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 2013 
ii 

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 and Acceptable Knowledge Procedures ................. 10

Table 3. Batch Data Reports ......................................................................................................... 14

LIST OF FIGURES 

Figure 1. AMWTP and INL-CCP Characterization Relationship .................................................. 6

Figure 2. AMWTP Waste Management Process ............................................................................ 8

Figure 3. Document Hierarchy and Information 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 AMWTP CH Waste Characterization Program 

Attachment C List of Documents Reviewed by EPA during Continued Compliance 

Inspection 

Attachment D Inspection Personnel 

Attachment E.1 Nondestructive Assay Inspection Checklist 

Attachment E.2 Real-Time Radiography Inspection Checklist 

Attachment E.3 Visual Examination Inspection Checklist 

Attachment F EPA Inspection Issue Tracking Form, Issue No. AMWTP-CH-CC-AK-12-

001CR, Final 

Attachment G EPA Inspection Issue Tracking Form, Issue No. AMWTP-CH-CC-RTR-12-

002CR, Final
iii 

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 Technical 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 detection 
iv 

LOQI list of qualified individuals 

LWA Land Withdrawal Act 

m3

 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 Environmental 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 Authorized Methods for Payload Control 

TRU transuranic 

TRUCON Transuranic Waste Content Code 

U uranium 

VE Visual Examination 
v 

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 System 
1 

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-handled (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, EPA 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 inspection took place over two visits to 

AMWTP: (1) acceptable knowledge (AK), real-time radiography (RTR) 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 continued compliance inspection, EPA 

confirmed that the AMWTP TRU waste characterization program continues to characterize CH 

TRU waste consistent with the conditions and limitations that are discussed in the baseline 

inspection report (see EPA Docket No. A-98-49; II-A4-66). 

In October 2011, Idaho Treatment Group (ITG), a DOE Carlsbad Field Office (CBFO) 

contractor, took over AMWTP’s TRU waste characterization program from the previous 

contractor. During this transition, ITG adopted “as is” the existing CH TRU waste 

characterization program that had been implemented by the previous contractor [see Item (2), 

section 6.1 of this report], which EPA had approved via a baseline inspection in October 2006 

(See EPA Report A-98-49; II-A4-66 in EPA Air Docket). ITG also adapted relevant CH TRU 

waste characterization documents, which serve as a basis for the continued 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, Argonne National Laboratory East (ANLE) and the 

Materials and Fuel Complex (MFC). The continued compliance inspection discussed in this 

report, therefore, was necessary to determine technical adequacy of the ITG-implemented 

processes, procedures, equipment and training 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 related to RTR. Both concerns were adequately 

resolved and ITG provided supporting documentation in February 2013. In Item (2) of section 

6.3, this report discusses three items related to RTR that were relatively minor in nature or onetime occurrences which EPA brought to the attention of AMWTP personnel and management 

during the inspection. These relate to the reporting of container weight, reporting of prohibited 

items in a nonconformance report and an incomplete inventory 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 requires CBFO to notify EPA of how 

AMWTP has addressed these issues when submitting 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 October 2006 baseline inspection, the original T1 and 

T2 designations were modified as a result of two T1 change requests EPA approved in January 
2 

2013.1 Table 1 provides the current tiering requirements for AMWTP (see footnote 1). 

Attachment A provides the original tiering table, dated October 2006, that was current during the 

AK, RTR and VE continued compliance evaluations in October/November 2012. 

Based on the results of this inspection, EPA confirms its original approval of the AMWTP CH 

TRU waste characterization program, now implemented by ITG, in the configuration observed 

during this continued compliance inspection consistent with the limitations described in the 

baseline inspection report cited above and subsequent EPA T1 approvals. Attachment B provides 

a table listing all of EPA’s approvals of the AMWTP CH TRU waste characterization program. 

This report serves as EPA’s public notification of the results of the continued compliance 

inspection. This information will 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. 
3 

Table 1. Tiering of CH TRU Waste Characterization Processes Implemented by AMWT

(Based on March 28–30 and April 11–13, 2006, Baseline Inspection and Subsequent T1 Evaluations, Upd

Process Elements AMWTP CH Waste Characterization Processes – T1 Changes AMWTP CH Waste Characterizatio

Acceptable Knowledge, 

including Load Management 

Any new waste category Any waste from sources other than Mound, RFETS, Battelle 

Columbus, Bettis, ANLE and MFC 

Load management of any new or unapproved waste stream 

Notification to EPA upon completion of or 

 Site procedures requiring CBFO approv Load management status of approved w All final WSPFs with related attachmen

additions to waste streams within approradiological data for those containers in

 AK accuracy reports (annually, at a min All new and revised AKSRs and genera

reports (e.g., RPT-TRUW-79 and RPT-

 Any waste identified outside of the was

TWBIR, when applicable 

 Implementation of procedures and relat

NDA-AK communication requirements

 RPT-TRUW-05, RPT-TRUW-07 and R

Nondestructive Assay New equipment or physical modifications to approved equipment*** 

Extension or changes to approved calibration range for approved equipment 

Notification to EPA upon substantive modi

 Site procedures requiring CBFO approv Software for approved equipment  Operating ranges upon CBFO approval 

Real-Time Radiography None Notification to EPA upon substantive modi

 Site procedures requiring CBFO approv New equipment or physical modificatio

Visual Examination and Visual Examination Technique 

Changes in vendor performing VE and/or VET Notification to EPA upon: 

 Substantive modification** to site proc Addition of new waste category  Addition of new procedure or site equip

WIPP Waste Data System Changes to WDS algorithms specific to load management Notification to EPA upon substantive modi

 Site procedures requiring CBFO approv Load management status of approved w

New T1s, T2s and significant modifications to existing T1s or T2s would be in bold text; T1s or T2s that were only revised for style are not sho

* 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 waste characterization processes or documentati

are solely related to environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act, or that are editorial in 

administrative 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 cha

safety-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 baseline 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 site’s waste characterization program, based on a 

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

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

TRU wastes destined for disposal at the WIPP. 

Following EPA’s baseline approval, EPA has the authority to conduct continued compliance 

inspections to verify that the site (1) continues to use only the approved 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 decision to maintain the approval of the AMWTP 

waste characterization program for CH TRU 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 completed during the course of the inspection and 

their relevance to EPA’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 documents 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 inspection 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 baseline inspection and subsequent T1 evaluations. Waste 
5 

characterization activities evaluated included AK for Summary Category Group (SCG) S3000 

and S5000 CH waste streams, NDA systems represented by Integrated Waste Assay System 

(IWAS) units Z-390-100 and Z-390-101 and IWAS 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 conducted interviews with AMWTP waste characterization 

personnel in several disciplines. The personnel contacted represented a sample of the CH TRU 

waste characterization staff. The EPA inspection team and AMWTP personnel contacted are 

listed in Attachment D, with their affiliations and areas of expertise or function. 

6.0 TECHNICAL EVALUATION 

Sections 6.1 through 6.4 of this report detail the four technical 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 Treatment Project waste management flow and 

characterization processes were examined and found to be adequately explained. 

EPA interviewed AMWTP personnel to understand the waste characterization and waste 

management processes performed by AMWTP. The Central Characterization Project (CCP) at 

INL and the ITG program at AMWTP are both authorized to characterize CH TRU waste at INL, 

with some activities shared between the two entities. Legacy waste in storage at the INL complex 

is managed by both INL-CCP and AMWTP depending on the waste origin and storage location. 

In addition, AMWTP also operates a small-quantity-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 Recovery 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, including VE, RTR, NDA and radiological characterization. AMWTP 

does not generate an AMWTP waste profile form for any of the INL-CCP managed waste. 

Figure 1 presents the AMWTP and INL-CCP characterization relationship. 
6 

Figure 1. AMWTP and INL-CCP Characterization 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 per CCP-TP-005a

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 and waste characterization processes for waste 

profiled under the AMWTP program, including AMWTP newly generated waste,2

 legacy waste,3

offsite waste4 and waste generated at INL but outside 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 originating outside of AMWTP. 

Upon arrival, AMWTP conducts fingerprint analyses of these wastes to ensure that the waste 

accepted matches the waste manifests. Wastes that are AMWTP-generated or originate within 

AMWTP (i.e., legacy waste) do not require this manifest process. INL waste is tracked using the 

Integrated Waste Tracking System (IWTS), and AMWTP waste characterization data are input 

into the AMWTP Waste Tracking System (WTS). These systems track waste movement and 

characterization, as well as many AMWTP-specific forms as the waste is moved through 

shipment to AMWTP, acceptance, characterization 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 process 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 required for waste generated 

within AMWTP, including legacy waste in storage at INL. Once waste is accepted, AMWTP 

performs the same general waste characterization processes for all waste according to the type of 

waste managed (i.e., solid or debris) and whether the waste is to be supercompacted. INL-CCP 

packages and ships AMWTP-profiled and-characterized 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 waste includes waste that is generated as a result of 

repackaging, treatment (e.g. supercompaction), retrieval, characterization, and/or handling of retrieved or accessibly 

stored primary waste or as a result of conducting maintenance activities” (MP-TRUW-8.13, Revision 24). 

3

 “Historically stored waste containers that comprise the 65,000 cubic meters (m3) of waste outlined in the 

agreement with the State of Idaho (i.e., the ‘Batt Agreement’)” (MP-TRUW-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 transuranic waste received from an offsite waste 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 Transuranic Storage Area on the INL and received at the 

Transuranic Storage Area after September 11, 1991. [An] 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 wastea 

 Non-AMWTP INL waste 

 Offsite wastea

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 AMWTP 
9 

(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) transferred 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 (Reference 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 reviewed and accepted without major changes, 

although many procedures were later revised to address ongoing program modifications and 

updates. The Blue Sheet process allowed relatively smooth transition of activities between 

contractors and is still in progress. ITG uses previous Bechtel BWXT procedures without 

revision until the Blue Sheet review is completed. EPA agrees that the process is satisfactory and 

that Bechtel BWXT successfully transitioned procedures previously examined by EPA to the 

ITG program. 

AMWTP currently ships both compacted and uncompacted waste to the WIPP. AMWTP shreds 

and repackages CH debris waste in its presupercompaction process lines, creating about 500 

silvers6

 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 approximately 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 and DOE reached an agreement (referred to as the 

“Batt Agreement”) that included a requirement that DOE ship all transuranic waste located at 

INL (estimated to be 65,000 m3 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 the Batt and other agreements, AMWTP personnel 

stated that INL has shipped 40,000 m3 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 contract-required shipment volumes but did not disclose 

the specific volume to EPA. ITG shipped approximately 3,200 m3 of supercompacted and directship waste between October 2011 and October 2012. 

(3) Selected Advanced Mixed Waste Treatment Project waste management procedures were 

examined and are adequately implemented by Idaho Treatment Group, LLC. 

Table 2 presents the selected key procedures that EPA examined during the continued 

compliance inspection. EPA determined that these procedures were adequately transitioned to 

the ITG program. AMWTP maintains upper level procedures that address WIPP waste 

characterization requirements, AK characterization, AMWTP waste acceptance requirements for 

onsite and offsite waste, and procedures associated with readying waste for shipment to WIPP. 

 6

 “Silvers” are 55-grallon drums that contain 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 the 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 Waste Facility Permit, New Mexico Environment Department, Waste Analysis Plan, 

Santa Fe, NM, June 29, 2010. 

c

 U.S. Department of Energy, “Contact-Handled 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 examined several example completed forms, including 

Form 1066 (“TRU Waste Management AK Checklist”), Form 1070 (“Acceptable Knowledge 

Resolution Checklist”), Form 1727 (“Non-AMWTP Generator Shipping Request”), Form 1736 

(“AMWTP Safety Basis Radioactive 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 Payload Verification Checklist”). The examined forms supported the 

associated procedural references and demonstrated that procedures were adequately implemented 

and documented. The forms also demonstrated container traceability, as addressed in Item (4). 
11 

Additionally, EPA examined implementation of AK procedure MP-TRUW-8.13, Revision 24. 

The review included the source document assembly and review process, preparation of AKrelated documents, subsequent preparation of the AK summary report (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. AMWTP manages wastes from various sources, 

including offsite wastes, INL wastes and AMWTP-generated wastes. AMWTP assembles AK 

data for all of these sources and writes generator-site-specific AK summary reports for each 

waste facility of origin. AMWTP also typically prepares AKSRs for each waste stream but may 

not require AKSRs for a waste population that is to be included in the supercompacted waste 

stream. Instead, AMWTP integrates the waste into the BN510.1 AKSR by acceptable item 

description codes (IDCs) and updates the “Acceptable 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 not required to maintain drum lists that 

document initial waste stream populations. Drums are identified individually and placed 

into existing waste streams, but upon request AMWTP can determine candidate 

populations that are assigned 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-site-specific summary AK reports (AMWTP 

sometimes refers to these reports as “baselines”) 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 stream is included in an “AMWTP Offsite 

Waste Stream Profile” (Form 1900) created by the generator site (e.g., Reference 

P861A). 

 AMWTP divides AK information into different documents rather than include all 

information in a single document. As shown in Figure 3, AMWTP prepares RPT-TRUW05, “Waste Matrix Code Reference Manual”; RPT-TRUW-06, “AMWTP Baseline AK 

for Newly Generated Waste”; RPT-TRUW-07, “Determination of Radioisotopic Content 

in TRU Waste Based on Acceptable Knowledge”; and RPT-TRUW-12, “AMWTP Waste 

Stream Designations.” For the evaluation of the history of a given drum or waste stream, 

any of these documents may include pertinent information and all provide information 

included in waste stream AKSRs. For example, RPT-TRUW-83 is the AKSR for the 

BN510.1 waste stream, which is supported by the site summary AMWTP AK Report 

RPT-TRUW-06. 

EPA determined that the procedures examined 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 Information 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 adequately demonstrated. 

EPA evaluated the traceability of supercompacted waste stream BN510.1 drums as well as the 

traceability of two cemented wastewater sludge drums (BN-836) that originated 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 populations that were the subject of an ongoing T1 

evaluation (T1 approved January 29, 2013; see EPA Docket No. A-98-49, II-A4-169). However, 

AMWTP representatives indicated they were not prepared to provide complete information 

about these wastes at the time of the AK continued compliance inspection held in October 2012. 

EPA agreed to accept traceability information 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 available on a container basis, including waste 

travelers or other information generated prior to AMWTP waste characterization. AMWTP 

representatives do not have ready access to any original waste travelers or similar container data 

created by the generator site, but information from these data sources are input into the IWTS 

database. The IWTS is readily accessible and is the starting point for waste characterization. 

AMWTP provided IWTS printouts that present historical 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 determine if the containers are 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 are 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 are 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 transfer 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 Generator 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 (Pu239), including at least one 

standard deviation error level. 

o Each crate or box to be received at AMWTP contains at most 325 FGE Pu239, 

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 transportation equipment inspections, land 
14 

disposal restriction manifests, and other inter-site shipment and transportation 

requirements. These may include a package receipt checklist. 

 Form 1901, “Non-AMWTP Generator 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 Analysis Plan (WAP) 

to undergo waste fingerprinting by non-WIPP program RTR to verify waste contents. 

Completion of adequate fingerprinting is documented on a Form 1901. 

 Form 1915, “Offsite Waste Generator Shipment Acceptance Checklist.” Form 1915 is 

completed prior to waste acceptance at AMWTP. The form verifies that the accepted 

waste is certified by the offsite generator and that he necessary forms and checks were 

performed. 

EPA examined several example forms to evaluate 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 characterization batch data reports (BDRs) 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 information 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 determination 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 documentation 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 response, AMWTP-CH-CC-AK12-001CR (see Attachment F). 

EPA requires that AMWTP document additional analyses or evaluations performed to ensure 

that the IDCs to be included in the BN510.1 waste stream meet the Land Withdrawal Act (LWA) 

requirements of being defense in origin and excluding 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 prepare 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 with 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 supporting 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 Knowledge 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 required 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 (Waste 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 WIPP 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, respectively. Therefore, EPA determined that 

training to these important documents is taking place. Training was up to date at the time of the 

AK portion of the continued compliance inspection. 

 8

 DOE CBFO, “Transuranic Waste Acceptance 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 supercompacted 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 characterization compliance. 

6.2 Nondestructive Assay 

EPA had approved the four IWAS NDA systems initially during the baseline inspection and 

again at an unannounced continued compliance inspection in 2010. The systems’ abilities to 

perform the required analyses had been demonstrated during the baseline and confirmed by the 

continued compliance inspection. Accordingly, this inspection focused on the following: 

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

and software had not changed since EPA’s last inspection. 

 Adequacy of the current revisions of the 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 Building 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 two 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 evaluated during previous EPA inspections, the focus of this inspection 

emphasized operational aspects that occurred within 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 documents, procedures and controls. 

 Knowledge and understanding of the personnel involved in the NDA program. 

 Performance indicators relevant to the past year’s operation. 
17 

The modified NDA checklist used for this evaluation is included as Attachment E.1 to this 

report. This checklist contains 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 had been disabled in 2010 for operational reasons 

and EPA confirmed that this was stillo the case for 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 overpacks. 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 assay 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, these systems are essentially matrix-independent 

within the range of demonstrated applicability for each measurement technique. 

There were no substantive changes in the operational 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 were 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 Measurement Uncertainty for the AMWTP Integrated 

Waste Assay Systems,” Revision 1, July 30, 2003. This 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 passive neutron mode included those due to 

calibration, counting statistics, matrix/source distribution effects and elevated backgrounds due 

to high Z matrices. For the active neutron mode, uncertainties due to calibration, counting 

statistics, matrix/source distribution effects, neutron multiplication and self-shielding were also 

included. Uncertainties for the gamma-ray mode included those due to calibration, counting 

statistics, self-absorption, matrix heterogeneity and source heterogeneity. The uncertainty due to 

the measurement of isotopic ratios was also included. 
18 

(4) The lower limit of detection, including the minimum detectable concentration, 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 that, if present, yields 

a measured value greater than the critical level with a 95% probability, where 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 background and the efficiency of the system. The 

NDA-2000 software calculates the LLD and the minimum detectable concentration (MDC) for 

each assay based on the background and efficiency associated with that particular measurement. 

AMWTP determined nominal LLDs and MDCs for a variety of matrices for the active neutron, 

passive neutron and gamma modes by assaying surrogate drums of those matrices with no 

radioactive sources present. Matrices used for the active and passive neutron modes included 

combustibles, metals, glass, and inorganic and organic sludge. For the gamma mode, the LLD 

and MDC were estimated for four matrices varying 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 reports 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 content, uncertainty, total TRU alpha activity, other calculated 

(derived) quantities, proper identification of measurement system and technique, and the use of 

measured isotopic ratios or default isotopic ratios. Using a hand-held calculator that had been 

programmed prior to the inspection, the EPA inspector spot-checked several aspects of the 

radionuclide information provided on all of the radioassay data sheets in each BDR, specifically, 

the following items: 

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

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

 TRU alpha activity concentration (curies per gram), based on a simple arithmetic sum 

divided by the container’s net weight in kilograms. 

 Correlation of cesium-137 (137Cs) and strontium-90 (90Sr), when applicable, evaluated 

relative to AMWTP’s stated approach for deriving these quantities as documented in 

AMWTP-RPT-TRUW-03, Revision 8, Section 3.1. 

 Correlation of uranium-234 (234U) to 238U and/or 235U, when applicable, evaluated 

relative to AMWTP’s stated approach for deriving 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 compliance 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. RTR12-001369

 during the onsite visit to the AMWTP facility. The operator performed the 

necessary equipment checks prior to EPA’s arrival. EPA observed the entire RTR examination of 

the drum, including generation of the written and audiovisual records. Waste items were 

identified by the operator on the audiovisual recording 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 tables 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 qualified individuals and determined that the 

operator performing the demonstrated RTR examination was properly qualified. 

(2) Real-time radiography operating records were 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, RTR12-00029 and RTR12-00127. The waste described in 

these three BDRs was debris of various types with Waste Matrix Codes of S5112, S5123, S5300, 

S5410, S5490 and S5900. EPA reviewed in detail the recordings and written 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 that the Independent Technical 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 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. EPA asserts that changes to original records 

should be made by the original operator whenever possible and that this step should be integrated 

into an applicable procedure. If changes are made by a different operator, that operator should be 

required to review the original data to ensure that he or she concurs 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 response on EPA Inspection Issue Tracking Form No. 

AMWTP-CH-CC-RTR-12-002CR, part (a) (see Attachment G). AMWTP responded by 

proposing a “tail gate training” for 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 adequately 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 personnel and management during the inspection: 

 Weights of containers are recorded on data 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 personnel to investigate this practice and 

change how weights are recorded if necessary. 

 A nonconformance report (NCR) is written against RTR operators who fail to identify a 

prohibited item during normal operations. AMWTP’s procedure allows an operator three 

separate misses of prohibited items in a year before a corrective action request is written 

and a complete root cause analysis is performed. 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 because 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 CBFO notify EPA how AMWTP has addressed these 

three minor issues as part of AMWTP’s submission 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 documentation that the data were reviewed at the 

data generation and Site Project Manager levels; the reviews were 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 prohibited items before taking action. This issue will be 

referred to EPA’s quality assurance 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, prohibited 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 reviewed 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 and 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 demonstration may be sufficient for WAC compliance, 

identification of 100% of the container’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 formalized 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 procedure MP-TRUW-8.39 to incorporate estimation 

of waste material parameters (WMPs) and to revise the AMWTP RTR Bi-Annual Drum 

Qualification Package to incorporate estimation of WMPs. EPA found AMWTP’s response to 

adequately address 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 operations. AMWTP adequately addressed this concern on February 

26, 2013. EPA also raised three minor issues discussed 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 observed 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 Examination Operations.” One operator controlled the 

Brokk arm and manipulated the waste while the other operator electronically entered data into 

the WTS. At the end of packaging, both operators 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 record is required. EPA 

reviewed paper BDR Nos. VEB12-00732, VEB12-00758 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 generation 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, Employees by Qualifications/Certifications,” 

dated October 16, 2012, and verified that the VE operators performing the demonstration were 

qualified. Both operators were included on the list of qualified individuals. EPA reviewed the 

“QCITR0VE – Level 1 Validation ITR VE” list to verify 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 determined 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 related to AK and one concern related to RTR as 

performed by AMWTP. These concerns are discussed 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 adequate. EPA is not proposing any 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–November 1, 2012, and February 26, 2013. 

Section 6.3, Item (2), discusses three items related to RTR that were minor in nature or one-time 

occurrences which EPA brought to the attention of AMWTP personnel and management during 

the inspection. These relate to the reporting of container weight, reporting of prohibited items in 

a nonconformance report and an incomplete inventory 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 requires CBFO to notify EPA of how AMWTP has 

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

current quarter. 
A-1 

ATTACHMENT A 

Tiering of Transuranic Waste Characterization Processes Implemented by the Advanced Mixed Waste 

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

Process Elements AMWTP T1 Changes AMWTP T2 Chan

AK including Load Management 

Any new waste category Changes to WDS algorithms specific to load management 

Notification to EPA upon the following: 

- Changes in load management status of appr

- Availability of WSPFs, including updates o

within an approved waste category 

- Changesb to site procedures requiring appro

changes as discussed in Section 8.1 of the b

NDA New equipment or physical modifications to approved 

equipmentc

Changes to approved calibration range for approved equipment

Notification to EPA upon completion of changeequipment, operating range(s), and site procedurand other changes as discussed in Section 8.2 of 

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

- Implementation of new equipment 

- Modificationc to approved equipment 

- Changes to site procedures requiring CBFO 

discussed in Section 8.3 of the baseline repo

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

- Addition of new waste category 

- Addition of new procedure or site equipmen- Changes to site procedures requiring CBFO 

discussed in Section 8.4 of the baseline repo

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

and other changes as discussed in Section 8.5 of 

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

end of a fiscal quarter. 

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

to ES&H, nuclear safety, RCRA or are editorial in nature. 

c Modifications to approved equipment include all changes with the potential to affect NDA and/or RTR data relative to waste isolation and exc

addition of safety-related equipment. 
B-1 

ATTACHMENT B 

APPROVAL SUMMARY FOR AMWTP 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-Compacted 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-A4-169 
C-1 

ATTACHMENT C 

LIST OF DOCUMENTS REVIEWED BY EPA DURING CONTINUED COMPLIANCE 

INSPECTION 

1995 Settlement Agreement: Overview & FAQs, Idaho 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 website, http://amwtp.inl.gov, accessed February 15, 

2013 

AMWTP Form 1066, TRU Waste Management AK Checklist Mound Laboratory (Draft), 

printed October 10, 2012 

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

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

AMWTP Form 1727, Non-AMWTP Generator Shipping Request, ID-ICP-MFC-Gloves, March 

20, 2011 

AMWTP Form 1736, AMWTP Safety Basis Radioactive Material Waste Acceptance Criteria 

Calculator, ANLE Inorganic 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 Generator Container Certification, 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 Report, dated October 1, 2012

BDR No. RTR11-00414, December 6, 2011 

BDR No. RTR12-00029, March 5, 2012 

BDR No. RTR12-00127, September 28, 2012 
C-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 Operations, 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 (For WIPP Certification of Boxes), Advanced 

Mixed Waste Treatment Project, Revision 10, August 6, 2012 

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

Mixed Waste Treatment Project, Revision 11, January 5, 2010 

IWTS Drum Screen Shots, Historic and Ongoing 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 Nonconforming Conditions, Revision 21, September 17, 2012 

MP-TRUW-8.1, Certification Plan for INL Transuranic Waste, Advanced Mixed Waste 

Treatment Project, Revision 22, September 12, 2012 

MP-TRUW-8.11, Data Reconciliation, Advanced Mixed Waste Treatment Project, Revision 24, 

September 25, 2012 

MP-TRUW-8.12, Waste Receipt and Shipping Inspection, Advanced Mixed Waste Treatment 

Project, Revision 22, March 30, 2010 

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

Documentation, Advanced Mixed Waste Treatment 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 Plan, Advanced Mixed Waste Treatment 

Project, Revision 16, June 4, 2012 
C-3 

MP-TRUW-8.34, WIPP Sample Transfers, Advanced Mixed Waste Treatment Project, 

Revision 8, June 20, 2012 

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

MP-TRUW-8.40, INL Waste Acceptance, Advanced Mixed Waste Treatment Project, 

Revision 9, October 1, 2012 

MP-TRUW-8.41, Offsite DOE CH-TRU Waste Acceptance, Advanced Mixed Waste Treatment 

Project, Revision 3, March 9, 2009 

MP-TRUW-8.5, TRU Waste Certification, Advanced Mixed Waste Treatment Project, 

Revision 28, September 10, 2012 

MP-TRUW-8.8, Level I Data Validation, Advanced Mixed Waste Treatment Project, 

Revision 32, April 25, 2012 

MP-TRUW-8.9, Level II Data Validation, Advanced 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 Profile for ID-MFC-S5490, MFC CH-TRU 

Heterogeneous Debris (AW-167), Roy P. Grant, AMWTP ID-MFC-S5490, April 20, 2010 

QCAKE01A – Acceptable Knowledge Expert, Employees by Qualifications/Certifications, 

Training Database Screenshot, October 16, 2012 

QCITR0VE – Level 1 Validation ITR VE, Employees by Qualifications/Certifications, Training 

Database Screenshot, October 16, 2012 

QPOT034A0 – Real-Time Radiography, Employees by Qualifications/Certifications, Training 

Database Screenshot, October 16, 2012 

QPVE0001 – Visual Examiner, Employees by Qualifications/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 Technical Review Report, Advanced 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, 2012 
C-4 

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

Acceptable Knowledge, Advanced Mixed Waste Treatment Project, Revision 17, June 

23, 2011 

RPT-TRUW-12, AMWTP Waste Stream Designations, 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 Treatment 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 Project, Revision 2, January 31, 2012 

RPT-TRUW-87, Documentation of QAPjP Test Containers, Advanced Mixed Waste Treatment 

Project, Revision 0, January 27, 2011 

RTR Bi-Annual Drum Written and DVD Record, RTR Test Drum # 3, for one operator 
D-1 

ATTACHMENT D 

INSPECTION PERSONNEL 

Name Affiliation and Area of Expertise/Function 

Opening 

Meeting 

10/23/12 

Close-out 

Meeting 

10/25/12 

Opening 

Meeting 

2/26/13 

Rajani Joglekar Inspector-Team Leader, EPA Ed 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 Shift Supervisor – 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 Program Angie 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-1 

ATTACHMENT E.1 

NONDESTRUCTIVE ASSAY INSPECTION CHECKLIST 

EPA Inspection No.: EPA-AMWTP-10.12-24 Inspectio

Technical Elements Objective Evidence/Comment 

Identify the NDA systems by name, location and number and determine if these are the same systems in the same locations as EPA had approved previously. 

The two In-Plant IWAS NDA Units Z-390-100 and Z-390-101 are located IWAS Retrieval Units Z-211-102 and Z-211-103 are located in Building Whad previously approved all four IWAS NDA systems in their current loca

Establish the current operational status of all IWASs for assaying TRU waste. 

All four IWAS NDA systems were operational. 

Confirm any substantive changes to the four IWASs in the last year with respect to activity or density operating ranges. 

There were no substantive changes to the four IWAS NDA systems. 

Identify all NDA personnel who have operated the IWAS units, performed data review or validation, or served as an Expert Analyst for the last year. Confirm that all personnel were current on the LOQI as appropriate. 

AMWTP provided a comprehensive listing of all personnel qualified for dtechnical review and independent technical review that was current as of Fthe AMWTP equivalent of an LOQI. 

Determine what maintenance events or repairs were performed to the four IWASs over the last year as documented in AMWTP records. 

Work Order No. 411486 documented a detector gain adjustment of the Z-32011. Work Order No. 427738 documented a detector gain adjustment of September 11, 2011. Work Order No. 400148 documented a detector replaadjustment of the Z-211-102 IWAS on March 6, 2012. Work Order No. 40detector replacement on the Z-390-100 IWAS on May 10, 2012. 

Identify the number of waste containers that have been assayed using the four IWAS units. Indicate how many BDRs were assembled and indicate how many of these BDRs have been promoted through Project-Level Review. Confirm the sample types that all four IWASs have assayed in the past year (debris and solids). 

For calendar year 2012, there were 30,816 assay events on all four IWAS 

compiled in a total of 3,734 NDA BDRs. 

Confirm that the four IWAS units are able to report quantitative values and uncertainties for 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr and 137Cs. 

All four IWAS NDA systems report quantitative values and uncertainties 

241Am, 233U, 234U, 238U, 90Sr and 137Cs, as evidenced by NDA BDRs review

following BDRs were reviewed: ASY11-02568, ASY12-00374, ASY12-0ASY12-01969, ASY12-01595, ASY12-00915, ASY12-01508, ASY12-01ASY13-00110. 

Identify any sample conditions, interferences, radionuclides or other aspects that are potentially problematic or require specific corrections for the four IWAS units. 

There are no potentially problematic sample conditions or interferences th

AMWTP NDA personnel were not able to adequately address. 

Determine how many calibration verification have been performed on each IWAS unit over the last year. 

Z-390-100 and Z-390-101 Z-211-102 and Z-211-103 
E-2 

EPA Inspection No.: EPA-AMWTP-10.12-24 Inspectio

Technical Elements Objective Evidence/Comment 

Identify any changes to the methods used to derive the isotopic contribution for the unmeasured radionuclides for the four IWASs. 

There have been no changes in the manner in which the unmeasured radiothe four IWAS NDA systems. 

Confirm the AMWTP procedures for operation, data reduction, review and validation and expert analysis of NDA data for all four IWASs. Establish the current revisions of all procedures cited. 

Current revisions of all procedures are as follows: INST-OI-14, Revision 3TRUW-8.1.1, 4, Revision 11, January 5, 2010; MP-TRUW-8.1, Revision MP-TRUW-8.8, Revision 33, November 10, 2012; RPT-TRUW-03, RevisTRUW-07, Revision 17, June 23, 2011. 
E-3 

ATTACHMENT E.2 

REAL-TIME RADIOGRAPHY INSPECTION CHECKLIST 

EPA Inspection No.: EPA-AMWTP-10.12-24 Inspection Date: Octo

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Ev

Comme

RTR-1: Site procedures identify required training and qualifications for RTR personnel 

QPOT34A0 RPT-TRUW-87MP-TRUW-8.39MP-TRUW-8.1 

Operator training was consistent with applicable procedures. Operator certification is current. OJT was documented for each operator. Operators are requalified every two years. RTR operators passed a training drum test that includes items common to the waste streams examined at the site (biannually). Training drum contains all required items. RTR operators receive training on the waste matrix parameters and typical packaging configurations expected to be found in each waste stream. 

EPA reviewed demonstration of caprecordings, written records and recoselected operators. A concern requibecause RTR operators are not requthe test drums, only those specified CC-RTR-12-002CR, part (b)). Objective evidence:

1. Requalification Package QPOT

Radiography, for two operators

2. RTR Biannual drum written an

Drum No. 3, for one operator. 

3. QPOT034A0, Real Time Radio

Qualifications/Certifications, 1

4. RPT-TRUW-87, Documentatio

Containers, Revision 0, 1/27/1

5. MP-TRUW-8.39, RTR Operato

Revision 7, 04/26/12. 

6. Concern AMWTP-CH-CC-RT

RTR-2: Site procedures provide complete instructions for operators to perform the RTR examination and completion of the associated documentation 

INST-OI-12, Revision 48 (drums) INST-OI-81, Revision 10 (boxes) 

RTR operator adequately explained the process followed for examining a drum and entering data into data forms (whether hard copy or electronic data entry is used). 

EPA observed an operator perform the onsite inspection. The EPA inspDVD recordings of various RTR exbeen through project-level review. Objective evidence:

1. Container Nos. 10371838, 103

10006114 from BDR No. RTR

2. Container No. 10104637 from 
E-4 

EPA Inspection No.: EPA-AMWTP-10.12-24 Inspection Date: Octo

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Ev

Comme

RTR-3: The RTR procedures require an image quality check to be performed 

INST-OI-12, Revision 48 (drums) INST-OI-81, Revision 10 (boxes) 

Operator adequately explained how the acceptability of an image is determined. Image quality check is performed once per day. Performance of the image quality check is documented and recorded. 

The image quality test had already of the EPA demonstration. Howevebeen through data generation and pissues were identified for image quObjective evidence:

1. BDR Nos. RTR11-00414, RTR

00127. 

RTR-4: The procedure allows the operator to adjust the RTR to accommodate the physical properties of the waste and waste containers likely to be encountered at the site 

INST-OI-12, Revision 48 (drums) INST-OI-81, Revision 10 (boxes) 

Operator could identify applicable policies and procedures governing the operation of RTR equipment. 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 an image is unacceptable (e.g., the waste is solidified or the container is lead-lined). 

During the demonstration, the operINST-OI-12 to achieve a compliant several audiovisual recordings to veand data record generation. All of thclear and easy to understand and foObjective evidence:

1. Container Nos. 10371838, 103

10006114 from BDR No. RTR

2. Container No. 10104637 from 

RTR-5: The procedures require that the RTR recording be of 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 is audible, and the required information is contained on the audible portion of the tape. The RTR recording is consistent with the data package for the same drum. 

EPA reviewed several audiovisual rperformance and data record generareviewed were clear and easy to unThe RTR system now has an electrothe operator can use to point out cerThis system appeared to work correany prejudice into the examination. Objective evidence:

1. Container Nos. 10371838, 103

10006114 from BDR No. RTR

2. Container No. 10104637 from 

RTR-6: There is a procedure for determining whether the waste matches the waste stream description and Waste Matrix Code, and 

INST-OI-12, Revision 48 (drums) INST-OI-81, Revision 10 

The procedure is adequately implemented. Operators verify that the waste matches the waste stream description. Waste Matrix Code is verified. If not, corrective action is taken. 

During the demonstration, the oper12 to achieve a compliant examinatA single example of an operator noinventory of waste items was identigenerated were correct but the operitems rolled into each WMP. AMW
E-5 

EPA Inspection No.: EPA-AMWTP-10.12-24 Inspection Date: Octo

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Ev

Comme

for determining Waste Material Parameters and weights 

(boxes) WMP weights are estimated by compiling an 

inventory of waste items and residual/packaging materials. Does the RTR operator use a standard weight lookup table to provide an estimate of WMP weights? If so, has the table been updated to reflect additional information gained through previous RTR/VE exams or updated AK information? 

informed of this occurrence. Objective evidence:

1. Data sheets contained in BDR N

00029 and RTR12-00127. 

RTR-7: The RTR procedure provides instructions for identifying prohibited items and for processing drums containing prohibited items 

INST-OI-12, Revision 48 (drums) INST-OI-81, Revision 10 (boxes) 

Operator could name prohibited items. Operator adequately explained how the presence of free liquids is determined. Operator’s explanation of required actions if prohibited items were encountered was consistent with procedure. Corrective actions are taken when necessary. 

EPA observed the RTR examinatio10306633 from BDR No. RTR12-0waste drum (SCG S3900, IDC RF7waste items, entered them into an echecked for the presence of prohibiexamination, the operator verified tBuilding WMF-634 for more than 7equilibration requirement for drums Objective evidence:

1. Container No. 10306633 data s

RTR12-00136. 

2. Nonconformance Report Nos. 

67218, 67219, 70583, 14196, 1

RTR-8: RTR procedures include the required QC examinations, evaluation accuracy and reproducibility of the RTR process 

INST-OI-12, Revision 48 (drums) INST-OI-81, Revision 10 (boxes) 

A replicate scan is performed on one waste container per day or on one container per testing batch (whichever is less frequent). An independent observation of one scan (not the replicate) is performed by a qualified RTR operator (anyone but the initial RTR operator). 

Each BDR reviewed contained a rescan. Objective evidence:

1. BDR Nos. RTR11-00414, RTR

00127. 
E-6 

EPA Inspection No.: EPA-AMWTP-10.12-24 Inspection Date: Octo

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Ev

Comme

RTR-9: Procedures contain standardized forms for recording RTR data 

INST-OI-12, Revision 48 (drums) INST-OI-81, Revision 10 (boxes) 

RTR operator adequately explained the process followed for examining a drum and entering data into data forms (whether hard copy or electronic data entry is used). Direct data entry into an electronic form is done by the RTR operator using a computer while the operator is still in the RTR booth. The electronic data file undergoes the same QC checks used for hand-written data entries. 

During the demonstration, the operaidentified into the electronic data fooperator made a complete audiovisuexamination. Objective evidence:

1. BDR Nos. RTR11-00414, RTR

00127. 

RTR-10: Site procedures require review of BDRs at the data generation and project level 

INST-OI-12, Revision 48 (drums) INST-OI-81, Revision 10 (boxes) (Level II Data Validation) MP-TRUW-8.8, Revision 32 (Level I Data Validation) 

Data-generation-level reviews are performed and documented. Project-level reviews are performed and documented.

BDRs reviewed had been through dlevel reviews. Checklists for each rsigned. Objective evidence:

1. BDR Nos. RTR11-00414, RTR

00127. 
E-7 

ATTACHMENT E.3 

VISUAL EXAMINATION INSPECTION CHECKLIST 

EPA Inspection No.: EPA-AMWTP-10.12-24 Inspection Date: Octo

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Ev

Comme

VE-1:Site procedures identify required training and qualifications for VE personnel. 

MP-TRUW-8.1, Revision 22 QPVE0001 QCITR0VE

Visual Examination Expert’s (VEE’s) explanation of job duties was consistent with applicable procedures. VE personnel’s training was consistent with applicable procedures. VE personnel’s certification is current. 

VE personnel are requalified every two years. 

VE personnel received training on specific waste generating processes, typical packaging configurations, WMPs expected to be found in each Waste Matrix Code. 

EPA reviewed the requalification poperators and also the appointment reviewed the list of current VE opeObjective evidence:

1. QPVE0001, Visual Examiner, 

Qualifications/Certifications, 1

2. QCITR0VE, Level I Validation 

Qualifications/Certifications, 1

3. Requalification Package for tw

VE-2:Procedures and technical guidance documents provide complete instructions for performing VE. 

INST-OI-34, Revision 27 INST-FOI-17, Revision 25 

The site uses AK to identify the matrix parameter category and to estimate waste material parameters present. 

Procedures are sufficiently detailed to enable the operator to determine if a waste container meets the criteria of 40 CFR 194.24 with regard to identifying applicable parameters with waste limits. Establish standard nomenclature, based on current site practice, so that all personnel recognize waste by the same descriptors. 

EPA observed VE operation during interviewed an operator about data AMWTP has developed standard woperator has the ability to add itemreviewed validated BDRs to verify of VE operations. Objective evidence:

1. BDR Nos. VEB12-00732, VEB

VNC12-00156. 

2. Procedures INST-FOI-17 and I
E-8 

EPA Inspection No.: EPA-AMWTP-10.12-24 Inspection Date: Octo

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Ev

Comme

VE-3 Procedures require identification of safety hazards. 

INST-OI-34, Revision 27 INST-FOI-17, Revision 25 

Prior to starting the VE, the VEE reviews all documented data related to the waste container and its contents to ensure that there are no safety hazards for the VE operators. 

A VEE is available to operators on operations are being performed. Thperformed by two operators and no required. Objective evidence:

1. BDR Nos. VEB12-00732, VEB

00156. 

2. Procedures INST-FOI-17 and I

VE-4:Procedure requires an audiovisual recording of the VE event. 

INST-OI-34, Revision 27 INST-FOI-17, Revision 25 

VEE’s/operator’s explanation of how to operate the data recording system was consistent with applicable procedures. The video camera was focused prior to the start of VE. An audiovisual recording is made of the waste container exam and maintained as a nonpermanent record. Data on the audiovisual recording are consistent with documentation. 

EPA observed VE operation during interviewed an operator about data is available to operators on all shiftbeing performed. The VE demonstoperators and no audiovisual recordObjective evidence:

1. BDR Nos. VEB12-00732, VEB

00156. 

2. Procedures INST-FOI-17 and I

VE-5:There is a procedure for handling instances when the VEE is unable to see through the inner plastic bags/packages/ containers of waste. 

INST-OI-34, Revision 27 INST-FOI-17, Revision 25 

The VEE has decisionmaking criteria for assessing the need to open the bags/packages in order to identify all of their contents. If the bags are not opened, a brief written description of the contents of the bags is prepared with estimates of the amount of each waste type in the bags. 

EPA observed VE operation during interviewed an operator about data available to operators on all shifts wbeing performed. The VE demonstoperators and no audiovisual recordObjective evidence:

1. BDR Nos. VEB12-00732, VEB

00156. 

2. Procedures INST-FOI-17 and I
E-9 

EPA Inspection No.: EPA-AMWTP-10.12-24 Inspection Date: Octo

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Ev

Comme

VE-6:The VE procedure requires verification of Waste Matrix Code and WMP weights. 

INST-OI-34, Revision 27 INST-FOI-17, Revision 25

If an automated data entry system is used, data entry VE personnel could navigate through the various screens. A VE data form is used to document the matrix parameter category and estimated WMP weights of the waste. VE personnel have access to standardized charts or tables to aid in the consistent estimation or assignment of weights, WMPs and waste matrix codes. The estimated or weighed WMP weights are determined by compiling an inventory of waste items, residual materials and packaging materials. 

The items on the inventory list are sorted by WMP and combined with a standard weight look-up table to provide an estimate of WMP weights. References tables are updated as site gains information from VE. VEE verifies WMC and recommends changes as needed. 

EPA observed VE operation during interviewed one operator about datAMWTP has developed standard woperator has the ability to add itemreviewed validated BDRs to verify of VE operations. Objective evidence:

1. BDR Nos. VEB12-00732, VEB

00156. 

2. Procedures INST-FOI-17 and I

VE-7:Procedure provides instructions for processing of containers with prohibited items. 

INST-OI-34, Revision 27 INST-FOI-17, Revision 25

Procedure provides adequate instructions for implementation 

EPA has reviewed the procedures mthat they provide complete instructEPA also reviewed validated BDRperformance of VE operations. Objective evidence:

1. BDR Nos. VEB12-00732, VEB

00156. 

2. Procedures INST-FOI-17 and I
E-10 

EPA Inspection No.: EPA-AMWTP-10.12-24 Inspection Date: Octo

Establishment of 

Required Technical 

Elements in Procedures 

Applicable 

Procedures/ 

Documentation 

Execution of Procedures Objective Ev

Comme

VE-8: Procedures require gross weight and volume utilization to be recorded. 

INST-OI-34, Revision 27 INST-FOI-17, Revision 25

The gross weight of the waste container (container plus contents) is recorded on the VE data form. Volume utilization of the container is documented. 

All required information was inclureviewed. Objective evidence:

1. BDR Nos. VEB12-00732, VEB

00156.

VE-9: Procedures require corrective actions to be taken as necessary. 

INST-OI-34, Revision 27 INST-FOI-17, Revision 25

The procedure is adequately implemented and corrective actions are taken when necessary. 

No corrective actions were required BDRs reviewed. Objective evidence:

1. BDR Nos. VEB12-00732, VEB

00156. 

VE-10: Site procedures require data generation and project-level reviews of BDRs. 

MP-TRUW-8.9, Revision 24 MP-TRUW-8.8, Revision 32 

Data generation and project level reviews are complete. 

All BDRs reviewed had been validand project level. Checklists were cBDRs. Objective evidence:

1. BDR Nos. VEB12-00732, VEB

00156. 

2. Procedures MP-TRUW-8.8 and 
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 knowledge 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 waste. 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 BN508 meet the LWA 

requirements. The EPA inspector discussed options to accomplish this with AMWTP-ITG acceptable 

knowledge personnel, who acknowledged EPA’s concern about the need for additional documentation that 

the waste in question meets LWA restrictions 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, 2012 
G-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) batch data reports (BDRs) that the Independent 

Technical Reviewer (ITR) identifies as necessary 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 accompanied by the signature of the individual making the 

changes upon reviewing and concurring with the needed change. That is, changes to original 

records should be made by the original operator whenever possible. If changes are made by a 

different operator, that operator should be required to review the original data to ensure that he or 

she concurs with the requested change for which he or she is taking responsibility. This step should 

be integrated into an applicable procedure. 

b. RTR operators are not required to identify all waste items in contact-handled test containers for the 

biannual demonstration of capability. Test containers include items required by the WIPP waste 

acceptance criteria (WAC) plus other material added to fill the container. The success of this 

demonstration of capability is based on identification of WAC-required items only. While this 

demonstration may be sufficient for WAC compliance, identification of 100% of the container’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. 

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