DOCKET NO: A-98-49, II-A4-73

WASTE CHARACTERIZATION INSPECTION REPORT

EPA BASELINE INSPECTION NO. EPA-ANL-CCP-RH-9.06-8

OF THE CENTRAL CHARACTERIZATION PROJECT

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION

PROGRAM AT THE ARGONNE NATIONAL LABORATORY

September 12-14, 2006

U.S. Environmental Protection Agency

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

January 2007i TABLE OF CONTENTS

Section Page

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

................................................... ........................... 1

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

................................................... ............................. 5

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

................................................... ............................. 6

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

................................................... ............................... 7

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

................................................... ......................... 8

6.0 Personnel .....................................

................................................... ..................................... 8

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

................................................... ................ 8

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

................................................... .................. 9

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

................................................... ......................... 9

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

................................................... .............. 10

8.1 Acceptable Knowledge ..........................

................................................... ............ 10

8.2 Radiological Characterization..................

................................................... .......... 34

8.3 Visual Examination.............................

................................................... ............... 54

8.4 Real-Time Radiography .........................

................................................... ............ 60

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

................................................... ..... 60

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

................................................... ....................... 60

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

................................................... ........................... 61

10.1 Findings and Concerns.........................

................................................... .............. 61

10.2 Conclusions ...................................

................................................... ..................... 61

11.0 References ...................................

................................................... ................................... 65ii ATTACHMENTS

Attachment A.1 Acceptable Knowledge (AK) Checklist Attachment A.2 Dose To Curie (DTC) Checklist Attachment A.3 Visual Examination (VE) Checklist

Attachment B.1 EPA Inspection Issue Tracking Form, EPA Issue No.

ANL-CCP-RH-VE-06-001CR Attachment B.2 EPA Inspection Issue Tracking Form, EPA Issue No.

ANL-CCP-RH-VE-06-002C Attachment B.3 EPA Inspection Issue Tracking Form

, EPA Issue No.

ANL-CCP-RH-AK-06-003C

Attachment C Public Comments and EPA’s Responses1

1.0 EXECUTIVE SUMMARY

In accordance with 40 CFR 194.8(b), the U.S. Enviro nmental Protection Agency (EPA or the Agency) conducted Baseline Inspection No. EPA-ANL-C CP-RH-9.06-8 of the Central Characterization Project’s (CCP) waste characteriza tion (WC) program for remote-handled (RH) transuranic (TRU) waste at the U.S. Department of E nergy’s (DOE) Argonne National Laboratory (ANL), also known as Argonne National Lab oratory East (ANLE), located in Argonne, Illinois. EPA conducted a baseline inspec tion of the ANL-CCP’s program to characterize RH TRU wastes proposed for disposal in the Waste Isolation Pilot Plant (WIPP). The inspection activities described in this report occurred September 12-14, 2006.

On November 2006, EPA issued a Federal Register (FR) notice (71 FR 65488, November 8, 2006) announcing the proposed approval of the RH WC program implemented at ANL by CCP. The FR notice opened a 45-day comment period to sol icit public comment on the proposed approval of ANL-CCP’s RH WC program and the ANL Bas eline Inspection Report (EPA Air Docket A98-49, II-A4-70). The comment period ended December 26, 2006. EPA received one set of public comments. (See EPA Docket ID No. EPA-H Q-OAR-2006-0881). EPA evaluated and responded to the public comments (see Attachmen t C of this report), and made changes to the proposed approval decision, where appropriate. This report discusses EPA’s approval of the RH WC program implemented at ANL by CCP.

EPA must verify compliance with 40 CFR 194.24 befor e waste may be disposed of at the WIPP, as specified in Condition 3 of the Agency’s certifi cation of the WIPP’s compliance with disposal regulations for TRU radioactive waste (63 Federal Register (FR) 27354 and 27405, May 18, 1998). This was the first inspection of RH WC activities c onducted by EPA at ANL-CCP. EPA Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8 was pe rformed in accordance with the provisions of 40 CFR 194.8(b), as issued in a July 16, 2004, FR notice (Vol. 69, No. 136, pp. 42571–42583). The purpose of the ANL-CCP RH WC ins pection was to evaluate the adequacy of the site’s WC programs for one RH debris waste ( S5000) stream to be disposed of at the WIPP. The activities examined during the inspectio n included the following:

• Acceptable knowledge (AK) for RH retrievably-stored TRU debris waste (S5000)

• Visual examination (VE) for RH retrievably-stored T RU debris waste (S5000)

• Radiological characterization as described in this report for RH retrievably-stored TRU debris waste (S5000)

EPA’s inspection team determined that ANL-CCP’s RH WC program activities were technically adequate. EPA is therefore, approving the ANL-CCP RH WC program in the configuration observed during this inspection, described in this report, and documented in detail in the checklists in Attachment A. The approval includes the following:

(1) The AK process for RH retrievably-stored TRU de bris in one waste stream, Argonne National Laboratory Waste Stream AERHDM, as defined in CCP-AK-ANLE-500, Revision 1, July 18, 20062

(2) The radiological characterization process usin g Dose-to-Curie (DTC) and modelingderived scaling factors for assigning radionuclide values to one RH waste stream for which the scaling factors are applicable, as descri bed in CCP-AK-ANL-501

, Revision 0

(3) The VE process for one retrievably-stored RH S 5000 debris waste stream AERHDM using the trained personnel, documentation, and pro cedures discussed in this report

EPA is not approving the WIPP Waste Information Sys tem (WWIS) for entry and tracking of the

waste contents of RH debris wastes at this time. A lthough the WWIS is currently approved by EPA for tracking contact-handled (CH) waste, ANL-CC P had not demonstrated its adequacy to enter and track RH waste contents during this basel ine inspection. During the comment period for the proposed approval the Carlsbad Area Field O ffice (CBFO) notified EPA that the WWIS was operational for RH wastes and was ready for EPA evaluation as a Tier 1 (T1) change. EPA has begun this evaluation and the results of EPA’s T1 evaluation will be provided upon completion separately.

EPA is not approving Real Time Radiography (RTR) at ANL-CCP. ANL-CCP did not have an operational RTR unit in place at the time of the in spection. ANL-CCP cannot ship RH waste to WIPP using RTR as a WC technique until it is inspec ted and approved by EPA.

Any changes to the WC activities from the date of t he baseline inspection must be reported to and, if applicable, approved by EPA, according to T able 1. Please note that each T1 and Tier 2 (T2) change listed in Table 1 is followed by a refe rence to the report section where the technical basis for the T1 or T2 designation is presented.

EPA will notify the public of the results of its ev aluations of T1 and T2 changes established as part of today’s approval through the EPA Web site a nd by sending e-mails to the WIPPNEWS list (see Section 2.0, below, for a brief discussio n of tiering). All T1 changes must be submitted for approval before their implementation and will b e evaluated by EPA. Upon approval, EPA will post the results of the evaluations through th e EPA Web site and the WIPPNEWS list, as

described above.

In October 2006, EPA concurred with CBFO’s request for allowing INL-CCP to submit T2 changes implemented at the EPA-approved TRU sites f our times a year at the end of each fiscal quarter. (See EPA letter to CBFO dated October 26, 2006; EPA Air Docket No. A-98-49, II-A4-76). ANL-CCP may submit all T2 changes discu ssed in this report on the same schedule.3Table 1. Tiering of RH TRU WC Processes Implemented by ANL-CCP(Based on September 12–14, 2006 Baseline Inspection)RH WC Process ElementsANL-CCP RH WC Process - T1 ChangesANL-CCP RH WC Process - T2 Changes*Acceptable Knowledge (AK)Any new waste streams not approved under this baseline; AK (1)Modification of the approved waste stream AERHDM toinclude additionalcontainers beyond the approximately 45 included inCCP-AK-ANLE-500,Revision 1. The 20additionalcontainers identified in the AK summary asbeing presentarenot included in this waste stream approval; AK (1)Substantive modification(s)*** that have the potential to affect thecharacterization process to CCP-AK-ANLE-500, CCP-AK-ANLE-501 orCCP-AK-ANLE-502; AK (8)Implementation of load management for any RH wastestream; AK (16)Notification to EPA that the final DTC determination iscomplete for RH containers in the approved wastestream; AK (3)Notification to EPA when updates are made to AKdocumentation as a result of WCPIP revisions**; AK(4)Notification that updates have been completed to thefollowing documents:•All future revisions of CCP-ANLE-AK-500,CCP-ANLE-AK-501; AK (4)•Listing of the references that document theassembly of fuel pin data and review process;AK (5)•All future revisions of CCP-ANLE-AK-502;AK (8)•CCP-AK-ANLE-500 and CCP-AK-ANLE-502 toaddress freeze file changes; AK (8)Notification to EPA that the data package for thisdebriswaste stream is completed, including any modificationsto the WSPF including the CRR and AK Summary;AK (9), and AK (14)Notification to EPA when AK accuracy reports arecompleted, prepared annually at a minimum; AK (15)Radiological Characterization,including Dose-To-Curie (DTC)Use of any alternate radiological characterizationprocedure other than DTCwith established scaling factors as documented in CCP-TP-504 andCCP-AK-ANLE-501, Revision 0, respectively, or substantive modificationthereof***; RC (8.2.2 and 8.2.3)Any new waste stream not approved under this baseline or addition ofcontainers to waste stream AERHDM that require changing the establishedradionuclide scaling factors; RC (8.2.3)Application of new scaling factors for isotopic determination other thanthose documented in CCP-AK-ANLE-501; RC (8.2.2 and8.2.3)Notification to EPA that revisions of CCP-AK-ANLE501 or CCP-TP-504 that require CBFO approval** arecomplete; RC (8.2.2 and 8.2.3)4Table 1. Tiering of RH TRU WC Processes Implemented by ANL-CCP(Based on September 12–14, 2006 Baseline Inspection)RH WC Process ElementsANL-CCP RH WC Process - T1 ChangesANL-CCP RH WC Process - T2 Changes*Visual Examination (VE) VE by reviewing existing audio/visual recordings for Summary wastecategory not covered by this approval; VE (1) & VE(3)VE by any new process for S5000 debris wastes; VE (1) and VE (3)Notification to EPA that revisions of any VE procedurethat require CBFO approval are complete; VE (1) andVE (3)Addition of new S5000 debris waste streams; VE (2)Real Time Radiography (RTR) Any use of RTR requiresEPA approvalNoneWIPP Waste Information System(WWIS)Any use of WWIS requires EPA approval prior to RH waste disposal None* ANL-CCP will report all T2 changes to EPA every three months.** Excluding changes that are editorial in nature or are required to address administrative concerns.New references that are included as part of the document revision may berequested by EPA.***Substantive modificationrefers to a change with the potential to affect ANL’s RH WC process, e.g., the use of an inherently different type of measurement instrument or theuse of the high range probe as described for CCP-TP-504 for radiological characterization.5

2.0 PURPOSE OF INSPECTIONS

On May 18, 1998, EPA certified that the WIPP will c omply with the radioactive waste disposal regulations at 40 CFR Part 191. In this certificat ion, EPA also included Condition No. 3, which states that “the Secretary shall not allow shipment of any waste from...any waste generator site other than LANL [Los Alamos National Laboratory] for disposal at the WIPP until the Agency has approved the processes for characterizing those waste streams for shipment using the process set forth in §194.8.” The approval process describ ed at 40 CFR 194.8 requires DOE to (1) provide EPA with information on AK 1 for waste streams proposed for disposal at the WIP P, and (2) implement a system of controls used to conf irm that the total amount of each waste component that will be emplaced in the WIPP will no t exceed limits identified in the WIPP Compliance Certification Application (CCA).

Under the changes to 40 CFR 194.8 promulgated in th e July 16, 2004, FR notice, EPA must perform a single baseline inspection of each TRU wa ste generator site’s WC program. The purpose of the baseline inspection is to approve th e site’s WC program based on the demonstration that the program’s components, with a pplicable conditions and limitations, can adequately characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes destined for disposal at the WIPP. An E PA inspection team conducts an onsite inspection to verify that the site’s system of cont rols is technically adequate and properly implemented. Specifically, EPA’s inspection team v erifies compliance with 40 CFR 194.24(c)(4), which states the following:

Any compliance application shall: . . . Provide inf ormation which demonstrates that a system of controls has been and will continu e to be implemented to confirm that the total amount of each waste component that will be emplaced in the disposal system will not exceed the upper limiting value or fall below the lower limiting value described in the introductory text o f paragraph of this section. 2

The system of controls shall include, but shall not be limited to: measurement; sampling; chain of custody records; record keeping systems; waste loading

schemes used; and other documentation.

In other words, the purpose of the baseline inspect ion is to assess whether DOE sites that characterize TRU waste prior to disposal at the WIP P are capable of characterizing and tracking

the waste in such a manner that EPA is confident th at the waste will not exceed the approved limits. By approving the WC systems and processes at ANL-CCP, EPA has evaluated the capabilities of systems and processes to accomplish two tasks: (1) the identification and

1 As of the FR notice of July 16, 2004, EPA has repl aced the term process knowledge with acceptable knowledge . Acceptable knowledge refers to any information a bout the process used to generate waste, material inputs to the process, and the time period during w hich the wastes were generated, as well as data res ulting from the analysis of waste conducted prior to or separate fr om the waste certification process authorized by an EPA certification decision to show compliance with Cond ition 3 of the certification decision.

2 The introductory text of 40 CFR 194.24(c) states, “For each waste component identified and assessed p ursuant to [40 CFR 194.24(b)], the Department shall specify the limiting value (expressed as an upper or lower limit of mass, volume, curies, concentration, etc.), and the associated uncertainty (i.e., margin of error) for each limiting value, of the total inventory of such waste propose d for disposal in the disposal system.”6

measurement of waste components (such as plutonium) that must be tracked for compliance, 3

and (2) the confirmation that the waste in any give n container has been properly identified as belonging to the group of approved waste streams.

Following EPA’s approval of WC processes evaluated during the baseline inspection, EPA is authorized to evaluate and approve, if necessary, c hanges to the site’s approved WC program by conducting additional inspections under the authori ty of 40 CFR 194.24(h). Under 40 CFR 194.24, EPA has the authority to conduct continued compliance inspections (both announced and unannounced) to verify that the site continues to u se only the approved WC processes to characterize the waste, and that those WC processes remain in compliance with all the applicable regulatory requirements. Based on the adequacies o f the WC processes demonstrated during the baseline inspection, including all conditions and l imitations, EPA will specify which subsequent WC program changes or modifications must undergo fu rther EPA inspection or approval under 40 CFR 194.24. This will be accomplished by assign ing a tier level to each aspect of the characterization program, i.e., T1 and T2 activitie s. T1 activities have more stringent reporting requirements and require that DOE notify EPA of pro posed T1 changes prior to implementation, and that EPA provide approval prior to implementati on. T2 activities are reported to EPA by DOE based on the frequency established in the inspe ction report. DOE may choose to characterize and dispose of at risk while EPA consi ders the proposed T2 changes.

If ANL-CCP contemplates a change that is not identi fied in this report, EPA recommends that

the site in consultation with CBFO discuss the natu re of the change with EPA. This would minimize a possibility of EPA not approving the sit e-assigned tiers. The rule under which this baseline inspection was conducted can be found in t he FR (Vol. 69, No. 136, pp. 42571–42583, July 16, 2004).

3.0 PURPOSE OF THIS REPORT

This report documents the basis for EPA’s approval decision, and explains the results of Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8 in terms of fin dings or concerns. Specifically, this report does the following:

• Describes the characterization systems for approval

• Provides objective evidence of the approval basis f or all WC systems

• Identifies all relevant limitations and/or conditio ns for each WC system

• Provides objective evidence of findings or concerns in the form of documentation, as applicable

3 The potential contents of a single or group of wast e streams determine which processes can adequately characterize the waste. For example, if AK suggest s that the waste form is heterogeneous, the site sh ould select the matrix-appropriate radiological characterization te chnique to obtain adequate radionuclide measurement s. VE serves to confirm and quantify non-radiological was te components, such as cellulosics, rubbers, plasti cs, and metals. Once the nature of the waste has been confirmed, ch aracterization techniques will be applied to quanti fy selected radionuclides in the waste. In some cases, a TRU w aste generator site may be able to characterize a r ange of heterogeneous waste streams or only a few. A site’ s stated limits on the applicability of proposed WC processes govern the scope of EPA’s inspection.7

• Describes any tests or demonstrations completed dur ing the course of the inspection and their relevance to EPA’s approval decision

The completed checklists attached to this report in conjunction with the listings in each section, reference the documents that the EPA inspection tea m members reviewed in support of the technical determination. To see or obtain copies o f any items identified in the attached checklists, write to the following address:

Quality Assurance Manager

USDOE/Carlsbad Field Office

P.O. Box 3090 Carlsbad, NM 88221

EPA’s final approval of the ANL-CCP RH WC program i s conveyed to DOE separately by

letter. This information is also available on EPA’ s Web site at http://www.epa.gov/radiation/WIPP, in accordance wi th 40 CFR 194.8(b)(3).

4.0 SCOPE OF INSPECTION

The scope of Baseline Inspection No. EPA-ANL-CCP-RH- 9.06-8 included the technical adequacy of the WC systems in use at ANL-CCP to cha racterize RH TRU wastes. These systems were evaluated with respect to their abilit y to perform the following:

• Identify and quantify the activities of the 10 WIPP -tracked radionuclides ( 241 Am, 137 Cs,

238 Pu, 239 Pu, 240 Pu, 242 Pu, 90 Sr, 233 U, 234 U, and 238 U) using a combination of AK and radiological characterization, including DTC and ra dionuclide scaling factors derived from modeling

• Assign waste material parameters (WMPs) correctly a nd confirm the presence or absence of prohibited items using VE for RH retrievably-sto red debris waste

Specifically, these systems consisted of the follow ing components:

• The AK process that supports retrievably-stored S50 00 debris wastes from one RH debris waste stream, Argonne National Laboratory Waste Str eam No. AERHDM

• The system of radiological characterization includi ng DTC and the application of radionuclide scaling factors derived by modeling fo r one RH debris waste stream, Argonne National Laboratory Waste Stream No. AERHDM

• VE for retrievably-stored S5000 RH debris wastes

During an inspection, EPA does not approve characte rization data; that function is the sole responsibility of the WC organization being evaluat ed during the inspection, in this case ANL-CCP. EPA evaluated the WC processes implemente d by the site to characterize RH retrievably-stored debris. The evaluation consi sted of interviewing personnel, observing equipment operations that are controlled through si te procedures, and inspecting records related to each of the WC processes within the inspection’s scope. An important aspect of this evaluation is the objective evidence that documents the effectiveness of the WC processes.8

Objective evidence typically takes the form of batc h data reports (BDRs) for radiological characterization and VE; AK Summaries and accuracy reports; and VE tapes. During an inspection, EPA typically selects samples of each o f these items, based on the number and variety of items that were completed and available for each WC process, consistent with standard auditing techniques. Due to the newness of the RH TRU characterization program, there was only one completed BDR for VE and radiological char acterization available for the EPA inspection team’s evaluation. Due to the limited n umber of BDRs, the EPA inspection team evaluated one hundred percent of the drums in this package rather than choose a subset (sample) from a population of completed BDRs. Based on the evaluation of the WC processes in conjunction with the objective evidence, EPA determ ined the technical adequacy of the WC processes within the inspection’s scope.

5.0 INSPECTION-RELATED DEFINITIONS

During the course of an inspection, EPA inspectors may encounter items or activities that require further inquiry for their potential to adversely af fect WC and/or isolation within the repository. The two main categories relevant to WC inspections are identified below:

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

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

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

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

response.

Note: Concerns not requiring a response do not have to be addressed prior to program approval. However, EPA recommends that when DOE accepts the s ite’s response addressing the issue raised in the EPA concern, EPA should be informed c oncurrently with implementation of the corrective action in response to the concern, simil ar to a T2 issue.

6.0 PERSONNEL

6.1 EPA Inspection Team

The members of the EPA WC inspection team are ident ified below.

Table 2. EPA Inspection Team Members

Inspection Team Member Position Affiliation

Mr. Ed Feltcorn Inspection Team Leader U.S. EPA ORI A

Ms. Rajani Joglekar Inspector U.S. EPA ORIA

Ms. Lisa Sharp Observer U.S. EPA ORIA

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

Ms. Dorothy Gill Inspector S. Cohen & Associates, I nc.

Mr. Patrick Kelly Inspector S. Cohen & Associates, Inc.9

6.2 Personnel Contacted

The EPA inspection team conducted interviews with A NL-CCP personnel in several disciplines. The personnel contacted represented a sample of the RH TRU WC staff, and they are listed in the table below, along with their affiliation and t echnical area.

Table 3. Personnel Contacted During Inspection

Personnel Affiliation Area of Expertise

Eric D’Amico CCP AK, DTC, SPM Jene Vance CCP AK, AKE/DTC; Scaling Factors A.J. Fisher CCP SPQAO

Lisa Price CCP AK, AKE Larry Porter CCP AK, VE SPM; Scaling Factors

Steve Schafer CCP AK, AKE

Jeff Harrison CCP AK, AKE

Kevin Peters CCP AK, AKE

Ed Gulbransen CCP DTC, SME Mark Doherty CCP/WTS DTC & Scaling Factors Joe Harvill CCP/WTS DTC & Scaling Factors Tommy Mojica CCP Operator/ITR, SME/OJT, VEE Gloria Ruppert CCP Operator/ITR Gary Redman CCP Operator/ITR Irene Quintana WTS SPM

Wes Root CCP VE, VPM

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

EPA selected the individuals to be interviewed. Th e EPA inspectors reviewed the qualifications and training records of these individuals relative to their WC responsibilities. Based on this evaluation, EPA determined that ANL-CCP WC personne l responsible for characterizing RH TRU waste and certifying it as TRU waste were quali fied and had received adequate training to perform their assigned function. If key WC personn el changes occur, EPA may request qualification and training records of the new indiv iduals identified as key WC personnel. EPA will review these records and may interview the per sonnel to determine their abilities to produce quality data. This personnel qualification evaluat ion and review of training records would be the equivalent of the evaluation done by the EPA inspec tion team on site during this inspection.

7.0 PERFORMANCE OF THE INSPECTION

Site Background and History

ANL is located in Argonne, Illinois, approximately 22 miles southwest of downtown Chicago and 25 miles west of Lake Michigan. The site encom passes 1,275 acres, 200 of which are occupied by laboratory facilities. Founded in 1946 by the Atomic Energy Commission to support the initial production of plutonium for the Manhattan Project, ANL is a multidisciplinary laboratory that performs work in basic and applied science. ANL initially included a facility in Idaho, called ANL-West, located on the Idaho National Laboratory (INL) site outside of Idaho Falls, Idaho. In 2005, the ANL-W facility was formally incorporated into the INL and the name of the ANL-W facility was changed to the M aterials and Fuel Complex. At that time, it was no longer necessary to distinguish between ANL- W and ANL-E, and the name of ANL-E10

was changed to simply ANL. This report contains re ferences to ANL and ANL-E; however, the distinction is not significant and is used to maint ain consistency with references to specific documents, processes, or other records.

Inspection Process Overview

EPA Inspection No. EPA-ANL-CCP-RH-9.06-8 occurred o n-site at ANL on September 12-14, 2006. The inspection was conducted in the followin g steps:

(1) Obtaining and reviewing site procedures, reports, a nd other technical information related

to RH WC activities at ANL-CCP in advance of the in spection

(2) Preparing draft checklists and technical questions specific to WC areas prior to the inspection, as appropriate

(3) Participating in a conference call with CBFO techni cal support contractors to brief the EPA inspection team members regarding technical det ails related to the ANL-CCP RH WC program

(4) Interacting with CBFO and ANL-CCP personnel to arra nge inspection logistics

(5) One visit onsite at ANL to review personnel qualifi cations and training, and verify the technical adequacy or qualifications of RH WC perso nnel, procedures, processes, and equipment by means of interviews, observation, and demonstrations, and recording the

results

(6) Recording all concerns on EPA issue-tracking forms, which were completed and provided to CBFO and site personnel as they were ge nerated (see Attachment B)

(7) Communicating all pertinent information with CBFO a nd ANL-CCP personnel on site and in other meetings, as appropriate

(8) Pursuing resolution of all identified issues prior to completion of the inspection and postinspection by discussions with CBFO and ANL-CCP per sonnel

(9) Conducting entrance, exit, and daily briefings for CBFO and ANL-CCP management personnel at ANL and CBFO, as appropriate

(10) Preparation of this inspection report

8.0 TECHNICAL WASTE CHARACTERIZATION AREAS

8.1 Acceptable Knowledge

EPA examined the AK process and associated informat ion to determine whether ANL-CCP demonstrated compliance with 40 CFR 194.8 requireme nts for RH waste stream: Argonne National Laboratory Waste Stream No. AERHDM.11

Waste Characterization Element Description

As part of the inspection, EPA reviewed the followi ng with respect to the use of AK for RH

waste characterization at ANL:

• Waste stream identification and the definition of w aste stream, including radiological

content of the waste

• Identification of HLW, TRU vs. LLW, spent nuclear f uel

• Role of AK in the characterization methodology (inc luding AK characterization using modeling/scaling factors derived by ANL)

• Compiling AK documentation and assembly of required information

• Adequacy of WCPIP AK process implementation and the AK Summary Report

• AK data traceability

• AK source document sufficiency

• WCPIP interpretation with respect to AK qualificati on

• Confirmatory Test Plan preparation and plan adequac y

• Characterization Reconciliation Report preparation and plan adequacy

• Correlation and Surrogate Summary form and CH-RH co rrelation

• Personnel training and qualification

• Applicability of mass spectrometry information

• NCRs and AK discrepancy resolution

• AK accuracy

• Plans for load management

• Identification of the method for determining data q uality objectives (DQOs)

• DQOs attained through AK Qualification

Documents, Waste Containers, and Batch Data Reports Provided

Many of the documents listed below are considered b y ANL-CCP as common to both the ANL and INL RH waste streams recently inspected by EPA. Therefore, some of the references listed were provided to EPA during the earlier INL inspect ion and were not requested again during the ANL inspection. EPA verified that the appropriate revision of each document was provided.

• DOE/WIPP-02-3214, Remote Handled TRU Waste Characte rization Program Implementation Plan, Revision 0D, October 30, 2003

• DOE/WIPP-02-3122, Transuranic Waste Acceptance Crit eria for the Waste Isolation Pilot Plan, Revision 5, effective date TBD

• CCP-PO-002, Revision 16, CCP Transuranic Waste Cert ification Plan, dated May 8, 2006

• CCP-AK-ANLE-500, Central Characterization Project A cceptable Knowledge Summary Report for Argonne Remote-Handled Debris Waste, Rev ision 1, July 18, 2006

• CCP-AK-ANLE-501, Central Characterization Project R emote-Handled Transuranic Radiological Characterization Technical Report for Remote-handled Transuranic Debris Waste from Argonne National Laboratory-East, Revisi on 0, July 21, 200612

• CCP-AK-INL-502 Central Characterization Project, RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation Test Pl an for ANL RH Waste Stream: AERHDM, Revision 0, July 21, 2006

• CCP-TP-506, CCP Preparation of the Remote-Handled T ransuranic Waste Acceptable Knowledge Characterization Reconciliation Report, R evision 2, June 8, 2006

• Inter-Office Correspondence, from A.J. Fisher to I. Quintana, Acceptable Knowledge Accuracy Report: Argonne National Laboratory- East W aste Stream Number AERHDM, dated August 28, 2006

• P593, Engineering Design File, Quantifying Special Actinides in RH-TRU Waste from Irradiated Fuel Examined at ANL-E, EDF-2555 Revisio n 0, December 16. 2002

• P592, Evaluation of Radionuclide contents in RH-TRU Waste Drums 728 through 737 Based on Reported Irradiated Fuel Examination INEEL/EXT-02 -00168, Revision 0, September

2003

• AK Tracking Spreadsheet for Argonne National Laborat ory, print out dated September 13,

2006

• Characterization Reconciliation Report for Waste St ream CRR-ANLE-AERHDM, signed August 30, 2006

• NCR-RHANL-0002-06, Revision 0, NCR dealing with waste cans 292 (Drum 00825) and 257 and 260 (Waste Drums 00829), dated July 12, 200 6

• AK Pu-FGE Factor Calculation, Including AK-derived Isotopics, for Drums 810 (Container 76642), 815 (76650), 817 (76652), 820 (78103), 824 (78107) and 826 (78109), provided during inspection (individual sheets dated March 7- 8, 2002, and August 1999 (824)

• CCP-TP-500 Revision 2, Attachment 1 VE Data Forms f or RH Drums 810, 815, 817, 820, 824, and 826 BDR RHANLVE060001, various dates, 2006

• Container Dose to Curie Conversion Records for Drum s 810, 815, 817, 820, 824, and 826, provided during inspection September 2006 (dated an alysis August 8-9, 2006)

• RH TRU Waste Correlation and Surrogate Summary Form , ANL RH TRU Waste Stream AERHDM, provided during audit September 13, 2006

• AK Qualification Card, Kevin Peters dated August 6, 2003; Resumes for K. Peters and S. Schafer provided September 13, 2006

• Source Documents Reference List (CCP-TP-005 Revisio n 17 Attachment 4) undated

• Solid Radioactive Waste Disposal Requisition Date s heets, various containers provided September 2006

• CCP-QP-002, CCP Training and Qualification Plan, Re vision 20 Effective date 5/3/2006

• C003, Intra-laboratory Memo to Harvey Welsh re: Dim ensions of Intermediate TRU Waste Containers, prepared by Dennis Donahue, dated Septe mber 14, 1989

• C006, Interview with Larry Neimark, re: AGHCF sample s, applicable programs, defense relationship to materials and commingling of the wa ste; Cheryl Schultz Record of communication ROC-C6, July 17, 200113

• C024, Intra-laboratory memo to W.C. Kettman from L. A. Neimark IPR, Clarification of 00 No.29 with Regard to Inventory of 8-inch Storage Hol es, dated December 7, 1993

• C058, Intra-laboratory memo to R. Boule from Ralph Ditch, re: Needs Prior to Shipment of Nelmarks’s TRU-RH Drums to Idaho, dated March 1, 199 0

• C060, Intra-laboratory memo to R. Boule from A.C. S mith, re: Status: Resumption of Shipments of TRU waste to INEL, dated March 30, 1990

• C066, Record of Communication between Bill Kettman and Dennis Donahue, re: AGHCF Operations and Waste Packaging, recorded by Julia W hitworth and M. Wyco, dated August 7, 2001

• C084, Intra-laboratory Memo to Building 212 Personn el re: Disposal of Solid Radioactive Waste, F.P. Marchetti, dated February 4, 1986

• C121, Record of Communication with L. Neimark, A. C ohen, and F. Pausche by J. Whitworth and J. Biedscheld, and P. Kuan, R. Bhatt, and S. Kheriche, re: ACHCF Radiological Characterization of RH-TRU Waste Shipp ed to INEEL, dated December 19,

2001

• C149, Correspondence to Mr. Daniel Hecker, Waste Ma nagement Office, Argonne National Laboratory-East re: Transmittal of Final Argonne Nat ional Laboratory-East Transuranic Waste Acceptable Knowledge Report; Tom Krause, Proj ect Manager, Benchmark Environmental Corporation, a ThermoRetec Company, S eptember 29, 2000

• C306, Memo from R.J. Page to G.L. Winner, Subject: Isotopic Inventory of the AGHCF, R.J. Page, July 20, 2005

• C330, Memorandum to Ines Tray, CBFO from F. Marcino wski, Determination and Findings, Defense Origin of Nuclear Waste, Kerr-McGee Waste, d ated April 15, 2005

• C331, Memorandum to CCP Central Records from K. Pet ers, re: Evaluation of Kerr-McGee Production and FFTF History, dated June 26, 2004

• C332, Memorandum to CCP Central Records from D.B. B ecker, re: Assessment of Waste Material Parameters for Waste Stream ID-ANLE-S5000, dated January 3, 2006

• C333, Memorandum to CCP Central Records from D.B. B ecker, re: Assessment of Waste Material Parameters for Waste Stream AERHDM, dated January 2006

• C345, Shaw Discrepancy Report R8 for RH TRU Waste f orm ANL-E, AGHCF, re: WMC determination, Cheryl Schultz, July 15, 2003

• C349, Radiological Evaluation for Waste Stream AERH DM, S. Schafer, August 3, 2006

• DR10, Discrepancy Resolution Regarding the Volume o f 7-Gallon Waste Cans, K. Peters,

DR10 June 7, 2006

• DR011, Waste Requisition and Videotape Discrepancie s, Lisa Price, undated (signed August 16, 2006)

• DR013, Discrepancy Resolution Form Regarding the Ar gonne Waste Population of 44 drums versus 45 drums, S. Schafer, August 28, 200614

• P001, AGHCF Operations Manual, Argonne National Labo ratory, IPS-2-00-00, 2, dated September 10, 1990

• P002, Central Characterization Project Acceptable K nowledge Report for Argonne National Laboratory-East Contact Handled TRU Waste Facility Maintenance and Laboratory Operations; CCP-AK-ANLE-001, Revision 11, dated Dec ember 31, 2003

• P006, Safety Analysis for Twenty Year Retrievable S torage of Intermediate Gamma Level Transuranic Waste, W.D. Jackson Alpha-Gamma Hot Cel l Facility, Argonne National Laboratory, dated June 1, 1976

• P009, TRU-RH Waste Certification Plan for Waste Man agement Operations, Ralph W. Ditch and Gary Griggin, J0306-0033-SA Revisions 2 and 4, dated November 10, 1986 and April 16, 1991

• P012, The Status of Uranium-Silicon Alloy Fuel Deve lopment for the RERTR Program, R.F Domagia, C. Wiencek, H.R. Thresh and D. Stahl; Argo nne National laboratory, Materials Science Division, November 1, 1990

• P013, Frontiers: Research Highlights 1946-1996, Arg onne National Laboratory, January 1,

1996

• P023, Argonne National Laboratory-East Remote Handl ed Waste, by W. Mahlon Hellaeson, EDF-RWMC-759, August 29, 1994

• P032, Procedure for Sorting Remote-Handled TRU Wast e (30-Gallon Intermediate-Level Waste), Alpha-Gamma-Hot Cell Facility Irradiation P erformance Section Materials and Components Technology Division, dated January 7, 19 87

• P055, [Argonne East] Waste Handling Procedures, C. L. Cheever, Manager Waste Management Operations, dated September 18, 1986

• P380, Alpha Gamma Hot Cell Facility (ACHCF) Safety Analysis Report, ANL-IPS-221-00- 01, Revision 1, October 2001

• P412, Remote Handled Transuranic Waste Sorting and Packaging, ANL AGHCF-OPS-302, Revisions 0 and 2, July 9, 2001 and March 29, 2006

• P414, Estimation of Activity in Waste Containers, A NLE AGHCF-OPS-304, Revision 0, April 20, 2001

• P575, Work Plan for the Examination of Fuel Plates from the RERTR-4 Experiment in ATR, Revision 1, R.V. Strain IPS-400-01-00, February 22, 2002

• P587, Program Scoping Plan for the Fast Flux Test F acility, A Nuclear Science and Irradiation Services User Facility, PNNL-12245, Rev ision 1, August 1999

• P599, the Defense Programs Origin of Transuranic Wa ste at Argonne National LaboratoryWest, H.F. McFarlane, ANLE-NT-192, November 2001

• P604, Criticality Hazards Control Statement, Alpha- Gamma Hot Cell Facility, Special Facility FF12, and Addendum 1, Use of a Safe Vac Va cuum Cleaner in Alpha-Gamma Hot Cell Facility Areas 1 and 3, James A. Morman, IPS-6 -00-09; IPS-6-01-10; Revisions 9 and 10, March 1990 and July 200115

• P611, Waste Handling Procedures Manual-Appendix I, Radioactive Waste Management Basis, ANL, RWMB-01, Revision 1, April 6, 2004

• U001, AGHFC Position Statement Regarding Defense Ve rsus Non Defense TRU Waste, no author cited, April 7, 2000

• U013, Waste Stream Fissile Content [AGHCF], March 2 3, 1990

• U015, RH-TRU 1995, Book 5 Drums 798 to 809, no auth or cited, January 1, 1995

• U027, Report of Analytical Results; CMT-84 (10-84), August 1, 1990

• U036, Acceptable Knowledge for ANL RH-TRU Waste, R. T. Klann, K.N. Grimm, and B.A. Brush, ANL-E-U036, undated

• U040, Spreadsheet Correlating Number Quota with Quot a Title and Number Project, no author cited, July 31, 2002

• U041, Videotape Logs data [Cans 100, 102-187, 217-2 31, and 234-246], Cheryl L. Schulz (no title given), September 15, 2001

• U072, MSDS sheets, various components, no author ci ted, undated

• U076, AGHCF Fissile Inventory Management System Dat abase; July 16, 2001

• U305, Isotopic Data Report from H.B. Robinson Repor t; undated and source not cited

• U332, WMO-105 Radioactive and Mixed Waste Disposal Requisitions, ANL, no specific

dates or authors cited

• U334, Handwritten Drum list of Drums with top and b ottom can numbers, Terry Bray, 1976–

2002

• U335, Various Excel Spreadsheets Regarding Fissile Material and Waste Management Tracking, no specific dates or authors cited

• U336, Various Inventory Spreadsheets from AGHCF, no specific dates or authors cited

• U882, Pre-Irradiated Fuel Composition, ANLE, June 22 , 2006

• U887, Uncertainty Analysis for Drums, June 22, 2006

Table 4. Listing of BDRs

Drum VE BDR DTC BDR

00810 RHANLE VE 06001 ANLE RH DTC C06001

00815 RHANLE VE 06001 ANLE RH DTC C06001

00817 RHANLE VE 06001 ANLE RH DTC C06001

00820 RHANLE VE 06001 ANLE RH DTC C06001

00824 RHANLE VE 06001 ANLE RH DTC C06001

00826 RHANLE VE 06001 ANLE RH DTC C06001

Waste Stream AERHDM consists of waste both generate d prior to an approved QA program, i.e., retrievably-stored waste, as well as wastes t hat will be packaged and generated in the future and will be considered newly-generated waste. ANL- CCP proposed the use of confirmatory testing for the retrievably-stored component, while “qualification” of the AK via approved characterization methodologies will be used for the newly-generated component. The16

retrievably-stored confirmatory testing and newly-g enerated AK qualification both assign TRU and activity-related DQOs using DTC and AK-based sc aling factors derived through ORIGEN2.2 modeling (previously examined as part of t he RH baseline inspection at the Idaho National Laboratory and found adequate by EPA). Inp ut parameters to this modeling were not individual drum AK data; rather, the individual fue l pins that contributed radionuclides to various waste drum lots were individually used as i nput to the ORIGEN2.2 code.

The evaluation presented in this section assesses t he AK process and related activities dealing with the determination of physical and radiological waste composition, up to but not including model parameter determination, waste data input, an d determination of scaling factors. Evaluation of individual model input parameters wit h respect to the related source documents was undertaken during activities presented in Secti on 8.3 that also address DTC for radiological

waste characterization .

EPA’s evaluation focused on the processes and relat ed objective evidence. Therefore, EPA’s summation, presented below, includes observations r egarding the completeness of the AK record

and inclusion of data in that record. EPA believes that the record must be complete to ensure data and process traceability. Future examination of AK records may include personnel that are not as directly associated with the generation of t he data as those who compiled the AK data examined during this inspection; therefore, the rec ommended changes described below are made

with that future examination in mind.

Technical Evaluation

(1) Waste Stream AERHDM was examined with respect to wh ether the stream is adequately

defined.

The RH Waste Characterization Program Implementatio n Plan (WCPIP) defines waste stream as “waste material generated from a single process or activity, or as waste with similar physical, chemical, and radiological properties.” Waste stre am AERHDM is a debris waste stream that was generated in the ANL-E hot cell and includes wa stes that are currently in drums, as well as waste awaiting packaging that still resides in the hot cell.

As indicated in the AK Summary CCP-AK-ANLE-500, the waste stream consists of about 45 drums of waste generated in the cells from February 1993 through February 2002. In addition to these drummed wastes, some waste material created d uring the same time period remains in the hot cell, and will be packaged in the future as new ly-generated waste. Between 50-100 drums of additional newly-generated waste may be packaged. The physical characteristics of each drum are recorded on waste can inventory records; inform ation recorded includes the individual drum contents on a volume percent (glass bottles, cotton rags) that were assigned to EPA waste material parameters (WMPs) and converted to weight percentages. This analysis, documented in Reference C333, showed that this waste stream consi sts of about 64% inorganics (ferrous/non ferrous metals) and 36% organics (cellulosics, plas tics and rubber). Analysis showed the absence of organic matrix (e.g., organic sludges). ANL-CCP representatives were asked about waste-generating processes to be used for newly-gen erated waste, specifically for the purpose of determining whether the newly-generated component o f the waste stream would be physically similar to the retrievably-stored component. ANL-C CP representatives indicated that the17

AGHCF 4 currently contained cellulosics, plastics, and rub bers (CPR), as well as large pieces of equipment and other metals/inorganics that would re quire size reduction prior to packaging. ANL-CCP provided photographs of the AGHCF and anoth er hot cell showing the contents of each, and these are included in Figures 1, 2 and 3, below. Waste-generating procedures were not available for the newly-generated component of the waste stream. ANL-CCP representatives indicated that the newly-generated component will c onsist predominantly of inorganic materials consistent with the retrievably-stored drums, but t he newly-generated waste may contain more decommissioning and decontamination (D&D) materials . Based on this information and the process history associated with the stream, the was te stream has been appropriately assigned with respect to physical characteristics.

AK radiological data pertaining to content of waste drums is presented in several references. As indicated in the AK Summary, ANLE used an ORIGEN2.2- based methodology to assign drumspecific radiological content using methods similar to that employed by ANL-CCP, but conducted this analysis on a per-campaign rather th an waste stream basis. As a result, the AK record (Reference C349) includes drum-specific radi ological data assigned by ANLE, using a method similar to that employed by ANL-CCP. Refere nce C349 states the range of reported

external dose rates for the 45 containers as 0.58 R /hr to 180 R/hr, with an average of greater than 17 R/hr. It is not clear if this value represents a value on contact with each container or at 1 meter, which seems more likely. The TRU alpha co ncentration is listed as greater than 1,900 nCi/g per container. This value is heavily weighte d by a small number of containers that are listed with concentrations in excess of 10,000 nCi/ g, but these containers also had identified quantities of 241 Am, 238 Pu, 240 Pu, 241 Pu, and 242 Pu that were not assigned to the other containers. Three of the 45 containers have an AK-assigned TRU alpha concentration of less than 100 nCi/g, but these containers did not have assigned values f or 241 Am, 238 Pu, 240 Pu, 241 Pu, and 242 Pu, so their assigned TRU values are likely to be too low. Based on this information, every container is expected to be RH, and AK suggested that each also contains TRU material.

In addition to the above, EPA examined the isotopic composition of the stream based on AK data as summarized in References C359 and U332. Every c ontainer from the waste stream that was examined had an AK-assigned gram value for 239 Pu and 235 U, with the values assigned via use of scaling factors (see item 3) to the following radio nuclides: 113m Cd, 144 Ce, 152 Eu, 154 Eu, 155 Eu,

241 Fe, 54 Mn, 147 Pm, 106 Ru, 125 Sb 151 Sm, 123 Sn, 126 Sn, 90 Sr, 99 Tc, 127 Te, and 93 Zr. ANL-CCP Reference C359 reported the weight percent of 239 Pu and 235 U for each container, as well as other nuclides for which a calculated weight was provided . Data presented suggested that the per drum weight percent 239 Pu varied from 24%-72%, with an average of approxim ately 48%. For

235 U, the content varied from approximately 11% to 60% , with an average of approximately 50%. The remaining approximately 2% not accounted for by 235 U and 239 Pu is represented by the gamma emitters listed above, as well as by 241 Am, 242 Am, 243 Am, and other radionuclides reported for four of the 45 containers. This analy sis shows that the per-drum 235 U and 239 Pu values are expected to vary, but should average app roximately 50-50 on a weight percent basis. It should be noted that AK suggests that Drums 7664 2-78117 (AK-assigned drum numbers) appear to have approximately 40% Pu and 60% 235 U, while Drums 81790-81799 contain approximately 60% 239 Pu and 40% 235 U, indicating that these drums may have somewhat different isotopic signatures [see item (3) for ANL -CCP’s assessment of the validity of AK data].

4 AGHCF is the Alpha-Gamma Hot Cell Facility at ANL- E.18

Figure 1. Interior of AGHCF Hot Cell Showing Waste Material Still In Cell

Figure 2. Exterior View of AGHCF Hot Cell19

Figure 3. Interior View of a Hot Cell Showing Wast es Typical of AGHCF

EPA recognizes that the accuracy of these values ha s been questioned by ANL-CCP, and EPA believes this analysis generally indicates a compar able isotopic composition within the stream. On this basis, EPA concludes that the waste stream was appropriately defined based on the similarity of radiological components.

This examination was performed only for the purpose of verifying the waste stream assignment, and not for the purpose of assessing the adequacy o r appropriateness of the per-drum radiological values. The above analysis applies only to the ret rievably-stored portion of the waste stream. The material remaining in the hot cell that will be newly-generated cannot be assigned to any waste generating campaigns, and will be most accura tely defined from a radiological perspective on a waste stream basis. The addition of any new w aste streams not approved under this baseline is a T1 change. (See Table 1, where this is includ ed as a T1 change.) Additionally, the

modification of this waste stream to include additi onal containers beyond the 45 containers included in CCP-AK-ANLE-500, Revision 3 is a T1 cha nge. (See Table 1, where this is included as a T1 change.)

(2) The identification of HLW, TRU vs. LLW, and Sp ent Nuclear Fuel was examined.

CCP-AK-INL-500 indicates that while samples of spen t nuclear fuel were assessed to determine composition (References P344, P349 and P602), the a ctual spent nuclear fuel is separate from the RH debris waste generated through testing of this f uel, and is therefore not included in this waste stream. ANL-CCP representatives interviewed indica ted that HLW is by definition not included in this waste stream. See item (16)

, below, for discussion of load management.20

(3) The drum-specific AK data were assessed, inclu ding ANLE AK-based characterization methodology presented in CCP-AK-ANLE-500 for the re trievably-stored portion of the

waste stream.

ANL-CCP is required to obtain and evaluate as much drum-specific information as possible for RH waste. Drum-specific AK data for each of the re trievably-stored containers was identified by ANL-CCP, including both physical and radiological c haracterization information. The physical composition was assessed as part of item (1), above . The radiological AK data as it pertains to

waste stream identification was also evaluated unde r item (1), above. Technical analysis with respect to how this AK data may be used is discusse d herein.

CCP-AK-ANLE-500 presents a characterization activit y performed by ANLE to assign radionuclide composition to each of the retrievably -stored waste containers in waste stream AERHDM. This method was formalized in 1996. Groups of cans were administratively combined into campaigns based on common waste gener ation dates. For each campaign, the AGHCF activities performed in the cell during the c ampaign period were determined from ANLE’s Fissile Inventory Management System (FIMS), and the 235 U and 239 Pu contents of the materials tested in the hot cells during the time p eriod were ascertained. ANLE assumed that when fuel segments were mounted, 50% was lost as sw arf (shavings and chippings of metal), and 75% of the swarf was ultimately collected with the remaining 25% considered to have been in the form of dust and associated small particle s ize debris. Of this 25%, it was assumed that

7.5% was fixed on the cell’s surface and not in the waste, while the remaining 17.5% was assumed to be in the RH waste. ANLE assigned Pu an d 235 U values to each drum, and also assigned fission products using surface dose rates and applied scaling factors derived from the AGHCF Safety Analysis Report. ANL-CCP representati ves indicated that these scaling factors were based in part on the maximum allowable amount of fission products within the cell, based on the facility’s authorization basis. ANL-CCP rep resentatives also indicated that derivation of the scaling factors was complex and difficult to fo llow based on the AK record. Data from this effort is presented in several references including C349 and U332. ANL-CCP representatives indicated that the method used by ANLE was incomple te, and did not include all of the materials managed in the hot cell during the specific campaig n interval. Because the scaling factors were assigned based on the maximum allowable amount of f ission products within the cell based on the facility’s authorization basis, the AK data, wh ile useful, was not accurate on a drum-specific

basis. This determination was not documented in t he AK summary, so ANL-CCP created a freeze file changed to CCP-AK-ANLE-500 as follows:

Replace the last paragraph of Section 5.4.2.1 with the following:

The stated purpose of the method employed by Argonn e to estimate the radiological composition in individual waste containers was to a ddress site accountability requirements and to comply with the maximum allowab le fissile content of RH TRU drums. While the Argonne reported radiological con tent of containers in this waste stream was used to support the CCP waste stream del ineation, RH, and TRU determinations, the Argonne methodology did not pro duce results adequate for the purposes of WIPP certification. For this reason, i t is not appropriate to compare the Argonne estimates to the results of the CCP radiolo gical characterization activities in AK accuracy evaluations. The approach employed by CCP to fully characterize this waste

stream is described in Section 6.0 below, and the r esults of the CCP radiological21

characterization are documented in CCP-AK-ANLE-501 (Reference 13, C350, P051, P414).

EPA compared the AK-derived values for 239 Pu, 235 U, 90 Sr, and 137 Cs with those that were derived by the dose-to-curie (DTC) method for Drum Nos. 810, 815, 817, 820, 824, and 826. This comparison showed that the AK-derived values f or 239 Pu and 235 U were generally approximately one order of magnitude lower than tho se determined by DTC, while the AK-assigned values for 137 Cs and 90 Sr values were as much as two orders of magnitude l ower. Differences in these values are expected because th e ANLE values did not take into account all of the activities identified in the FIMS for the sp ecified campaigns. The ANL-CCP process applies the same scaling factors to the whole waste stream, while the ANLE AK process considered waste on a campaign or container basis. ANL-CCP representatives stated during the inspection that ANLE’s scaling factors would be “co nservative,” i.e., would result in higher than actual values, because the scaling is based on maxi mum allowed fission products in the cell, not measured values. If this is the case, the disparit y between the true drum values and that obtained by DTC calculations may be greater than the AK-DTC comparison showed. Based on this analysis, use of the AK data as the absolute value of individual drum contents is not supported by the AK record, although comparison of the total was te stream contents as provided by AK with values derived through DTC would support the use of stream rather than drum-specific scaling factors. Performance of this analysis after full c haracterization of the approximately 45 drums in the stream would provide information directly relev ant to the use of waste stream scaling factors in the future. In the proposed decision EPA specif ied that ANL-CCP perform a comparison of

radionuclide values based on AK with radionuclide v alues derived by the application of the application of DTC/scaling factors and provide this comparison to EPA as a T2 change. EPA received a comment objecting to obtaining this info rmation as a T2 change. (See Attachment C, CBFO Comment No. 9). Upon review, EPA concurs with the reasoning provided in the Comment. (See Attachment C for EPA response to Com ment No. 9). Upon completion of the

final DTC determination for each of the 45 drums in this waste stream, ANL-CCP must notify EPA that these determinations are complete through a T2 change notice. EPA may then request

these results or other related data from ANL-CCP in order to compare how the data sets compare. Consistent with EPA’s authority under 194 .24(h) EPA may request new or additional information when it is necessary to ensure continue d compliance with EPA regulations. Providing notification of the completion of the fin al DTC determination for each of these containers is a T2 change. (See Table 1, where thi s is included as a T2 change).

(4) Sufficiency of the AK Summary was evaluated, a s well as implementation of AK as required

in Attachment A of the WCPIP.

Attachment A of the WCPIP specifies that the follow ing be included in AK Summaries: Executive Summary, Waste Stream Identification Summ ary, AK Data and Information description, Program Information, Waste Stream Info rmation, Qualification of AK Information, and Container-Specific Information. Furthermore, A ttachment A mandates a process that should be followed to collect and analyze AK data, similar to that used for CH waste. Both the content of the AK Summary and sufficiency of AK implementat ion were assessed.

CCP-AK-ANLE-500 represents ANLE waste generated in the AGHCF from 1993–2003; waste generated prior to this date was shipped to INL for storage and is described in

CCP-AK-INL-500. Most of the references and technic al content within the two AK documents22

are the same, although the general types of reactor pins managed prior to 1993 (fast fuel) are different than the predominant types tested after 1 993 (light water reactors). The reason that shipment to INL ceased is not presented in either d ocument, and its inclusion would help to clarify whether this change represents a process br eak or changes in pin composition, or is based on other, non-technical reasons.

Chapter 6 of CCP-AK-ANLE-500 presents the general c haracterization methodology as it relates to AK and the qualification methods for each DQO. This information is satisfactory to the extent that the DQO methods are identified for general AK, but the section does not differentiate between AK generated prior to an approved quality a ssurance (QA) program and requiring 194.22-based QA qualification, and that obtained af ter program approval. While the overall methods may be the same for this waste stream, futu re streams may employ different methods

for different elements of the waste stream and diff erent AK confirmation requirements may apply.

The AK Summary does not address drum storage in suf ficient detail to determine whether the containers could have become inundated, as was the case for RH wastes at INL (see Docket No: A-98-49, II-A4-69). During the inspection, ANL-CCP representatives provided data indicating

that the drums were stored in surface vaults and th at the likelihood of any secondary water infiltration is minimal. EPA expects every AK summ ary to address the storage and management of RH containers to ensure that secondary events th at would impact the content or characteristics of the waste have not taken place. References were requested and examined with respect to the specific phrases in the AK Summary attributed to th at reference. However, several documents

listed as references in CCP-AK-ANLE-500 are not ref erenced in the text, and other references appear to have minimal relevance to AERHDM. EPA ex pects that ANL-CCP will continue to refine each AK summary, streamlining the document t o ensure relevancy of information in the future. Additionally, Chapter 7 discusses tracking of ongoing characterization data using a tracking spreadsheet, but the intent of the WCPIP r equirement to collect drum-specific AK data

is to ensure that AK data are assembled and assesse d. Examination of the AK Source Document Summary and other reference lists in CCP-AK-ANLE-50 0 and -501 show that these two documents do not completely reference relevant and appropriate support documentation (e.g., P801-P832, U801-U838, C801-C817). In short, the AK Summaries appear to reference documents not specifically relevant to Waste Stream AERHDM and to exclude references that are relevant and are documented in the Acceptable K nowledge Source Document Reference List. ANL-CCP is expected to continually refining these d ocuments to ensure completeness. ANLCCP should address the above potential changes to t he AK summaries in forthcoming changes,

and revisions to CCP-AK-ANLE-500 and CCP-AK-ANLE-50 1. CCP should notify EPA of these changes as a T2 change. Also, changes made t o AK documentation as a result of revisions of the WCPIP EPA requires that ANL-CCP notify EPA t hrough a T2 change notice when

revisions to these documents have been made and are available. Consistent with EPA’s authority under 194.24(h), EPA may request this information i f EPA deems it necessary to ensure continued compliance with EPA regulations. (See Ta ble 1 where this is included as a T2 change.)

CCP-AK-ANLE-500 included the content mandated by th e WCPIP, and the general process outlined in the WCPIP for AK data assembly was foll owed. ANL-CCP submitted a freeze file change to this AK Summary that documented ANL-CCP’s analysis of drum-specific AK data,23

and why those data are not acceptable for use in AK accuracy calculations [see Items (3) and (15)].

(5) Data traceability was examined.

As indicated in item (1) above, Reference U332 incl udes AK data for each drum in the waste stream, specifically WMO-195 Radioactive and Mixed Waste Disposal Requisitions that include detailed information regarding drum contents, inclu ding physical descriptions of drum contents in each 7-gallon container. Calculated isotopic co mpositions for each drum are also provided. When asked whether similar data would be generated for each newly-generated container, ANLCCP representatives indicated that they had no info rmation as to what the ANL personnel might generate based on site-specific requirements that a re outside of the ANL-CCP program.

ANL-CCP representatives provided historic AK data f or Drums 810, 815, 817, 820, 824, and 826, represented by AK container IDs 76642, 76650, 76652, 78103, 78107, and 78109, respectively. AK data provided included Plutonium Fissile Gram Equivalence (FGE) Calculation sheets, as well as selected WMO-195 Dis posal Requisitions pages as presented in U332. Visual Examination Data Forms completed by A NL-CCP as part of their characterization program were provided for each drum, showing that e xamination of VE tapes for the selected drums had been completed. Waste Container Dose-to- Curie Conversion (DTC) Records for each

container that documented the DTC calculations were also provided. Based on this information, traceability of container data from the AK record t hrough current analysis is demonstrated. Scaling factors are assigned through the assembly, analysis, and modeling of fuel pin data, and traceability and technical viability of the data mu st be demonstrated. Examining the FIMS database, as documented in AK Reference U335, asses sed traceability of the various PIN data to the AK record. ANL-CCP representatives performed a dditional data searches and identified more information that was not presented in the FIMS , or at least not in the portion of the FIMS that was originally examined. ANL-CCP indicated th at a detailed data assembly process was

followed to assess the information and obtain fuel pins relevant to the ANLE analysis, but this process is not formally documented. ANL-CCP summar ized the process they used to assemble and assess fuel pin data as follows:

The first set of pins was identified by Terri Bray by a query she did from her FIMS database. Incidentally, a FIMS database query is w here the INL population of pins came from as well. George Fenske (from ANL) worked on t his list of pins and provided us with a spreadsheet (U841) of all the relevant informatio n. We collected the documentation files and made them part of the AK record (P801-P83 2; U801-U838; C801-C817).

There were 2 different pin collection efforts going on simultaneously. INL was getting pin information on the INL population from Bud Fabi an at Argonne, and we (CCP) were getting pin information on the ANL population from George Fenske. INL went through cutting and grinding logs and identified several ad ditional pins of interest. INL documented those pins in an EDF (P614). We (CCP) w ent to Argonne and collected source documentation in order to identify compositi on, burnup, etc., for the pins that were identified for the INL population (U839).

We also took a trip to ANL to go through the sectio ning slips (U840 and U826), which they began using in 1994, to ensure that all applic able ANL pins had been identified. We24

identified several items of interest - we identifi ed material type, etc., and sent the list to Jene. Jene went through the list and eliminated al l but 9 of the pins, either because they were unirradiated or cladding, etc. These addition al 9 pins plus the original list from George Fenske are all included in Jene’s calc packa ge (U882). Upon examination of these 9 pins, Jene determined that further data col lection efforts were not needed because the necessary information was contained in the sour ce documents that had already been collected (P801-P832; U801-U838; C801-C817).

It should be noted that ANL-CCP did not prepare an Engineering Design File (EDF) or an equivalent document that specifically identifies th e additional data assembled or the assembly process. None of the EDFs cited above are included or referenced in CCP-AK-ANLE-500 or CCP-AK-ANLE-501, which document the review process, and accordingly these EDFs were not examined during the inspection. While these refere nces are included on the AK Source Document Reference List, relevance of the reference s to the pin data assembly process could not be ascertained until ANL-CCP clarified the process post-inspection. Also, the source document

reference list included several references not incl uded in document-specific reference lists at the back of CCP-AK-ANLE-500 or CCP-AK-ANLE-501 (see ite m (4), above, for additional discussion). While the process described above app ears logical, it must be fully described, include reference to the appropriate document(s), a nd be placed in the AK Record. The AK record must be complete and accurately document the processes for which approval is granted. Accordingly, the process by which fuel pin data wer e compiled and assessed that was provided to EPA post-inspection by e-mail should be formally documented in and submitted to the auditable record. EPA requires that ANL-CCP notify EPA through a T2 change notice when this information (listing of the references documenting the assembly of fuel pin data) has been completed and is available for EPA review. Consist ent with EPA’s authority under 194.24(h), EPA may request this information if EPA deems it ne cessary to ensure continued compliance with EPA regulations. (See Table 1 where this is i ncluded as a T2 change.)

(6) Sufficiency of AK Support Documents and Relate d Document Tracking was evaluated.

An AK Source Document Reference List was prepared u sing unique identifiers for the different document types following the format used by ANL-CCP for CH wastes. The listing provided is based on CCP-TP-005 Revision 17, Attachment 4. The listing appears complete, and is easy to

understand because it follows the same format that ANL-CCP uses for CH waste streams. It should be noted that EPA only examines support docu mentation specific to the technical element being referenced in the AK summary that caused that support reference to be selected for examination. EPA does not perform a full analysis of all data, but instead only checks the

document to be sure that it addresses the technical issue for which is it referenced in the text of the AK summary.

(7) Interpretation of WCPIP, with respect to conte nts of the Certification Plan and Confirmatory Test Plan, was evaluated.

ANL-CCP provided a combined site-specific RH TRU Wa ste Certification Plan for 40 CFR 194 Compliance and Confirmatory Testing Plan (see item (8), below, for commentary on this Plan) that describes how DQOs will be met. In the case o f ANL, and as stated in Chapter 6 of the AK summary, the ANL-CCP intends to use a combination o f methods to qualify AK data. EPA interprets this to mean that ANL-CCP commits to col lecting AK data for every RH waste stream,25

and all AK for each DQO will be technically validat ed or verified by characterization methods presented in the WCPIP, primarily AK confirmation. While the reported methods, on the whole state, that AK is the basis for all DQOs that will be verified in various manners, it does not

differentiate between the subsets of methods that w ill be used based upon the nature of the waste. For example, the newly-generated component of the w aste will undergo actual VE while the physical attributes of the retrievably-stored porti on of the stream will be assessed through VE tape review. In the future versions of this and ot her AK Summaries, EPA expects to see this

differentiation.

Also note that the WCPIP states that if AK is insuf ficient, “additional information” will be collected using the same characterization methods a s used to “qualify” AK, but this data, in turn, will not require qualification. It is unclear whet her any of the information collected to meet DQOs as presented in Table 6 of CCP-AK-ANLE-500 is considered this additional information.

(8) Content and technical adequacy of the Confirma tory Test Plan was evaluated.

The WCPIP requires the following to be included in the Confirmatory Test Plan (CTP):

• A description of the waste stream or waste stream l ots to which the plan applies

• A description of the confirmatory testing proposed, including the percentage of waste containers that will be subject to confirmatory tes ting

• An explicit description of the WC DQOs and QAOs tha t will be satisfied with the data being qualified

• A description of the DQOs and QAOs that will not be confirmed with the data being qualified and an explanation of how compliance with those DQOs and QAOs will be

demonstrated

• A description of how the tested subpopulation will be representative of the waste stream

or waste stream lot

The WCPIP requires submission of a CTP when confirm atory testing is to be performed outside

of that described in the PIP. ANL-CCP indicates th at the CTP was provided because the DTC method deviates from that presented in the WCPIP, b ut that the CTP will always be used to communicate the full characterization methodology t hat will be used for a given ANL-CCP waste stream. Furthermore, ANL-CCP will combine th e EPA Certification Plan with the CTP, to ensure that EPA is fully informed of the charact erization process intended for a given ANLCCP waste stream. This approach is acceptable.

As indicated in Item (7), above, ANL-CCP provided a combined Confirmatory Test Plan (CTP) and Site Specific Certification Plan (CP) for AERHD M. The Plan appears to address many of the required elements that must be in a CTP, but th e following statement is made with respect to the DQOs for TRU Waste Determination and Activity D etermination:

The required site methodology for comparing radionu clide information from the confirmation with the AK record is performed in two parts. The work required to develop the isotopic abundances has been completed and is d escribed in CCP-AK-ANLE-50126

(Reference 3). It establishes that there are no si gnificant discrepancies between the AK information used in the modeling and the qualificat ion of that AK (modeling and sampling)...

It was not clear what ANL-CCP meant with regard to lack of discrepancies between AK information used in modeling and qualification of t hat data. Inclusion of the AK accuracy discussion under the Defense Determination DQO was found to be confusing, as it should be in a separate section. Also, sites are required to deve lop stream-specific AK accuracy evaluations with respect to radiological characteristics, and t he discussion presented in the CCP-AK-ANLE502 did not adequately address why ANLE AK drum-spe cific radiological data were not being used in AK accuracy determinations for TRU waste de terminations and for Activity

Determinations.

To address these concerns, ANL-CCP representatives prepared the following freeze file changes

to CCP-AK-ANLE-502:

1. Move the AK accuracy report discussions from 4.1 to 4.0. The text begins with “An annual AK Accuracy Report...) and continues to the en d of 4.1.

2. In the AK accuracy discussion, currently the 1 st paragraph on page 12 beginning, “The radiological characterization...” Add as a new 2 nd sentence “The process used to compile the AK information used as input data in the model (fuel characteristics and operating history), was evaluated by comparing this same type of information with mass spectrometry results on a specific set of fuel pins .”

3. Add as a new paragraph (between “These two evaluati ons....” and “Consequently...”

“Argonne had developed radiological information for containers in this waste stream primarily for the purposes of estimating the fissil e content of individual waste containers to comply with accountability requiremen ts and to comply with the

maximum allowable fissile content of TH TRU drums. The Argonne methodology did not produce results adequate for the purposes o f WIPP certification. For this reason, it is not appropriate to compare the Argonn e estimates to the results of the ANL-CCP radiological characterization activities fo r purposes of AK accuracy

evaluations.”

4. Same section, in the paragraph “DQO for TRU Waste D etermination.” Add as new 3 rd

sentence, “The process used to compile the AK infor mation used as input data in the model (fuel characteristics and operating history), was evaluated by comparing this same type of information with mass spectrometry results on a specific set of fuel pins.” In the

current 4 th sentence, revise to “...of the reported measurement results as documented in the QA Equivalency report (Reference 4) (nanocuries per gram)...”

5. Same section, in the paragraph “DQO for Activity De termination.” Add as new 3 rd

sentence “The process used to compile the AK inform ation used as input data in the model (fuel characteristics and operating history), was evaluated by comparing this same type of information with mass spectrometry results on a specific set of fuel pins.”

6. Same section, “DQO for Physical Form.”27

EPA requires that ANL-CCP notify EPA through a T2 c hange notice upon completion of any

revision to CCP-AK-ANLE-502 that reflects these cha nges. Consistent with EPA’s authority under 194.24(h), EPA may request this information i f EPA deems it necessary to ensure continued compliance with EPA regulations. (See Ta ble 1 where this is included as a T2 change.) Additionally, because CCP-AK-ANLE-500, C CP-AK-ANLE-501 and CCP-AKANLE-502 are integral to the ANL RH characterizatio n process, substantive modifications to any of these documents that have the potential to a ffect the characterization process are T1 changes. (See Table 1, where this is included as a T1 change.)

The revised CTP also addresses DQOs, including a se ction on AK QAOs and application of AK accuracy. The adequacy of DTC with respect to addr essing related DQOs is addressed in Section 8.2, as are the QAOs for that method. The DQO for RH waste determination is satisfactory. The QAOs associated with VE at the t ime of packaging have not been evaluated, because ANL-CCP has not yet implemented this proces s and EPA has not evaluated this method

for RH waste at ANL.

The specific relevancy of the LANL mass spectrometr y data to the ANLE pins and overall characterization process was discussed with ANL-CCP representatives, because CCP-AKANLE-502 states that there are “no significant disc repancies between the AK information used in the modeling and the qualification of that AK (m odeling and sampling).” ANL-CCP representatives stated that the “AK information use d in the modeling” is the ANLE fuel pin data assembled and evaluated by Mr. Jene Vance. ANL-CCP also indicated that “qualification of that AK” refers to the qualification of fuel pin data (A NLE included) through a demonstration that fuel pin data (LANL) used in ORIGEN2.2 can be valida ted using mass spectrometry data for those same fuel pins. ANL-CCP representatives clar ified that the LANL mass spectrometry data are only relevant in that the overall use of ORIGEN2 .2 and related codes using fuel pin data were validated by the comparison of the fuel pin data wi th mass spectrometry data for the same fuel pins. The ANLE fuel pins are not “the same” as LAN L or INL fuel pins; ANLE is predominantly RERTR (a process that generated fuel pins) and light water reactor related, while INL/LANL fuel pins are predominantly breeder reacto r (e.g., EBR-II) fuel pins. Therefore, the isotopic composition of the two is expected to be s omewhat different, as evidenced by the development of different scaling factors for the AN LE and INL waste streams. While LANL mass spectrometry data helped show the need for (an d ways to create) adjustment factors, the LANL data are not direct inputs to ANLE specific ad justment factors. ANL-CCP representatives

indicated that the intent of the demonstration was to show that because the same process was used to assemble and assess ANLE and INL pin data, the overall process has been demonstrated to be satisfactory. This clarification was helpful , but CCP should provide documentation of the pin assembly and review process prior to calculatin g package development [see item (5), above]. EPA requires that ANL-CCP notify EPA through a T2 c hange notice upon completion of

modifications to CCP-AK-ANLE-500 and/or CCP-AK-ANLE -502 as a result of the freeze file changes. Consistent with EPA’s authority under 194 .24(h), EPA may request this information if EPA deems it necessary to ensure continued complian ce with EPA regulations. (See Table 1 where this is included as a T2 change.)

(9) Content and technical adequacy of the Characte rization Reconciliation Report was evaluated.

The content of CCP-TP-506, Revision 1, CCP Preparation of the Remote-Handled Transuranic Waste Acceptable Knowledge Characterization Reconci liation Report, was evaluated to28

determine whether this document reflected the assem bly of information required in the WCPIP.

The content of the Characterization Reconciliation Report (CRR) was examined to see whether this report reflected requirements of CCP-TP-506, t o ensure that the CRR addressed required elements. The CRR Report was evaluated to determin e the completeness and adequacy of its contents as required in the WCPIP, including but no t limited to:

• Specification of applicable site and waste stream

• A listing of each DQO

• Data from the AK record that addresses each DQO

• AK source document references that support/provide the data

• A listing of AK record discrepancy resolutions, if any, that are relevant to each DQO

• Documentation, including specific references, of ho w the AK data for each DQO were qualified, such as batch data reports, corroborativ e data, proceedings of a peer review,

etc.

• Radiography and/or VE summary to document that liqu ids greater than 1 percent are absent from the waste and to confirm AK concerning the physical properties of the waste

• A summary presentation of radiological measurement data used to meet the DQOs and to

confirm AK

• A complete AK summary

• A complete listing of all container identification numbers used to generate the WSPF, cross-referenced to each batch data report

• A listing of AK discrepancies generated by an AK qu alification process and the corresponding resolutions

• Signature of the SPM

The example examined included all of the above requ irements when examined as a whole. The CRR DQO worksheet (Attachment 3 of CCP-TP-506) shou ld include the 10 WIPP-tracked radionuclides as part of the DQO assessment process , because this is a DQO as supported by EPA’s CRA review. Site representatives recognized this, and indicated that the CRR will be revised when the revised WCPIP is in place. EPA’s rule and CRA determinations have indicated that the 10 WIPP-tracked radionuclides presented in the CRA have specified quantities that serve as de facto repository limits. Therefore, these ra dionuclides should be included in the DQO analysis. EPA requires that ANL-CCP notify EPA thro ugh a T2 change notice upon completion

of the revised CRR that includes the 10 WIPP-tracke d radionuclides. Consistent with EPA’s authority under 194.24(h), EPA may request this inf ormation if EPA deems it necessary to ensure continued compliance with EPA regulations. (See Table 1 where this is included as a T2 change.)

(10) Use of a Correlation and Surrogate Summary Fo rm was evaluated.

Completion of a Correlation and Surrogate Summary F orm is required when AK information

from a related CH waste stream is used in the RH WC process. ANL-CCP representative29

indicated that CH data was not used in this manner. However, a Correlation and Surrogate Summary form was completed to support the correlati on of LANL mass spectrometry data to ANL data for subsequent use in AK qualification. T he form states:

Information and records retrieved from LANL were us ed not only in the radiological characterization of LANL’s RH TRU waste, but also in the demonstration of the adequacy of the ANL-E input information and the ove rall modeling approach. A comparison between sampling data and ORIGEN 2.2 mod eling at LANL demonstrated that the modeling approach used for ANL-E is a soun d approach for determining scaling factors for use in characterizing the RH TRU debris waste stream...

The use of a correlation and surrogate summary for this purpose is satisfactory, noting that it should reference detailed reports, memos, or other data sources that support the issue. See item (5), above, for an evaluation of ANL-E input d ata traceability, data adequacy, and the overall modeling approach.

(11) Personnel training was evaluated.

Training records for Kevin Peters (AKE), Steve Scha fer (AKE), Lisa Price (AKE), Larry Porter (SPM), Michael Walantine (SPQAO), and Jene Vance (S ME/DTC) were evaluated during the INL inspection, with respect to: (1) training to t he RH TRU WCPIP, (2) non conformance and corrective action processes, (3) the AK procedure p resented in Attachment A of the WCPIP, (4) site-specific training relative to the contents of the subject waste stream(s) and (5) determination of radiological contents of indiv idual drums. Each person demonstrated training in the first four areas.

With respect to determination of radiological conte nts of each drum, the resumes of Jene Vance, Kevin Peters, and Steve Schafer were examined. Jen e Vance’s expertise had been examined at INL (see Docket No: A-98-49, II-A4-69,) because he a ssembled and assessed INL and ANLE AK data that were used to derive scaling factors th at were used in conjunction with DTC to determine radionuclide content. Although Mr. Vance did not show direct training with respect to this area, his resume showed sufficient expertise. Mr. Peters’ and Mr. Shafer’s resumes showed experience in the assembly and evaluation of AK dat a, including radiological information. It is expected that individuals associated with AK data a ssembly and interpretation, including SMEs,

will have read all RH AK summaries and other summar ies relevant to the waste stream being audited, and will have demonstrated experience or e xpertise in the assembly and interpretation of AK radiological, physical, and other data.

(12) The use of LANL mass spectrometry information was examined with respect to relevance

to ANLE waste.

ANL-CCP has proposed the use of mass spectrometry d ata obtained from LANL to verify ORIGEN2.2 code results. The ANLE pins and resulting waste were contaminated from destructive examination of fuel pins from different reactors than the INL/LANL pins. Therefore, the mass spectrometry data are useful only in valid ating the use of ORIGEN2.2, and the mass spec data were not collected from pins common with the ANLE pins. ANL-CCP representatives indicated that they did not intend to demonstrate t his relationship; instead, ANL-CCP intended to demonstrate the commonality of the type of data, da ta assembly/interpretation process, and30

relevant calculations between INL and ANLE to show that the same process used to calculate INL scaling factors can be used for ANLE waste. Th erefore, traceability of LANL mass spectrometry data to the specific pins used to dete rmine ANLE scaling factors is apparently not required for this particular waste stream. See ite m (8), above, for additional analysis of fuel pin data, and item (5) for the ANLE Pin Data traceabili ty analysis.

(13) NCRs and Discrepancy Resolution Forms were exa mined.

ANL-CCP personnel provided the following: NCR-RHANL- 0002-06, Revision 0, NCR dealing with waste can nos. 292 (Drum 00825), 257, and 260 (Drum 00829), dated July 12, 2006; Discrepancy Resolution (DR) DR013, Discrepancy Reso lution Form Regarding the Argonne Waste Population of 44 drums versus 45 drums, S. Sc hafer, August 28, 2006; DR11; and, DR10. DR11 concerns waste requisition and video discrepan cies, while DR10 concerns a discrepancy regarding the volume of a 7-gallon waste can. Base d on this information, it appears that ANLCCP can adequately prepare NCRs and DRs to document nonconforming items or containers, as well as the types of discrepancies presented for re view. EPA was not provided a specific example of an AK-AK discrepancy resolution involvin g radiological composition of waste, even though ANL-CCP representatives indicated that drum/ lot AK data had been assessed and was not called upon to provide absolute or even qualita tive data on a drum or lot basis. ANL-CCP did propose, however, to include this analysis as a “freeze file” change to CCP-AK-ANLE-500 [see item (3), above]. AK-AK discrepancies should be included in the AK record, particularly if

AK data are found to be insufficient.

(14) A Waste Stream Profile Form was examined.

An example Waste Stream Profile Form was examined f or Waste Stream Number ANL-AERHDM. The form included required line items as presented in the WCPIP, Attachment 4; the CRR and RH AK summary are also required for submission to CBFO to allow assessment of the waste stream profile form (WSPF). It is und erstood that this form is abbreviated because it was provided for audit purposes only, and it is expected that the completed form will include more AK data, checklists, etc., to better present t he required information. See comments on the CRR and AK summary for additional information. EPA requires that ANL-CCP notify EPA through a T2 change notice upon completion of the a ctual, completed WSPF and all related attachments. Consistent with EPA’s authority under 194.24(h), EPA may request this information if EPA deems it necessary to ensure con tinued compliance with EPA regulations. (See Table 1 where this is included as a T2 change. )31

(15) AK accuracy was assessed.

The WCPIP requires AK accuracy be assessed in three areas: reassignment of the waste to a different Summary Category Group; reassignment of t he waste to a different waste stream; and stream-specific assessment of radiological paramete r accuracy. The AK Accuracy Report does not call for comparison of AK drum-specific radiolo gical data as a measure of AK accuracy for TRU waste determination or radiological component/a ctivity determination. ANL-CCP revised the AK Summary to justify this exclusion, as ANL-CC P believes that the per-drum radiological AK data calculated by ANLE is inadequate and theref ore cannot be used for comparison purposes. See item (3), above, for EPA analysis of this conclusion. EPA initiated an EPA Inspection Issue Tracking Form for the concern disc ussed below (see Attachment B.4 for a copy of this form):

EPA Concern No. EPA-ANL-RH-CCP-AK-06-003C:

Section 4.1.1.2 of the WCPIP states the following: “The percentage of waste containers which require reassignment to a new SCG or new waste stre am ...will be reported as a measure of AK Accuracy”. The AK Accuracy Report dated August 28, 2006, reports SCG accuracy, but not

waste stream accuracy.

Resolution: This concern did not require an immediate response, noting that the AK accuracy document would be among those documents expected to require revising when the latest revision of the WCPIP is approved. EPA’s concern stated tha t revising the AK Accuracy Report to address the above requirements might be completed w hen other revisions are in process, e.g.,

addition of the 10 WIPP-tracked radionuclides as a DQO.

Status of Concern: EPA considers this concern closed. EPA requires th at ANL-CCP notify EPA through a T2 change notice when the revised AK accuracy memorandum is complete and available for EPA review. EPA expects that the AK accuracy memoranda will be prepared annually, at a minimum. Consistent with EPA’s auth ority under 194.24(h), EPA may request

this memorandum or related information if EPA deems it necessary to ensure continued compliance with EPA regulations. (See Table 1 wher e this is included as a T2 change.)

(16) Load Management was assessed.

The possibility that containers may exhibit less th an 100 nCi/g TRU was evaluated. AK data presented in U332 and summarized in C349 indicated that three of the 45 containers had AKassigned TRU concentrations of less than 100 nCi/g based on 239 Pu, noting that none of these containers had assigned 241 Am, 238 Pu, 240 Pu, 241 Pu and 242 Pu values so the assigned value of 100nCi/g is likely to be too low. ANL-CCP represen tatives also indicated that based on the application of the scaling factors developed for th is waste stream, a container with a measured 1- meter dose rate of 3.8 mR/hr results in a TRU Alpha Concentration of 101 nCi/g, and containers

with measured dose rates below this would be consid ered non-TRU and would be segregated for shipment in a different waste stream. The EPA insp ection team verified this calculation using the spreadsheet shown in Section 8.2 and the input 1-meter dose rate of 3.8 mR/hr.

The average reported contact dose rate in the AK re cord for each of the 45 containers is over 17 rem/hr, with a range of 0.58 to 180 R/hr. The C TP states, “In the rare event that a waste32

container might be 200mRem/hr at its surface (and a s such, RH waste), but less than

200 mRem/hr at the surface when three such containe rs are loaded into an RH-72B canister, the

canister will still be considered RH waste as defin ed in the LWA.” EPA expects that every container emplaced in the RH 72B canister will exhi bit a contact external exposure rate (dose rate) equal to or greater than 200 mRem/hr prior to loading. If a container measures less than this value, IANL-CCP will consider the container to be that of contact-handled waste and will remove it from the RH waste stream. The implementa tion of load management for RH waste by ANL-CCP is a T1 change. (See Table 1 where this is included as a T1 change.)

(17) AK Qualification Method identification for ea ch DQO was assessed.

ANL-CCP representatives indicated that the “qualifi cation” method for all DQOs except for RH waste determination will be met through application of characterization methods to check AK. ANL-CCP indicates that confirmatory testing will be used for each DQO, but also implies that establishment of an equivalent QA program may be us ed to qualify the mass spectrometry data that are required to check ORIGEN2.2 runs.

EPA differentiates between the processes of characterization/confirmation and qualification , the later being wholly a QA function and beyond the pur view of this EPA inspection. EPA’s term

characterization does not modify the process proposed by ANL-CCP, b ut is a distinct language difference in that EPA’s characterization program d oes not perform QA data qualification. Rather, EPA examines the collection process whereby characterization data used to verify the AK data for relevant DQOs are assembled. Regardles s, EPA notes that ANL-CCP has committed to verifying AK for each DQO. Verificati on includes the technical evaluation of confirmation methodologies, the results of the peer review process, and corroborating data, noting that corroborating data is not an allowed me thodology in the version of the WCPIP in place at the time of the ANLE inspection.

(18) Attainment of DQOs through AK verification was eval uated.

As a result of the analysis presented in items (1) through (17), above, EPA was able to assess how each DQO will be addressed. The following DQOs must be addressed as per the WCPIP:

- Defense determination

- TRU waste determination

- RH waste determination

- Activity determination (TRU Alpha Activity per cani ster, including quantification and identification of 10 EPA radionuclides)

- Residual liquids

- Physical form, including metals and CPR

All of these DQOs, except for RH waste and defense determination, are based on AK that is confirmed through various WCPIP-allowed techniques or variants on those techniques. RH status is determined through direct dose rate measu rement. DOE is responsible for making a

defense determination as discussed in the AK docume ntation, and cannot be qualified or otherwise verified through confirmatory sampling, e tc. The use of AK to determine all DQOs, with accompanying confirmation or other verificatio n of AK data that EPA evaluated during this inspection, is acceptable to EPA and comports with the fundamental intent of the WCPIP.33

Summary of AK Findings and Concerns

The EPA inspection team identified the concerns rel ated to AK that are discussed above. Copies of the EPA Inspection Issue Tracking Forms are prov ided in Attachments B.4 through B.7. EPA considers all findings and concerns to have been ad equately addressed, and there are no open finding or concerns related to AK resulting from th is inspection.

Baseline Approval

EPA is approving the AK process evaluated during th is baseline inspection. Specifically, the approval is limited to one ANL RH retrievably-store d debris waste stream, AERHMD, consistent with the limitations described in CCP-AK-ANLE-500, Revision 3.

AK Tiers

Based on the inspection and the results discussed a bove, EPA assigns the following tiers:

T1 AK changes that will require EPA review and approval prior to implementation and apply to any new waste category not evaluated during the bas eline inspection include the following:

• Any new waste streams not approved under this basel ine

• Modification of the approved waste stream AERHDM to include additional containers beyond the approximately 45 included in CCP-AK-ANLE -500, Revision 1. The 20

additional

containers identified in the AK summary as being p resent are not included in this waste stream approval

• Substantive modification(s)*** that have the potent ial to affect the characterization process to CCP-AK-ANLE-500, CCP-AK-ANLE-501 or CCP- AK-ANLE-502

• Implementation of load management for any RH waste stream

T1 changes will be reported and documentation will be submitted when ANL-CCP is ready for EPA review. Upon initial review, EPA will inform A NL-CCP and CBFO whether a site inspection is necessary. EPA may request additiona l information, choose to conduct a desktop review, and/or confer with CBFO and ANL-CCP personn el. Upon AK evaluation with or without site inspection, EPA will issue a decision. Only upon receiving EPA written approval may ANL-CCP implement T1 changes.

T2 AK changes that do not require EPA approval prior to implemen tation but require a brief description of the changes to the documents along w ith the notification, include the following:

• Notification to EPA that the final DTC determination is complete for RH containers in the approved waste stream

• Notification to EPA when updates are made to AK docu mentation as a result of WCPIP

revisions**

• Notification that updates have been completed to the following documents:34 o All future revisions of CCP-ANLE-AK-500, CCP-ANLE-A K-501

o Listing of the references that document the assembl y of fuel pin data and review

process

o All future revisions of CCP-ANLE-AK-502

o CCP-AK-ANLE-500 and CCP-AK-ANLE-502 to address free ze file changes

• Notification to EPA that the data package for this d ebris waste stream is completed, including any modifications to the WSPF including t he CRR and AK Summary

• Completion of AK accuracy reports, prepared annuall y at a minimum

Following EPA approval, ANL-CCP will provide EPA wi th information concerning T2 changes on a quarterly basis. When notifying EPA as a T2 c hange that additional information is available, the notification should provide a brief description of the type of additional

information. EPA will then determine whether to se ek the new, additional information from ANL-CCP. EPA will evaluate these changes and commu nicate with ANL-CCP as to whether the changes raise any concerns and require an ANL-C CP response, or whether ANL-CCP can continue to implement the changes. Consistent with EPA’s authority under 194.24(h) EPA may request information relative to these changes if EP A deems the information is necessary to ensure continued compliance with EPA regulations.

8.2 Radiological Characterization

EPA inspected the method by which the required radi ological constituents for each waste

container were determined. The nature of RH TRU wa stes presents considerable difficulty with respect to obtaining meaningful measurement data. Apart from the obvious ALARA

considerations associated with external radiation f ields in excess of 200 mrem/hr, RH TRU waste containers typically contain concentrations of 137 Cs that prevent a meaningful isotopic

determination in the same manner as is done for CH TRU wastes. At this time, ANL-CCP has not proposed to assay RH containers for radiologica l contents. An alternative approach is the use of a scaling factor, which allows the correlation o f an easily measurable gamma emitter such as

137 Cs with difficult-to-measure actinides and TRU radi onuclides. This is the essence of ANL-CCP’s approach to radiological characterization . This method is a complex process and the inspection focused primarily on the following t wo aspects:

• The application of the Dose-to-Curie (DTC) techniqu e to determine a container’s external

gamma exposure rate 5 (dose rate) by correlating the measured dose rate to an activity

concentration for 137 Cs

• Using scaling factors to convert the derived 137 Cs activity to activity values for the other 9 of the 10 WIPP-tracked radionuclides, including t he uncertainty for each

5 The external exposure rate is a numerical value ex pressed in units of rem per unit time (typically mr em/hr) that includes the contributions of all radiations, i.e., neutron, gamma, beta and alpha. The formal d etermination of a container’s RH status is documented in mrem/hr, but for the DTC procedure only a photon (gamma) determ ination is performed and this is referred to informally as a dose rate . For consistency, the term dose rate is used throughout this report.35

This section provides an overview of the ANL RH rad iological characterization process and discusses EPA’s evaluation of the adequacy of ANL-C CP’s radiological characterization program. The checklist in Attachment A.2 identifies the objective evidence that was examined and used to complete the technical assessment for t he DTC aspect. Evaluation of the scaling factors was not amenable to a checklist, and this a spect is discussed in the text directly.

8.2.1 Overview of ANL Radiological Characterization Program

The radiological characterization aspect of the ANL RH WC program that EPA evaluated focused on techniques to characterize containers fr om a single RH TRU waste stream, AERHDM. This waste stream consists of 45 30-gallon drums of debris waste (S5000) that were generated at ANL between February 1993 and February 2002. ANL-CCP estimates that an additional 50 to 100 drums will be generated during the packaging of existing wastes at the

AGHCF. Based on the nature of the waste materials and the types and quantities of information available, ANL-CCP chose the approach of developing a WC protocol that, in their opinion, was best suited for characterizing the population of al l RH TRU waste containers within ANL waste stream AERHDM. Specifically, a single scaling fact or was assigned to fuel pin-related wastes generated from a variety of fuel types, an approach which is essentially the same as that used for RH TRU wastes by INL-CCP. The report for EPA Basel ine Inspection No. EPA-INL-CCP-RH-6.06-8 (Docket No: A-98-49, II-A4-69) describes this approach in detail.

The actual measurement aspect, formalized in CCP pr ocedures, consists of four simple external gamma readings of each waste container (the average value is used), all of which are attributed to a single photon-emitting radionuclide, 137 Cs. From a radiometric perspective, this is a simp le task. The complexity of radiological characterizat ion is contained in the development of the DTC approach that transforms each container’s measu red dose rate into a 137 Cs activity value which, in turn, is used in conjunction with scaling factors to produce concentrations for the remaining 9 of the 10 WIPP-tracked radionuclides an d their corresponding uncertainties.

CCP generated the scaling factors using the Monte C arlo Neutron-Photon (MCNP5), ORIGEN2.2, and MicroShield computer codes, and compa red them to isotopic distribution values based on mass spectrometry (MS) data that we re generated at LANL. Beginning in the 1970s, destructive analyses were performed on 400 f uel pins at LANL to determine the relative abundances of plutonium and uranium isotopics along with isotopes of neodymium. Neodymium-148 is a fission product that is used to c alculate burnup in fuel and is analogous to the fission product 137 Cs. ANL-CCP refers to this use of the MS data as qualifying the

ORIGEN2.2 results with the LANL MS data, and the scaling factors wer e adjusted as a result of the comparison. In general, MS is an excellent ana lytical technique, and use of the MS data to adjust the isotopic scaling factors provided the op portunity to verify the results of the application

of the ORIGEN2.2 codes. A technical assessment of t he LANL MS data used to verify the ORIGEN2.2 codes was performed as part of EPA Baselin e Inspection No. EPA-INL-CCP-RH-6.06-8 (Docket No. A-98-49, II-A4-69) at INL in June 2006. Based on this evaluation, EPA determined that the MS data were te chnically adequate to support ANL-CCP’s use in verifying the ORIGEN2.2 results. Accordingly , the use of MS data to support the ANL RH WC program is not addressed in this report.36

Figure 4 presents a flow chart of the ANL-CCP radio logical characterization process given in CCP-AK-ANLE-501, Revision 0. The conceptual basis for the DTC approach and development of the scaling factors is documented in the 23 calc ulation packages that are listed in Table 10-1 of CCP-AK-ANLE-501, as well as the others listed be low.37Figure 4. Overview of RH Characterization Process atANL-EDevelop Uncertainties inQuantitiesPin Characteristics fromFuel Suppliers andReactor OperatorsU-235 EnrichmentPu-240 EnrichmentU/Pu RatioBurnupLocate and RetrieveRelevant LANLRecordsCalculate FuelComposition for 126PinsMake ORIGEN2.2 Runsfor 126PinsOutputMass SpectrometryResults for 400LANLPinsU and Pu RelativeAbundancesCompare Mass SpecResults to ORIGEN2.2Output for400PinsDetermine AverageAdjustment Factors to Applyto ORIGEN ResultsPost-IrradiationForms for 400 LANLPinsU-235 EnrichmentPu-240 EnrichmentU/Pu RatioBurnupCalculate Fuel Compositionfor 400 Fuel PinsMake ORIGEN2.2Runs for 400PinsOutputApply Average AdjustmentFactors to ORIGEN Resultsfor Fast Reactor Pins andAdjust RERTR OutputsCalculate Isotope/Cs-137Scaling Factors from isotopetotals for 53 PinsDevelop Cs-137 Dose-to-CurieRelationships for 30-GallonsDrums as a Function of WasteDensity Using MCNP5Determine the Quantitiesin Mass and Curies inDrums for AllReportable NuclidesCalculate Cs-137 Contentin Each Waste CanDetermine AverageDose Rate for 30-galDrumsLocate and RetrieveRelevant ANL Records38

Documents, Waste Containers, and Batch Data Reports Reviewed

The list of documents provided below includes all d ocuments related to the ANL-CCP RH radiological characterization program that were eva luated to support this inspection:

• CPP-PO-002, CCP Transuranic Waste Certification Pla n, Revision 17

• CCP-AK-ANLE-500, Central Characterization Project A cceptable Knowledge Summary Report for Argonne Remote-Handled Debris Waste, Rev ision 1, July 18, 2006

• CCP-AK-ANLE-501, Central Characterization Project R emote-Handled Transuranic Radiological Characterization Technical Report for Remote Handled Transuranic Debris Waste from Argonne National Laboratory-East, Revisi on 0, July 21, 2006

• CCP-AK-ANLE-502 Central Characterization Project, R H TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation Test Pl an for ANL RH Waste Stream: AERHDM, Revision 0, July 21, 2006

• CCP-TP-504, Dose-to-Curie Survey Procedure for Remo te Handled Transuranic Waste,

Revision 3

• CCP-TP-506, CCP Preparation of the Remote-Handled T ransuranic Waste Acceptable Knowledge Characterization Reconciliation Report, R evision 2

• DTC BDR No. ANLRHDTC06001

• Calculation Package Supporting Scaling Factor Deriv ation: ANLE-RH-01, Fuel Information Input Check, Revision 1

• Calculation Package Supporting Scaling Factor Deriv ation: INL-RH-02, Scaling Factor Development

• Calculation Package Supporting Scaling Factor Deriv ation: INL-RH-03, Dose-to-Curie Derivations for Cs-137 in 30-gallon Drums

• Calculation Package Supporting Scaling Factor Deriv ation: ANLE-RH-03, Modification of ORIGEN2.2 INPUT files for Specific Fuel Pins

• Calculation Package Supporting Scaling Factor Deriv ation: ANLE-RH-04, Scaling Factor Development

• Calculation Package Supporting Scaling Factor Deriv ation: ANLE-RH-05, Dose-to-Curie and Related Calculations for Drum Characterization, Revision 1

• Calculation Package Supporting Scaling Factor Deriv ation: ANLE-RH-06, Uncertainty Analysis for Drums

• Calculation Package Supporting Scaling Factor Deriv ation: INL-RH-06, DTC Spreadsheet

for Drum Characterization

• Calculation Package Supporting Scaling Factor Deriv ation: ANLE-RH-07, Determination of Isotopes To Be Reported per WIPP WAC39

• Calculation Package Supporting Scaling Factor Deriv ation: LANL-RH-08, MicroShield 7.00

Verification

8.2.2 Radiological Characterization Element: Dose-To-Cur ie (DTC) Procedure

DTC Overview

ANL-CCP’s approach was based on translating the mea surable external gamma radiation from

137 Cs into an activity value using the MCNP5 code, as d ocumented in INL-RH-03. All of the gamma radiation measured from each drum of RH waste was attributed to 137 Cs, as discussed in LANL-RH-10, INL-RH-09, and INL-RH-08. This include s contributions from 60 Co and other gamma-emitting members of the 232 U decay series, e.g., 228 Ac and 208 Tl. Once the container’s

measured gamma dose rate was converted into a 137 Cs activity, activities for the other nine

WIPP-tracked radionuclides were scaled to the 137 Cs activity using a single set of scaling factors that were applied to all waste containers within th e waste stream AERHDM. An example calculation using the observed dose rate in the DTC procedure is presented in Section 8.2.3, along with a discussion of the development of radio nuclide scaling factors.

ANL-CCP formalized the 137 Cs measurement in the DTC procedure, CCP-TP-504 , Dose-toCurie Survey Procedure for Remote Handled Transurani c Waste, Revision 3. This procedure was evaluated prior to and during the inspection. The DTC process was evaluated relative to the following:

• Capability of the DTC hardware to adequately determ ine a container’s external gamma exposure (dose) rate

• Technical adequacy of the radiological characteriza tion program’s documents, procedures, and controls

• Knowledge and understanding of the personnel involv ed in the radiological characterization program

The external dose rate determination was done empir ically using measurements that took place at

ANL outside in the Area 398 Yard. This area was co nfigured specifically for the purpose of performing the DTC measurements and it is shown sch ematically in Figure 5. The EPA inspection team did observe the DTC procedure, but had to do this from a considerable distance due to the area’s safety requirements. The measure ment assembly was inspected in detail prior to the measurements, but all non-essential personne l had to evacuate before the top of the RH cask was opened. ANL-CCP personnel did provide pho tographs of the process. The conceptual basis for the DTC approach is explained in CCP-AK-I NL-501, Revision 1, and is formalized in procedure form in CCP-TP-504, Revision 3, both of w hich were reviewed for this inspection. The requirements of these two documents were used t o formulate a basis by which the EPA inspection team evaluated the DTC process. Additio nally, several of the calculation packages listed in Section 8.2.1 supported technical aspects of the DTC approach.40 Figure 5. ANL DTC Measurement Facility41

DTC Technical Evaluation

The EPA inspection team evaluated the following asp ects:

(1) Instrumentation for making dose rate measurements

The EPA inspection team verified the following:

• There are two RO-7 Ion Chambers, SN 002003 and 00200 8. Each instrument had three different probes: RO-7LD with a full-scale range o f 1,999 mR/hr and a resolution of 1 mR/hr (Low Range); RO-7BM, with a full-scale range of 199,900 mR/hr and a resolution of 100 mR/hr (Medium Range); and RO-7BH with a full -scale range of 199,900,000 mR/hr and a resolution of 10,000 mR/hr (High Range) . Calibrations of the ion chambers and probes are independent, allowing any probe and ion chamber combination as long as

each was calibrated.

• Both RO-7 Ion Chambers and all six probes had curre nt calibrations as follows: RO-7 SN 002003, LD SN 727004, BM SN 726921, and BH SN 726656 were calibrated on February 28, 2006; and RO-7 SN 002008, LD SN 727010, BM SN 726938, and BH SN 726657 were calibrated on May 24, 2006.

• Both instruments had 60-ft cables that were used to measure the dose rate of containers for the DTC method, and there was a spare 60-ft cab le (SN 302582) in the equipment trailer on-site. The cable length is important sin ce the probes provide an analog signal to the ion chamber, which in turn functions as an anal og-to-digital converter (ADC).

• It was verified that the scale used to weigh the co ntainers has been calibrated and that the scale has been checked daily.

• The battery and performance checks for the RO-7 use d to measure the dose rate of containers for the DTC method had been performed an d documented at least once per day prior to the first measurement of the shift.

• The background rate of 1 mR/hr was measured and rec orded. Measurement personnel stated that they would take actions to reduce the b ackground if the measured background radiation levels are greater than one-tenth of the expected container dose or exposure rate, as required by the WCPIP and CCP-TP-504, Revision 2

.

(2) Execution of the dose rate measurements at ANL on S eptember 14, 2006

The EPA inspection team verified the following:

• For the waste containers observed (Drum No. 00829), the dose rate was measured four times, each at a distance of 1 meter and the contai ner was rotated on the turntable 90° between each measurement, yielding readings of 160 mR/hr, 270 mR/hr, 250 mR/hr, and

185 mR/hr.42

• The ANL-CCP personnel were working to the approved document, CCP-TP-504, Revision 2, and all measurements were taken at the center line of the drum’s height and were lined up to the center height of the active vo lume of the ion chamber probe.

• The appropriate range probe for the ion chamber was used, i.e., Low Dose Probe SN

727010 with Ion Chamber SN 002008.

• The container number and measurement data were ente red into the “Waste Container Dose-to-Curie Conversion Record” spreadsheet. Info rmation entered included:

o Date of the gamma measurements with the RO-7 Ion Ch amber and Probe SN – September 14, 2006, Ion Chamber SN 002008 and Low Do se Probe SN 727010

o Container number – 00829

o Expected dose rate – 800 mR/hr

o Container gross weight – 60.8 kg

o Four quadrant dose rate measurements – 160, 270, 25 0 and 185 mR/hr

o Background dose rate – 1 mR/hr

(3) DTC BDR

The EPA inspection team verified DTC BDR No. ANLRHDT C06001 included the following:

• SPM checklist, Attachment 8

• BDR cover sheet, Attachment 4

• DR table of contents, Attachment 5

• BDR narrative summary, Attachment 6

• ITR review checklist, Attachment 7

• Measurement control report, Attachment 1

• Container data sheets for seven containers, Attachm ent 2

• Waste container DTC conversion records for seven co ntainers, Attachment 3

• Evidence of signatures by the ITR on Attachment 7 a nd a SPM on Attachment 8

• Type of waste in each container on Attachment 3, al l organic

• Fill height of each container on Attachment 3, all 90% full

• Estimated Can Size for each container on Attachment 3, all 7-gallon containers

(4) Meeting quality assurance objectives (QAOs)

The EPA inspection team verified that:

• Precision had been established and maintained withi n the manufacturer’s specifications for the RO-7 Ion Chamber by successful source check s made prior to obtaining dose rate

measurements on actual waste containers.

• Accuracy had been established and maintained by ope rating the instrument within the

manufacturer’s recommendations.

• Representativeness had been maintained by applying the dose rate measurement to the

entire waste container.43

• Completeness had been achieved by measuring the dos e rate for every container in the BDR, i.e., one hundred percent assay.

• Comparability had been achieved by using standardiz ed instructions to design and implement the DTC protocol, including the dose rate measurements.

(5) RH TRU Determination

It was not entirely clear at what point the formal determination regarding a waste container’s

status would be made relative to the criteria for R H TRU. The EPA inspection team evaluated the two following aspects:

• RH TRU containers must have a contact external dose equivalent rate in excess of

200 mrem/hr: The DTC measurements that were observ ed and are discussed in this section represent only the photon (gamma) contribut ion to a container’s external radiation field. There was a neutron-sensitive instrument (R em Ball) in the same area as the RO-7 that could be used to provide the necessary informa tion to support a complete determination regarding a waste container’s status relative to the 200 mrem/hr criterion. ANL-CCP personnel stated that the Rem Ball was used to measure each waste container, but the results were used primarily for health phys ics/ALARA purposes. However, the

RH determination based on the external dose rate is typically made on the basis of the transportation package and is therefore not within the purview of this inspection.

• RH TRU containers must have a concentration of TRU radionuclides greater than 100 nCi/g: CCP-TP-504 requires the container’s dos e rate to be at least a factor of ten greater than background, and the lowest reading pos sible on the RO-7 with the low dose probe is 1 mR/hr. This means that the minimum dose rate that can be measured at 1 meter is 10 mR/hr. Additionally, based on the factor of 20 difference between the contact and 1 meter readings 6 , a container would have to read at least 10 mR/hr at 1 meter to qualify as RH, i.e., have a contact reading greater than 200 m R/hr. The EPA inspection team wanted to verify that it was possible to ensure tha t a container at a boundary condition, i.e., with a 1-meter dose rate of 10 mR/hr, did in fact contain greater than 100 nCi/g of TRU radionuclides. As a check, the sp readsheet shown in Figure 6 was used with input values for a hypothetical 1-meter d ose rate of 10 mR/hr. For this case, the spreadsheet yields a TRU Alpha Concentration of approximately 184 nCi/g, which meets the greater-than-100 nCi/g criterion for TRU waste. For comparison, the data for ANL Waste Container No. 00820 that has an average 1 -meter dose rate of 230.25 mR/hr are shown in Figure 7. Its calculated TRU Alpha Co ncentration of 8,660 nCi/g is discussed in greater detail in Section 8.2.3 (see T able 9).

The EPA inspection team did not have any technical concerns or issues with the execution of the DTC methodology observed at ANL-CCP during this ins pection, or with the method’s technical basis and documentation based on the objective evid ence that was reviewed.

6 The strength of the gamma intensity decreases as t he square of the distance such that when the distan ce increases by a factor of two the gamma intensity de creases by a factor of four, i.e., two squared. Th is means that the container’s contact dose reading is approximately 2 0 times greater than the reading at a distance of o ne-meter.44 A B C D E F G H

Operating Procedure CCPTP-504 Rev. 2 8

Date of Survey 6/1/2006 9 Waste Stream Designation AERHDM 10 Container Number 11 Container Gross Weight 70 Kg 12 Waste Cans Can #1 Can #2 Can #3 13 Can Sizes 7 7 0 gallons 14 Estimate Fill Percentages 100 100 78.5 % 15 Container Net Weight 46.5 Kg 16 Measured Container Dose Rate 17 Quadrant #1 10 mR/hr 18 Quadrant #2 10 mR/hr 19 Quadrant #3 10 mR/hr 20 Quadrant #4 10 mR/hr 21 Calculated Average Dose Rate 10 mR/hr 22 Waste Material Type Organic (organic, steel, cement)

Figure 6. EXCELTM (Version 2002, Release 10), DTC S preadsheet Version 1.0 051006,

Using Boundary Condition of a 1-Meter Reading of 10 mR/hr

A B C D E F G H

Operating Procedure CCPTP-504 Rev. 3 8

Date of Survey 8/9/2006 9 Waste Stream Designation AERHDM 10 Container Number 00820 11 Container Gross Weight 41.6 kg 12 Waste Cans Can #1 Can #2 Can #3 13 Can Sizes 7 7 gallons 14 Estimate Fill Percentages 90 90 % 15 Container Net Weight 18.1 Kg 16 Measured Container Dose Rate 17 Quadrant #1 214 mR/hr 18 Quadrant #2 238 mR/hr 19 Quadrant #3 252 mR/hr 20 Quadrant #4 217 mR/hr 21 Calculated Average Dose Rate 230.25 mR/hr 22 Waste Material Type Organic

Figure 7. EXCELTM (Version 2002, Release 10), DTC S preadsheet Version 2.0 080406, Using Actual Data from Container No. 00820, Waste S tream AERHDM, Assayed August 10, 200645

EPA requires that ANL-CCP notify EPA through a T2 c hange notice upon completion of modifications to CCP-TP-504 that require CBFO appro val. Consistent with EPA’s authority under 194.24(h), EPA may request this information i f EPA deems it necessary to ensure continued compliance with EPA regulations. (See Ta ble 1 where this is included as a T2 change.) Additionally, the use of any alternate r adiological other than the DTC technique as documented in CCP-TP-504 observed during this basel ine inspection is a T1 change. (See Table 1, which includes this as a T1 change.)

8.2.3 Radiological Characterization Element: Scali ng Factor Development

Scaling Factor Overview

As shown in the nine calculation packages listed in Section 8.2.1, this was a complex task that incorporated information from ANL-E, ANL-W, INL, an d LANL, including the following:

• Fuel pin type and characteristics from fuel supplie rs and reactor operators

• 235 U enrichment

• 240 Pu enrichment (for mixed oxide fuels) and burnup

• Uranium/plutonium ratios (for mixed oxide fuels)

• Examination of 603 fuel pins at ANL

• Mass spectrometry results for destructive assay (DA ) of 400 fuel pins

• Other records related to AGHCF activities, names of experimenters, etc.

The scaling factors were incorporated in a drum cha racterization spreadsheet that required the following input:

• Drum gross weight in kilograms (kg)

• Identification of the can sizes (5-, 7- or 10-gallo n) and number of cans in the drum

• Estimates of the can fill heights in percent

• Dose rate measurements at four quadrant points in m R/hr

The drum’s gross weight is calculated as:

Gross drum weight – (drum weight + packaging materials + can weights) (1)

The weight values used for the various drum items a re listed in Table 5.

Table 5. Weights of Items Used to Calculate Waste Weight and Density

Waste Items Weight, kg

30-gallon drum 16.36 Polyethylene liner 3.61 Plastic pouch 1.73

Cardboard sleeve 1.41

Plastic lid 0.39

Total minus cans 23.5 7-gallon drum 2.8446 5-gallon drum 2.26 10-gallon drum 3.42

The container’s apparent weight density in g/cm 3 is calculated as:

Net Waste Weight / (can #1 %H fill + can #2 %H fill + can #3 %H fill ) (2)

Where the net waste weight is in units of grams and can fill volume is given by:

C size * %H fill * 3785 cm 3 /gal (3)

Where:

C size = can size in gallons

%H fill = estimated fill height of each can in percent, e xpressed as a decimal

The inputs for the spreadsheet are shown in Figures 6 and 7 above for the hypothetical measured

1-meter dose rate of 10mR/hr and the actual measure d dose rate of 230.25 mR/hr from Container No. 00820. Each uses a drum configuration of two 7- gallon cans each 90% full, net weights as shown, an organic matrix, and an apparent weight de nsity. In both cases, the drum’s 137 Cs

content is derived as follows:

137 Cs Activity in Ci = dose rate / (11.91 * X 2 - 82.126 * X + 194.64) (4)

Where: X = apparent waste density, g/cm 3

The scaling factors for Container No. 00820 and the hypothetical example using the 10 mR/hr input discussed above are the same. All containers in this waste stream use the same scaling factors and the sample-specific variables are the c ontainer’s measured dose rate and density. At a hypothetical value of zero density (X = 0), equat ion (4) becomes essentially a bare-source calculation; at higher densities, the effects of th e waste’s self-shielding are evident. Equation (4)

is taken from INL-RH-03 and is based on a total of eight (8) MCNP cases that were generated using a waste material density varying from 0.0 g/c m 3 to 1.4 g/cm 3 in intervals of 0.2 g/cm 3 , a range that spans the expected range of waste densit ies in ANL drums. The results of the eight runs are presented in Table 6, below, and were used to generate a second-order polynomial curve to fit the data, shown in Figure 8. The constants and other values required for these calculations, i.e., Fissile Gram Equivalent (FGE) and Plutonium E quivalent Curies (PE Ci), were taken from the appropriate sources (CH WAC and TRAMPAC) and we re checked for accuracy. These were found to be accurate and they are summarized in Tab le 7.

Determination of the 137 Cs activity for a container allows the calculation of the following quantities for each RH container measured:

• Activity in curies (Ci) and mass in grams (g) for e ach of the other nine WIPP-tracked radionuclides, i.e., 241 Am, 238 Pu, 239 Pu, 240 Pu, 242 Pu, 90 Sr, 233 U, 234 U, and 238 U

• FGE47

• PE Ci

• Decay heat in watts

• Associated uncertainty for all values listed in pre vious bullets

Table 6. MCNP Input – Observed Dose Rate As a Function of Waste Density

Waste Density Dose Rate mR/hr

0.0 193.993

0.2 179.322

0.4 164.203

0.6 149.743

0.8 136.207

1.0 124.006

1.2 112.991

1.4 103.45

Figure 8. ANL DTC Correlation Dose Rate Versus Was te Density

For Cs-137 in 30-gallon Drums48 Table 7. Constants Used in Scaling Factor Developm ent

Radionuclide Specific Activity

(Ci/g) FGE/g PE-Ci/Ci Watts/g

U-233 9.76E-03 9.00E-01 3.90 2.84E-04

U-234 6.32E-03 0.00E+00 0.00 1.82E-04

U-235 2.19E-06 6.43E-01 0.00 6.04E-08

U-238 3.40E-07 0.00E+00 0.00 8.62E-09

Pu-238 1.73E+01 1.13E-01 1.10 5.73E-01

Pu-239 6.29E-02 1.00E+00 1.00 1.95E-03

Pu-240 2.30E-01 2.25E-02 1.00 7.16E-03

Pu-241 1.04E+02 2.25E+00 51.00 3.31E-03

Pu-242 3.97E-03 7.50E-03 1.10 1.17E-04

Am-241 3.47E+00 1.87E-02 1.00 1.16E-01

Cs-137 8.80E+01 0.00E+00 0.00 9.74E-02

Ba-137m 5.38E+08 0.00E+00 0.00 2.12E+06

Sr-90 1.38E+02 0.00E+00 0.00 1.60E-01

Y-90 5.44E+05 0.00E+00 0.00 3.01E+03

These values are shown below in Tables 8 and 9 for the hypothetical 10 mR/hr 1-meter dose rate and the observed average dose rate of 230 mR/hr for Container No. 00820, respectively. The reported values listed for radionuclides, FGE, PE C i, and decay heat values plus uncertainties are all produced as a function of the measured dose rat es at 1 meter and the application of the scaling

factors discussed below. The values in Table 9 are the actual data that ANL reported in BDR No. ANLRHDTC06001, based on the radiological charact erization observed during the inspection.

Scaling Factor Technical Evaluation

The technical basis and degree to which the scaling factors are representative of the RH TRU wastes for which ANL-CCP requested approval were ev aluated during this inspection. The following elements were evaluated and verified:

(1) Waste stream definition

This inspection focused on a group of wastes that A NL-CCP stated were contained in a single waste stream, which included fuel pins that were di ssimilar with respect to their radionuclide content. Specifically, they consisted of three fue l types:

• Uranium, Low Enriched Uranium (LEU) and Highly Enri ched Uranium (HEU)

• Uranium and plutonium

• Thorium49Table 8. Summary of Reportable Values Using Boundary Condition of 10 mR/hr 1-Meter Dose RateRadionuclideCurie ScalingFactorsActivity(Ci)MassGramsFGEPE-CiWattsUncertainty%UncertaintyCuriesUncertaintyGramsU-233 2.59E-09 1.87E-10 1.92E-08 1.73E-08 4.80E-115.45E-1281.69% 1.53E-10 1.57E-08U-234 6.48E-05 4.68E-06 7.41E-04 0.00E+00 0.00E+001.35E-0760.71% 2.84E-06 4.50E-04U-235 1.99E-06 1.43E-07 6.55E-02 4.21E-02 0.00E+003.96E-0965.33% 9.37E-08 4.28E-02U-238 2.32E-06 1.68E-07 4.93E-01 0.00E+00 0.00E+001.36E-0451.44% 8.63E-08 2.54E-01Pu-238 5.70E-02 4.12E-03 2.38E-04 2.69E-05 3.74E-031.36E-0460.82% 2.50E-03 1.45E-04Pu-239 1.08E-02 1.30E-03 2.06E-02 2.06E-02 1.30E-034.03E-0579.45% 1.03E-03 1.64E-02Pu-240 1.23E-02 8.91E-04 3.88E-03 8.72E-05 8.91E-042.77E-0575.94% 6.77E-04 2.94E-03Pu-241 8.11E-01 5.86E-02 5.63E-04 1.27E-03 1.15E-031.86E-0655.78% 3.27E-02 3.14E-04Pu-242 3.01E-05 2.17E-06 5.47E-04 4.10E-06 1.97E-066.40E-0856.63% 1.23E-06 3.10E-04Am-241 3.11E-02 2.25E-03 6.48E-04 1.21E-05 2.25E-037.51E-0570.07% 1.57E-03 4.54E-04Cs-137 1.00E+00 7.22E-02 8.21E-04 0.00E+00 0.00E+007.99E-0531.77% 2.30E-02 2.61E-04Ba-137m9.46E-01 6.83E-02 1.27E-10 0.00E+00 0.00E+00 2.69E-0431.77% 2.17E-02 4.04E-11Sr-906.40E-01 4.62E-02 3.35E-04 0.00E+00 0.00E+00 5.36E-0533.77% 1.56E-02 1.13E-04Y-906.40E-01 4.62E-02 8.49E-08 0.00E+00 0.00E+00 2.56E-0433.77% 1.56E-02 2.87E-08Totals— 3.00E-01 5.87E-01 6.41E-02 9.33E-03 9.40E-04— — —TRU Alpha Activity Concentration 1.84E+02 nCi/gTRU Alpha Activity 8.56E-03 CiTotal239Pu Equivalent Activity 9.33E-03 CiTotal239Pu Fissile Gram Equivalent 6.41E-02 gTotal Decay Heat 9.40E-04 wattsVolume Activity 2.64E-03 Ci/liter50Table 9. Summary of Reportable Values Using ActualData from Container No. 00820,Waste Stream AERHDM, Assayed August 10, 2006RadionuclideCurie ScalingFactorsActivity(Ci)MassGramsFGEPE-CiWattsUncertainty%UncertaintyCuriesUncertaintyGramsU-233 2.59E-09 3.43E-09 3.51E-07 3.16E-07 8.79E-109.98E-1180.25% 2.75E-09 2.82E-07U-234 6.48E-05 8.58E-05 1.36E-02 0.00E+00 0.00E+002.47E-0658.76% 5.04E-05 7.97E-03U-235 1.99E-06 2.63E-06 1.20E+00 7.71E-01 0.00E+007.24E-0863.52% 1.67E-06 7.62E-01U-238 2.32E-06 3.07E-06 9.03E+00 0.00E+00 0.00E+007.79E-0849.12% 1.51E-06 4.44E+00Pu-238 5.70E-02 7.54E-02 4.36E-03 4.92E-04 6.85E-022.50E-0358.87% 4.44E-02 2.57E-03Pu-239 1.08E-02 2.38E-02 3.78E-01 3.78E-01 2.38E-027.37E-0477.97% 1.85E-02 2.95E-01Pu-240 1.23E-02 1.63E-02 7.10E-02 1.60E-03 1.63E-025.08E-0474.39% 1.21E-02 5.28E-02Pu-241 8.11E-01 1.07E+00 1.03E-02 2.32E-02 2.10E-023.41E-0553.65% 5.75E-01 5.53E-03Pu-242 3.01E-05 3.98E-05 1.00E-02 7.52E-05 3.62E-051.17E-0654.53% 2.17E-05 5.46E-03Am-241 3.11E-02 4.12E-02 1.19E-02 2.22E-04 4.12E-021.38E-0368.39% 2.81E-02 8.11E-03Cs-137 1.00E+00 1.32E+00 1.50E-02 0.00E+00 0.00E+001.46E-0327.87% 3.69E-01 4.19E-03Ba-137m9.46E-01 1.25E+00 2.33E-09 0.00E+00 0.00E+00 4.93E-0327.87% 3.49E-01 6.49E-10Sr-906.40E-01 8.46E-01 6.13E-03 0.00E+00 0.00E+00 9.81E-0430.13% 2.55E-01 1.85E-03Y-906.40E-01 8.46E-01 1.56E-06 0.00E+00 0.00E+00 4.68E-0330.13% 2.55E-01 4.69E-07Totals— 5.50E+00 1.08E+01 1.17E+00 1.71E-01 1.72E-02— — —TRU Alpha Activity Concentration 8.66E+03 nCi/gTRU Alpha Activity 1.57E-01 CiTotal239Pu Equivalent Activity 1.71E-01 CiTotal239Pu Fissile Gram Equivalent 1.17E+00 gTotal Decay Heat 1.72E-02 wattsVolume Activity 4.84E-02 Ci/liter51

The following definition is taken from page 12 of t he WCPIP:

A waste stream is defined as waste material generat ed from a single process or from an activity which is similar in material, physical for m and radiological constituents. Only those containers that can be related to a particula r waste stream will be contained in that

waste stream.

In light of the apparent differences among the thre e fuel types listed above, the consolidation of these drums in a single waste stream bears investig ation. The radionuclide profiles of the three fuel types are clearly different; however, followin g irradiation these fuel types have a common, salient characteristic, i.e., the presence of fissi on and activation products. Of these, 137 Cs is the main interest due to its physical half-life (~30.2 years) and high transition probability photon

emission at 662 keV. There are other fission and a ctivation products but these are not an issue to this approach because they have short physical half -lives and have decayed or, more importantly, their contribution is insignificant relative to 137 Cs. In a sense, one could consider that these materials have been treated by their exposure to th e intense neutron field produced during irradiation (fission). The materials’ characterist ics that have bearing on DTC have been reduced to a common element, i.e., the predominance of 137 Cs, after irradiation, and the differences of the fuel’s pre irradiation composition do not affect th e radiological characterization process. The EPA inspection team concluded that the assignment o f all containers to a single waste stream was technically justified and technically supportab le.

(2) Technical aspects and derivation of scaling factors

The EPA inspection team evaluated the following asp ects:

• Activity values used are derived from modeling and statistical metrics that support their use, and the statistical metrics include mean and s tandard deviation values for each

measured radionuclide.

• Isotopic activity values are normalized to the majo r radionuclide(s) responsible for the external container dose rate, i.e., 137 Cs.

• The calculated results are used to develop the scal ing factors and convert the measured dose rate to radionuclide activity levels.

• The expected dose rates at a distance of 1 meter fr om the outer surface of the waste container, at the mid-height of the container, have been calculated as a function of the waste’s activity, and the calculation accounts appr opriately for container properties i.e., fill height or (apparent) density, waste type, shie lding effects of the container and/or liner

wall.

• Calculations supporting the scaling factors are per formed using appropriate shielding analysis techniques, i.e., MCNP5 and MicroShield 7.0 0.

• Computer programs (ORIGEN2.2) used for calculations of the activities of the 10 WIPPtracked radionuclides account for the following:52

o The beginning conditions of the fuel used to produc e the TRU isotopes

o Exposure of fuel to neutron fields in a nuclear rea ctor (fission)

o Change in radionuclides following irradiation

o Reactor neutron energy spectrum is known or calcula ted in order to determine the effective cross-sections of radionuclides leading t o the creation of 10 WIPP-tracked

radionuclides

o Appropriate cross-sections are used or generated fo r each reactor condition

o Fuel exposure history is used to calculate isotope generation and depletion

(3) Documentation of technical aspects

Development of the scaling factors is documented in ten calculation packages that were prepared by Jene Vance and Jim Holderness (see Section 8.2.1 ). These packages address a variety of aspects, including:

• Verification of MCNP5, MicroShield 7.00 and ORIGEN2. 2

• Evaluation of all potential contributors to a conta iner’s dose rate, specifically 60 Co and other gamma emitting members of the 232 U decay series, e.g., 228 Ac and 208 Tl

• Uranium and plutonium relationship in the fuel pins from which the wastes originated

• The nature and history of the fuel pins, reactor cr oss-sections, and operating histories

• Potential sources of uncertainty, discussed below

The EPA inspection team members reviewed a subset o f these packages in detail and discussed them with the documents’ authors and Mark Doherty. During these discussions, several aspects were probed in detail and, apart from minor discrep ancies with respect to specific documentation details; the calculation packages were found to be technically adequate.

(4) Evaluation of Total Measurement Uncertainty (TMU)

The development of TMU for ID-ANLE-S5000 is based o n the propagation of uncertainties present in all aspects of the determination of the radiological constituents of RH TRU waste.

The TMU determination included the contributions of :

• Drum weight measurement

• Measurement uncertainty of 137 Cs

• MCNP5 issues

• MicroShield issues

• Other gamma emitters

• Individual pins to the total

• Specific pins in a single drum

• Burnup history

• Reported burnup

• Internal code issues53

• Contributions from unirradiated pins

• Modeling

EPA raised a technical concern regarding TMU with r espect to the appropriateness of the statistical model during the EPA RH Inspection at I NL, see EPA Baseline Inspection Report No.

EPA-INL-CCP-RH-6.06-8. This technical issue result ed in INL-CCP reissuing calculation package INL-RH-06 that provides the technical suppo rt for the calculation of TMU at both INL and ANL. The EPA Inspection Team reviewed the appl icability of the reissued procedure to the

ANL RH waste stream and determined that it was tech nically appropriate and it correctly

addressed the TMU issue.

The EPA inspection team did not have any technical issues or concerns relative to the development and application of radionuclide scaling factors based on the objective evidence reviewed during this inspection.

The application of scaling factors for isotopic det ermination other than those observed during this baseline inspection and documented in CCP-AK-A NLE-501 is a T1 change. (See Table 1, where this is included as a T1 change). Likewise, the use of any alternate radiological characterization technique procedure other than DTC with the established scaling factors cited in the previous sentence, or substantive modification thereof, is a T1 change. (See Table 1, where this is included as a T1 change). Any new waste str eam not approved under this baseline inspection or the addition of containers to Waste S tream AERHDM that require changing the established radionuclide scaling factors is a T1 ch ange. (See Table 1, where this is included as a T1 change).

Summary of Radiological Characterization Findings a nd Concerns

The EPA inspection team did not identify any findin gs or concerns related to radiological characterization during this inspection.

Baseline Approval

EPA approves the ANL-CCP radiological characterizat ion process that the EPA inspection team evaluated during the baseline inspection and consis ts of the following two techniques used jointly for containers of RH TRU in one waste strea m, AERHDM and consists of the following:

• The determination of the 10 WIPP-tracked radionucli des based on the DTC procedure presented in CCP-TP-504

• The application of radionuclide scaling factors der ived as documented in CCP-AK-ANLE-501 and supported by the calculation pa ckages referenced in

Section 8.2.1

Radiological Characterization Tiers

Based on the inspection and the results discussed a bove, EPA assigns the following tiers:54

T1 radiological characterization changes that will require EPA review and approval prior to implementation and apply to any waste stream not ev aluated during the baseline inspection include the following:

• Use of any alternate radiological characterization procedure other than DTC with established scaling factors as documented in CCP-TP -504 and CCP-AK-ANLE-501, Revision 0, respectively, or substantive modificati on thereof***

• Any new waste stream not approved under this baseli ne or addition of containers to waste stream AERHDM that require changing the established radionuclide scaling factors

• Application of new scaling factors for isotopic det ermination other than those

documented in CCP-AK-ANLE-501

T1 changes will be reported and documentation will be submitted when ANL-CCP is ready for EPA review. Upon initial review, EPA will inform A NL-CCP and CBFO whether a site inspection is necessary. EPA may request additiona l information, choose to conduct a desktop review, and/or confer with CBFO and ANL-CCP personn el. Upon EPA’s evaluation with or without site inspection, EPA will issue a decision. Only upon receiving EPA written approval may ANL-CCP dispose of the new waste at the WIPP.

T2 radiological characterization changes that do not require EPA approval prior to implementation but require a brief description of t he changes to the documents along with the notification, include the following:

• Notification to EPA that revisions of CCP-AK-ANLE-50 1 or CCP-TP-504 that require CBFO approval** are complete

Following EPA approval, ANL-CCP will provide EPA wi th information concerning T2 changes on a quarterly basis. When notifying EPA as a T2 c hange that additional information is available, the notification should provide a brief description of the type of additional

information. EPA will then determine whether to se ek the new, additional information from ANL-CCP. EPA will evaluate these changes and commu nicate with ANL-CCP as to whether the changes raise any concerns and require an ANL-C CP response, or whether ANL-CCP can continue to implement the changes. Consistent with EPA’s authority under 194.24(h) EPA may request information relative to these changes if EP A deems the information is necessary to ensure continued compliance with EPA regulations.

8.3 Visual Examination

WC Element Description

The VE process used for identifying contents of RH waste drums allows the review of existing audio/video recordings made at the time of packagin g to generate VE data. Two VE operators

identified and documented the waste contents of the containers examined by this technique. VE determines the following aspects of RH TRU waste:55

• Confirmation that the waste matches the waste strea m description

• Description of the container contents including was te material parameters (WMP)

• Confirm the presence or absence of residual liquid that exceed one percent of the volume

of the waste container

Procedure CCP-TP-500 was used for conducting VE of RH TRU waste at ANL-CCP.

Documents Reviewed

The following documents were among those reviewed t o assess whether VE operations follow appropriately the implemented procedures and meet V E requirements:

• CCP-TP-500, Revision 2, Remote-Handled Waste Visual Examination, June 19, 2006

• CCP-QP-002, Revision 21, Training and Qualification Plan, June 13, 2006

• Remote-Handled TRU Waste Characterization Program I mplementation Plan, Revision 0D, October 30, 2003

• VE Batch Data Report (BDR): RHANLVE060001

A complete listing of all objective evidence that w as evaluated during the inspection is provided

below.

• VE Batch Data Report, RHANLVE060001

• Audio/visual recording for BDR RHANLVE060001

• Qualification cards for VE operators

• Qualification card for SME/VEE

• VEE appointment letter, dated April 17, 2006

• List of Qualified Individuals (LOQI) for ANLE RH VE program

• Attendance Sheets for CCP-AK-ANLE-500 training

• Processing information for BDR RHANLVE060001

• AK tracking spreadsheet for containers in waste str eam AERHDM

• Acceptable Knowledge Summary Report Training Certificates for Argonne RemoteHandled Debris Waste Stream – AERHDM

Technical Evaluation

During the inspection, the technical elements of th e VE process were evaluated using the

checklist contained in Attachment A.2. These areas are summarized below:56

(1) Overall procedural technical adequacy and implement ation

The VE procedure, documented in CCP-TP-500, Revisio n 2, provided instructions to VE personnel for performing VE by review of existing a udio/visual recordings. The procedure was technically adequate and complete. Initially, the operators did not make a complete inventory of the waste items, but the inventories were revised a pproximately two months after the original VE events. At the time of the on-site inspection, the single BDR generated, RHANLVE060001, contained complete waste inventories. EPA requires that ANL-CCP notify EPA through a T2 change notice upon completion of any revisions of a ny of the VE procedures observed during this baseline inspection that require CBFO approval . Consistent with EPA’s authority under 194.24(h), EPA may request these revisions and othe r related information if EPA deems it necessary to ensure continued compliance with EPA r egulations. (See Table 1 where this is included as a T2 change.)

The use of any new VE technique not observed during this baseline inspection for one retrievably-stored debris waste stream AERHDM using the trained personnel, documentation, and procedures discussed in this report is a T1 cha nge. (See Table 1, where this is included as a T1 change.) Additionally, using the VE process eva luated during this inspection for a Summary Waste category that is not a debris waste, is a T1 change. (See Table 1, where this is included as a T1 change.)

(2) Characterization of WMPs and prohibited items was e valuated.

EPA reviewed selected data sheets contained in BDR RHANLVE060001 in conjunction with the audio/visual recordings to ensure consistency betwe en the visual and written records. The data sheets and audio/video recordings for Container Nos . 00816, 00826, 00825, and 00815 were reviewed. EPA did not identify any discrepant info rmation for these containers. During this review, a VE operator explained the process and how decisions were made with regard to identification of WMPs. However, the operator inte rviewed could not explain how they were able to answer certain questions on the VE data she et, e.g., “The waste is consistent with the waste stream description and waste matrix code (Sum mary Category Group)?” “Yes” had been

entered on the data sheet for each container in BDR RHANLVE060001 in response to this question, but the operator was unable to provide th e information about the waste stream description that was necessary to answer this quest ion. EPA included this issue on an EPA Inspection Issue Tracking Form (see Attachment B.2 for a copy of this form), described below.

EPA Concern No. ANL-CCP-RH-VE-06-002C: The Independent Technical Reviewer (ITR) had not fully implemented the requirement for compl ete inventory put in place on June 15, 2006, at the time BDR #RHANLVE060001 was signed off on Ju ly 19, 2006. The ITR signed off on the checklist on July 19, 2006; however, it was the n corrected to reflect the “complete inventory” requirement on August 25, 2006. The ITR initiated the change after he fully understood the expected criteria of “complete inventory” based on the issue at INL. At the time of the inspection, the VE data had been revised to include a complete inventory of the waste items in

each container. EPA considers this concern closed. The audio/video recordings did not show the 7.5-gallon cans being loaded into the 30-gallon containers, but the cans and containers were57

associated through the original packaging informati on and this information was included in the BDR for each container. VE operators confirmed the absence/presence of prohibited items in each can, and if operators were not able to verify this information, an NCR was to be generated and the containers were rejected.

Resolution: A formal response to this concern was not required.

Status of Concern: Based on discussions with ANL-CCP, EPA considers th is concern to be

closed.

EPA requires that ANL-CCP notify EPA through a T2 c hange notice regarding the addition of any new S5000 debris waste stream. Consistent with EPA’s authority under 194.24(h), EPA may request information relative to any new debris waste streams) if EPA deems it necessary to ensure continued compliance with EPA regulations. (See Table 1 where this is included as a T2 change.)

(3) Documentation of VE activities was examined.

Two operators generated VE data for RH containers f rom review of audio/video recordings. The operators reviewed existing recordings and complete d the required data sheets from their observations. The container inventories initially generated by the operators were incomplete, but this issue was identified by ANL-CCP and the invent ories were revised. At the time of the onsite EPA inspection, all of the inventories for the non-rejected containers in BDR RHANLVE060001 were complete. At the end of the VE event, the operators assign percentages to each WMP and manually calculate the weight of ea ch WMP using these percentages and the weight of the waste contained in the cans. Operato rs did not retain any records for the manual calculations they performed and these calculations were not verified during the ITR review. Completed data generation and project level review checklists were included in the data package that EPA reviewed. The Visual Examination Expert ( VEE) who performed the ITR review on BDR RHANLVE060001 failed to recognize that not all data were recorded. This issue was documented on EPA Inspection Issue Tracking Form (s ee Attachment B.1 for a copy of this form) and the three aspects of this issue are prese nted below.

EPA Concern No. ANL-CCP-RH-VE-06-001CR, Part 1: The method of manually calculating the weights of Waste Material Parameter s (WMP) is not contained within the existing procedure. Failure to document this process in the procedure may lead to the use of inconsistent and undocumented methodologies for this calculation

.

Resolution: ANL-CCP revised procedure CCP-TP-500 and removed th e requirement to estimate WMP weights because it is not required by the WCPIP. Upon completion of the procedural modification, ANL-CCP provided EPA a cop y of the revised procedure that was reviewed and found to be acceptable.

Status of Concern: EPA considers this part of the concern to be closed

.58

EPA Concern No. ANL-CCP-RH-VE-06-001CR, Part 2: The VE ITR is required to review all manual calculations, but the calculation of WMP wei ghts is not reviewed and the requirement to review it is not contained in any ITR checklist. F ailure to do so removes the only required check of the calculation on which WMP quantities are base d.

Resolution: Procedure CCP-TP-500 was revised and calculation of the WMP weights no longer requires verification. Upon completion of the modi fication to CCP-TP-500, ANL-CCP provided EPA a copy of the revised procedure that was review ed and found to be acceptable.

Status of Concern: EPA considers this part of the concern to be closed

.

EPA Concern No. ANL-CCP-RH-VE-06-001CR, Part 3: VE operators are completing “Visual Examination Data Form” without the knowledg e necessary to make the correct decisions regarding specific items. For example, checking yes in response to the question, “The waste is consistent with the waste stream description?” Whe n questioned, a VE operator could not explain how he was able to answer this question. C onfirmation of waste stream description is essential to AK confirmation required by 40 CFR 194 .24(c). The VE operator is responsible for deciding if the drum examined is part of the waste stream.

Resolution: ANL

- CCP has provided additional training for VE operato rs. Upon completion of the training, ANL-CCP submitted objective evidence of the training to EPA and this was found to be acceptable.

Status of Concern: EPA considers this part of the concern to be closed

.

EPA requires that ANL-CCP notify EPA through a T2 c hange notice upon completion of any revisions of any of the VE procedures observed duri ng this baseline inspection that require CBFO approval. Consistent with EPA’s authority und er 194.24(h), EPA may request these

revisions and other related information if EPA deem s it necessary to ensure continued compliance with EPA regulations. (See Table 1 wher e this is included as a T2 change.)

The use of any new VE technique not observed during this baseline inspection for one retrievably-stored debris waste stream AERHDM using the trained personnel, documentation, and procedures discussed in this report is a T1 cha nge. (See Table 1, where this is included as a T1 change.) Additionally, using the VE process eva luated during this inspection for a Summary Waste category that is not a debris waste, is a T1 change. (See Table 1, where this is included as a T1 change.)

(4) Training for VE personnel was examined.

The site maintains a list of qualified individuals, which is used to ensure that all training is current. During the inspection, the qualification packages for the three RH VE operators were reviewed and found to document adequate training fo r VE personnel. ANL-CCP’s RH VEE was designated prior to generation of any RH VE data. The VEE was present at the site to train the operators but is not necessarily present when VE ev ents take place. The VEE is, however, available for discussion with the operators either by telephone or e-mail.59

The following records were reviewed:

• V E Operator/ITR/TS/FQAO Qualification Card for thr ee operators

• Qualification card for one VEE

• Letter designating RH SME/VEE

• List of qualified RH VE personnel

• Acceptable Knowledge Summary Report Training Certificates for Argonne RemoteHandled Debris Waste Stream – AERHDM

Summary of VE Findings and Concerns

The EPA inspection team identified the two concerns related to VE that are discussed above, along with ANL-CCP’s response and the resolution fo r each concern. Copies of the EPA Inspection Issue Tracking Forms that document these concerns are provided in Attachments B.1

and B.2. EPA considers both concerns to have been adequately addressed and there are no open concerns related to VE resulting from this inspecti on.

VE Baseline Approval

The VE system for RH waste that the EPA inspection team evaluated during this baseline inspection consisted of the following:

• Trained personnel: VE operators, VEE

• Approved and controlled operating procedures CCP-TP -500, Revision 2; CCP-QP-002,

Revision 21

• VE records and supporting data: Visual Examination Data Forms, CCP-TP-500 review checklists, and one VE BDR

• Waste stream AERHDM

Based on the results of this inspection of the VE s ystem implemented by CCP at ANL for RH waste, specifically VE by review of existing audio/ visual recordings, EPA approves this process

for S5000 waste.

VE Tiers

Based on the inspection and the results discussed a bove, EPA assigns the following VE tiers.

T1 VE changes that require EPA approval prior to implementation:

• VE by reviewing existing audio/visual recordings fo r Summary waste category not covered by this approval

• VE by any new process for S5000 debris wastes60

T2 VE changes that do not require EPA approval prior to implemen tation but require a brief description of the changes to the documents along w ith the notification, include the following:

• Notification to EPA that revisions of any VE procedu re that require CBFO approval are complete

• Addition of new S5000 debris waste streams

Following EPA approval, ANL-CCP will provide EPA wi th information concerning T2 changes on a quarterly basis. EPA will evaluate these chan ges and communicate with ANL-CCP as to whether the changes raise any concerns and require an ANL-CCP response, or whether ANL-CCP can continue to implement the changes. Con sistent with EPA’s authority under 194.24(h) EPA may request information relative to t hese changes if EPA deems the information is necessary to ensure continued compliance with EP A regulations.

8.4 Real-Time Radiography

The technical area of RTR was not evaluated during this inspection. If ANL-CCP wishes to use RTR to characterize RH TRU wastes, EPA approval sep arate from what is contained in this report is required.

EPA is not approving RTR at ANL-CCP. ANL-CCP did n ot have an operational RTR unit in place at the time of the inspection. ANL-CCP canno t ship RH waste to WIPP using RTR as a WC technique until it is inspected and approved by EPA through a T1 change.

8.5 WIPP Waste Information System

The technical area of WWIS was not evaluated during this inspection. Prior to ANL-CCP using the WWIS to characterize RH TRU wastes, EPA approva l separate from what is contained in this report is required.

EPA is not approving the WWIS for entry and trackin g of the waste contents of RH debris wastes at this time. Although the WWIS is currentl y approved by EPA for tracking CH waste, ANL-CCP had not demonstrated its adequacy to enter and track RH waste contents during this baseline inspection. During the comment period for the proposed approval CBFO notified EPA that the WWIS was operational for RH wastes and was ready for EPA evaluation as a T1 change. EPA has begun this evaluation and the results of EP A’s T1 evaluation will be provided upon completion separately.

9.0 RESPONSE TO COMMENTS

By the end of the comment period (December 26, 2006 ), EPA received one set of public comments. (Comments are available from EPA Docket ID No. EPA-HQ-OAR-2006-0881.) EPA evaluated those comments and revised the report accordingly. Attachment C provides the public comments and EPA’s response.61

10.0 SUMMARY OF RESULTS

ANL-CCP responded to all EPA issues that required a response prior to the inspection closeout on site, as well subsequent to the inspection. Thes e are summarized in the preceding sections. The EPA inspection team members evaluated all of CB FO’s responses for completeness and adequacy, and concluded that each EPA issue requiri ng a response had been resolved satisfactorily. No EPA issues remain open at this t ime.

10.1 Findings and Concerns

The EPA did not identify any findings during the AN L-CCP inspection. The concerns identified during the inspection, as well as ANL-CCP’s respons es, are discussed in the preceding sections of this report. Copies of the EPA Inspection Issue Tracking Forms that capture these issues are included in Attachment B. ANL-CCP responded to all EPA findings and concerns that required a response prior to the inspection closeout on site , as well subsequent to the inspection. The EPA inspection team members evaluated all responses for completeness and adequacy, and concluded that each EPA issue requiring a response had been resolved satisfactorily. No EPA issues remain open at this time.

10.2 Conclusions

EPA’s inspection team determined that ANL-CCP’s RH WC program activities were technically adequate. EPA is approving the ANL-CCP-RH WC progr am in the configuration observed during this inspection, described in this report, a nd documented in detail in the checklists in Attachment A. The approval includes the following:

• The AK process for RH retrievably-stored TRU debris in one waste stream, Argonne National Laboratory Waste Stream No. AERHDM, as defin ed in CCP-AK-ANLE-500, Revision 1, July 18, 2006

• The radiological characterization process using DTC and modeling-derived scaling factors for assigning radionuclide values to one RH waste stream for which the scaling factors are applicable, as described in CCP-AK-ANLE -501, Revision 0

• The VE process for one retrievably-stored RH S5000 debris waste stream AERHDM using the trained personnel, documentation, and pro cedures discussed in this report.

EPA is not approving the WWIS for entry and trackin g of the waste contents of RH debris wastes at this time. Although the WWIS is currentl y approved by EPA for tracking CH waste, ANL-CCP had not demonstrated its adequacy to enter and track RH waste contents during this baseline inspection. During the comment period for the proposed approval CBFO notified EPA that the WWIS was operational for RH wastes and was ready for EPA evaluation as a T1 change. EPA is in the process of reviewing the WWIS databas e that has been populated with actual RH

waste content data. The results of the T1 evaluati on will be provided upon completion. No RH waste can be shipped to WIPP for disposal until EPA approves the WWIS as a T1 change.62

EPA is not approving RTR at ANL-CCP. ANL-CCP did n ot have an operational RTR unit in place at the time of the inspection. ANL-CCP canno t ship RH waste to WIPP using RTR as a WC technique until it is inspected and approved by EPA.

Any changes to the WC activities from the date of t he baseline inspection must be reported to and, if applicable, approved by EPA, according to T able 10.63Table 10. Tiering of RH TRU WC Processes Implementedby ANL-CCP(Based on September 12–14, 2006 Baseline Inspection)RH WC Process ElementsANL-CCP RH WC Process - T1 ChangesANL-CCP RH WC Process - T2 Changes*Acceptable Knowledge (AK)Any new waste streams not approved under this baseline; AK (1)Modification of the approved waste stream AERHDM toinclude additionalcontainers beyond the approximately 45 included inCCP-AK-ANLE-500,Revision 1. The 20additionalcontainers identified in the AK summary asbeing presentarenot included in this waste stream approval; AK (1)Substantive modification(s)*** that have the potential to affect thecharacterization process to CCP-AK-ANLE-500, CCP-AK-ANLE-501 orCCP-AK-ANLE-502; AK (8)Implementation of load management for any RH wastestream; AK (16)Notification to EPA that the final DTC determination iscomplete for RH containers in the approved wastestream; AK (3)Notification to EPA when updates are made to AKdocumentation as a result of WCPIP revisions**; AK(4)Notification that updates have been completed to thefollowing documents:•All future revisions of CCP-ANLE-AK-500,CCP-ANLE-AK-501; AK (4)•Listing of the references that document theassembly of fuel pin data and review process;AK (5)•All future revisions of CCP-ANLE-AK-502;AK (8)•CCP-AK-ANLE-500 and CCP-AK-ANLE-502 toaddress freeze file changes; AK (8)Notification to EPA that the data package for thisdebriswaste stream is completed, including any modificationsto the WSPF including the CRR and AK Summary;AK (9), and AK (14)Notification to EPA when AK accuracy reports arecompleted, prepared annually at a minimum; AK (15)Radiological Characterization,including Dose-To-Curie (DTC)Use of any alternate radiological characterizationprocedure other than DTCwith established scaling factors as documented in CCP-TP-504 andCCP-AK-ANLE-501, Revision 0, respectively, or substantive modificationthereof***; RC (8.2.2 and 8.2.3)Any new waste stream not approved under this baseline or addition ofcontainers to waste stream AERHDM that require changing the establishedradionuclide scaling factors; RC (8.2.3)Application of new scaling factors for isotopic determination other thanthose documented in CCP-AK-ANLE-501; RC (8.2.2 and8.2.3)Notification to EPA that revisions of CCP-AK-ANLE501 or CCP-TP-504 that require CBFO approval** arecomplete; RC (8.2.2 and 8.2.3)64Table 10. Tiering of RH TRU WC Processes Implementedby ANL-CCP(Based on September 12–14, 2006 Baseline Inspection)RH WC Process ElementsANL-CCP RH WC Process - T1 ChangesANL-CCP RH WC Process - T2 Changes*Visual Examination (VE) VE by reviewing existing audio/visual recordings for Summary wastecategory not covered by this approval; VE (1) & VE(3)VE by any new process for S5000 debris wastes; VE (1) and VE (3)Notification to EPA that revisions of any VE procedurethat require CBFO approval are complete; VE (1) andVE (3)Addition of new S5000 debris waste streams; VE (2)Real Time Radiography (RTR) Any use of RTR requiresEPA approvalNoneWIPP Waste Information System(WWIS)Any use of WWIS requires EPA approval prior to RH waste disposal None* ANL-CCP will report all T2 changes to EPA every three months.** Excluding changes that are editorial in nature or are required to address administrative concerns.New references that are included as part of the document revision may berequested by EPA.***Substantive modificationrefers to a change with the potential to affect ANL’s RH WC process, e.g., the use of an inherently different type of measurement instrument orthe use of the high range probe as described for CCP-TP-504 for radiological characterization.65

11.0 REFERENCES

New Mexico Environment Department, Waste Isolation P ilot Plant Hazardous Waste Facility Permit, NM48901 139088-TSDF, Santa Fe, New Mexico, 1 989.

U.S. Code of Federal Regulations, Title 40

, Protection of Environment , Part 191, “Environmental Radiation Protection Standards for Management and D isposal of Spent Nuclear Fuel, High-Level

and Transuranic Radioactive Wastes.”

U.S. Code of Federal Regulations, Title 40

, Protection of Environment , Part 194, “Criteria for the

Certification and Re-Certification of the Waste Iso lation Pilot Plant’s Compliance with the 40 CFR Part 191 Disposal Regulations.”

U.S. Department of Energy, Title 40 CFR Part 191, C ompliance Certification Application for the Waste Isolation Pilot Plant, DOE/CAO 1996-2184, Car lsbad, New Mexico, 1996.

U.S. Department of Energy, Carlsbad Area Field Offi ce, “Remote Handled TRU Waste Characterization Program Implementation Plan,” DOE/ WIPP-02-3214, Revision 0D, Carlsbad, New Mexico, October 30, 2003.

U.S. Department of Energy, Title 40 CFR Part 191, S UBPART D AND C, Compliance Recertification Application 2004, DOE/WIPP/2004-323 1.

U.S. Department of Energy, Carlsbad Area Field Offi ce, “Contact-Handled Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot P lant (CH-WAC),” Revision 3, DOE/WIPP-02- 3122, Carlsbad, New Mexico, April 25, 2005.

U.S. Department of Energy, Carlsbad Area Field Offi ce, “Quality Assurance Program Description (QAPD),” DOE/CBFO-94-1012, Revision 7, Carlsbad, New Mexico, July 2005.

U.S. Environmental Protection Agency, “Criteria for the Certification and Recertification of the Waste Isolation Pilot Plant’s Compliance with the D isposal Regulations: Certification Decision; Final Rule,” Federal Register , Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405.

U.S. Nuclear Regulatory Commission, “Contact-Handle d Transuranic Waste Authorized Methods for Payload Control (CH-TRAMPAC).”Attachments A.1 through A.3Revision No.: 3Date of Revision: 05/25/06AK-1ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-ANLE CCP RH-9.06-8Inspection Date: September 12-14, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/AdequacyImplementation of Characterization Methods to Satisfy DQOs (WCPIP Section 4.2)How are the following DQOs being addressed—any ofthese that AK is used to determine must bequalified/verified as per Section 4.3, except for the firstbullet (defense):•Defense determination•TRU waste determination•RH waste determination•Activity determination (total and activity percanister)•Residual liquids•Physical form•Metals•Cellulosics, plastics, rubberWCPIP Rev. 0D, Section 4.2; CCPP0-002, Rev. 16.Interview of AKEsincluding Steve Shafer,Kevin Peters, LisaWatson; examination ofobjective evidence.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-500 Rev.1; CCP-AKANLE-501 Rev 0, CCP-AK-ANLE-502Rev. 0, CCP-TP-506 Rev. 2, CRR-ANLEAERHDM, AK Accuracy Report, WSPF,CRR.It is anticipated that the WCPIP will berevised in the future. One major changeexpected is the addition of a DQP requiringidentification/quantification of the EPA 10radionuclides. Revisions of severaldocuments are anticipated including manyof those listed above. Revisions to anydocuments reviewed as part of thisinspection, but changed due to WCPIPrevisions, must be provided to EPA.Qualification/Verification of AK Data (WCPIP Section 4.3)Is AK qualification/verification required becausecharacterization information exists that was generatedprior to an established QA Program?WCPIP Rev. D, Section 4.3, CCPP0-002, Rev. 16.Interview of AKEsincluding Steve Shafer,Kevin Peters, LisaWatson; examination ofobjective evidence.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-502 Rev.0;CCP-AK-ANLE-500a. If yes, what qualification approach is used andforwhich characterization data (e.g. Peer Review,Confirmatory Testing, Equivalent QA)WCPIP Rev. D, Section 4.3, CCPP0-002, Rev. 16.Interview of AKEsincluding Steve Shafer,Kevin Peters, LisaWatson; examination ofobjective evidence.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-502 Rev.0;CCP-AK-ANLE-500b. If Peer Review performed, does it follow requirementspresented in Section 4.3.1 of the PIP?WCPIP Rev. D, Section 4.3, CCP-P0-002, Rev. 16.Interview of AKEsincluding Steve Shafer,Kevin Peters, LisaWatson.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-502 Rev.0;CCP-AK-ANLE-500Revision No.: 3Date of Revision: 05/25/06AK-2ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-ANLE CCP RH-9.06-8Inspection Date: September 12-14, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/AdequacyNo Peer Review Performed.c. If Confirmatory Testing is performed, does it followrequirements presented in Section 4.3.3 of the PIPandwhich methods are used?•100 % VE at time of packaging•10-10-all•Representative sample collection to confirmisotopic distribution•100% NDA•DA•DTC•Other as described in a Confirmatory Testing Plan:- VE by review of a percentage of audio/videotapes- Analysis of representative samples forradiological data- VE/radiography of a subpopulation of waste- Qualification of existing radiological samplingand analytical info via modeling (e.g. ORIGEN)•Did the generator submit a Confirmatory Test Planas described in Section 4.3.3 of the PIP? If so, hasCBFO audited and approved the process? Did itcontain the following and was it adequate:-Description of the waste stream or waste streamlots to which the plan applies-Explicit description of DQOs and QAOs thatwill be satisfied with the data being qualified-Description of DQOs and QAOs that will NOTbe confirmed with the data being qualified, andan explanation of how compliance with thoseDQOs and QAOs will be demonstrated-Description of the confirmatory testingproposed, including the percentage of wastecontainers subject to confirmatory testingWCPIP Rev. D, Section 4.3,CCP-P0-002, Rev. 16.Interview of AKEsincluding Steve Shafer,Kevin Peters, LisaWatson.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-502 Rev.0; CCP-AKANLE-500; AK Tracking Spreadsheet,CCP-AK-501, DTC Conversion Records,CRR-ANLE-AERHDM, BDRs forcontainers 00810, 817, 820, 824, 826.CCP performed DTC and examination ofall VE tapes/records for each container.CTP described process including requiredcontents of PIP and including DQO andQAO identification (see checklistdiscussion below).Revision No.: 3Date of Revision: 05/25/06AK-3ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-ANLE CCP RH-9.06-8Inspection Date: September 12-14, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacy-Description of how the tested subpopulationswill be representative of the waste stream orwaste stream lot-Quantitative acceptance criteria for determiningthat the AK information in question can bequalified as characterization dataGeneral Checklist QuestionsIs the scope of the waste for which approval is soughtdefined? What is it?WCPIP Rev. 0D, CCP-P0-002, Rev.16.Interview of AKEsincluding Steve Shafer,Kevin Peters, LisaWatson.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-500; CCP-AK-ANLE502.Approval sought for single waste streamAERHDM as defined in CCP-AK-ANLE500. This includes approximately 45drums and 50 newly generated wastecontainers sourced from the AGHCF, anddoes not include other wastes such as theadditional 20 containers identified in theAK Summary but not currently consideredpart of the waste stream. Changes to thestream to include these new wastes wouldrequire EPA notification, as would additionof any new waste streams.Is the waste TRU by definition as presented in theLWA?(P.L.102-579)WCPIP Rev. 0D, CCP-P0-002,Rev. 16.Interview of AKEsincluding Steve Shafer,Kevin Peters, LisaWatson.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-500, CCP-AK-ANLE501, TRU WAC, C349, P002, U332, U334,U335, U336.CCP does not intend to load manage thisstream, but if this is performed EPAnotification is required. This includes theinclusion of CH containers in the RHcanister.Revision No.: 3Date of Revision: 05/25/06AK-4ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-ANLE CCP RH-9.06-8Inspection Date: September 12-14, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/AdequacyAre any wastes considered (or previously considered)HLW? HLW are prohibited.(P.L.102-579)Are any wastes considered (or previously considered)Spent Nuclear Fuel?(P.L.102-579)WCPIP Rev. D, CCP-P0-002,Rev. 16.Interview of AKEsincluding Steve Shafer,Kevin Peters, LisaWatson; review ofobjective evidence.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-500, CCP-AK-ANLE501; P593, P592, C121, C332, P001, P002,P023, P032, P055, P380, P412, U013Personnel and TrainingWho are the AK personnel? Upon interview, do theyperform the duties presented in Attachment A, Section 3?Who is the Site Project Manager (SPM)? Uponinterview, do they perform the duties presented inAttachment A, Section 3?Who is the Site Project Quality Assurance Officer(SPQAO)? Upon interview, do they perform the dutiespresented in Attachment A, Section 3?Are the above trained in the following:•The RH TRU WCPIP•Non conformance and corrective action processes•The AK Procedure presented in Attachment A ofthe PIP•Site-specific training relative to the contents ofthesite’s waste streams•Determining radiological contents of individualcontainersWCPIP Rev. D Attachment A; CCPP0-002, Rev. 16; CCP-QP-001,Rev. 20Interview of AKEsincluding Steve Shafer,Kevin Peters, LisaWatson, Larry Porter, A.J.Fisher; review of objectiveevidence.Examples of objective evidence obtainedinclude but are not limited to:Qualification cards and training recordsincluding resumes for Kevin Peters, SteveShafer. Lisa Watson interviewed. Duringinterview, ascertained that personnel wereknowledgeable in areas required by theWCPIP.Compiling AK Documentation and Defining the Waste Stream(s)AK documentation must be compiled. What documentshave been compiled? Are they among the following:•Published documents/controlled databasesWCPIP Rev. D Attachment A Interview of AKEsincluding Steve Shafer,Kevin Peters, LisaWatson, Review of AKExamples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-500, CCP-AK-ANLE501, Source Documents Reference List forRevision No.: 3Date of Revision: 05/25/06AK-5ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-ANLE CCP RH-9.06-8Inspection Date: September 12-14, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacy•Unpublished data•Internal procedures and notes (log books,correspondence, etc)•Engineering Documents•Mission Statements•OtherDocumentation is among the data used to define thewastestream. Has the waste stream been adequately defined asper the definition of waste stream as presented intheWCPIP: Waste stream is a waste material generatedfroma single process or from an activity which is similar inmaterial, physical form, and radiological constituents.Summary and AK SourceDocument Reference List;examination of selectedobjective evidence.AERHDM. Dozens of examples ofcorrespondence (C), Published (P), andunpublished (U) documents were providedby CCP that included various databases,internal procedures/notes, engineeringdocuments, mission statements, SafetyAnalysis Reports, etc.Waste stream was adequately defined. Notethat the source documents reference listincluded several references not cited inCCP-AK-ANLE 500 or 501, and thereference list did not include a documentthat tracked or recorded the efforts made tocompile and assess AK radiological datafor use in DTC. A reference thatdocuments fuel pin data assembly andassessment for use in DTC is required byEPA.Does additional documentation used to characterizewasteand delineate the waste stream include the following:•Previous NDA, radiochemistry, dosimetry, and nondestructive examination data•Waste generating procedures•Physical, chemical, and radionuclide inputs to theprocess•Time period that the process took place•Facilities involved•Types of waste generated (waste materialparameters)•Process descriptions and flow diagrams•Packaging logs and video tapes•MSDS•Procurement recordsWCPIP Rev. D Attachment A Interview of AKEsincluding Steve Shafer,Kevin Peters, LisaWatson; review of AKSummary and AK SourceDocument Reference List;examination of selectedobjective evidence.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-500, CCP-AK-ANLE501, Source Documents Reference List forAERHDM; U336, U335, U334, U332,C349, U305, U072, P575, P414, P380,P032, P002, C306Revision No.: 3Date of Revision: 05/25/06AK-6ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-ANLE CCP RH-9.06-8Inspection Date: September 12-14, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacy•Administrative/Process controls used as the basisfor the absence of residual liquids•Container-specific information (AK data, i.e. wastecontainer input forms, etc).Were correlations made between CH and RH TRU Wasteoperations at a site including related CH wastecharacterization data? If so, are correlations documentedon a Correlation and Surrogate Summary Form and isthisform adequate and included in the AK Summary?Were correlations and similarities with the RH TRUwaste operations at other generator/storage sites made,including characterization information for that RHTRUwaste stream? If so, are the correlations documented onthe Correlation and Surrogate Summary Form and is thisform adequate and included in the AK Summary?WCPIP Rev. D Attachment AInterview of AKEsincluding Steve Shafer,Kevin Peters, LisaWatson; review of AKSummary and AK SourceDocument Reference List;examination of selectedobjective evidence.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-500, CCP-AK-INL-501,CCP-AK-ANLE-500, CCP-AK-ANLE501, Correlation/Surrogate Summary Form,P593, P592, C060, P002, U305If containers from this stream aredetermined to be CH rather than RH, NDAof the drums would occur and the isotopicdata would be presented on a Correlationand Surrogate Summary Form that must beprovided to EPA.Has an AK Source Document Reference list beenassembled for each AK Summary/waste stream, and havereferences been assigned unique identifiers (Attachment 2of Attachment A of the WCPIP?WCPIP Rev. D Attachment A Interview of AKEs/SPMincluding Steve Shafer,Kevin Peters, LisaWatson; review of AKSummary and AK SourceDocument Reference List.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-500, Source DocumentReference List.Reference list is complete and easy tofollow.Have Source Document Summaries been developed perAttachment 5 and are these adequate? Do they identifydata limitations?WCPIP Rev. 0D Attachment A Review of SourceDocument SummariesExamples of objective evidence obtainedinclude but are not limited to:See all Source Documents (C), (P) and (U)provided (D349, P002, U332, etc.). Eachsource document has a source documentRevision No.: 3Date of Revision: 05/25/06AK-7ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-ANLE CCP RH-9.06-8Inspection Date: September 12-14, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacysummary attached to the front of thereference that summarizes documentcontents and provides a location fordocumenting data limitations.AK-AK Discrepancy ResolutionHow are AK-AK discrepancy resolutions documentedand does the documentation:•Identify the affected waste stream(s)•Identify all relevant AK source documents•State the nature of the discrepancyHas there been an instance where an AK-AK discrepancycannot be resolved or if the resolution results ina failureof a DQO? If so, the waste cannot be shipped to WIPPwithout further evaluation.WCPIP Rev. 0D Attachment A Interview of AKEs/SPMincluding Steve Shafer,Kevin Peters, LisaWatson, Larry Porter,Mark Doherty; review ofAK Summary and AKSource DocumentReference List;examination of selectedobjective evidence.Examples of objective evidence obtainedinclude but are not limited to:AK-AK radiological DRs are not provided;EPA expects these to be included in the AKrecord as they are identified. DR010,DR011, DR013 show ability of CCP todocument and resolve discrepancyresolutions. No examples of major issuesidentified thus far.Characterization of the Waste – DQO Assessment / Preparation of the AK Summary ReportWhat DQOs are assigned by AK? How are each to bequalified/verified (peer review, confirmation, equivalentQA program)•Defense determination•TRU waste determination•RH waste determination•Activity determination (total and activity percanister)•Residual liquids•Physical form•Metals•Cellulosics, plastics, RubberFor each DQO related to AK, AK personnel must identifythe DQO, supporting AK information, justify theassignments/conclusions, reference the AK SourceDocuments and applicable pages supporting theassessment, method of 40 CFR 194.22(b) will be qualifiedWCPIP Rev. 0D Section 4 Interview of AKEs/SPMincluding Steve Shafer,Kevin Peters, LisaWatson, Larry Porter,Mark Doherty; review ofAK Summary and AKSource DocumentReference List;examination of selectedobjective evidenceExamples of objective evidence obtainedinclude but are not limited to CCP-AKANLE-500 and CCP-AK-ANLE-502.CCP added a Chapter to the AK Summarythat addresses DQO assessment.Revision No.: 3Date of Revision: 05/25/06AK-8ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-ANLE CCP RH-9.06-8Inspection Date: September 12-14, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/AdequacyHave applicable DQOs been addressed as follows:•Has adequate review of AK information beenperformed to determine whether the waste wasgenerated by defense activities or is commingledwith RH TRU waste generated by defenseactivities? This determination will be establishedby the AK data compiled.•Review the AK information to determine thenuclear properties of the waste stream. The nuclearproperties relevant to RH TRU waste include:TRU activity of the waste stream greater than 100nCi/g of waste. Is this TRU waste? Will loadmanagement take place?•What information is included in the AK Recordand AK Summary to demonstrate that the waste isRH waste? Dose equivalent rate equal to or greaterthan 200 mrem/hr and less than 1,000 rem/hr at thesurface of the payload container.•Does the AK record adequately present, support,and report activity of the 10 required radionuclides(TRU isotopes238Pu,239Pu,240Pu,242Pu, and241Am; and non-TRU isotopes137Cs,90Sr,233U,234U, and238U)? Furthermore, does AK provideinformation to determine the total activity in eachcanister? Must be less than 23 curies per liter.•Are AK records used to calculate, compute, orotherwise derive the total activity and/or TRUactivity of the waste and the records? If so, werethey qualified by peer review, confirmation, orequivalent QA (see relevant checklists/analysis forthese elements, if performed)? Were data collectedunder an EPA approved program? If so, therecords alone may be used to satisfy DQOs;otherwise, the above characterization objectivesmust be met by collecting additional data duringpackaging, etc. Were data that would beWCPIP Rev. 0D Section 4 Interview of AKEs/SPMincluding Steve Shafer,Kevin Peters, LisaWatson, Mark Doherty,Larry Porter; review ofAK Summary and AKSource DocumentReference List;examination of selectedobjective evidenceExamples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-500, CCP-AK-ANLE502, CCP-AK-ANLE-501 Rev. 0, CCPAK-ANLE-502 Rev. 0, CCP-TP-506 Rev.2, CRR-ANLE-AERHDM, U001, P599,C331, C330, U015, C349, P002, U332,U334, U335, U336, P593, P592, C121,C332, P001, P002, P023, P032, P055,P380, P412, U013, C332, C333, P306AK record includes defense determinationsupporting documents. AK record includesdata that support TRU and RH designationof waste noting that the RH determinationwill be made through measurement ratherthan the AK record. Data pertaining to theEPA 10 radionuclides is present in the AKrecord, and ANLE did a separateradiological analysis similar to thatperformed by CCP, but performed on a percampaign rather than waste stream basis;this analysis provide some isotopicinformation. Note that confirmation isused for all verification except for thedefense determination. WMPs identifiedvia waste disposal records and can be usedto assess waste stream assignments;examination of VE tapes/records isperformed separately from the AK effort.Note that EPA expects the AK record toinclude information pertaining to wastestorage that would identify whether anyresidual liquids due to post containerinundation or management might haveoccurred. Also, load management is notplanned, but would require directnotification of EPA if it was done.Revision No.: 3Date of Revision: 05/25/06AK-9ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-ANLE CCP RH-9.06-8Inspection Date: September 12-14, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacyconsidered AK, collected and assembled under anEPA qualified program, and were those data used?If so, what was it and how was it used? (E.g.,identification of SCG for use in DTC)•Has AK been used to compile informationregarding the waste stream waste materialparameters to provide a detailed description of thewaste stream in accordance with the format of theAK Summary Report?•Has AK information been used to determine theabsence of residual liquids? This review mayinclude waste packaging procedures and otherdocumented administrative controls such astraining records that identify control of residualliquids. It may also include previous wastecharacterization data or information from wastecontainer-specific packaging logs. The criterion inthe DQO is that residual liquids must be less than1 percent by volume of the waste container.AK Summary Report PreparationHas an AK Summary been prepared and does it followthe format specified in Attachment 1? The report shallinclude the following:•Program and waste stream narrative•Sections as defined in the WCPIP•Detailed description of the waste stream includinginformation on, for example, specific waste matrixmaterials and fill volumes•The report shall address all of the DQOs as notedin previous steps with appropriate justificationsand references in the textWCPIP Rev. 0D Attachment A Interview of AKEsincluding Steve Shafer,Kevin Peters, LisaWatson; review of AKSummary and AK SourceDocument Reference List;examination of selectedobjective evidenceExamples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-500. The report includesrequired sections, but some references inthe back of the report are not applicable toArgonne, and some references pertinent toANLE on the Source Document ReferenceList are not included in the AK Summary.Additionally, CCP committed to a freezefile change to the text to address why AKDTC data comparison with respect to AKaccuracy is not appropriate. Furthermore,it is expected that this document might beamong those changed when a new WCPIPis implemented. Therefore, provision toEPA of all revisions to CCP-AK-ANLE-Revision No.: 3Date of Revision: 05/25/06AK-10ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-ANLE CCP RH-9.06-8Inspection Date: September 12-14, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacy500 is required.Have the following documents been completed inaddition to the AK Summary; are they available forEPAreview and are they technically adequate?•AK Waste Summary Report•AK Source Document Reference List•Correlation and Surrogate Summary Form•AK discrepancy resolution documentation•AK source document summariesWCPIP Rev. 0D Attachment A Interview of AKEsincluding Steve Shafer,Kevin Peters, LisaWatson; review of AKSummary and AK SourceDocument Reference List;examination of selectedobjective evidence.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-500; AK SourceDocument Reference List, Correlation andSurrogate Summary Form, DR010, DR011,DR013. Source Document Summaries areplaced on each correspondence (C),published (P), and unpublished (U)document.Have all of these been provided to the SPM for review, asrequired in Section 6.7 of the WCPIP Attachment A?Didthe AK personnel recommend how the SPM should assessand qualify the information? (6.8)WCPIP Rev. 0D Attachment A Interview of AKEsincluding Steve Shafer,Kevin Peters, LisaWatson; review of AKSummary and AK SourceDocument Reference List;examination of selectedobjective evidence.Examples of objective evidence obtainedinclude but are not limited to:Characterization Reconciliation Report andWaste Stream Profile Form. Interviewwith SPM indicated he had all informationcited in Section 6.7 available for review. Itwas not determined that AK personnelrecommend how the SPM assess data, asthe SPM did so independently.Reconciling Compiled AK InformationHas the SPM Reviewed the AK Summary Report, AKSource Document Reference List, Correlation andSurrogate Summary Forms, the referenced sourcedocument summaries, if applicable, batch data reportsfrom any confirmatory activities such as VE or NDAand,if applicable, supplemental data collected duringrepackaging using an approved technique, to determine ifthe AK record is reconciled and is adequate tocharacterize the waste stream or waste stream lot andsatisfy the relevant DQOs?WCPIP Rev. 0D Attachment A Interview of Larry Porter;review of the AKSummary Report,Correlation and SurrogateSummary forms, BDRs,and other supportingverification activities.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-500; CCP-AK-ANLE502, AK Source Document Reference List,Correlation and Surrogate SummaryForms; source document summaries (asincluded for each source documentprovided), and BDR for Drum C810.Revision No.: 3Date of Revision: 05/25/06AK-11ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-ANLE CCP RH-9.06-8Inspection Date: September 12-14, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/AdequacyDiscrepancies between the AK record and confirmatorytest results identified during this reconciliationprocessmust be resolved and documented. What is the AKmeasurement discrepancy resolution process employedand is it satisfactory? Does it involve reevaluation of theAK record, reassignment of waste stream parameters,anda revision to the AK Summary Report?WCPIP Rev. 0D Attachment A Interview of AKEs/SPMincluding Steve Shafer,Kevin Peters, LisaWatson, Mark Doherty,and Larry Porter; reviewof AK Summary and AKSource DocumentReference List;examination of selectedobjective evidence.Examples of objective evidence obtainedinclude but are not limited to:WSPF, CRR. No discrepancies betweenthe AK Record and the confirmatory testresults were found. However, ANLEperformed a detailed analysis of the streambased on AK using a similar process as thatused by CCP. Comparison of results willbolster use of the waste stream scalingfactor, assuming that the results arecomparable. Therefore, EPA requiresprovision of all DTC radiological data(DTC conversion records) summarizingDTC results for the purposes of AK-DTCcomparison.AK AccuracyHas the SQAO, consistent with the requirements ofSection 4.1.1.2 of the WCPIP, reviewed the AK SummaryReport, confirmatory test data, identified AKdiscrepancies, and prepared an AK Accuracy Report?This report will identify the percentage of containers thathave been assigned to another SCG, as well asradiological issues.WCPIP Rev. 0D Attachment A Interview of A.J. Fisher;examination of AKAccuracy Report.Examples of objective evidence obtainedinclude but are not limited to:AK Accuracy Report for initial containers,stream AERHDM. The report did notconsistently indicate that accuracy wouldbe based both on waste stream andsummary category group reassignment asrequired by the WCPIP. EPA noted this inconcern No. EPA-ANL-RH-CCP-09-001C,and expects that the concern will bereconciled in the next AK Summary thatmay also include modifications to addressWCPIP changes.How did the SQAO determine what is to be considereda“significant” radiological discrepancy and is thisdetermination technically sufficient and adequate?WCPIP Rev. 0D Attachment A Interview of A.J. Fisher;examination of AKAccuracy Report.Examples of objective evidence obtainedinclude but are not limited to:AK Accuracy Report; CCP-AK-ANLE502. CCP committed to freeze file changesto CCP-AK-ANLE-502 and CCP-AKANLE-500 that both address whyRevision No.: 3Date of Revision: 05/25/06AK-12ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-ANLE CCP RH-9.06-8Inspection Date: September 12-14, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacycomparison of AK and DTC data, withrespect to accuracy, is not appropriate.CCP-AK-ANLE-502 was also revised toclarify how the mass spectrometry data areused in the comparison process.Has the AK Accuracy report been updated annually?Even if the report is only updated annually, will theycontinually assess AK Accuracy?WCPIP Rev. 0D Attachment A Interview of A.J. Fisher;examination of AKAccuracy Report.Examples of objective evidence obtainedinclude but are not limited to:AK Accuracy Report. In the past CCP hasperformed AK Accuracy on a lot basis.Provision of AK Accuracy reports to EPAas they are prepared, is required.Has the AK Accuracy fallen below 90%? If so, the siteshall document this as a significant condition adverse toquality as defined by the CBFO QAPD. The site shallnotify the CBFO of this condition and implementappropriate corrective actions before proceeding withfurther characterization activities on the affectedwastestream(s).WCPIP Rev. 0D Attachment A Interview of A.J. Fisher;examination of AKAccuracy Report.Examples of objective evidence obtainedinclude but are not limited to:Accuracy reports, as revised to addressWCPIP and EPA concerns is required, butit is anticipated that these revisions will notshow that the accuracy has fallen below90%.Preparation of the CRRHas the SPM reviewed the qualified AK characterizationinformation and the corresponding required DQOs anddocumented this review in an RH TRU waste AKCharacterization Reconciliation Report (CRR)? At aminimum the CRR shall include:•Specification of applicable site and waste stream•A listing of each DQO•Data from the AK record that addresses each DQO•AK source document references thatsupport/provide the data•A listing of AK record discrepancy resolutions, ifany, that are relevant to each DQOWCPIP Rev. 0D Attachment A; CPTP-506 Rev. 2Review of the CRR forselect ANLE RH wastestream; interview of LarryPorter, SPM.Examples of objective evidence obtainedinclude but are not limited to:WSPF and CRR; BDRs for containers00810, 815, 817, 820, 824, 826. CRR shallbe revised to include WCPIP revisions thatrecognize identification of EPA 10radionuclides as a DQO.The CRR included information required bythe WCPIP Attachment A.Revision No.: 3Date of Revision: 05/25/06AK-13ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-ANLE CCP RH-9.06-8Inspection Date: September 12-14, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacy•Documentation, including specific references, ofhow the AK data for each DQO were qualified,such as batch data reports, corroborative data,proceedings of a peer review, etc.•Radiography and/or visual examination summaryto document that liquids greater than 1 percent areabsent from the waste and to confirm AKconcerning the physical properties of the waste•A summary presentation of radiologicalmeasurement data used to meet the DQOs and toconfirm AK•A complete AK summary•A complete listing of all container identificationnumbers used to generate the WSPF, crossreferenced to each batch data report•A listing of AK discrepancies generated by an AKqualification process and the correspondingresolutions•Signature of the SPMHas the SPM verified that the applicable QAOs(accuracy, completeness, representativeness, andcomparability) associated with the AK process havebeenmet?WCPIP Rev. 0D Attachment A;CCP-TP-506 Rev. 2Review of the CRR forselect ANLE RH wastestream; interview of LarryPorter, SPM.Examples of objective evidence obtainedinclude but are not limited to:WSPF, CRR. Applicable QAOs have beenincluded on the CRR.Preparation of the Waste Stream Profile FormHas the SPM completed the Waste Stream Profile Form(WSPF) (Attachment 4) based on AK characterizationand confirmation results and other relevantcharacterization data? Is the form complete andadequate/accurate?WCPIP Rev. 0D Attachment A Review of the WSPF andrelated attachments;interview of Larry Porter,SPM.Examples of objective evidence obtainedinclude but are not limited to:Draft WSPF and related attachments (AKSummary and CRR)See comments pertaining to the AKSummary and CRR. Note that the WSPFwas a draft version prepared for auditpurposes only; EPA must be provided thefinal version of the WSPF once it isRevision No.: 3Date of Revision: 05/25/06AK-14ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-ANLE CCP RH-9.06-8Inspection Date: September 12-14, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacycompleted and approved.EPA also requires provision of allforthcoming DTC results, not just thosethat might be summarized in the CRR,including the radiological data(identification/quantification) of the EPAradionuclides so that EPA may comparethis information with AK data.Have the WSPF, the RH AK Summary Report and theCharacterization Reconciliation Report, resulting fromwaste characterization activities, been transmittedto theDepartment of Energy Carlsbad Field Office(DOE/CBFO). Only RH TRU waste that is characterizedin accordance with the EPA requirements and WCPIPwill be accepted for disposal at the WIPP.WCPIP Rev. 0D Attachment A Review of the WSPF andrelated attachments;interview of Larry Porter,SPM.Examples of objective evidence obtainedinclude but are not limited to:Draft WSPF, CRR, AK Summary for CCPAK-ANLE-500. Only draft version wereavailable at the inspection; EPA must beprovided the final version of the WSPF andrelated attachments once completed andapproved.RecordsHave the following records been generated and whatisthe disposition of these records?•AK Summary Report (Attachment 1)•AK Source Document Reference List(Attachment 2)•Correlation and Surrogate Summary Form(Attachment 3)•Waste Stream Profile Form (Attachment 4)•AK Source Document Summary (Attachment 5)•Characterization Reconciliation Report•AK Source Documents•AK Training Records•AK Discrepancy Resolution Documentation•AK Accuracy ReportWCPIP Rev. 0D Attachment A Interview of AKEs KevinPeters, Steve Shafer, LisaWatson; examination ofrequired references aslisted (objective evidence).Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-500, CCP-AK-ANLE501, AK Source Document Reference List,Correlation and Surrogate Summary Form,draft WSPF including the CRR, requestedC, U, and P source documents, trainingrecords for K. Peters and S. Shafer, DR010,DR011, DR013, AK Accuracy Report(current containers waste streamAERHDM).Lisa Watson verified that all documents areincluded at the CCP Files in Carlsbad, NewMexico.Revision No.: 3Date of Revision: 05/25/06AK-15ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-ANLE CCP RH-9.06-8Inspection Date: September 12-14, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/AdequacyConfirmatory Test PlanWCPIP Rev. 0D Attachment A Interview of AKEs KevinPeters, Steve Shafer, andMark Doherty, andexamination of objectiveevidence.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-ANLE-502, Rev. 0. The test planrequires revision to move the AK accuracyassessment discussion to a moreappropriate location, clarify the use of massspec data, and clarify why AK-DTC datacomparisons as part of AK Accuracy areinappropriate. CCP committed to thesechanges in a Freeze File change. EPArequires provision of revisions to CCP-AKANLE-502 to verify that these freeze filechanges were made, and to assess changesimplemented to address WCPIPmodifications.Revision No.: 3Date of Revision: 05/25/06RC-DTC-1ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIEEPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12–14, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceTechnical Documents/ProceduresIdentify all ANL-CCP documents thatprovide technical information relative toperforming and documenting theimplementation of the DTC method,including operational procedures, andindicate the current revision of each.YDOE/WIPP-02-3124, Rev.0DAll ANL-CCP documents werereviewed before, during, or directlyfollowing this inspection. The correctrevisions for each are noted in ObjectiveEvidence in the cell to the left in thisrow.Y Documents include: CCP-TP504, Rev. 3; CCP-AK-ANEL500, Rev. 1; CCP-AK-ANLE501, Rev. 0; and 9 Calculationpackages prepared by J. Vance &J. Holderness cited in Section8.2.1.Dose-To-Curie InstrumentsVerify the following:•Specifications for the instrumentsused for dose rate measurements ofRH TRU waste containers areprovided in ANL-CCP documents•Performance and measurementcontrol criteria for dose rateinstruments have been specified andintegrated in ANL-CCP operatingprocedure(s)•The instruments used to make doserate measurements of RH containersare identified•The instruments identified inprevious bullet have beenappropriately calibrated•The scale used to weigh thecontainers has been calibrated andthat the scale has been checked eachoperational dayY CCP-TP-504, Rev. 3,Section 4.1These technical aspects were verified byexamination during the inspectionYCCP-TP-504, Rev. 3; CCP-AKANLE-501, Rev. 0; ANL-CCPDTC Batch Data Report No.ANLRHDTC06001 that containscopies of Attachment 1,Measurement Control Report,Attachment 2,Container DataSheet,from CCP-TP-504 andAttachment 3,Waste ContainerDose-to-Curie ConversionRecord, from CCP-TP-504, Rev.3, for each container in the BDRthat was assayed.Verify that the instruments used for dose ratemeasurements of RH TRU containers areproperly calibrated to provide data that areconsistent with those used in the calculationof the radionuclide-specific activity.Y CCP-TP-504, Rev. 3,Section 4.1Calibration sheets for the ion chambersused were examined.Y ANL-CCP DTC Batch DataReport No. ANLRHDTC06001Revision No.: 3Date of Revision: 05/25/06RC-DTC-2ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIEEPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12–14, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceVerify that the position of the detectorrelative to the waste container and anyintervening shielding is consistent with thatused in the calculation of the expectedradiation dose.Y CCP-TP-504, Rev. 3,Section 4.1Detector position relative to the wastecontainer and shielding is addressedappropriately.Y ANL-CCP DTC Batch DataReport No. ANLRHDTC06001Revision No.: 3Date of Revision: 05/25/06RC-DTC-3ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIE (DTC)EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12–14, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceGeneral Technical RequirementsDTC must provide information to support thereporting of quantitative values anduncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr and137Cs.Y DOE/WIPP-02-3124, Rev.0D, Attachment C, Section8.0Quantitative values and uncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs are reported.Y ANL-CCP DTC Batch DataReport No. ANLRHDTC06001Verify that a waste container is classified asRH TRU only if the dose equivalent rate atthe exterior of the surface of the container isbetween 200 mrem/hr and 1000 rem/hr andthe concentration of alpha emitting TRUradionuclides is greater than 100 nCi/g waste.Y DOE/WIPP-02-3124, Rev.0D, Attachment C, Section12.0All containers in RH TRU waste streamAERHDM meet the criteria for TRU(concentration of alpha-emitting TRUradionuclides greater than 100 nCi/gwaste) and RH (dose equivalent rate atthe exterior of the surface of thecontainer between 200 and 1000rem/hr).Y ANL-CCP DTC Batch DataReport No. ANLRHDTC06001Assess the technical adequacy of thecalculations involving the application ofscaling factors and/or correlation techniques.Y DOE/WIPP-02-3214, Rev.0D, Attachment C, Section7.0The technical adequacy of thecalculations involving the application ofscaling factors and/or correlationtechniques is addressed in Section 8.3.Y See Section 8.2 of this report,also INL-RH-02; INL-RH-03;ANEL-RH-03; ANLE-RH-05;ANLE-RH-06; ANLE-RH-07.Measurements: Dose Rate and BackgroundVerify the following:•Dose rates are measured four (4) timesat a detector-to-container distance of 1meter, with the container rotated 90°between each of the fourmeasurements•The appropriate ion chamber andprobe are used•The radiation field is measured at leasttwo locations about the container atthe mid-height of the container and adistance of 1 meter from the surface ofthe container.Y DOE/WIPP-02-3214, Rev.0D, Attachment C, Section7.0ANL-CCP Batch Data Report No.ANLRHDTC06001examined for thisinspection documented technicallyappropriate collection of containerspecific dose rate information.Y ANL-CCP DTC Batch DataReport No. ANLRHDTC06001,copies of copies of Attachment 1,Measurement Control ReportandAttachment 2,Container DataSheetand Attachment 3,WasteContainer Dose-to-CurieConversion Record, from CCPTP-504, Rev. 3.Verify that the background rate is measuredand recorded and that actions are taken toreduce the background if the measuredY CCP-TP-504, Rev. 3,Section 4.1ANL-CCP Batch Data Report No.ANLRHDTC06001examined for thisinspection documented technicallyY ANL-CCP DTC Batch DataReport No. ANLRHDTC06001,copies of Attachment 2,Revision No.: 3Date of Revision: 05/25/06RC-DTC-4ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIE (DTC)EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12–14, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidencebackground radiation levels are greater thanone-tenth of the expected container rate.appropriate background measurementdata.Container Data Sheetfrom CCPTP-504, Rev. 3Measurement DocumentationVerify that container number, waste streamidentifier, and all pertinent container-specificmeasurement data are entered into the“Waste Container Dose-to-Curie ConversionRecord” spreadsheet, including:•Date of the gamma measurements•Waste Stream Designation•Container Number•Container Gross Weight•Estimated Can Size for Cans #1, #2,#3•Estimated Fill Percentage for Cans #1,#2, #3•Four (4) quadrant dose rates•Average of four (4) dosemeasurements•Expected container dose rate•Waste Material Type (matrix)Y DOE/WIPP-02-3124, Rev.0D; CCP-TP-504, Section4.2ANL-CCP Batch Data Report No.ANLRHDTC06001examined for thisinspection contained all requireddocumentation.Y ANL-CCP DTC Batch DataReport No. ANLRHDTC06001,copies of Attachment 2,Container Data SheetandAttachment 3,Waste ContainerDose-to-Curie ConversionRecord, from CCP-TP-504, Rev.3.Verify that DTC BDR ANLRHDTC06001contains the following items:•Batch Data Report Cover Sheet,Attachment 4•Batch Data Report Table of Contents,Attachment 5•Batch Data Report NarrativeSummary, Attachment 6•ITR Review Checklist, Attachment 7•Measurement Control Report,Attachment 1•Container Data Sheet(s), Attachment 2•Waste Container Dose-to-CurieConversion Record(s), Attachment 3•Copy of NCRs, if applicableY CCP-TP-504, Rev. 3,Section 4.3ANL-CCP DTC Batch Data Report No.ANLRHDTC06001examined for thisinspection contained all requiredelements.Y ANL-CCP DTC Batch DataReport No. ANLRHDTC06001Revision No.: 3Date of Revision: 05/25/06RC-DTC-5ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIE (DTC)EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12–14, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidence•Evidence of a review by an ITR andSPM, as appropriate.Verify that records generated in support ofDTC are available for inspection. Recordsinclude the following, at a minimum:•Site-specific procedures developed toimplement the DTC method•Technical basis for the determinationof the waste stream’s “Standard Mix”shielding calculations for wastecontainers•Technical basis for determination ofradionuclide scaling factors•TMU technical support documentsY DOE/WIPP-02-3214, Rev.0D, Attachment C, Section15.0All records related to DTC wereavailable for this inspection on-site atINL and in CBFO Headquarters inCarlsbad, New Mexico.Y ANL-CCP DTC Batch DataReport No. ANLRHDTC06001Revision No.: 3Date of Revision: 05/25/06RC-DTC-6ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIE (DTC)EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12–14, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceTechnical BasisVerify the following:•Results of sampling and calculationform the basis for the development ofradionuclide scaling factors used toconvert measured dose rates toradionuclide-specific activities•Dose rates are measured at a distanceof one meter from the outer surface ofthe waste container at the mid-heightof the container•Calculations appropriately present therelationship between a container’smeasured dose rate and the waste’sactivity•Calculations account for all relevantcontainer properties, specifically fillheight (apparent density), waste type(matrix) and attenuation (shielding) ofthe container and/or liner wall•Calculations are performed usingtechnically appropriate shieldinganalysis techniquesY DOE/WIPP-02-3214, Rev.0D, Attachment C, Section7.0; CCP-AK-INL-501,Rev. 0; CCP-TP-504, Rev.3, Section 4.3These technical aspects were examinedbefore, during, and following thisinspection in consultation with CTACtechnical personnel.Y CCP-AK-ANLE-501, Rev. 0;INL-RH-02; INL-RH-03; ANELRH-03; ANLE-RH-04; ANLERH-05; ANLE-RH-06; ANLERH-07; INL-RH-09; INL-RH-10;INL-RH-12Verify that waste containers contain onlymatrices for which the DTC methodology hasbeen established.Verify that the type of waste (waste matrix)in each container is recorded along with theheight of the waste in the container.Y DOE/WIPP-02-3214, Rev.0D, Attachment C, Section5.0RH waste cans contain metals (steel),concrete, or organics with a minimumof mixing of dissimilar types ofmaterials. Fill heights are specified forall containers, i.e., less than 25% full,25% to 66% full, 66% to 90% full, morethan 90% full.Y ANL-CCP DTC Batch DataReport No. ANLRHDTC06001;DTC spreadsheets in BDRVerify that all DTC-related calculations havebeen subjected to a technical review and thatall technical review comments and theirresolutions are documented.Y DOE/WIPP-02-3214, Rev.0D, Attachment C, Section14.0With minor exceptions, all calculationpackages contain evidence of atechnical review.Y Examination of the 9 calculationpackages that supported thedevelopment of radionuclidescaling factors prepared by J.Vance & J. Holderness; seeRevision No.: 3Date of Revision: 05/25/06RC-DTC-7ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIE (DTC)EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12–14, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceSection 8.2.1Verify that the ratio of actual measured doserate to the calculated dose rate is used tocalculate a scaling factor that is applied to the“Standard Mix” or subset thereof, that wasused to estimate individual radionuclideactivities.Y DOE/WIPP-02-3214, Rev.0D, Attachment C, Section11.0; CCP-TP-504, Rev. 3,Section 4.2The “Standard Mix” was not used togenerate scaling factors for this wastestream. The technical documentation ofthe scaling factor development supportsthe use of dose rate measurements.YCCP-AK-ANLE-501, Rev. 0;INL-RH-02; INL-RH-03; ANELRH-03; ANLE-RH-04; ANLERH-05; ANLE-RH-06; ANLERH-07Total Measurement Uncertainty (TMU)Verify that a method for estimating totalmeasurement uncertainty (TMU) has beendeveloped and documented for RH TRUwaste stream AERHDM.Y DOE/WIPP-02-3214, Rev.0D, Attachment C, Section13.0This checklist addresses the aspects ofTMU attributable to DTC. The aspectsof TMU related to the development andapplication of radionuclide scalingfactors are addressed in Section 8.3.Y CCP-AK-ANLE-501, Rev. 0;INL-RH-02; INL-RH-03; ANELRH-03; ANLE-RH-04; ANLERH-05; ANLE-RH-06; ANLERH-07TMU is based upon the propagation ofuncertainties present in all aspects ofradiological characterization, including DTC.Y DOE/WIPP-02-3214, Rev.0D, Attachment C, Section13.0TMU includes the contributions of allapplicable aspects of the DTC process.Y CCP-AK-ANLE-501, Rev. 0;INL-RH-02; ANLE-RH-05;ANLE-RH-06Verify that the approach for TMUdetermination incorporates the contributionsof all applicable components of DTC,including:•Measured sample isotopic activities•Relative uncertainties associated witheach measured radionuclide•Measurement of the container’s doserate•Determination of waste mass•Modeling errors or biases.Y DOE/WIPP-02-3214, Rev.0D, Attachment C, Section13.0TMU includes the contributions of allapplicable aspects of the DTC process.Y CCP-AK-ANLE-501, Rev. 0;INL-RH-02; INL-RH-03; ANELRH-03; ANLE-RH-04; ANLERH-05; ANLE-RH-06; ANLERH-07Verify that the TMU approach has beenformally submitted to CBFO for review andapproval.Y DOE/WIPP-02-3214, Rev.0D, Attachment C, Section13.0The TMU approach was evaluated bythe CTAC Technical Specialists (D.Stuenkel and J. Oliver) during thisinspection.Y INL-RH-02; INL-RH-03; ANELRH-03; ANLE-RH-04; ANLERH-05; ANLE-RH-06; ANLERH-07Revision No.: 3Date of Revision: 05/25/06VE-1ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12-14, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentRHVE-1Site procedures identifyrequired training andqualifications for RHVEpersonnel.WCPIP, Rev.0D, Section4.1.2.2CCP-QP-002,Rev. 21•Formal training elements include:project requirements, containeridentification and labeling, applicablestate and federal regulations.•Site-specific training program:OJT,identification of summary categorygroups, WMPs, packagingconfigurations, residual liquids.Y During the on-site inspection, EPA interviewed two (2) of thethree (3) qualified operators and the designated SME/VEE.The operators had received training on AK Summary CCPAK-ANLE-500 for the waste stream being examinedAERHDM. This is a S5000 debris waste stream. Operatorswere also required to read the WCPIP, which includes EPAregulations and requirements. The VEE for ANL is also theVEE for INL and spends his time between the two sites. TheVEE is also the OJT/SME and provided the OJT for theoperators. The operators passed the required written test onMay 22, 2006. The operators reviewed revision 1 ofthe AKSummary on August 14, 2006.Objective evidence:1.Qualification cards for VE operators2.Qualification Card for SME/VEE3.VEE appointment letter, dated April 17, 20064.List of Qualified Individuals (LOQI) for ANLE RH VEprogram5.Attendance Sheets for CCP-AK-ANLE-500 training6.Acceptable Knowledge Summary Report TrainingCertificates for Argonne Remote-Handled Debris WasteStream – AERHDM.RHVE-2Operator qualification andre-qualificationrequirements are described.WCPIP, Rev.0D, Section4.1.2.2CCP-QP-002,Rev. 21, Section4.2.5•To become qualified, the RHVE operatormust pass a comprehensive written testbased on training objectives with aminimum score of 80%•Demonstrate capability in the presence ofthe site VEE during OJT•RHVE operators re-qualified every 2years based on continued satisfactoryperformanceY EPA reviewed the Qualification Cards for the three (3)qualified operators and the designated VEE. The VEEis theOJT/SME and provided the OJT for the operators. Theoperators passed the required written test on May 22, 2006.The Qualification Cards reviewed were completed asrequired. As this program is new, the re-qualification ofoperators has not been required.Objective evidence:1.Qualification cards for VE operatorsRevision No.: 3Date of Revision: 05/25/06VE-2ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12-14, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Comment•Unsatisfactory performance – failed toidentify prohibited item during OJT withscore of less than 80% on exam2.Qualification Card for SME/VEE3.VEE appointment letter, dated April 17, 20064.List of Qualified Individuals (LOQI) for ANLE RH VEprogramRHVE-3Each site has a designatedVE expert (VEE)WCPIP, Rev.0D, Section4.1.2.2CCP-PO-001,Rev. 12•VEE designation is documented•VEE has knowledge of the RH TRUwaste being characterized•Responsible for overall direction andimplementation of VE at the facility•Certification Plan specifies the selection,qualification, and training requirementsof VEEYVEE training and designation were reviewed during the onsite inspection. The VEE was designated as such ina letterfrom the SPM, dated April 17, 2006. Although the VEE hasoverall responsibility for the VE process, the VEEandoperators are not necessarily at the same locationwhencontainer audio/visual recordings are processed. The VEEand the operators have copies of the VE recordingsso thatproblems encountered by the operators can be discussed,reviewed, and resolved with the VEE by electronic ortelephonic communication.Objective evidence:1.Qualification Card for VEE2.List of Qualified Individuals (LOQI)RHVE-4CCP-TP-509,Rev. 0, Section4.4•Operators review AK TrackingSpreadsheet to verify that correctcontainers examined•Rejected containers are placed in ashielded container with a CCP Hold Tagattached•Provide container processing informationto SPM/VPMYPrior to commencing VE operations, the operators review theAK Tracking Spreadsheet to determine which containers willbe examined. During the on-site inspection, EPA inspectedthe hold tags applied to the shielded containers, located in331 yard, Building 331 Dome, and 398 yard, for therejectedcontainers from BDR RHANLVE060001. A hold tag wascorrectly attached to each container. The processinginformation for each BDR is contained within the WTSsystem and identifies the container number and theNCRnumber for rejected containers.The operators populate an Excel spreadsheet, “DGLContainer Management”, with the VE data. Only completedBDRs are uploaded to the spreadsheet. The spreadsheet isaccessed by the SPM to obtain the container information.Revision No.: 3Date of Revision: 05/25/06VE-3ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12-14, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentObjective evidence:1.AK tracking spreadsheet for containers in waste streamAERHDM2.BDR # RHANLVE0600013.Processing information for BDR RHANLVE060001RHVE-5Procedures and technicalguidance documentsprovide completeinstructions for performingRHVE.WCPIP, Rev.0D, Sections4.1.2, 4.1.2.1,4.3.3CCP-TP-500,Rev. 2, Sections4.1-4.2,Attachment 1Procedures are sufficiently detailed to enablethe operator to determine if a waste containermeets the criteria of '194.24 with regard toidentifyingapplicable parameters with wastelimits [194.24, c, (4)] – demonstrate that asystem of controls has been and will continueto be implemented to confirm that the totalamount of each waste component that will beemplaced in the disposal system will notexceed the upper limiting value, or fall belowthe lower limiting value described in theintroductory text of paragraph (c) of thissection).•All existing VE tapes will be reviewedand the VE data will be documented•Existing waste container packagingrecords will be qualified by VE or RTR•100% of containers will be subject to VEat the time of packaging•Waste stream description and WMCverified•Presence/absence of prohibited itemsYIn this waste stream, 44 containers were already packagedand CCP has audio/visual tapes for all of these. CCPestimates that there will be an additional 50 ± 100drums thatstill need to be packaged. Packaging will take place in 7.5-gallon cans and two cans will be placed in each 30-galloncontainer.Two (2) operators generated VE data for RH containers fromreview of audio/visual recordings. The operators reviewedexisting recordings and completed the required datasheetsfrom their observations. Operators were given training on thewaste stream prior to processing containers.CCP had generated only one (1) Batch Data Report (BDR)that had been through project-level review at the time of theinspection. Of the ten (10) containers in BDRRHANLVE060001, four were rejected and six (6) met therequired VE QAOs.At the end of the VE event, the operators assignedpercentages to each WMP and manually calculated, fromthese percentages and the weight of the waste contained in thecans, the weight of each WMP. Operators did not retain anyof the manual calculations performed. The ITR didnotperform the required check of these manual calculations andthe requirement to perform this verification was not includedin the ITR checklist. When interviewed, an operatorcould notprovide the basis for answering at least one of thedata formquestions. EPA generated concern ANL-CCP-RH-VE-06-001CR to address these issues.Revision No.: 3Date of Revision: 05/25/06VE-4ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12-14, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentANL-CCP-RH-VE-06-001CR:1.Method of manual calculation of WMP weights is notcontained within the existing procedure. Failure todocument this process in the procedure may lead toinconsistent and undocumented methodologies beingused for this calculation.Resolution: CCP will remove the requirement toestimate WMP weights from procedure CCP-TP-500, asit is not required by the WCPIP.2.ITR is required to review all manual calculations butWMP weight calculations are not reviewed, nor is theneed to review the item contained in any ITR checklist.Failure to do so removes the only required check onthecalculation on which WMP quantities are based.Resolution: When procedure CCP-TP-500 is revised,WMP weights will not be calculated and therefore willnot require verification of the calculation.3.Operators are filling out some “Visual ExaminationDataForm” items without the knowledge necessary to makethe correct decision. Example: Checking off yes for“The waste is consistent with the waste streamdescription?” When questioned, a VE operator couldnotexplain how they were able to answer this question.Confirmation of waste stream description is essential toAK confirmation required by 40 CFR 194.24(c).Operator is responsible to decide if the drum examined ispart of the waste stream.Resolution: CCP will provide additional training for theoperators.EPA considers this concern closed.RH drums are stored in shielded containers and, ifa containeris rejected, CCP/ANL personnel place a hold tag onthat outercontainer. The hold tags on all of the rejected containers inBDR # RHANLVE060001 were inspected by EPA.Revision No.: 3Date of Revision: 05/25/06VE-5ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12-14, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentEPA reviewed the data sheets and audio/video recordings forcontainers 00816, 00826, 00825, and 00815 to ensureconsistency between the written and visual records.EPA didnot identify any discrepant information for these containers.The audio/video recordings do not show the 7.5-gallon cansbeing loaded into the 30-gallon containers but thecans andcontainers can be associated through the original packaginginformation. This information is included in the BDR foreach container.Objective evidence:1.BDR # RHANLVE0600012.List of Qualified Individuals (LOQI) for ANLE RH VEprogram3.Attendance Sheets for CCP-AK-ANLE-500 training4.Acceptable Knowledge Summary Report TrainingCertificates for Argonne Remote-Handled Debris WasteStream – AERHDM.RHVE-6CCP-TP-500,Rev. 2, Section2.4.2•Corrective actions are taken whennecessaryY NCRs were written as needed during processing ofthecontainers in batch RHANLVE060001. Containers 00831and 00816 were rejected because CCP operators couldnotverify that containers were free of liquids. CCP NCRRHANL-0001-06 was issued by CCP to document thiscondition. NCR NCR-RHANL-0002-06 was generated forcontainers 00825 and 00829 because the operators wereunable to determine the primary contents of the containers.All of the above containers were rejected by CCP.Objective evidence:1.BDR # RHANLVE060001RHVE-7Site procedure(s) requireWCPIP, Rev.0D, Section•ITR review Attachment 2Y The VEE signed off on the BDR RHANLVE060001 althoughthe container inventories were incomplete. This wasRevision No.: 3Date of Revision: 05/25/06VE-6ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12-14, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentdata generation and projectlevel reviews of Batch DataReports (BDRs).4.1.2.1CCP-TP-500,Rev. 1, ITR:Sections 4.3.5-4.3.8,Attachment 2,SPM: Section4.4, Attachment3•SPM review Attachment 3identified by CCP and the inventories were revisedprior tothe on-site inspection. As the sign-off date for the BDR wasafter the additional training provided by CCP on June 15,2006 EPA generated concern ANL-CCP-RH-VE-06-002C toaddress this issue.ANL-CCP-RH-VE-06-002C:The ITR had not fully implemented the requirement forcomplete inventory put in place on June 15, 2006 atthe timeBDR #RHANLVE060001 was signed off on July 19, 2006.The ITR signed off on the checklist on July19, 2006,however, it was then corrected to reflect the “completeinventory” requirement on August 25, 2006.Resolution:The ITR initiated the change after he fullyunderstood the expected criteria of “complete inventory”based on the issue at INL. At the time of the inspection theVE data had been revised to include a complete inventory ofthe waste items in each container. EPA considers thisconcern closed.The SPM checklist listed the containers that were rejected inthe batch and also provided the applicable NCR numbers.Objective evidence:1.BDR # RHANLVE060001RHVE- 8CCP-TP-500,Rev. 2, Section5.0•Lifetime/QA records – Attachments 1-5,Copy of NCRs•QA/nonpermanent records – VHS tape orDVD (primary and backup)Y Both the BDR and audio/visual recordings forRHANLVE060001 were available for review during theonsite inspection. Two copies of the original VHS recordingsare made, one being sent to the VEE and one to theoperatorsfor processing.Objective evidence:1.BDR # RHANLVE0600012.Audio/visual recordings for container inBDR # RHANLVE060001Revision No.: 3Date of Revision: 05/25/06VE-7ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12-14, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentRHVE-9Quality AssuranceObjectives are defined andmetWCPIP, Rev.0D, Section4.1.2.3Data Accuracy:194.22, b, (1)the degree to which data agreewith an acceptable reference or true valueWCPIP:maintained by requiring operators topass a comprehensive test with a score of80% and demonstrate satisfactoryperformance for initial qualification and requalificationData Precision:194.22, b, (2)a measure of the mutualagreement between comparable data gatheredor developed under similar conditions,expressed in terms of a standard deviationWCPIP:– maintained by reconciling anydiscrepancies between 2 operators (oroperator and ITR) with regard to physicalform of waste, absence of residual liquidData Representativeness:194.22, b, (3)the degree to which dataaccurately and precisely represent acharacteristic of a population, a parameter,variations at a sampling point, orenvironmental conditionsWCPIP:– Contents placed in a container willbe described on the data formsData Completeness:194.22, b, (4)a measure of the amount ofvalid data obtained compared to the amountthat was expectedWCPIP: – Relevant waste information mustbe collected and documented on a videotapeY Data Accuracy:This QAO was met by using qualified operators and VEE togenerate and review the VE data generated.Data Precision:This QAO was met by the two operators accepting andsigning the data sheets. CCP has never encounteredasituation where the two operators could not resolvean initialdifference in what data should be recorded. The VEE, who isalso the ITR, discusses and resolves any VE datadiscrepancies with the operators.Data Representativeness:To ensure that the Data Representativeness QAO wasmet,the VEE reviewed the visual recording and the datasheet foreach container in the batch that did not have an NCRassociated with it. The SPM checked WMP weights againstthe item descriptions to ensure that this QAO was met.Data Completeness:The VEE determined that the Data Completeness QAO wasmet by reviewing the data sheets to ensure that someinformation is present in each block.Data Comparability:Data Comparability QAO was met by the use of an approvedtraining procedure (CCP-QP-002) and ensuring that operatorsand VEE were fully qualified. This training and qualificationwas documented in the VEE and operator QualificationCards.Revision No.: 3Date of Revision: 05/25/06VE-8ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12-14, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentand/or data form or other unalterable mediaData Comparability:194.22, b, (5)a measure of the confidencewith which one data set can be compared toanotherWCPIP:– ensured by site meeting trainingrequirements and complying with theminimum standards used to implement VERHVE-10VE as a method to qualifyAK dataWCPIP, Rev.0D, Sections 4.3,4.3.3194.24, c, (4) – demonstrate that a system ofcontrols has been and will continue to beimplemented to confirm that the total amountof each waste component that will beemplaced in the disposal system will notexceed the upper limiting value or fall belowthe lower limiting value described in theintroductory text of paragraph (c) of thissection.If VE is used as a qualification method forAK all of the requirements in section 4.3 and4.3.3 are met:•Quality and reliability of themeasurement control program underwhich the data were generated (QCsamples included in the VE process)•Extent to which the data demonstrate theproperties of interest (VE processgenerates data for allitems in containers)•Qualification of personnel generatingdata (training records for personnel ontapes performing the original VE event)•Technical adequacy of the proceduresused to generate the original data (copiesY•CCP uses two (2) qualified operators and an approvedprocedure to generate VE data.•The data sheets in BDR # RHANLVE060001 wererevised approximately two (2) months after the originalVE examinations. This revision was due to the originalcontainer inventories being incomplete. The BDRreviewed by EPA at the time of the on-site inspectioncontained complete container inventories as required.•The two operators that generated the only completedBDR (RHINLVE60001) at the time of the on-siteinspection were qualified and had passed the requiredexamination when they generated the VE data. Trainingrecords for the three (3) operators and the VEE werecomplete and available for review.•Procedure CCP-TP-500, Rev. 2 contains instructionsforperforming VE by review of original audio/visualrecordings. The procedure was technically adequate.Revision No.: 3Date of Revision: 05/25/06VE-9ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-ANL-CCP-RH-9.06-8Inspection Date: September 12-14, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentof original procedures)RHVE-11CCP-AK-ANLE502, Rev. 0,Section 3.2Verify from the packaging records whichsmaller cans were placed into any particularcontainer.Y Packaging records are included in the BDR for eachcontainer.Objective evidence:1.BDR # RHANLVE060001RHVE-12WCPIP, Rev.0D, Section2.2.3.2DQO for Physical Form – “Generator sitesmust determine the uncertainty in the estimateof the weight of the waste.”Y CCP SPM stated that this will be done when containerinformation is entered into WWIS. At this time theRHWWIS modules are not complete and WWIS was notincluded in the scope of this inspection.All WMPs for debris waste will be entered into WWISasplastic as required by the WCPIP.Attachments B.1 through B.3

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B-1 Attachment B.1 EPA Inspection Issue Tracking Form, EPA Issue No. ANL-CCP-RH-VE-06-001CR

Inspection No. EPA-ANL-CCP-RH 9.06-8 Issue Number: ANL-CCP-RH-VE-06-001CR, Rev. 1

Date: 9-13-06

Inspector: Dorothy E. Gill

Attachments? YES NO Sample Size: All Available BDRs

Population size (if known): One (1)

A. Description of Issue:

1. Method of manual calculation for WMP weights is not contained within the existing procedure. Fail ure to document this process in the procedure may lead to inconsistent and undocumented methodologies bein g used for this calculation.

CCP Response: CCP will initiate the process to rem ove this requirement in the procedure to determine the WMP weights. The requirement is self-imposed in th e procedure is not required by the PIP or the WAP.

2. ITR is required to review all manual calculation s but WMP weight calculations are not reviewed nor is the need to review the item contained in any ITR ch ecklist. Failure to do so removes the only require d check on the calculation on which WMPs quantities a re based.

CCP Response: Based on resolution to comment 1, th e ITR will no longer have manual calculations to

review so the resolution to comment 1 also resolves comment 2.

3. Operators are filling out some “Visual Examinat ion Data Form” items without the knowledge necessar y to make a correct decision. Example:

Checking off yes for “The waste is consistent with the waste stream description?” When questioned, a VE operator could not explain how they were able to an swer this question. Confirmation of waste stream description is essential to AK confirmation as requ ired by 40 CFR194.24 (c). Operator is responsible to decide if the drum examined is part of the waste st ream.

CCP Response: The VE operators were comparing the items listed in Table 2 of Section 5.4.1 of the AK Summary Report (posted in VE work area) to the item s seen on the video. This table is more detailed t han Section 2.0, Waste Stream Description and, therefor e, the operators were adequately verifying that the

waste items were consistent with the waste stream d escription. However, when the operators were asked the question with respect to the text description g iven in Section 2.0, they did not give a crisp clea r explanation. Based on the comment, CCP will provid e additional training to the operators.

B. Regulatory Reference: 40 CFR 194.24 (c)

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B-2 Attachment B.1 EPA Inspection Issue Tracking Form, EPA Issue No. ANL-CCP-RH-VE-06-001CR

Inspection No. EPA-ANL-CCP-RH 9.06-8 Issue Number: ANL-CCP-RH-VE-06-001CR, Rev. 1

Date: 9-13-06

C. Site requirement(s): 1. CCP-TP-500, Revision 2, 4.1.2 [F] 2. DOE/WIPP-02-3214, WCPIP, Revision 0D, Section 3. 5.1.2 3. CCP-TP-500, Revision 2, Section 4.1.2 [H.4]

D. Discussed with: Site Personnel: Irene Quintana, Tommy Mojica DOE/CTAC Personnel: Wayne Ledford, Karen Gaydosh Other Personnel: Eric D’Amico, Larry Porter

E. Additional Comments: Before implementing this procedure at other CCP sit es, the impact of this concern should be evaluated for inadequacies.

F. Site Response Information:

Site Response Required? YES NO Site Response Due Date: October 5, 2006

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B-3 Attachment B.2 EPA Inspection Issue Tracking Form, EPA Issue No. ANL-CCP-RH-VE-06-002C

Inspection No. EPA-ANL-CCP-RH 9.06-8 Issue Number: ANL-CCP-RH-VE-06-002C

Date: 09-13-06

Inspector: Dorothy Gill

Attachments? YES NO Sample Size: All BDRs

Population size (if known): One (1)

A. Description of Issue: The ITR had not fully implemented the requirement for complete inventory put in place on June 16, 2006 at the time BDR #RHANLVE0 60001 was signed off on July 19, 2006. The ITR signed off on the checklist on July 19, 2006, howev er, it was then corrected to reflect the “complete inventory” requirement on August 25, 2006.

CCP Response: The ITR initiated the change after h e fully understood the expected criteria of “comple te inventory” based on the issue at INL.

B. Regulatory Reference: 40 CFR 194.24 (c)

C. Site requirement(s): DOE/WIPP-02-3214, WCPIP, Revision 0D, Section 4.1.2 .1

D. Discussed with: Site Personnel: Irene Quintana, Tommy Mojica DOE/CTAC Personnel: Wayne Ledford, Karen Gaydosh Other Personnel: Eric D’Amico, Larry Porter

E. Additional Comments:

F. Site Response Information:

Site Response Required? YES NO Site Response Due Date: N/A

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B-4 Attachment B.3 EPA Inspection Issue Tracking Form

, EPA Issue No. ANL-CCP-RH-AK-06-003C

Inspection No. EPA-ANL-CCP-RH 9.06-8 Issue Number: ANL-CCP-RH-AK-06-003C

Date: 09-13-06

Inspector: Connie Walker

Attachments? YES NO Sample Size:

Population size (if known): 1 AK Accuracy Report A. Description of Issue: Section 4.1.1.2 of the WCPIP states that: The pe rcentage of waste containers which require reassignment to a new SCG and new was te stream will be reported as a measure of AK Accuracy. The AK Accuracy Report dated August 28, 2006, reports SCG accuracy, but not waste stream

accuracy.

CCP Response: CCP will be to ensure that “or new w aste stream” is included in AK Accuracy Report to comply with Section 4.1.1.2.

B. Regulatory Reference: 40 CFR 194.24 (c) (3)

C. Site requirement(s): DOE/WIPP-02-3214, WCPIP, Revision 0D, Section 4.1.1 .2

D. Discussed with: Steve Schafer, Kevin Peters Eric D’Amico, A.J. Fisher

E. Additional Comments: It is noted that the AK Accuracy Report will be amo ng those documents requiring revision when the latest revision of the WCPIP is approved. Revision of the AK Accuracy Rep ort to address the above requirements may be done at th at time, when other revisions are being done (e.g.

addition of the EPA 10 radionuclide identification as a DQO).

F. Site Response Information:

Site Response Required? YES NO Site Response Due Date: N/AAttachment C

EPA’s Response to Public CommentsC-1 EPA’s Response to Public Comments

EPA received one set of public comments from DOE’s Carlsbad Area Field Office (CBFO) in response to the November 8, 2006, Federal Register notice that proposed EPA’s decision to approve various components of the RH TRU waste char acterization program implemented by CCP at ANL and INL (71 FR 65488, November 8, 2006).

All comments are reproduced here along with EPA’s r esponse to each comment. Both ANL and INL Baseline Inspection Reports have been revised t o reflect EPA’s response, where appropriate.

Comment No. 1: On page 65490 of the Federal Register (FR) Notice in the 3 rd column it references “EPA INL CCP RH Inspection Report A-98-4 2, II-A4-69” and the correct reference is A-98-49. In addition, on page 65492 of the same no tice in the 1 st column the reference should be to A-98-49, as well, instead of A-98-42.

Response: The comment applies to the FR notice. We concur with the comment, however, the error does not affect the sufficiency of the public’s notice of the proposed approval nor does it affect the final approval itse lf.

Comment No. 2: EPA is using the Tier I and Tier II change notice process to collect additional information regarding a site’s waste characterizati on program. See Comments 9 and 10 below. The Tier change process is designed to notify the E PA of changes or expansions to programs subsequent to a Baseline Compliance Decision, not t o generate additional information. The authority provided to the Agency under 40 CFR Part 194.8(b)(4) is for the expressed purpose of reporting changes to the Agency. For requests for additional information, the Agency is encouraged to implement the provisions of 40 CFR 19 4.4(b)(2).

Response:

By requiring INL-CCP and ANL-CCP to notify EPA of the availability of new or additional information generated following the E PA’s baseline inspection and the approval decision as part of the Tier 2(T2) change notice process, EPA will remain informed of improvements in the approved waste char acterization processes (e.g., AK and DTC) in a timely manner. Through this process, EPA will verify that CCP has updated/substantiated information that was EPA eval uated during the baseline and follow-up inspections.

EPA’s baseline inspection approvals are not conting ent on review of any additional information. EPA agrees that T2 reports are intended to report changes to approv ed waste characterization programs. Also, T2 change r eports are not the appropriate mechanism to generate new information that would as sist in evaluating continuing compliance. As described in EPA’s final modificati on to 194.8(b) (69 FR 42571, July16, 2004), EPA uses its authority under §194.24(h), whe n it is necessary, to generate new or additional information to ensure continued complian ce with EPA regulations. When reporting T2 changes reflecting updates or addition of new information to the material inspected during the baseline inspections, EPA expe cts the RH site to provide a briefC-2

description of additions/updates to various AK and DTC documents. EPA can then decide whether review of this additional informatio n under the authority of §194.24(h) is warrented for evaluating adequacy and continued com pliance with regulatory requirements. EPA then will request such informati on. EPA have made appropriate modifications to the INL and ANL final baseline ins pection reports to clarify our intent.

Comment No. 3: DOE is unclear as to the reasoning that the additio n of a new piece of RTR equipment is considered a Tier I change by EPA for RTR of RH. However, as evidenced, for example, by the EPA approval of the INL-CCP CH Base line, the addition of new RTR equipment would be a Tier II change. DOE requests that EPA explain this inconsistency.

Response:

EPA identified the use of new RTR equipment for R H waste as a Tier I change because we did not evaluate any RTR equipment during the baseline inspection of June 2006 at INL. Since EPA has no information of how RTR would be applied to RH waste to characterize physical waste contents and t he absence of prohibited items in the retrievably-stored RH containers, EPA identified RTR equipment and its use for RH waste as a T1 change. Under the CH program, EPA ide ntified a new RTR process at an approved site as a T2 change because we had evaluat ed the CH RTR process during baseline inspections at all CH sites.

Comment No. 4: There are a number of inaccuracies in the Inspect ion Report A-98-49, II-A4- 69 for EPA Baseline Inspection No. EPA-INL-CCP-RH-6. 06-8. Some examples follow:

a. Page 63, Section 8.3 in fifth bullet under Docu ments Reviewed identifies 19 containers in VE Batch Data Report (BDR) RHINLVE600 01, 17 of which were subject to a CCP Non Conformance Report (NCR). Actua lly, at the time of the inspection, 5 of the 19 containers were rejected by an NCR.

b. Page 8, Section 6.2, Table 3 identifies personne l that were not at the inspection. For example, James Mobley (as a VEE), Buddy Fussell (as VE/VET) and Marcus Steade (as VE/VET) did not participate in the inspection.

Response: EPA concurs with the comment. We have revised repo rt text accordingly. The revision described in (a), above increases the number of acceptable RH containers to 19 and not the number of containers stated in the p roposed for approval in November 2006. (For additional discussion, see EPA’s respon se to Comment Nos. 8 and 12, below.)

Comment No. 5: On page 2 of the EPA-INL-CCP-RH-6.06-8 Inspection Report, the EPA limits their approval of processes (AK, DTC, and VE) based upon waste streams reviewed during the inspection. The CBFO agrees that the EPA has the a uthority to limit their approvals to specific waste streams at a particular site; however, it is important to note that these characterization processes do not change between waste streams.

As written, it is confusing as to which characteriz ation processes are approved. The CBFO recommends that the EPA remove any waste stream spe cific approvals from process approvals and add an item 4 specifically detailing which wast e streams are approved, as follows:C-3

(4) Waste Stream No. ID-ANLLE-S5000 is approved fo r shipment. Any waste stream not approved under this approval must undergo a T1.

The removal of waste stream approvals from process approvals should be done throughout the text, including Table 1 and Table 14 of Baseline In spection Report No.

EPA-INL-CCP-RH-6.06-8.

Response: Waste characterization processes may change dependi ng on the complexity of different waste streams. Therefore, until the RH si tes generate and apply detailed procedures for the derivation/generation of scaling factors and other critical radiological characterization inputs from the analytical data an d AK records, EPA must restrict its approval to waste streams that have demonstrated co mpliance during the baseline inspection and cannot approve entire waste categori es as is typically done under the CH program. EPA expects scaling factors will vary by waste stream and the RH sites need a consistent way to generate them. Therefore, we bel ieve it is premature for EPA to approve the DTC process until the RH sites develop pr ocedure(s) for calculating scaling factors.

EPA did not approve CH TRU Summary Waste Categories at the beginning of the CH program. When approving the site-specific CH TRU wa ste characterization programs initially, EPA approval was also limited to specifi c waste streams. The reason for a limited approval was that both characterization act ivities at the waste generator sites and EPA’s inspection process were in their infancy. As knowledge was gained and the sites’ CH waste characterization program matured, EPA was a ble to approve summary waste categories. EPA expects that as RH waste characteri zation programs mature and gains confidence in the sites’ ability to implement the R H WCPIP and comply with regulatory requirements as additional waste streams are charac terized, we may be able to approve RH waste by Summary Waste Categories. The experienc e gained would then justify such an approval and could support moving from more rest rictive tiering of waste streams to broader approvals of RH summary waste categories.

INL-CCP and ANL-CCP provided EPA several AK documen ts (CCP-AK-INL-500, CCPAK-INL-501 and CCP-AK-INL-502) that described the r esults of analyses or activities performed at both sites to generate scaling factors , which are critical to the characterization of radiological components in the RH waste streams. These documents

were reports , not controlled procedures , with the exception that a portion of the AK process dealing with data assembly/assimilation is included in the RH WCPIP. These reports present the results of AK-related character ization activities and do not provide the detailed procedures used to obtain the results. The reports contain the results of a process used to develop radionuclide concentrations retrospectively. They did not provide instructions whereby RH site’s WC staff coul d perform the task in the same manner prospectively. The technical calculations a nd data handling that were performed to assess AK in support of the generation of radion uclide scaling factors were complex and were appropriately presented to EPA during insp ection interviews and in the form of approximately 36 calculation packages. The calcula tion packages containedC-4

considerable detail and represent the primary docum entation of the results of the activities and processes used to derive the scaling factors. During the inspection and follow-up interviews, EPA did not obtain objective evidence documenting a set of instructions governing this waste steam-specific co ncentration development activity ensuring that the processes we observed at INL and ANL would be the same. Therefore, approving the DTC process beyond the waste streams e valuated during the EPA inspection, in the absence of a formal, controlled procedure for developing scaling factors would be premature. For this reason, EPA is approving the DTC process for only specific waste streams. If an RH site chooses to de velop procedure(s) to control the generation of scaling factors for additional waste streams and upon EPA review of the procedure(s), EPA may, if appropriate, be able to g ive a broader approval of a DTC process that can be applied to a waste category.

With respect to AK, EPA does not distinguish betwee n parts of the AK process because INL-CCP and ANL-CCP use AK for a continuum of chara cterization activities, from data collection through modeling and scaling factor deve lopment. The only measurement part of the characterization process, i.e., DTC, occurs w ell after the fundamental AK data assessment has been performed. Because the entire AK process is not formalized in a procedure or procedures for a summary waste category, and is instead applied to wastestream specific activities, AK is approved for the waste stream evaluated during the baseline inspection and discussed in Sections 8.1 a nd 8.2 of the final INL and ANL baseline inspection reports. Both EPA and CCP’s ex perience to date is limited for RH, i.e., essentially one waste stream at two sites, IN L and ANL. As additional waste streams are brought forward, the need for Tier 1 change des ignation can be reevaluated and a tier adjustment could be made through the process i dentified in 40 CFR 194.8.

Comment No. 6: Section III.A.(1) of the Federal Register Notice r eferences the June 1, 2006 version (Revision 2) of CCP-AK-INL-500. Though thi s revision of the report was reviewed during the June inspection, Revision 3 of this repo rt (dated July 7, 2006) addressing comments made during this inspection was presented and revie wed during the follow-up inspections in August as documented in Inspection Report A-98-49, II-A4-69.

Response: In Section 8.1 of this final baseline inspection re port EPA has made appropriate changes to reflect Revision 3 that addr esses EPA comments on the initial AK report made during the baseline inspection.

Comment No. 7: Section III.A.(1) of the Federal Register Notice, a nd the associated Inspection Report A-98-49, II-A4-69 identifies “... Waste Stream No. ID-ANLE-S5000, Lots 1 through 20, as defined in CCP-AK-INL-500, Revision 2, June 1, 2 006. ” CCP-AK-INL-500 does not define these lots. The Central Characterization Project ( CCP) acceptable knowledge (AK) process was applied to a population of 549 thirty-gallon RH deb ris drums, which is described in CCP-AKINL-500. Of these drums, approximately 70 had been subjected to visual examination (VE), which was recorded on audio/video media during pack aging. There is no further distinction made in this waste stream inventory. The designati on of “lots” has no relevance in the characterization and certification process and shou ld be deleted. As described in CCP reference C350 prepared for EPA during the inspections, CCP d etermined, and EPA agreed, that further segregation of the waste stream into lots based on the radiological characterization performed byC-5

ANLE was not appropriate. References to “lots” occ ur in numerous places in docket EPA-HQOAR-2006-0881 and the associated Inspection Report A-98-49, II-A4-69; these references

should be deleted.

Response: EPA recognizes that historic AK data is presented i n “lots” by INL (and therefore EPA examined this historic data by the gr oupings provided by CCP), but EPA does not expect CCP to characterize this waste stre am by these or any other predetermined lots.

INL-CCP AK supporting references identify INL’s Lot assignment of “lots” and several AK documents that are important to the characteriza tion process (e.g., EDF-6946 and EDF-6685) discuss the waste stream by INL “lots”. Therefore, portions of the EPA’s

reports use the same terminology and refer to “lots” becaus e the references examined present the information in this fashion. Appropria te changes to the text have been made when referring to the term “lots” in the context of historic AK data.

Comment No. 8: Section III.A.(3) of the Federal Register Notice s tates: “ The VE process used for a total of 8 retrievably-stored RH debris waste drums included in three batch data reportsBDR No.’s RHINLVE 6001-3. CCP has terminated the u se of VE process for this waste until further notice. If CCP decides to use VE in the fu ture, EPA inspection and approval is

necessary .” This citation is incorrect. CCP used the VE pr ocess to characterize a total of 70 drums of retrievably-stored RH debris waste where t he waste contents were recorded on audio/video media during waste packaging operations . The approval should apply to the process of conducting VE using audio/video media, not to a particular population of drums characterized using that process.

As stated in Section 4.0 on page 7 of both the INL EPA Inspection Report A-98-49, II-A4-69 and the ANL EPA Inspection Report A-98-49, II-A4-70 : “ During an inspection, EPA does not approve characterization data; that function is the sole responsibility of the site being evaluated during the inspection...EPA evaluated the WC processe s implemented by the site to characterize RH retrievably-stored debris waste. ” 40 CFR Part 194.8(b)(2) states, “ The Agency will verify the compliance of waste characterization programs and p rocesses. . . ” Nowhere does the Agency’s mandate require or allow for the approval by EPA, o n a drum-by-drum basis, waste to be shipped

to WIPP. Their mandate is to ensure that the waste characterization programs and processes are compliant. By approving eight drums (and only eigh t drums) for shipment to WIPP, the Agency is usurping the authority of the Department of Ener gy (the Certifying Authority for Waste Characterization Activities) to approve drums for s hipment to WIPP. The process of visual examination using audio/video media was extensively demonstrated during the inspection. EPA has not indicated any noncompliance with the proces s but has arbitrarily restricted its use to eight

drums.

The reference to the eight containers should be rem oved and it is recommended that the text read

as follows:

The VE process as defined in CCP-AK-INL-502, Centra l Characterization Project RH TRU Waste Certification Plan for 40 CFR Part 194 Co mpliance and Confirmation TestC-6

Plan for INL RH Waste Stream ID-ANLE-S5000 and imple mented by procedure CCPTP-500 CCP Remote-Handled Waste Visual Examination.

This same comment applies to item 3 on page 2, and any related text, of the associated inspection report (A-98-49, II-A4-69) for EPA Baseline Inspect ion No. EPA-INL-CCP-RH-6.06-8.

DOE CBFO agrees the language in the VE Tiering desi gnation in Table 2 of the Federal Register Notice correctly indicates what was inspected and sh ould be approved regarding the VE process. DOE CBFO requests that Table 1 in the FR and the co rresponding sections of the two inspection reports be made consistent with this language.

Response: EPA’s proposed approval was based on an evaluation of the VE process (i.e., visual examination of waste container contents reco rded on audio/visual media), interviews with VE personnel, and review of VE pers onnel training records. EPA identified one finding and one concern as a result of this review and concluded that the VE process implementation was not inadequate. CCP took steps to correct the EPAnoted inadequacies (e.g., additional training to VE staff and revisions to VE procedure(s) used by the VE personnel). EPA limited its proposed approval to only 9 drums because CCP had categorized the remaining 61 containers as not suitable for WIPP disposal using its own NCR (non compliance reporting) proces s. Following the inspection, CBFO informed EPA that (a) CCP does not plan to use this VE process beyond the 70 containers (included in 4BDRs that were part of the AK documentation), and (b) the 61 NCR drums would be reevaluated using real-time radi ography (RTR), or another nondestructive examination procedure, in the future.

Since the baseline inspection, however, DOE informed EPA that all 70 RH waste containers from INL were subjected to another VE re view using a better monitor. Upon the review of the video records for these drums, CC P revised the associated BDRs and after using a modified VE process (with a better mo nitor) CCP concluded that 60 of the 70 containers are eligible for disposal at WIPP. DO E submitted this new information to

EPA

.

As stated in the Comment No. 4, Commenter corrected EPA’s understanding of the number of containers suitable for the disposal at W IPP saying that 19 and not 9 RH waste containers were eligible for WIPP disposal at the time of the proposal.

In the proposed approval EPA designated the reuse o f the VE process (since then being retired) as a T1 change. EPA considers the use of a better monitor as a change in key VE equipment. Therefore, EPA must consider this new i nformation as a T1 change. Since CCP used a modified VE process and the additional

, (new) data generated from this action was provided during the public comment perio d on EPA’s proposed approval, EPA must consider this as a T1 change and complete a review accordingly. Therefore, as part of the T1 change review and approval proces s an EPA inspector will complete a review of the modified VE process. CBFO will be no tified of EPA’s decision, regarding the VE of additional drums in the waste stream. EP A’s T1 decision will also be posted on the EPA website at www.epa.gov/radiation/wipp

.C-7

Comment No. 9: Table 1 of the Federal Register Notice, INL-CCP RH WC process-T2 changes and the associated Inspection Report A-98-49, II-A4 -69 identifies “ ...AK accuracy report for Lot 16 (or the appropriate Lot) wherein individual drum data assessed by INL (e.g., P030) will be compared against DTC-derived values... ” As described in Comment 7 above, INL-CCP determined that the “lot” approach was not appropri ate for the reasons described in reference C350 and addressed on page 20 in Inspection Report A-98-49, II-A4-69:

“ These documents show that detailed analyses of AK d ata assembled for each drum can be performed to determine, in some detail, the esti mated radiological content of each lot, recognizing that the process to develop an accurate and complete picture requires analysis well beyond that performed by the generato r site, ANL-E (see item (1) above, and reference C350). This activity is also an alte rnative approach to characterizing

waste based on the AK record that does not use DTC in the manner currently proposed by INL-CCP but instead uses various calculations an d modeling efforts to determine values for the individual waste drums. INL-CCP has indicated, and EPA agrees, that this approach is time consuming (e.g., two years for 10 drums alone), and various assumptions and questions may still remain that cou ld bring considerable uncertainty to this approach (see reference C350). This alternati ve approach has not been used at INLCCP; therefore, EPA did not evaluate it in depth. ”

In Inspection Report A-98-49, II-A4-69, EPA request s that INL-CCP compare AK and DTC results for ten containers (lot 16) for the purpose of determining AK accuracy as a T2 change; however, since INL-CCP has chosen to radiologically characterize the waste stream as a whole, the level of accuracy can not be determined by comp aring the DTC results to those previously

calculated for a small subset of containers within the stream. If any of the containers are determined to be non-transuranic (TRU) waste using the dose-to-curie (DTC) methodology, they will be reported as an AK inaccuracy. There is nei ther a plan nor a requirement currently in place to prepare a separate AK Accuracy Report for the ten drums cited. This requirement for a T2 change notification should be deleted from the a pplicable tables and the text of Docket EPA-HQ-OAR-2006-0881 and Inspection Report A-98-49, II-A4-69.

Response: EPA’s intent behind the comparison requirement wa s to better understand the relationship between the results of the proposed ch aracterization approach and data for a small number of waste containers reviewed during the baseline inspection. The comment objects to the comparison of a small set of AK data to results that were obtained through DTC because INL-CCP proposes to characterize the stream “as a whole”, and the small subset may not match the stream as charac terized to that point. EPA

understands this concern and also understands that there may be variability in the characterization data at any point in time. EPA ha s changed the T2 change to require the site to notify EPA when this data set is availa ble. Under its authority of §194.24(h), EPA may request these data from INL-CCP in order to perform comparison as a verification of how the data sets compare. EPA bel ieves that a comparison may provide additional insight regarding AK accuracy and help t o better understand the variability of the characterization data, not to find a means to c riticize INL-CCP’s characterization approach for this waste stream that this report app roves. EPA has made the appropriate clarifications to the INL and ANL final baseline in spection reports to reflect this explanation.C-8

Note that the DTC process evaluated by EPA during th e baseline inspection had been proposed for approval and is being approved now and the comparison discussed here does not affect this approval.

Comment No. 10: Table 1 of the Federal Register Notice, INL-CCP RH WC process-T2 changes and Table 1 on page 3 of the associated Ins pection Report A-98-49, II-A4-69 identifies

“... Completed Correlation or Surrogate Summary Form of RH containers identified in this waste stream identified as CH based upon measured dose rat es that present NDA results for assayed containers, including isotopic ratios... ” As described in the AK procedure of the WCPIP, a Correlation and Surrogate Form is prepared to docum ent when contact-handled (CH) data are used to meet a required DQO for an RH waste stream. This form would not be completed unless the resulting CH assay data is specifically used to meet one of the RH DQOs. The comparison of isotopic ratios derived from modeling and mass s pectrometry for the waste stream as a whole to any isotopic ratios measured via NDA for one or more individual containers is likely to be

inconclusive. This is because variations in the is otopic ratios between containers is expected and may be difficult to quantify. This requirement for a T2 change notification should be deleted from cited tables and the text of the Inspection Re port A-98-49, II-A4-69.

Response: The Correlation or Summary (CSS) Form, if prepared, can easily address any discrepancies between an RH waste stream and its CH c ounterpart. The CSS could also add valuable information because it would provide a ctual assay measurement data. Accordingly, EPA requires that the site provide not ification, as a T2 change notice, when the CSS Form is available for a RH waste stream.

As stated in the previous responses to Comment Nos. 2 and 9 above, T1 and T2 reports are intended to report changes to approved waste ch aracterization programs. As described in the final modification to 40 CFR 194.8 (b) (69 FR 42581, July 14, 2004), EPA uses its authority under 194.24(h), when necess ary, to evaluate new or additional information to ensure continued compliance with reg ulatory requirements. Under §194.24(h) authority, EPA may ask for the CSS Form for an RH waste stream in question and may also require a listing of all RH containers that are ultimately identified as CH and the measurement (i.e., NDA) data for those cont ainers not presented on a CSS. EPA has made the appropriate clarifications to the INL and ANL final baseline inspection reports in accordance with this response.

EPA understands that the comparison of isotopic rat ios derived from modeling and mass spectrometry for the waste stream as a whole to any isotopic ratios measured via NDA for one or more individual containers may be inconc lusive. EPA also understands the potential for variations in the isotopic ratios bet ween containers. We do not necessarily consider that such variations would be problematic.

Comment No. 11: On page 16 of the inspection report, in the parag raph under Table 4, it states

that NDA will not be used “because of workers’ healt h concerns.” This entire sentence should be deleted. The DTC technique is an approved techn ique that is being implemented at this site and there is no reason for addressing why another t echnique is not being used.C-9

Response: We concur, the final report the text has been rev ised to remove reference to

the worker’s health concerns.

Comment No. 12: Clarify that implementation of VE following this baseline approval is a T1 change (Table 1 of the Federal Register Notice). Th is should apply to VE, not to VE using

audio/video media:

a. Under VE T1 changes, the use of the VE process and data, in a manner consistent with that applied to the subject waste stream, should no t require an EPA T1 approval as noted

above.

Response: When characterizing RH waste, INL CCP performed a visual examination of audio/video media depicting contents of RH waste con tainers. EPA has renamed the waste characterization process as “VE of audio/vide o media” in the Tiering tables in the Executive Summary and Conclusion sections of the re port.

Following the June 2006 baseline inspection, DOE pro vided additional information regarding drums that had been cited in INL-CCP non- conformance reports. Because this information identified a modified procedure for VE of this waste stream, EPA is evaluating this additional VE information as a T1 c hange. (For additional discussion, see Response to Comment No. 8, above.) Upon comple tion of the T1 evaluation, EPA may issue an approval of the modified VE process an d data applying to the waste stream

as a whole and not restricted to the 8 containers as proposed. As noted in the Response to Comment No. 4, above, the EPA proposed approval incorrectly states the number of containers as 9. The correct number of approved co ntainers for the proposed approval should have been 19. EPA has been informed by CCP that it will no longer use the VE of audio/visual media process for characterizing RH containers at INL. If CCP again uses this process for visually examining audio/vide o media records for RH waste containers at INL, its implementation will be subje ct to theT1 change procedures requiring EPA notification and approval prior to im plementation.

Comment No. 13: Table 2 of the Federal Register Notice, ANL-CCP RH WC process-T2 changes and Table 1 on page 3 of the associated Ins pection Report A-98-49, II-A4-70 identifies

“... Comparison of AK versus DTC-derived radiological da ta to support the use of waste streamspecific instead of drum-specific radiological data and the completed DTC results for all

containers in this waste stream ...” As discussed on page 20 in Inspection Report A- 98-49, IIA4-70, the following language was added to the AK R eport:

The stated purpose of the method employed by Argonn e to estimate the radiological composition in individual waste containers was to a ddress site accountability requirements and to comply with the maximum allowab le fissile content of RH TRU drums. While the Argonne reported radiological con tent of containers in this waste stream was used to support the CCP waste stream del ineation, RH, and TRU determinations, the Argonne methodology did not pro duce results adequate for the purposes of WIPP certification. For this reason, i t is not appropriate to compare the Argonne estimates to the results of the CCP radiolo gical characterization activities in AK accuracy evaluations.C-10

For this reason, the level of accuracy can not be d etermined by comparing the DTC results to those previously estimated by ANLE and this stipula tion should be deleted from the cited Tables and the text of the Inspection Report A-98-49, II-A 4-70.

Response: EPA concurs with the comment. The report including the Tables is modified accordingly.

Comment No. 14: Table 1 of the Federal Register Notice, INL-CCP RH WC process-T1 and Table 2 of the Federal Register Notice, ANL-CCP RH W C process-T1 changes are identified for the addition of containers to the existing waste st reams. Addition of containers to the existing waste streams should not be considered a change unl ess the addition of the containers changes the characteristics of the waste stream, which woul d require a change to the certification plan (CCP-AK-INL-502 for INL and CCP-AK-ANL-502 for ANL) . As stated in Section 4.0 on page 7 of both the INL EPA Inspection Report A-98-49, II -A4-69 and the ANL EPA Inspection Report A-98-49, II-A4-70: “ During an inspection, EPA does not approve character ization data; that function is the sole responsibility of the sit e being evaluated during the inspection...EPA evaluated the WC processes implemented by the site to characterize RH retrievably-stored debris

waste .” Therefore, EPA is only approving the waste char acterization processes implemented, such as the process used to assign waste containers to a waste stream, and not the assignment of individual, specific containers to a waste stream. As defined in the inspection reports (page 2, 6 th

paragraph) “

Any changes to the WC activities from the date of t he baseline inspection must be reported to and if applicable, approved by EPA. ” EPA tier changes therefore, should only address changes to WC and not routine modifications performed in accordance with the WC.

This same comment applies to the corresponding tabl es, and any related text, in the associated inspection reports (A-98-49, II-A4-69 and A-98-49, II-A4-70) for EPA Baseline Inspection No.’s

EPA-INL-CCP-RH-6.06-8 and EPA-ANL-CCP-RH-9.06-8.

Response: EPA inspected and approved the full AK process (i ncluding scaling factor development, etc.) through interviews and evaluatio ns that were applicable to a small sample size. It is quite possible that “new” contai ners would require a different approach to scaling factor development following a process t hat EPA has not inspected or examined. Therefore, addition of containers to the waste stream requires EPA notification to ensure that CCP has implemented a p rocess that is well documented. If CCP seeks a broader approval in the future whereby containers could be added without review, CCP could present to EPA for approval a doc umented process for AK data analysis beyond that in the WCPIP. This will need to include all other AK data manipulation (e.g., scaling factor development) up to application of the DTC measurement. Until that time, EPA believes it is p rudent to limit the approval to the waste stream evaluated during the baseline inspecti on, noting that our T1 review of waste stream expansion could be accomplished in a timely manner.

Comment No. 15: Under AK T2 changes, the term “waste stream data package” does not appear in the Remote-Handled Transuranic Waste Char acterization Program Implementation Plan (WCPIP). CBFO assumes that EPA is referring t o the primary AK documents referencedC-11

including the waste stream profile form (WSPF), the characterization reconciliation report (CRR), and the AK Summary Report.

Response: EPA agrees that the term “waste stream data package ” is broad, and CBFO’s assumption is correct. EPA is referring to the AK documents including the WSPF and CRR. If a Characterization Information S ummary is prepared and includes information pertinent to EPA compliance, EPA must b e notified of its availability using the T2 change notice process. EPA may request that this information be provided, consistent with 194.24(h). EPA has made the approp riate clarifications to the INL and ANL final baseline inspection reports.

Comment No. 16: Delete the wording: “or the use of the high rang e probe as described in CCP-TP-504”, from footnote *** to Table 1 and Table 2 of the Federal Register and the corresponding tables in the inspection reports. Us e of the high range probe is authorized in CCP-TP-504. Its operation is no different from the low- and mid-range probes that were demonstrated at the two inspections.

Response: EPA agrees that the use of all three probes is au thorized under CCP-TP-504, as discussed below. The operations observed at INL and ANL did not involve the use of the high range probe and EPA would be interested in such an application, not because of the probe itself, but because its use would require a significantly different DTC operation from what was observed during the inspections.

As stated in the INL-CCP Report:

• There are three ion chamber probes available for us e with the RO-7 Ion Chamber: RO-7LD with a full-scale range of 1,999 mR/hr and a resolution of 1 mR/hr (Low Range); RO-7BM, with a full-scale range of 199,900 mR/hr and a resolution of 100 mR/hr (Medium Range); and, RO-7BH with a full-s cale range of 199,900,000 mR/hr and a resolution of 10,000 mR/hr (High Range). The calibrations are essentially probe-specific, allowing the probes to be interchanged between ion

chamber bodies.

• The Low Range Probe No. 802038 and the Medium Range Probe No. 801254 were in calibration at the time of the inspection. The High Range probe was not observed in use, INL-CCP personnel stated that it had been neit her calibrated nor source checked. INL-CCP personnel stated that there was n o intention of using this probe in the foreseeable future.

CCP-TP-504 states that, prior to use, the high rang e probe requires a source check with a source of greater than or equal to 500,000 mR and less than or equal to 12,000,000 mR, i.e., a source with an external gamma exposure rate of between 500 and 12,000 R/hr (Roentgens per hour). The logistical aspects of su ch an operation would be considerably different from the operation observed during the in spections, and EPA wants to know about this in advance and have the opportunity to e valuate it prior to or during its application.