudice into the examination.Objective evidence:1.Container Nos. 10371838, 10368990, 10006014 and10006114 from BDR No. RTR11-00414.2.Container No. 10104637 from BDR No. RTR12-00127.RTR-6:There is a procedure fordetermining whether thewaste matches the wastestream description andWaste Matrix Code, andINST-OI-12,Revision 48(drums)INST-OI-81,Revision 10The procedure is adequately implemented.Operators verify that the waste matches thewaste stream description.Waste Matrix Code is verified. If not, correctiveaction is taken.During the demonstration, the operator followed SOP INST-OI12 to achieve a compliant examination.A single example of an operator not making a completeinventory of waste items was identified. The WMP datagenerated were correct but the operator did not identify singleitems rolled into each WMP. AMWTP management wasE-5EPA Inspection No.: EPA-AMWTP-10.12-24Inspection Date: October 30 – November 1, 2012Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/Commentfor determining WasteMaterial Parameters andweights(boxes) WMP weights are estimated by compiling aninventory of waste items and residual/packagingmaterials.Does the RTR operator use a standard weightlookup table to provide an estimate of WMPweights? If so, has the table been updated toreflect additional information gained throughprevious RTR/VE exams or updated AKinformation?informed of this occurrence.Objective evidence:1.Data sheets contained in BDR Nos. RTR11-00414, RTR12-00029 and RTR12-00127.RTR-7:The RTR procedureprovides instructions foridentifying prohibiteditems and for processingdrums containingprohibited itemsINST-OI-12,Revision 48(drums)INST-OI-81,Revision 10(boxes)Operator could name prohibited items.Operator adequately explained how the presenceof free liquids is determined.Operator’s explanation of required actions ifprohibited items were encountered wasconsistent with procedure.Corrective actions are taken when necessary.EPA observed the RTR examination of Container No.10306633 from BDR No. RTR12-00136. This was a solidswaste drum (SCG S3900, IDC RF751). The operator identifiedwaste items, entered them intoan electronic data form andchecked for the presence ofprohibited items. Prior to theexamination, the operator verified that the drum had been inBuilding WMF-634 for more than 72 hours to satisfy theequilibration requirement for drums in cold weather.Objective evidence:1.Container No. 10306633 data sheets from BDR No.RTR12-00136.2.Nonconformance Report Nos. 67187, 67188, 67173,67218, 67219, 70583, 14196, 14195 and 70586.RTR-8:RTR procedures includethe required QCexaminations, evaluationaccuracy andreproducibility of the RTRprocessINST-OI-12,Revision 48(drums)INST-OI-81,Revision 10(boxes)A replicate scan is performed on one wastecontainer per day or on one container per testingbatch (whichever is less frequent).An independent observation of one scan (not thereplicate) is performed by a qualified RTRoperator (anyone but the initial RTR operator).Each BDR reviewed containeda replicate and independentscan.Objective evidence:1.BDR Nos. RTR11-00414, RTR12-00029 and RTR12-00127.E-6EPA Inspection No.: EPA-AMWTP-10.12-24Inspection Date: October 30 – November 1, 2012Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentRTR-9:Procedures containstandardized forms forrecording RTR dataINST-OI-12,Revision 48(drums)INST-OI-81,Revision 10(boxes)RTR operator adequately explained the processfollowed for examining a drum and entering datainto data forms (whether hard copy or electronicdata entry is used).Direct data entry into an electronic form is doneby the RTR operator using a computer while theoperator is still in the RTR booth.The electronic data file undergoes the same QCchecks used for hand-written data entries.During the demonstration, the operator entered waste itemsidentified into the electronic data forms in the WTS. Theoperator made a complete audiovisual record of theexamination.Objective evidence:1.BDR Nos. RTR11-00414, RTR12-00029 and RTR12-00127.RTR-10:Site procedures requirereview of BDRs at thedata generation andproject levelINST-OI-12,Revision 48(drums)INST-OI-81,Revision 10(boxes) (Level IIData Validation)MP-TRUW-8.8,Revision 32 (LevelI Data Validation)Data-generation-level reviews are performed anddocumented.Project-level reviews are performed anddocumented.BDRs reviewed had been through data generation and projectlevel reviews. Checklists for each review were completed andsigned.Objective evidence:1.BDR Nos. RTR11-00414, RTR12-00029 and RTR12-00127.E-7ATTACHMENT E.3VISUAL EXAMINATION INSPECTION CHECKLISTEPA Inspection No.: EPA-AMWTP-10.12-24Inspection Date: October 30 – November 1, 2012Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentVE-1:Site procedures identifyrequired training andqualifications for VEpersonnel.MP-TRUW-8.1,Revision 22QPVE0001QCITR0VEVisual Examination Expert’s (VEE’s)explanation of job duties was consistent withapplicable procedures.VE personnel’s training was consistent withapplicable procedures.VE personnel’s certification is current.VE personnel are requalified every two years.VE personnel received training on specificwaste generating processes, typical packagingconfigurations, WMPs expected to be found ineach Waste Matrix Code.EPA reviewed the requalification packages for two VEoperators and also the appointment letter for one VEE. EPAreviewed the list of current VE operators and ITRs.Objective evidence:1.QPVE0001, Visual Examiner, Employees byQualifications/Certifications, 10/16/12.2.QCITR0VE, Level I Validation ITR VE, Employees byQualifications/Certifications, 10/16/12.3.Requalification Package for two visual examiners.VE-2:Procedures and technicalguidance documentsprovide completeinstructions forperforming VE.INST-OI-34,Revision 27INST-FOI-17,Revision 25The site uses AK to identify the matrixparameter category and to estimate wastematerial parameters present.Procedures are sufficiently detailed to enable theoperator to determine if a waste container meetsthe criteria of 40 CFR 194.24 with regard toidentifying applicable parameters with wastelimits.Establish standard nomenclature, based oncurrent site practice, so that all personnelrecognize waste by the same descriptors.EPA observed VE operation during the onsite visit andinterviewed an operator about data entry into the WTS.AMWTP has developed standard weights for items, and theoperator has the ability to add items as needed. EPA alsoreviewed validated BDRs to verify data entry and performanceof VE operations.Objective evidence:1.BDR Nos. VEB12-00732, VEB12-00758 andVNC12-00156.2.Procedures INST-FOI-17 and INST-OI-34.E-8EPA Inspection No.: EPA-AMWTP-10.12-24Inspection Date: October 30 – November 1, 2012Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentVE-3Procedures requireidentification of safetyhazards.INST-OI-34,Revision 27INST-FOI-17,Revision 25Prior to starting the VE, the VEE reviews alldocumented data related to the waste containerand its contents to ensurethat there are no safetyhazards for the VE operators.A VEE is available to operators on all shifts when VEoperations are being performed. The VE demonstration wasperformed by two operators and no audiovisual recording wasrequired.Objective evidence:1.BDR Nos. VEB12-00732, VEB12-00758 and VNC12-00156.2.Procedures INST-FOI-17 and INST-OI-34.VE-4:Procedure requires anaudiovisual recording ofthe VE event.INST-OI-34,Revision 27INST-FOI-17,Revision 25VEE’s/operator’s explanation of how to operatethe data recording system was consistent withapplicable procedures.The video camera was focused prior to the startof VE.An audiovisual recording is made of the wastecontainer exam and maintained as anonpermanent record.Data on the audiovisual recording are consistentwith documentation.EPA observed VE operation during the onsite visit andinterviewed an operator about data entry into the WTS. A VEEis available to operators on all shifts when VE operations arebeing performed. The VE demonstration was performed by twooperators and no audiovisual recording was required.Objective evidence:1.BDR Nos. VEB12-00732, VEB12-00758 and VNC12-00156.2.Procedures INST-FOI-17 and INST-OI-34.VE-5:There is a procedure forhandling instances whenthe VEE is unable to seethrough the inner plasticbags/packages/ containersof waste.INST-OI-34,Revision 27INST-FOI-17,Revision 25The VEE has decisionmaking criteria forassessing the need to open the bags/packages inorder 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 eachwaste type in the bags.EPA observed VE operation during the onsite visit andinterviewed an operator about data entry into WTS. A VEE isavailable to operators on all shifts when VE operations arebeing performed. The VE demonstration was performed by twooperators and no audiovisual recording was required.Objective evidence:1.BDR Nos. VEB12-00732, VEB12-00758 and VNC12-00156.2.Procedures INST-FOI-17 and INST-OI-34.E-9EPA Inspection No.: EPA-AMWTP-10.12-24Inspection Date: October 30 – November 1, 2012Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentVE-6:The VE procedurerequires verification ofWaste Matrix Code andWMP weights.INST-OI-34,Revision 27INST-FOI-17,Revision 25If an automated data entry system is used, dataentry VE personnel could navigate through thevarious screens.A VE data form is used to document the matrixparameter category and estimated WMP weightsof the waste.VE personnel have access to standardized chartsor tables to aid in the consistent estimation orassignment of weights, WMPs and waste matrixcodes.The estimated or weighed WMP weights aredetermined by compiling an inventory of wasteitems, residual materials and packagingmaterials.The items on the inventory list are sorted byWMP and combined with a standard weightlook-up table to provide an estimate of WMPweights.References tables are updated as site gainsinformation from VE.VEE verifies WMC and recommends changesas needed.EPA observed VE operation during the onsite visit andinterviewed one operator about data entry into the WTS.AMWTP has developed standard weights for items and theoperator has the ability to add items as needed. EPA alsoreviewed validated BDRs to verify data entry and performanceof VE operations.Objective evidence:1.BDR Nos. VEB12-00732, VEB12-00758 and VNC12-00156.2.Procedures INST-FOI-17 and INST-OI-34.VE-7:Procedure providesinstructions forprocessing of containerswith prohibited items.INST-OI-34,Revision 27INST-FOI-17,Revision 25Procedure provides adequate instructions forimplementationEPA has reviewed the procedures many times and determinedthat they provide complete instructions for performing VE.EPA also reviewed validated BDRs to verify data entry andperformance of VE operations.Objective evidence:1.BDR Nos. VEB12-00732, VEB12-00758 and VNC12-00156.2.Procedures INST-FOI-17 and INST-OI-34.E-10EPA Inspection No.: EPA-AMWTP-10.12-24Inspection Date: October 30 – November 1, 2012Establishment ofRequired TechnicalElements in ProceduresApplicableProcedures/DocumentationExecution of ProceduresObjective Evidence/CommentVE-8:Procedures require grossweight and volumeutilization to be recorded.INST-OI-34,Revision 27INST-FOI-17,Revision 25The gross weight of the waste container(container plus contents) is recorded on the VEdata form. Volume utilization of the container isdocumented.All required information was included on the data sheetsreviewed.Objective evidence:1.BDR Nos. VEB12-00732, VEB12-00758 and VNC12-00156.VE-9:Procedures requirecorrective actions to betaken as necessary.INST-OI-34,Revision 27INST-FOI-17,Revision 25The procedure is adequately implemented andcorrective actions are taken when necessary.No corrective actions were required for the containers in theBDRs reviewed.Objective evidence:1.BDR Nos. VEB12-00732, VEB12-00758 and VNC12-00156.VE-10:Site procedures requiredata generation andproject-level reviews ofBDRs.MP-TRUW-8.9,Revision 24MP-TRUW-8.8,Revision 32Data generation and project level reviews arecomplete.All BDRs reviewed had been validated at the data generationand project level. Checklists were completed and present in theBDRs.Objective evidence:1.BDR Nos. VEB12-00732, VEB12-00758 and VNC12-00156.2.Procedures MP-TRUW-8.8 and 8.9.F-1 ATTACHMENT F

EPA INSPECTION ISSUE TRACKING FORM,

ISSUE NO. AMWTP-CH- CC-AK-12-001CR, FINAL

Inspection No. EPA-AMWTP-10.12-24 Issue Number: AMWTP-CH-CC-AK-12-001CR

Date: November 1, 2012
Inspector: C. Walker

Attachments? YES NO Sample Size: 1 Population size (if known): Unknown

Description of Issue: AMWTP adds wastes to Waste Stream BN510.1 by Item Description Codes (IDCs), which are described in the AMWTP acceptable knowle dge baseline report. IDC BN508 feeds Waste Stream BN510.1. The AMWTP baseline report also documents that the waste, as a whole, does not contain nondefense waste, spent nuclear fuel, or high-level wa ste. However, the AMWTP baseline report may not

include sufficient information to document that each individual IDC added to BN-508 meets Land Withdrawal Act (LWA) restrictions with respect to these parameters. AMWTP must document additional analyses or evaluations performed to ensure that the IDCs to be included in BN 508 meet the LWA requirements. The EPA inspector discussed options to accomplish this with AMWTP-ITG acceptable knowledge personnel, who acknowledged EPA’s concern ab out the need for additional documentation that the waste in question meets LWA rest rictions on a case-by-case basis. B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable

D. Discussed with: Steve Carpenter, Tim Venneman, Sue Peterman

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES NO Site Response Due Date: December 1, 2012G-1 ATTACHMENT G

EPA INSPECTION ISSUE TRACKING FORM,

ISSUE NO. AMWTP-CH- CC-RTR-12-002CR, FINAL

Inspection No. EPA-AMWTP-10.12-24 Issue Number: AMWTP-CH-CC-RTR-12-002CR

Date: October 31, 2012
Inspector: D. Gill

Attachments? YES NO Sample Size: 1 Population size (if known): Unknown

Description of Issue:

a. Changes to written real-time-radiography (RTR) ba tch data reports (BDRs) that the Independent Technical Reviewer (ITR) identifies as necessa ry are not always made by the original RTR operator. For example, the original RTR operator for Container No.1006001 (from BDR No. RTR11-00414) was Cindy Tiegs, but a different RTR operator (Edwin Oldham) revised the BDR as requested by the ITR. The operator making the changes requested by the ITR is not required to review the RTR records (including the DVD) before making the changes. When changes are made to the original records, they must be accompan ied by the signature of the individual making the changes upon reviewing and concur ring with the needed change. Th at is, changes to original records should be made by the original operator whenever possi ble. If changes are made by a different operator, that oper ator should be required to review the original data to ensure that he or she concurs with the requested chan ge for which he or she is taking responsibility. This step should be integrated into an applicable procedure.

b. RTR operators are not required to id entify all waste items in contact- handled test containers for the biannual demonstration of capabili ty. Test containers include items required by the WIPP waste acceptance criteria (WAC) plus other material ad ded to fill the containe r. The success of this demonstration of capability is based on identi fication of WAC-required items only. While this demonstration may be sufficient for WAC complian ce, identification of 1 00% of the container’s inventory is required to demonstr ate an operator’s ability to dete rmine the cellulosics, plastic and rubber content of waste to be emplaced in the repo sitory. This step should be integrated into the training criteria for RTR operators. B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable

D. Discussed with: Denise Lee, Gina Tedford, Tom Morgan

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES NO Site Response Due Date: December 1, 2012