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 2007
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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 ......................................................................................................................... 65 
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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 Responses
1

1.0 EXECUTIVE SUMMARY 

In accordance with 40 CFR 194.8(b), the U.S. Environmental Protection Agency (EPA or the 

Agency) conducted Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8 of the Central 

Characterization Project’s (CCP) waste characterization (WC) program for remote-handled (RH) 

transuranic (TRU) waste at the U.S. Department of Energy’s (DOE) Argonne National 

Laboratory (ANL), also known as Argonne National Laboratory East (ANLE), located in 

Argonne, Illinois. EPA conducted a baseline inspection 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 solicit public comment on the proposed 

approval of ANL-CCP’s RH WC program and the ANL Baseline 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-HQ-OAR-2006-0881). EPA evaluated 

and responded to the public comments (see Attachment 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 before waste may be disposed of at the WIPP, 

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

regulations for TRU radioactive waste (63 Federal Register (FR) 27354 and 27405, May 18, 

1998). This was the first inspection of RH WC activities conducted by EPA at ANL-CCP. EPA 

Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8 was performed in accordance with the 

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

42571–42583). The purpose of the ANL-CCP RH WC inspection 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 inspection included the following: 

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

• Visual examination (VE) for RH retrievably-stored TRU 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 debris in one waste stream, Argonne 

National Laboratory Waste Stream AERHDM, as defined in CCP-AK-ANLE-500, 

Revision 1, July 18, 2006 
2

(2) The radiological characterization process using 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 described in CCP-AK-ANL-501, Revision 0 

(3) The VE process for one retrievably-stored RH S5000 debris waste stream AERHDM 

using the trained personnel, documentation, and procedures discussed in this report 

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

waste contents of RH debris wastes at this time. Although the WWIS is currently approved by 

EPA for tracking contact-handled (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 the Carlsbad Area Field Office (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 inspection. ANL-CCP cannot 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 the baseline inspection must be reported to 

and, if applicable, approved by EPA, according to Table 1. Please note that each T1 and Tier 2 

(T2) change listed in Table 1 is followed by a reference 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 evaluations of T1 and T2 changes established as 

part of today’s approval through the EPA Web site and by sending e-mails to the WIPPNEWS 

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

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

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

described above. 

In October 2006, EPA concurred with CBFO’s request for allowing INL-CCP to submit T2 

changes implemented at the EPA-approved TRU sites four 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 discussed in this report on the same schedule. 
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Table 1. Tiering of RH TRU WC Processes Implemented by ANL-CCP 

(Based on September 12–14, 2006 Baseline Inspection)

RH WC Process Elements ANL-CCP RH WC Process - T1 Changes ANL-CCP RH W

Acceptable Knowledge (AK) Any new waste streams not approved under this baseline; AK (1) 

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 present are not included in this waste stream approval; AK (1) 

Substantive modification(s)*** that have the potential to affect the 

characterization process to CCP-AK-ANLE-500, CCP-AK-ANLE-501 or CCP-AK-ANLE-502; AK (8) Implementation of load management for any RH waste stream; AK (16) 

Notification to EPA that 

complete for RH containstream; AK (3) 

Notification to EPA whe

documentation as a resu

Notification that updates 

following documents: 

• All future revision

CCP-ANLE-AK-5

• Listing of the refer

assembly of fuel pAK (5) 

• All future revision

AK (8) 

• CCP-AK-ANLE-5

address freeze file 

Notification to EPA that 

waste stream is completeto the WSPF including tAK (9), and AK (14) 

Notification to EPA whe

completed, prepared ann

Radiological Characterization, including Dose-To-Curie (DTC) 

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 modification thereof***; RC (8.2.2 and 8.2.3) Any new waste stream not approved under this baseline or addition of 

containers to waste stream AERHDM that require changing the established radionuclide scaling factors; RC (8.2.3) Application of new scaling factors for isotopic determination other than those documented in CCP-AK-ANLE-501; RC (8.2.2 and 8.2.3) 

Notification to EPA that 

501 or CCP-TP-504 that complete; RC (8.2.2 and 
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Table 1. Tiering of RH TRU WC Processes Implemented by ANL-CCP 

(Based on September 12–14, 2006 Baseline Inspection)

RH WC Process Elements ANL-CCP RH WC Process - T1 Changes ANL-CCP RH W

Visual Examination (VE) VE by reviewing existing audio/visual recordings for Summary waste 

category 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 

that require CBFO approVE (3) Addition of new S5000 

Real Time Radiography (RTR) Any use of RTR requires EPA approval WIPP Waste Information System (WWIS) 

Any use of WWIS requires EPA approval prior to RH waste disposal 

* 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 

requested by EPA. 

*** Substantive modification refers to a change with the potential to affect ANL’s RH WC process, e.g., the use of an inherently different typ

use of the high range probe as described for CCP-TP-504 for radiological characterization. 
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2.0 PURPOSE OF INSPECTIONS 

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

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

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

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

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

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

(1) provide EPA with information on AK1

 for waste streams proposed for disposal at the WIPP, 

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

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

Compliance Certification Application (CCA). 

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

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

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

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

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

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

inspection to verify that the site’s system of controls is technically adequate and properly 

implemented. Specifically, EPA’s inspection team verifies compliance with 

40 CFR 194.24(c)(4), which states the following: 

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

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

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

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

limiting value described in the introductory text of paragraph of this section.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 inspection is to assess whether DOE sites that 

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

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

limits. By 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 replaced the term process knowledge with acceptable 

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

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

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

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

2

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

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

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

value, of the total inventory of such waste proposed for disposal in the disposal system.” 
6

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

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

belonging to the group of approved waste streams. 

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

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

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

194.24, EPA has the authority to conduct continued compliance inspections (both announced and 

unannounced) to verify that the site continues to use 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 of the WC processes demonstrated during the 

baseline inspection, including all conditions and limitations, EPA will specify which subsequent 

WC program changes or modifications must undergo further EPA inspection or approval under 

40 CFR 194.24. This will be accomplished by assigning a tier level to each aspect of the 

characterization program, i.e., T1 and T2 activities. T1 activities have more stringent reporting 

requirements and require that DOE notify EPA of proposed T1 changes prior to implementation, 

and that EPA provide approval prior to implementation. T2 activities are reported to EPA by 

DOE based on the frequency established in the inspection report. DOE may choose to 

characterize and dispose of at risk while EPA considers the proposed T2 changes. 

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

the site in consultation with CBFO discuss the nature of the change with EPA. This would 

minimize a possibility of EPA not approving the site-assigned tiers. The rule under which this 

baseline inspection was conducted can be found in the FR (Vol. 69, No. 136, 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 findings or concerns. Specifically, this 

report does the following: 

• Describes the characterization systems for approval

• Provides objective evidence of the approval basis for all WC systems 

• Identifies all relevant limitations and/or conditions 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 waste streams determine which processes can adequately 

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

matrix-appropriate radiological characterization technique to obtain adequate radionuclide measurements. VE 

serves to confirm and quantify non-radiological waste components, such as cellulosics, rubbers, plastics, and metals. 

Once the nature of the waste has been confirmed, characterization techniques will be applied to quantify selected 

radionuclides in the waste. In some cases, a TRU waste generator site may be able to characterize a range 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.
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• Describes any tests or demonstrations completed during 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 team members reviewed in support of the 

technical determination. To see or obtain copies of any items identified in the attached 

checklists, write to the following address: 

Quality Assurance Manager 

USDOE/Carlsbad Field Office 

P.O. Box 3090 

Carlsbad, NM 88221 

EPA’s final approval of the ANL-CCP RH WC program is 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 with 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 characterize RH TRU wastes. These 

systems were evaluated with respect to their ability to perform the following: 

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

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

radiological characterization, including DTC and radionuclide scaling factors derived 

from modeling 

• Assign waste material parameters (WMPs) correctly and confirm the presence or absence 

of prohibited items using VE for RH retrievably-stored debris waste 

Specifically, these systems consisted of the following components: 

• The AK process that supports retrievably-stored S5000 debris wastes from one RH debris 

waste stream, Argonne National Laboratory Waste Stream No. AERHDM 

• The system of radiological characterization including DTC and the application of 

radionuclide scaling factors derived by modeling for 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 characterization data; that function is the sole 

responsibility of the WC organization being evaluated during the inspection, in this case 

ANL-CCP. EPA evaluated the WC processes implemented by the site to characterize 

RH retrievably-stored debris. The evaluation consisted of interviewing personnel, observing 

equipment operations that are controlled through site procedures, and inspecting records related 

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

evaluation is the objective evidence that documents the effectiveness of the WC processes. 
8

Objective evidence typically takes the form of batch 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 of 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 characterization available for the EPA 

inspection team’s evaluation. Due to the limited number 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 determined the technical adequacy of the WC 

processes within the inspection’s scope. 

5.0 INSPECTION-RELATED DEFINITIONS 

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

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

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

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

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

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

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

response. 

Note: Concerns not requiring a response do not have to be addressed prior to program approval. 

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

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

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

6.0 PERSONNEL 

6.1 EPA Inspection Team 

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

Table 2. EPA Inspection Team Members

Inspection Team Member Position Affiliation

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

Ms. Rajani Joglekar Inspector U.S. EPA ORIA 

Ms. Lisa Sharp Observer U.S. EPA ORIA 

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

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

Mr. Patrick Kelly Inspector S. Cohen & Associates, Inc. 
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6.2 Personnel Contacted 

The EPA inspection team conducted interviews with ANL-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 technical 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. The 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 personnel responsible for characterizing RH 

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

perform their assigned function. If key WC personnel changes occur, EPA may request 

qualification and training records of the new individuals identified as key WC personnel. EPA 

will review these records and may interview the personnel to determine their abilities to produce 

quality data. This personnel qualification evaluation and review of training records would be the 

equivalent of the evaluation done by the EPA inspection 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 encompasses 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 Materials and Fuel Complex. At that time, it 

was no longer necessary to distinguish between ANL-W and ANL-E, and the name of ANL-E 
10

was changed to simply ANL. This report contains references to ANL and ANL-E; however, the 

distinction is not significant and is used to maintain consistency with references to specific 

documents, processes, or other records. 

Inspection Process Overview

EPA Inspection No. EPA-ANL-CCP-RH-9.06-8 occurred on-site at ANL on September 12-14, 

2006. The inspection was conducted in the following steps: 

 

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

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

(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 technical support contractors to brief the 

EPA inspection team members regarding technical details related to the ANL-CCP RH 

WC program 

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

(5) One visit onsite at ANL to review personnel qualifications and training, and verify the 

technical adequacy or qualifications of RH WC personnel, 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 generated (see Attachment B) 

(7) Communicating all pertinent information with CBFO and 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 personnel 

(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 information to determine whether ANL-CCP 

demonstrated compliance with 40 CFR 194.8 requirements for RH waste stream: Argonne 

National Laboratory Waste Stream No. AERHDM. 
11

Waste Characterization Element Description

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

waste characterization at ANL: 

• Waste stream identification and the definition of waste stream, including radiological 

content of the waste 

• Identification of HLW, TRU vs. LLW, spent nuclear fuel 

• Role of AK in the characterization methodology (including 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 qualification 

• Confirmatory Test Plan preparation and plan adequacy 

• Characterization Reconciliation Report preparation and plan adequacy 

• Correlation and Surrogate Summary form and CH-RH correlation 

• 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 quality objectives (DQOs) 

• DQOs attained through AK Qualification 

Documents, Waste Containers, and Batch Data Reports Provided

Many of the documents listed below are considered by 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 inspection 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 Characterization Program 

Implementation Plan, Revision 0D, October 30, 2003 

• DOE/WIPP-02-3122, Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot 

Plan, Revision 5, effective date TBD 

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

• CCP-AK-ANLE-500, Central Characterization Project Acceptable Knowledge Summary 

Report for Argonne Remote-Handled Debris Waste, Revision 1, July 18, 2006 

• CCP-AK-ANLE-501, Central Characterization Project Remote-Handled Transuranic 

Radiological Characterization Technical Report for Remote-handled Transuranic Debris 

Waste from Argonne National Laboratory-East, Revision 0, July 21, 2006 
12

• CCP-AK-INL-502 Central Characterization Project, RH TRU Waste Certification Plan for 

40 CFR Part 194 Compliance and Confirmation Test Plan for ANL RH Waste Stream: 

AERHDM, Revision 0, July 21, 2006 

• CCP-TP-506, CCP Preparation of the Remote-Handled Transuranic Waste Acceptable 

Knowledge Characterization Reconciliation Report, Revision 2, June 8, 2006 

• Inter-Office Correspondence, from A.J. Fisher to I. Quintana, Acceptable Knowledge 

Accuracy Report: Argonne National Laboratory- East Waste 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 Revision 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 Laboratory, print out dated September 13, 

2006 

• Characterization Reconciliation Report for Waste Stream 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, 2006 

• 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 for RH Drums 810, 815, 817, 820, 

824, and 826 BDR RHANLVE060001, various dates, 2006

• Container Dose to Curie Conversion Records for Drums 810, 815, 817, 820, 824, and 826, 

provided during inspection September 2006 (dated analysis 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 Revision 17 Attachment 4) undated 

• Solid Radioactive Waste Disposal Requisition Date sheets, various containers provided 

September 2006 

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

• C003, Intra-laboratory Memo to Harvey Welsh re: Dimensions of Intermediate TRU Waste 

Containers, prepared by Dennis Donahue, dated September 14, 1989 

• C006, Interview with Larry Neimark, re: AGHCF samples, applicable programs, defense 

relationship to materials and commingling of the waste; Cheryl Schultz Record of 

communication ROC-C6, July 17, 2001 
13

• 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 Holes, 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, 1990 

• C060, Intra-laboratory memo to R. Boule from A.C. Smith, 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 Whitworth and M. Wyco, dated 

August 7, 2001 

• C084, Intra-laboratory Memo to Building 212 Personnel re: Disposal of Solid Radioactive 

Waste, F.P. Marchetti, dated February 4, 1986 

• C121, Record of Communication with L. Neimark, A. Cohen, 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 Shipped to INEEL, dated December 19, 

2001 

• C149, Correspondence to Mr. Daniel Hecker, Waste Management Office, Argonne National 

Laboratory-East re: Transmittal of Final Argonne National Laboratory-East Transuranic 

Waste Acceptable Knowledge Report; Tom Krause, Project Manager, Benchmark 

Environmental Corporation, a ThermoRetec Company, September 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. Marcinowski, Determination and Findings, 

Defense Origin of Nuclear Waste, Kerr-McGee Waste, dated April 15, 2005 

• C331, Memorandum to CCP Central Records from K. Peters, re: Evaluation of Kerr-McGee 

Production and FFTF History, dated June 26, 2004 

• C332, Memorandum to CCP Central Records from D.B. Becker, 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. Becker, re: Assessment of Waste 

Material Parameters for Waste Stream AERHDM, dated January 2006 

• C345, Shaw Discrepancy Report R8 for RH TRU Waste form ANL-E, AGHCF, re: WMC 

determination, Cheryl Schultz, July 15, 2003 

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

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

DR10 June 7, 2006 

• DR011, Waste Requisition and Videotape Discrepancies, Lisa Price, undated (signed 

August 16, 2006) 

• DR013, Discrepancy Resolution Form Regarding the Argonne Waste Population of 44 drums 

versus 45 drums, S. Schafer, August 28, 2006 
14

• P001, AGHCF Operations Manual, Argonne National Laboratory, IPS-2-00-00, 2, dated 

September 10, 1990 

• P002, Central Characterization Project Acceptable Knowledge Report for Argonne National 

Laboratory-East Contact Handled TRU Waste Facility Maintenance and Laboratory 

Operations; CCP-AK-ANLE-001, Revision 11, dated December 31, 2003 

• P006, Safety Analysis for Twenty Year Retrievable Storage of Intermediate Gamma Level 

Transuranic Waste, W.D. Jackson Alpha-Gamma Hot Cell Facility, Argonne National 

Laboratory, dated June 1, 1976 

• P009, TRU-RH Waste Certification Plan for Waste Management 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 Development for the RERTR Program, R.F 

Domagia, C. Wiencek, H.R. Thresh and D. Stahl; Argonne National laboratory, Materials 

Science Division, November 1, 1990 

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

1996 

• P023, Argonne National Laboratory-East Remote Handled Waste, by W. Mahlon Hellaeson, 

EDF-RWMC-759, August 29, 1994 

• P032, Procedure for Sorting Remote-Handled TRU Waste (30-Gallon Intermediate-Level 

Waste), Alpha-Gamma-Hot Cell Facility Irradiation Performance Section Materials and 

Components Technology Division, dated January 7, 1987 

• 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, ANLE 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 Facility, A Nuclear Science and 

Irradiation Services User Facility, PNNL-12245, Revision 1, August 1999 

• P599, the Defense Programs Origin of Transuranic Waste 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 Vacuum 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 2001 
15

• 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 Versus Non Defense TRU Waste, no 

author cited, April 7, 2000 

• U013, Waste Stream Fissile Content [AGHCF], March 23, 1990 

• U015, RH-TRU 1995, Book 5 Drums 798 to 809, no author 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 Quota Title and Number Project, no 

author cited, July 31, 2002 

• U041, Videotape Logs data [Cans 100, 102-187, 217-231, and 234-246], Cheryl L. Schulz 

(no title given), September 15, 2001 

• U072, MSDS sheets, various components, no author cited, undated 

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

• U305, Isotopic Data Report from H.B. Robinson Report; 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 bottom 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 generated prior to an approved QA program, 

i.e., retrievably-stored waste, as well as wastes that 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. The 
16

retrievably-stored confirmatory testing and newly-generated AK qualification both assign TRU 

and activity-related DQOs using DTC and AK-based scaling factors derived through 

ORIGEN2.2 modeling (previously examined as part of the RH baseline inspection at the Idaho 

National Laboratory and found adequate by EPA). Input parameters to this modeling were not 

individual drum AK data; rather, the individual fuel pins that contributed radionuclides to 

various waste drum lots were individually used as input to the ORIGEN2.2 code. 

The evaluation presented in this section assesses the 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, and determination of scaling factors. 

Evaluation of individual model input parameters with respect to the related source documents 

was undertaken during activities presented in Section 8.3 that also address DTC for radiological 

waste characterization . 

EPA’s evaluation focused on the processes and related objective evidence. Therefore, EPA’s 

summation, presented below, includes observations regarding 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 the data as those who compiled the AK data 

examined during this inspection; therefore, the recommended changes described below are made 

with that future examination in mind. 

Technical Evaluation

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

defined. 

The RH Waste Characterization Program Implementation 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 stream AERHDM is a debris waste stream that 

was generated in the ANL-E hot cell and includes wastes 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 during the same time period remains in the 

hot cell, and will be packaged in the future as newly-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; information 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 consists of about 64% inorganics (ferrous/non 

ferrous metals) and 36% organics (cellulosics, plastics 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-generated waste, specifically for the purpose of 

determining whether the newly-generated component of the waste stream would be physically 

similar to the retrievably-stored component. ANL-CCP representatives indicated that the 
17

AGHCF4 currently contained cellulosics, plastics, and rubbers (CPR), as well as large pieces of 

equipment and other metals/inorganics that would require size reduction prior to packaging. 

ANL-CCP provided photographs of the AGHCF and another 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 consist predominantly of inorganic materials 

consistent with the retrievably-stored drums, but the 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 waste 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 than waste stream basis. As a result, the AK 

record (Reference C349) includes drum-specific radiological data assigned by ANLE, using a 

method similar to that employed by ANL-CCP. Reference 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 concentration is listed as greater than 1,900 

nCi/g per container. This value is heavily weighted 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 241Am, 238Pu, 240Pu, 241Pu, and 242Pu 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 for 

241Am, 238Pu, 240Pu, 241Pu, and 242Pu, 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 container from the waste stream that was 

examined had an AK-assigned gram value for 239Pu and 235U, with the values assigned via use of 

scaling factors (see item 3) to the following radionuclides: 113mCd, 144Ce, 152Eu, 154Eu, 155Eu, 

241Fe, 54Mn, 147Pm, 106Ru, 125Sb 151Sm, 123Sn, 126Sn, 90Sr, 99Tc, 127Te, and 93Zr. ANL-CCP 

Reference C359 reported the weight percent of 239Pu and 235U for each container, as well as other 

nuclides for which a calculated weight was provided. Data presented suggested that the per 

drum weight percent 239Pu varied from 24%-72%, with an average of approximately 48%. For 

235U, the content varied from approximately 11% to 60%, with an average of approximately 

50%. The remaining approximately 2% not accounted for by 235U and 239Pu is represented by 

the gamma emitters listed above, as well as by 241Am, 242Am, 243Am, and other radionuclides 

reported for four of the 45 containers. This analysis shows that the per-drum 235U and 239Pu 

values are expected to vary, but should average approximately 50-50 on a weight percent basis. 

It should be noted that AK suggests that Drums 76642-78117 (AK-assigned drum numbers) 

appear to have approximately 40% Pu and 60% 235U, while Drums 81790-81799 contain 

approximately 60% 239Pu and 40% 235U, 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 Cell 
19

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

EPA recognizes that the accuracy of these values has been questioned by ANL-CCP, and EPA 

believes this analysis generally indicates a comparable 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 or appropriateness of the per-drum radiological 

values. The above analysis applies only to the retrievably-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 accurately defined from a radiological perspective 

on a waste stream basis. The addition of any new waste streams not approved under this baseline 

is a T1 change. (See Table 1, where this is included as a T1 change.) Additionally, the 

modification of this waste stream to include additional containers beyond the 45 containers 

included in CCP-AK-ANLE-500, Revision 3 is a T1 change. (See Table 1, where this is 

included as a T1 change.) 

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

CCP-AK-INL-500 indicates that while samples of spent nuclear fuel were assessed to determine 

composition (References P344, P349 and P602), the actual spent nuclear fuel is separate from the 

RH debris waste generated through testing of this fuel, and is therefore not included in this waste 

stream. ANL-CCP representatives interviewed indicated 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, including ANLE AK-based characterization 

methodology presented in CCP-AK-ANLE-500 for the retrievably-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 retrievably-stored containers was identified by 

ANL-CCP, including both physical and radiological characterization 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 under item (1), above. Technical analysis with 

respect to how this AK data may be used is discussed herein. 

CCP-AK-ANLE-500 presents a characterization activity 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 generation dates. For each campaign, the 

AGHCF activities performed in the cell during the campaign period were determined from 

ANLE’s Fissile Inventory Management System (FIMS), and the 235U and 239Pu contents of the 

materials tested in the hot cells during the time period were ascertained. ANLE assumed that 

when fuel segments were mounted, 50% was lost as swarf (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 size 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 and 235U 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 representatives 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 representatives also indicated that derivation of 

the scaling factors was complex and difficult to follow 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 incomplete, and did not include all of the materials 

managed in the hot cell during the specific campaign interval. Because the scaling factors were 

assigned based on the maximum allowable amount of fission products within the cell based on 

the facility’s authorization basis, the AK data, while useful, was not accurate on a drum-specific 

basis. This determination was not documented in the 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 Argonne to estimate the radiological 

composition in individual waste containers was to address site accountability 

requirements and to comply with the maximum allowable fissile content of RH TRU 

drums. While the Argonne reported radiological content of containers in this waste 

stream was used to support the CCP waste stream delineation, RH, and TRU 

determinations, the Argonne methodology did not produce results adequate for the 

purposes of WIPP certification. For this reason, it is not appropriate to compare the 

Argonne estimates to the results of the CCP radiological 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 results of the CCP radiological 
21

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

P414).

EPA compared the AK-derived values for 239Pu, 235U, 90Sr, and 137Cs 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 for 

239Pu and 235U were generally 

approximately one order of magnitude lower than those determined by DTC, while the 

AK-assigned values for 137Cs and 90Sr values were as much as two orders of magnitude lower. 

Differences in these values are expected because the ANLE values did not take into account all 

of the activities identified in the FIMS for the specified 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 “conservative,” i.e., would result in higher than 

actual values, because the scaling is based on maximum allowed fission products in the cell, not 

measured values. If this is the case, the disparity 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 waste 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 characterization of the approximately 45 drums in 

the stream would provide information directly relevant to the use of waste stream scaling factors 

in the future. In the proposed decision EPA specified that ANL-CCP perform a comparison of 

radionuclide values based on AK with radionuclide values 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 information 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 Comment 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 continued compliance with EPA regulations. 

Providing notification of the completion of the final DTC determination for each of these 

containers is a T2 change. (See Table 1, where this is included as a T2 change). 

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

in Attachment A of the WCPIP. 

Attachment A of the WCPIP specifies that the following be included in AK Summaries: 

Executive Summary, Waste Stream Identification Summary, AK Data and Information 

description, Program Information, Waste Stream Information, Qualification of AK Information, 

and Container-Specific Information. Furthermore, Attachment 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 implementation 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 technical content within the two AK documents 
22

are the same, although the general types of reactor pins managed prior to 1993 (fast fuel) are 

different than the predominant types tested after 1993 (light water reactors). The reason that 

shipment to INL ceased is not presented in either document, and its inclusion would help to 

clarify whether this change represents a process break or changes in pin composition, or is based 

on other, non-technical reasons. 

Chapter 6 of CCP-AK-ANLE-500 presents the general characterization 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 assurance (QA) program and requiring 

194.22-based QA qualification, and that obtained after program approval. While the overall 

methods may be the same for this waste stream, future streams may employ different methods 

for different elements of the waste stream and different AK confirmation requirements may 

apply. 

The AK Summary does not address drum storage in sufficient 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 that the likelihood of any secondary water 

infiltration is minimal. EPA expects every AK summary to address the storage and management 

of RH containers to ensure that secondary events that 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 that reference. However, several documents 

listed as references in CCP-AK-ANLE-500 are not referenced in the text, and other references 

appear to have minimal relevance to AERHDM. EPA expects that ANL-CCP will continue to 

refine each AK summary, streamlining the document to 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 requirement to collect drum-specific AK data 

is to ensure that AK data are assembled and assessed. Examination of the AK Source Document 

Summary and other reference lists in CCP-AK-ANLE-500 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 Knowledge Source Document Reference List. 

ANL-CCP is expected to continually refining these documents to ensure completeness. ANLCCP should address the above potential changes to the AK summaries in forthcoming changes, 

and revisions to CCP-AK-ANLE-500 and CCP-AK-ANLE-501. CCP should notify EPA of 

these changes as a T2 change. Also, changes made to AK documentation as a result of revisions 

of the WCPIP EPA requires that ANL-CCP notify EPA through 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 if EPA deems it necessary to ensure 

continued compliance with EPA regulations. (See Table 1 where this is included as a T2 

change.) 

CCP-AK-ANLE-500 included the content mandated by the WCPIP, and the general process 

outlined in the WCPIP for AK data assembly was followed. 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 includes 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, including physical descriptions of drum contents 

in each 7-gallon container. Calculated isotopic compositions 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 information as to what the ANL personnel might 

generate based on site-specific requirements that are outside of the ANL-CCP program. 

 

ANL-CCP representatives provided historic AK data for 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 Disposal Requisitions pages as presented in 

U332. Visual Examination Data Forms completed by ANL-CCP as part of their characterization 

program were provided for each drum, showing that examination 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 through 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 must be demonstrated. Examining the FIMS 

database, as documented in AK Reference U335, assessed traceability of the various PIN data to 

the AK record. ANL-CCP representatives performed additional 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 that 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 summarized 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 where the INL population of pins came 

from as well. George Fenske (from ANL) worked on this list of pins and provided us with 

a spreadsheet (U841) of all the relevant information. We collected the documentation 

files and made them part of the AK record (P801-P832; 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 Fabian 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 additional pins of interest. INL 

documented those pins in an EDF (P614). We (CCP) went to Argonne and collected 

source documentation in order to identify composition, burnup, etc., for the pins that 

were identified for the INL population (U839). 

We also took a trip to ANL to go through the sectioning slips (U840 and U826), which 

they began using in 1994, to ensure that all applicable ANL pins had been identified. We 
24

identified several items of interest - we identified material type, etc., and sent the list to 

Jene. Jene went through the list and eliminated all but 9 of the pins, either because they 

were unirradiated or cladding, etc. These additional 9 pins plus the original list from 

George Fenske are all included in Jene’s calc package (U882). Upon examination of 

these 9 pins, Jene determined that further data collection efforts were not needed because 

the necessary information was contained in the source 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 the 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 references are included on the AK Source 

Document Reference List, relevance of the references 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 included in document-specific reference lists at the 

back of CCP-AK-ANLE-500 or CCP-AK-ANLE-501 (see item (4), above, for additional 

discussion). While the process described above appears logical, it must be fully described, 

include reference to the appropriate document(s), and 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 were 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. Consistent with EPA’s authority under 194.24(h), 

EPA may request this information if EPA deems it necessary to ensure continued compliance 

with EPA regulations. (See Table 1 where this is included as a T2 change.) 

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

An AK Source Document Reference List was prepared using 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 documentation 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 contents of the Certification Plan and Confirmatory 

Test Plan, was evaluated. 

ANL-CCP provided a combined site-specific RH TRU Waste 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 of ANL, and as stated in Chapter 6 of the AK 

summary, the ANL-CCP intends to use a combination of methods to qualify AK data. EPA 

interprets this to mean that ANL-CCP commits to collecting AK data for every RH waste stream, 
25

and all AK for each DQO will be technically validated 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 will be used based upon the nature of the waste. 

For example, the newly-generated component of the waste will undergo actual VE while the 

physical attributes of the retrievably-stored portion of the stream will be assessed through VE 

tape review. In the future versions of this and other AK Summaries, EPA expects to see this 

differentiation. 

Also note that the WCPIP states that if AK is insufficient, “additional information” will be 

collected using the same characterization methods as used to “qualify” AK, but this data, in turn, 

will not require qualification. It is unclear whether 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 Confirmatory 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 lots to which the plan applies 

• A description of the confirmatory testing proposed, including the percentage of waste 

containers that will be subject to confirmatory testing 

• An explicit description of the WC DQOs and QAOs that 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 confirmatory testing is to be performed outside 

of that described in the PIP. ANL-CCP indicates that the CTP was provided because the DTC 

method deviates from that presented in the WCPIP, but that the CTP will always be used to 

communicate the full characterization methodology that will be used for a given ANL-CCP 

waste stream. Furthermore, ANL-CCP will combine the EPA Certification Plan with the CTP, 

to ensure that EPA is fully informed of the characterization 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 AERHDM. The Plan appears to address many of 

the required elements that must be in a CTP, but the following statement is made with respect to 

the DQOs for TRU Waste Determination and Activity Determination: 

The required site methodology for comparing radionuclide 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 described in CCP-AK-ANLE-501 
26

(Reference 3). It establishes that there are no significant discrepancies between the AK 

information used in the modeling and the qualification 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 that 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 develop stream-specific AK accuracy evaluations 

with respect to radiological characteristics, and the discussion presented in the CCP-AK-ANLE502 did not adequately address why ANLE AK drum-specific radiological data were not being 

used in AK accuracy determinations for TRU waste determinations 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 end of 4.1. 

2. In the AK accuracy discussion, currently the 1st paragraph on page 12 beginning, “The 

radiological characterization...” Add as a new 2nd 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 evaluations....” and “Consequently...” 

“Argonne had developed radiological information for containers in this waste stream 

primarily for the purposes of estimating the fissile content of individual waste 

containers to comply with accountability requirements and to comply with the 

maximum allowable fissile content of TH TRU drums. The Argonne methodology 

did not produce results adequate for the purposes of WIPP certification. For this 

reason, it is not appropriate to compare the Argonne estimates to the results of the 

ANL-CCP radiological characterization activities for purposes of AK accuracy 

evaluations.” 

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

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.” In the 

current 4th 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 Determination.” Add as new 3rd

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.” 

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

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

revision to CCP-AK-ANLE-502 that reflects these changes. Consistent with EPA’s authority 

under 194.24(h), EPA may request this information if EPA deems it necessary to ensure 

continued compliance with EPA regulations. (See Table 1 where this is included as a T2 

change.) Additionally, because CCP-AK-ANLE-500, CCP-AK-ANLE-501 and CCP-AKANLE-502 are integral to the ANL RH characterization process, substantive modifications to 

any of these documents that have the potential to affect 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 section on AK QAOs and application of AK 

accuracy. The adequacy of DTC with respect to addressing 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 time of packaging have not been evaluated, 

because ANL-CCP has not yet implemented this process and EPA has not evaluated this method 

for RH waste at ANL. 

The specific relevancy of the LANL mass spectrometry 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 discrepancies between the AK information used 

in the modeling and the qualification of that AK (modeling and sampling).” ANL-CCP 

representatives stated that the “AK information used 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 (ANLE included) through a demonstration that 

fuel pin data (LANL) used in ORIGEN2.2 can be validated using mass spectrometry data for 

those same fuel pins. ANL-CCP representatives clarified 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 with mass spectrometry data for the same fuel 

pins. The ANLE fuel pins are not “the same” as LANL 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 reactor (e.g., EBR-II) fuel pins. Therefore, the 

isotopic composition of the two is expected to be somewhat different, as evidenced by the 

development of different scaling factors for the ANLE and INL waste streams. While LANL 

mass spectrometry data helped show the need for (and ways to create) adjustment factors, the 

LANL data are not direct inputs to ANLE specific adjustment 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 calculating package development [see item (5), above]. 

EPA requires that ANL-CCP notify EPA through a T2 change 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 compliance with EPA regulations. (See Table 1 

where this is included as a T2 change.) 

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

The content of CCP-TP-506, Revision 1, CCP Preparation of the Remote-Handled Transuranic 

Waste Acceptable Knowledge Characterization Reconciliation Report, was evaluated to 
28

determine whether this document reflected the assembly 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, to ensure that the CRR addressed required 

elements. The CRR Report was evaluated to determine the completeness and adequacy of its 

contents as required in the WCPIP, including but not 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 how the AK data for each DQO were 

qualified, such as batch data reports, corroborative data, proceedings of a peer review, 

etc. 

• Radiography and/or VE summary to document that liquids 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 qualification process and the 

corresponding resolutions 

• Signature of the SPM 

The example examined included all of the above requirements when examined as a whole. The 

CRR DQO worksheet (Attachment 3 of CCP-TP-506) should 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 radionuclides should be included in the DQO 

analysis. EPA requires that ANL-CCP notify EPA through a T2 change notice upon completion 

of the revised CRR that includes the 10 WIPP-tracked radionuclides. Consistent with EPA’s 

authority under 194.24(h), EPA may request this information 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 Form was evaluated. 

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

from a related CH waste stream is used in the RH WC process. ANL-CCP representative 
29

indicated that CH data was not used in this manner. However, a Correlation and Surrogate 

Summary form was completed to support the correlation of LANL mass spectrometry data to 

ANL data for subsequent use in AK qualification. The form states: 

Information and records retrieved from LANL were used 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 overall modeling approach. A 

comparison between sampling data and ORIGEN 2.2 modeling at LANL demonstrated 

that the modeling approach used for ANL-E is a sound 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 data traceability, data adequacy, and the 

overall modeling approach. 

(11) Personnel training was evaluated. 

Training records for Kevin Peters (AKE), Steve Schafer (AKE), Lisa Price (AKE), Larry Porter 

(SPM), Michael Walantine (SPQAO), and Jene Vance (SME/DTC) were evaluated during the 

INL inspection, with respect to: (1) training to the RH TRU WCPIP, (2) non conformance and 

corrective action processes, (3) the AK procedure presented 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 individual drums. Each person demonstrated 

training in the first four areas. 

With respect to determination of radiological contents of each drum, the resumes of Jene Vance, 

Kevin Peters, and Steve Schafer were examined. Jene Vance’s expertise had been examined at 

INL (see Docket No: A-98-49, II-A4-69,) because he assembled and assessed INL and ANLE 

AK data that were used to derive scaling factors that 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 data, including radiological information. It is 

expected that individuals associated with AK data assembly and interpretation, including SMEs, 

will have read all RH AK summaries and other summaries relevant to the waste stream being 

audited, and will have demonstrated experience or expertise 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 data 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 validating 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 this relationship; instead, ANL-CCP intended to 

demonstrate the commonality of the type of data, data assembly/interpretation process, and 
30

relevant calculations between INL and ANLE to show that the same process used to calculate 

INL scaling factors can be used for ANLE waste. Therefore, traceability of LANL mass 

spectrometry data to the specific pins used to determine ANLE scaling factors is apparently not 

required for this particular waste stream. See item (8), above, for additional analysis of fuel pin 

data, and item (5) for the ANLE Pin Data traceability analysis. 

(13) NCRs and Discrepancy Resolution Forms were examined. 

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 Resolution Form Regarding the Argonne 

Waste Population of 44 drums versus 45 drums, S. Schafer, August 28, 2006; DR11; and, DR10. 

DR11 concerns waste requisition and video discrepancies, while DR10 concerns a discrepancy 

regarding the volume of a 7-gallon waste can. Based 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 review. EPA was not provided a specific 

example of an AK-AK discrepancy resolution involving 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 qualitative 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 for 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 understood 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 the 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 actual, 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 continued 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 the waste to a different waste stream; and 

stream-specific assessment of radiological parameter accuracy. The AK Accuracy Report does 

not call for comparison of AK drum-specific radiological data as a measure of AK accuracy for 

TRU waste determination or radiological component/activity determination. ANL-CCP revised 

the AK Summary to justify this exclusion, as ANL-CCP believes that the per-drum radiological 

AK data calculated by ANLE is inadequate and therefore 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 discussed 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 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. 

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 that revising the AK Accuracy Report to 

address the above requirements might be completed when 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 that 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 authority 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 where this is included as a T2 change.) 

 

(16) Load Management was assessed. 

The possibility that containers may exhibit less than 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 on239Pu, noting that none of these 

containers had assigned 241Am, 238Pu, 240Pu, 241Pu and 242Pu values so the assigned value of 

100nCi/g is likely to be too low. ANL-CCP representatives also indicated that based on the 

application of the scaling factors developed for this 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 considered non-TRU and would be segregated for 

shipment in a different waste stream. The EPA inspection 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 record for each of the 45 containers is over 

17 rem/hr, with a range of 0.58 to 180 R/hr. The CTP states, “In the rare event that a waste 
32

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

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

canister will still be considered RH waste as defined in the LWA.” EPA expects that every 

container emplaced in the RH 72B canister will exhibit 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 implementation 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 each DQO was assessed. 

ANL-CCP representatives indicated that the “qualification” 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 used 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 purview of this EPA inspection. EPA’s term 

characterization does not modify the process proposed by ANL-CCP, but is a distinct language 

difference in that EPA’s characterization program does 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. Regardless, EPA notes that ANL-CCP has 

committed to verifying AK for each DQO. Verification 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 methodology in the version of the WCPIP in 

place at the time of the ANLE inspection. 

(18) Attainment of DQOs through AK verification was evaluated. 

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 canister, 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 measurement. DOE is responsible for making a 

defense determination as discussed in the AK documentation, and cannot be qualified or 

otherwise verified through confirmatory sampling, etc. The use of AK to determine all DQOs, 

with accompanying confirmation or other verification 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 related to AK that are discussed above. Copies 

of the EPA Inspection Issue Tracking Forms are provided in Attachments B.4 through B.7. EPA 

considers all findings and concerns to have been adequately addressed, and there are no open 

finding or concerns related to AK resulting from this inspection. 

Baseline Approval

EPA is approving the AK process evaluated during this baseline inspection. Specifically, the 

approval is limited to one ANL RH retrievably-stored 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 above, 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 baseline inspection include the following: 

• Any new waste streams not approved under this baseline 

• 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 present are not included in 

this waste stream approval 

• Substantive modification(s)*** that have the potential 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 ANL-CCP and CBFO whether a site 

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

review, and/or confer with CBFO and ANL-CCP personnel. 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 implementation but require a brief 

description of the changes to the documents along with 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 documentation 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-AK-501 

o Listing of the references that document the assembly 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 freeze file changes 

• Notification to EPA that the data package for this debris waste stream is completed, 

including any modifications to the WSPF including the CRR and AK Summary 

• Completion of AK accuracy reports, prepared annually at a minimum 

Following EPA approval, ANL-CCP will provide EPA with information concerning T2 changes 

on a quarterly basis. When notifying EPA as a T2 change that additional information is 

available, the notification should provide a brief description of the type of additional 

information. EPA will then determine whether to seek the new, additional information from 

ANL-CCP. EPA will evaluate these changes 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. Consistent with EPA’s authority under 194.24(h) EPA may 

request information relative to these changes if EPA deems the information is necessary to 

ensure continued compliance with EPA regulations. 

8.2 Radiological Characterization 

EPA inspected the method by which the required radiological constituents for each waste 

container were determined. The nature of RH TRU wastes presents considerable difficulty with 

respect to obtaining meaningful measurement data. Apart from the obvious ALARA 

considerations associated with external radiation fields in excess of 200 mrem/hr, RH TRU waste 

containers typically contain concentrations of 137Cs 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 radiological contents. An alternative approach is the use 

of a scaling factor, which allows the correlation of an easily measurable gamma emitter such as 

137Cs with difficult-to-measure actinides and TRU radionuclides. 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 two aspects: 

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

gamma exposure rate5

 (dose rate) by correlating the measured dose rate to an activity 

concentration for 137Cs 

• Using scaling factors to convert the derived 137Cs activity to activity values for the other 

9 of the 10 WIPP-tracked radionuclides, including the uncertainty for each 

 

5

 The external exposure rate is a numerical value expressed in units of rem per unit time (typically mrem/hr) 

that includes the contributions of all radiations, i.e., neutron, gamma, beta and alpha. The formal determination of a 

container’s RH status is documented in mrem/hr, but for the DTC procedure only a photon (gamma) determination 

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 radiological characterization process and 

discusses EPA’s evaluation of the adequacy of ANL-CCP’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 the DTC aspect. Evaluation of the scaling 

factors was not amenable to a checklist, and this aspect 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 from 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 all RH TRU waste containers within ANL waste 

stream AERHDM. Specifically, a single scaling factor 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 Baseline 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 procedures, 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, 137Cs. From a radiometric perspective, this is a simple 

task. The complexity of radiological characterization is contained in the development of the 

DTC approach that transforms each container’s measured dose rate into a 137Cs 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 and their corresponding uncertainties. 

CCP generated the scaling factors using the Monte Carlo Neutron-Photon (MCNP5), 

ORIGEN2.2, and MicroShield computer codes, and compared them to isotopic distribution 

values based on mass spectrometry (MS) data that were generated at LANL. Beginning in the 

1970s, destructive analyses were performed on 400 fuel 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 calculate burnup in fuel and is analogous to 

the fission product 137Cs. 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 were adjusted as a result of 

the comparison. In general, MS is an excellent analytical technique, and use of the MS data to 

adjust the isotopic scaling factors provided the opportunity to verify the results of the application 

of the ORIGEN2.2 codes. A technical assessment of the LANL MS data used to verify the 

ORIGEN2.2 codes was performed as part of EPA Baseline 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 technically 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 radiological 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 calculation packages that are listed in Table 10-1 

of CCP-AK-ANLE-501, as well as the others listed below.
37

Figure 4. Overview of RH Characterization Process at ANL-E 

DeveQuan

Pin Characteristics from Fuel Suppliers and Reactor Operators U-235 Enrichment Pu-240 Enrichment U/Pu Ratio Burnup 

Locate and Retrieve Relevant LANL Records 

Calculate Fuel Composition for 126 Pins 

Make ORIGEN2.2 Runs for 126 Pins 

Output 

Mass SpectrometryResults for 400 LANL PinsU and Pu Relative Abundances 

Compare Mass Spec Results to ORIGEN2.2 Output for 400 Pins 

Determine Average Adjustment Factors to Apply to ORIGEN Results 

Post-Irradiation Forms for 400 LANL Pins U-235 Enrichment Pu-240 Enrichment U/Pu Ratio Burnup 

Calculate Fuel Composition for 400 Fuel Pins 

Make ORIGEN2.2 Runs for 400 Pins Output

Apply Average Adjustment Factors to ORIGEN Results for Fast Reactor Pins and Adjust RERTR Outputs 

Calculate Isotope/Cs-137 Scaling Factors from isotope totals for 53 Pins 

DeveloRelatioDrums Density 

DiDR

Cin 

DeDoDr

Locate and Retrieve Relevant ANL Records 
38

Documents, Waste Containers, and Batch Data Reports Reviewed

The list of documents provided below includes all documents related to the ANL-CCP RH 

radiological characterization program that were evaluated to support this inspection: 

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

• CCP-AK-ANLE-500, Central Characterization Project Acceptable Knowledge Summary 

Report for Argonne Remote-Handled Debris Waste, Revision 1, July 18, 2006 

• CCP-AK-ANLE-501, Central Characterization Project Remote-Handled Transuranic 

Radiological Characterization Technical Report for Remote Handled Transuranic Debris 

Waste from Argonne National Laboratory-East, Revision 0, July 21, 2006 

• CCP-AK-ANLE-502 Central Characterization Project, RH TRU Waste Certification Plan for 

40 CFR Part 194 Compliance and Confirmation Test Plan for ANL RH Waste Stream: 

AERHDM, Revision 0, July 21, 2006 

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

Revision 3 

• CCP-TP-506, CCP Preparation of the Remote-Handled Transuranic Waste Acceptable 

Knowledge Characterization Reconciliation Report, Revision 2 

• DTC BDR No. ANLRHDTC06001 

• Calculation Package Supporting Scaling Factor Derivation: ANLE-RH-01, Fuel Information 

Input Check, Revision 1 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-02, Scaling Factor 

Development 

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-03, Dose-to-Curie 

Derivations for Cs-137 in 30-gallon Drums 

• Calculation Package Supporting Scaling Factor Derivation: ANLE-RH-03, Modification of 

ORIGEN2.2 INPUT files for Specific Fuel Pins 

• Calculation Package Supporting Scaling Factor Derivation: ANLE-RH-04, Scaling Factor 

Development 

• Calculation Package Supporting Scaling Factor Derivation: ANLE-RH-05, Dose-to-Curie 

and Related Calculations for Drum Characterization, Revision 1 

• Calculation Package Supporting Scaling Factor Derivation: ANLE-RH-06, Uncertainty 

Analysis for Drums 

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

for Drum Characterization 

• Calculation Package Supporting Scaling Factor Derivation: ANLE-RH-07, Determination of 

Isotopes To Be Reported per WIPP WAC 
39

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

Verification 

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

DTC Overview

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

137Cs into an activity value using the MCNP5 code, as documented in INL-RH-03. All of the 

gamma radiation measured from each drum of RH waste was attributed to 137Cs, as discussed in 

LANL-RH-10, INL-RH-09, and INL-RH-08. This includes contributions from 60Co and other 

gamma-emitting members of the 232U decay series, e.g., 228Ac and 208Tl. Once the container’s 

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

WIPP-tracked radionuclides were scaled to the 137Cs activity using a single set of scaling factors 

that were applied to all waste containers within the 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 radionuclide scaling factors. 

ANL-CCP formalized the 137Cs measurement in the DTC procedure, CCP-TP-504, Dose-toCurie Survey Procedure for Remote Handled Transuranic 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 determine a container’s external gamma 

exposure (dose) rate 

• Technical adequacy of the radiological characterization program’s documents, 

procedures, and controls 

• Knowledge and understanding of the personnel involved in the radiological 

characterization program 

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

ANL outside in the Area 398 Yard. This area was configured specifically for the purpose of 

performing the DTC measurements and it is shown schematically 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 measurement assembly was inspected in detail prior 

to the measurements, but all non-essential personnel had to evacuate before the top of the RH 

cask was opened. ANL-CCP personnel did provide photographs of the process. The conceptual 

basis for the DTC approach is explained in CCP-AK-INL-501, Revision 1, and is formalized in 

procedure form in CCP-TP-504, Revision 3, both of which were reviewed for this inspection. 

The requirements of these two documents were used to formulate a basis by which the EPA 

inspection team evaluated the DTC process. Additionally, several of the calculation packages 

listed in Section 8.2.1 supported technical aspects of the DTC approach. 
40

Figure 5. ANL DTC Measurement Facility 
41

DTC Technical Evaluation

The EPA inspection team evaluated the following aspects: 

(1) Instrumentation for making dose rate measurements 

The EPA inspection team verified the following: 

• There are two RO-7 Ion Chambers, SN 002003 and 002008. Each instrument had three 

different probes: 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-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 current 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 cable (SN 302582) in the equipment 

trailer on-site. The cable length is important since the probes provide an analog signal to 

the ion chamber, which in turn functions as an analog-to-digital converter (ADC). 

• It was verified that the scale used to weigh the containers has been calibrated and that the 

scale has been checked daily. 

• The battery and performance checks for the RO-7 used to measure the dose rate of 

containers for the DTC method had been performed and documented at least once per day 

prior to the first measurement of the shift. 

• The background rate of 1 mR/hr was measured and recorded. Measurement personnel 

stated that they would take actions to reduce the background 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 September 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 container 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 volume 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 entered into the “Waste Container 

Dose-to-Curie Conversion Record” spreadsheet. Information entered included: 

o Date of the gamma measurements with the RO-7 Ion Chamber and Probe SN – 

September 14, 2006, Ion Chamber SN 002008 and Low Dose 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, 250 and 185 mR/hr 

o Background dose rate – 1 mR/hr 

(3) DTC BDR 

The EPA inspection team verified DTC BDR No. ANLRHDTC06001 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, Attachment 2 

• Waste container DTC conversion records for seven containers, Attachment 3 

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

• Type of waste in each container on Attachment 3, all 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 within the manufacturer’s specifications 

for the RO-7 Ion Chamber by successful source checks made prior to obtaining dose rate 

measurements on actual waste containers. 

• Accuracy had been established and maintained by operating 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 dose rate for every container in the 

BDR, i.e., one hundred percent assay. 

• Comparability had been achieved by using standardized 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 RH 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 observed and are discussed in this 

section represent only the photon (gamma) contribution to a container’s external radiation 

field. There was a neutron-sensitive instrument (Rem Ball) in the same area as the RO-7 

that could be used to provide the necessary information 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 physics/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 dose rate to be at least a factor of ten 

greater than background, and the lowest reading possible 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 readings6

, 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 mR/hr. The EPA inspection team 

wanted to verify that it was possible to ensure that 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 spreadsheet shown in Figure 6 was 

used with input values for a hypothetical 1-meter dose 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 Concentration of 8,660 nCi/g is 

discussed in greater detail in Section 8.2.3 (see Table 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 inspection, or with the method’s technical 

basis and documentation based on the objective evidence that was reviewed. 

 

6

 The strength of the gamma intensity decreases as the square of the distance such that when the distance 

increases by a factor of two the gamma intensity decreases by a factor of four, i.e., two squared. This means that the 

container’s contact dose reading is approximately 20 times greater than the reading at a distance of one-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 Spreadsheet 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 Spreadsheet Version 2.0 080406, 

Using Actual Data from Container No. 00820, Waste Stream AERHDM, Assayed 

August 10, 2006 
45

EPA requires that ANL-CCP notify EPA through a T2 change notice upon completion of 

modifications to CCP-TP-504 that require CBFO approval. Consistent with EPA’s authority 

under 194.24(h), EPA may request this information if EPA deems it necessary to ensure 

continued compliance with EPA regulations. (See Table 1 where this is included as a T2 

change.) Additionally, the use of any alternate radiological other than the DTC technique as 

documented in CCP-TP-504 observed during this baseline inspection is a T1 change. (See Table 

1, which includes this as a T1 change.) 

8.2.3 Radiological Characterization Element: Scaling 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, and LANL, including the following: 

• Fuel pin type and characteristics from fuel suppliers and reactor operators 

•

235U enrichment 

•

240Pu 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 characterization spreadsheet that required the 

following input: 

• Drum gross weight in kilograms (kg) 

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

• Estimates of the can fill heights in percent 

• Dose rate measurements at four quadrant points in mR/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 are 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 2.84 
46

5-gallon drum 2.26 

10-gallon drum 3.42 

The container’s apparent weight density in g/cm3 is calculated as: 

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

 

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

 Csize * %Hfill * 3785 cm3

/gal (3)

Where: 

Csize = can size in gallons 

%Hfill = estimated fill height of each can in percent, expressed 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 measured 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 density. In both cases, the drum’s 137Cs 

content is derived as follows: 

 137Cs Activity in Ci = dose rate / (11.91 * X2

- 82.126 * X + 194.64) (4)

Where: 

X = apparent waste density, g/cm3

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 container’s measured dose rate and density. At 

a hypothetical value of zero density (X = 0), equation (4) becomes essentially a bare-source 

calculation; at higher densities, the effects of the 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/cm

3 to 1.4 g/cm3

 in intervals of 0.2 g/cm3, a 

range that spans the expected range of waste densities 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 Equivalent Curies (PE Ci), were taken from 

the appropriate sources (CH WAC and TRAMPAC) and were checked for accuracy. These were 

found to be accurate and they are summarized in Table 7. 

Determination of the 137Cs 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 each of the other nine WIPP-tracked 

radionuclides, i.e., 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U, and 238U 

• FGE 
47

• PE Ci 

• Decay heat in watts 

• Associated uncertainty for all values listed in previous 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 Waste Density 

For Cs-137 in 30-gallon Drums 
48

Table 7. Constants Used in Scaling Factor Development 

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 Ci, and decay heat values plus uncertainties are 

all produced as a function of the measured dose rates 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 characterization 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 evaluated during this inspection. The 

following elements were evaluated and verified: 

(1) Waste stream definition 

This inspection focused on a group of wastes that ANL-CCP stated were contained in a single 

waste stream, which included fuel pins that were dissimilar with respect to their radionuclide 

content. Specifically, they consisted of three fuel types: 

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

• Uranium and plutonium 

• Thorium 
49

Table 8. Summary of Reportable Values Using Boundary Condition of 10 mR/hr 1-Meter D

Radionuclide 

Curie Scaling 

Factors 

Activity 

(Ci) 

Mass 

Grams FGE PE-Ci Watts 

Uncertainty 

% 

Uncertain

Curies

U-233 2.59E-09 1.87E-10 1.92E-08 1.73E-08 4.80E-11 5.45E-12 81.69% 1.53E-10 U-234 6.48E-05 4.68E-06 7.41E-04 0.00E+00 0.00E+00 1.35E-07 60.71% 2.84E-06 U-235 1.99E-06 1.43E-07 6.55E-02 4.21E-02 0.00E+00 3.96E-09 65.33% 9.37E-08 U-238 2.32E-06 1.68E-07 4.93E-01 0.00E+00 0.00E+00 1.36E-04 51.44% 8.63E-08 

Pu-238 5.70E-02 4.12E-03 2.38E-04 2.69E-05 3.74E-03 1.36E-04 60.82% 2.50E-03 Pu-239 1.08E-02 1.30E-03 2.06E-02 2.06E-02 1.30E-03 4.03E-05 79.45% 1.03E-03 Pu-240 1.23E-02 8.91E-04 3.88E-03 8.72E-05 8.91E-04 2.77E-05 75.94% 6.77E-04 Pu-241 8.11E-01 5.86E-02 5.63E-04 1.27E-03 1.15E-03 1.86E-06 55.78% 3.27E-02 Pu-242 3.01E-05 2.17E-06 5.47E-04 4.10E-06 1.97E-06 6.40E-08 56.63% 1.23E-06 

Am-241 3.11E-02 2.25E-03 6.48E-04 1.21E-05 2.25E-03 7.51E-05 70.07% 1.57E-03 

Cs-137 1.00E+00 7.22E-02 8.21E-04 0.00E+00 0.00E+00 7.99E-05 31.77% 2.30E-02 

Ba-137m 9.46E-01 6.83E-02 1.27E-10 0.00E+00 0.00E+00 2.69E-04 31.77% 2.17E-02 

Sr-90 6.40E-01 4.62E-02 3.35E-04 0.00E+00 0.00E+00 5.36E-05 33.77% 1.56E-02 

Y-90 6.40E-01 4.62E-02 8.49E-08 0.00E+00 0.00E+00 2.56E-04 33.77% 1.56E-02 

Totals — 3.00E-01 5.87E-01 6.41E-02 9.33E-03 9.40E-04 — — 

TRU Alpha Activity Concentration 1.84E+02 nCi/g TRU Alpha Activity 8.56E-03 Ci Total 239Pu Equivalent Activity 9.33E-03 Ci 

Total 239Pu Fissile Gram Equivalent 6.41E-02 g Total Decay Heat 9.40E-04 watts Volume Activity 2.64E-03 Ci/liter 
50

Table 9. Summary of Reportable Values Using Actual Data from Container No. 0082

Waste Stream AERHDM, Assayed August 10, 2006 

Radionuclide 

Curie Scaling 

Factors 

Activity 

(Ci) 

Mass 

Grams FGE PE-Ci Watts 

Uncertainty 

% 

Uncerta

Curie

U-233 2.59E-09 3.43E-09 3.51E-07 3.16E-07 8.79E-10 9.98E-11 80.25% 2.75E-U-234 6.48E-05 8.58E-05 1.36E-02 0.00E+00 0.00E+00 2.47E-06 58.76% 5.04E-U-235 1.99E-06 2.63E-06 1.20E+00 7.71E-01 0.00E+00 7.24E-08 63.52% 1.67E-U-238 2.32E-06 3.07E-06 9.03E+00 0.00E+00 0.00E+00 7.79E-08 49.12% 1.51E-

Pu-238 5.70E-02 7.54E-02 4.36E-03 4.92E-04 6.85E-02 2.50E-03 58.87% 4.44E-Pu-239 1.08E-02 2.38E-02 3.78E-01 3.78E-01 2.38E-02 7.37E-04 77.97% 1.85E-Pu-240 1.23E-02 1.63E-02 7.10E-02 1.60E-03 1.63E-02 5.08E-04 74.39% 1.21E-Pu-241 8.11E-01 1.07E+00 1.03E-02 2.32E-02 2.10E-02 3.41E-05 53.65% 5.75E-Pu-242 3.01E-05 3.98E-05 1.00E-02 7.52E-05 3.62E-05 1.17E-06 54.53% 2.17E-

Am-241 3.11E-02 4.12E-02 1.19E-02 2.22E-04 4.12E-02 1.38E-03 68.39% 2.81E-

Cs-137 1.00E+00 1.32E+00 1.50E-02 0.00E+00 0.00E+00 1.46E-03 27.87% 3.69E-

Ba-137m 9.46E-01 1.25E+00 2.33E-09 0.00E+00 0.00E+00 4.93E-03 27.87% 3.49E-

Sr-90 6.40E-01 8.46E-01 6.13E-03 0.00E+00 0.00E+00 9.81E-04 30.13% 2.55E-

Y-90 6.40E-01 8.46E-01 1.56E-06 0.00E+00 0.00E+00 4.68E-03 30.13% 2.55E-

Totals — 5.50E+00 1.08E+01 1.17E+00 1.71E-01 1.72E-02 — — 

TRU Alpha Activity Concentration 8.66E+03 nCi/g TRU Alpha Activity 1.57E-01 Ci Total 239Pu Equivalent Activity 1.71E-01 Ci 

Total 239Pu Fissile Gram Equivalent 1.17E+00 g Total Decay Heat 1.72E-02 watts Volume Activity 4.84E-02 Ci/liter
51

The following definition is taken from page 12 of the WCPIP: 

A waste stream is defined as waste material generated from a single process or from an 

activity which is similar in material, physical form and radiological constituents. Only 

those containers that can be related to a particular waste stream will be contained in that 

waste stream. 

In light of the apparent differences among the three fuel types listed above, the consolidation of 

these drums in a single waste stream bears investigation. The radionuclide profiles of the three 

fuel types are clearly different; however, following irradiation these fuel types have a common, 

salient characteristic, i.e., the presence of fission and activation products. Of these, 137Cs 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 activation 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 137Cs. In a sense, one could consider that these 

materials have been treated by their exposure to the intense neutron field produced during 

irradiation (fission). The materials’ characteristics that have bearing on DTC have been reduced 

to a common element, i.e., the predominance of 137Cs, after irradiation, and the differences of the 

fuel’s pre irradiation composition do not affect the radiological characterization process. The 

EPA inspection team concluded that the assignment of all containers to a single waste stream 

was technically justified and technically supportable. 

(2) Technical aspects and derivation of scaling factors

The EPA inspection team evaluated the following aspects: 

• Activity values used are derived from modeling and statistical metrics that support their 

use, and the statistical metrics include mean and standard deviation values for each 

measured radionuclide. 

• Isotopic activity values are normalized to the major radionuclide(s) responsible for the 

external container dose rate, i.e., 137Cs. 

• The calculated results are used to develop the scaling factors and convert the measured 

dose rate to radionuclide activity levels. 

• The expected dose rates at a distance of 1 meter from 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 appropriately for container properties i.e., 

fill height or (apparent) density, waste type, shielding effects of the container and/or liner 

wall. 

• Calculations supporting the scaling factors are performed using appropriate shielding 

analysis techniques, i.e., MCNP5 and MicroShield 7.00. 

• 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 produce the TRU isotopes 

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

o Change in radionuclides following irradiation 

o Reactor neutron energy spectrum is known or calculated in order to determine the 

effective cross-sections of radionuclides leading to the creation of 10 WIPP-tracked 

radionuclides 

o Appropriate cross-sections are used or generated for 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 container’s dose rate, specifically 60Co and 

other gamma emitting members of the 232U decay series, e.g., 228Ac and 208Tl 

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

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

• Potential sources of uncertainty, discussed below 

The EPA inspection team members reviewed a subset of 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 discrepancies 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 on 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 137Cs 

• MCNP5 issues 

• MicroShield issues 

• Other gamma emitters

• Individual pins to the total 

• Specific pins in a single drum

• Burnup history 

• Reported burnup 

• Internal code issues 
53

• Contributions from unirradiated pins 

• Modeling 

EPA raised a technical concern regarding TMU with respect to the appropriateness of the 

statistical model during the EPA RH Inspection at INL, see EPA Baseline Inspection Report No. 

EPA-INL-CCP-RH-6.06-8. This technical issue resulted in INL-CCP reissuing calculation 

package INL-RH-06 that provides the technical support for the calculation of TMU at both INL 

and ANL. The EPA Inspection Team reviewed the applicability of the reissued procedure to the 

ANL RH waste stream and determined that it was technically 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 determination other than those observed during 

this baseline inspection and documented in CCP-AK-ANLE-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 stream not approved under this baseline 

inspection or the addition of containers to Waste Stream AERHDM that require changing the 

established radionuclide scaling factors is a T1 change. (See Table 1, where this is included as a 

T1 change). 

Summary of Radiological Characterization Findings and Concerns

The EPA inspection team did not identify any findings or concerns related to radiological 

characterization during this inspection. 

Baseline Approval

EPA approves the ANL-CCP radiological characterization process that the EPA inspection team 

evaluated during the baseline inspection and consists of the following two techniques used 

jointly for containers of RH TRU in one waste stream, AERHDM and consists of the following: 

• The determination of the 10 WIPP-tracked radionuclides based on the DTC procedure 

presented in CCP-TP-504 

• The application of radionuclide scaling factors derived as documented in 

CCP-AK-ANLE-501 and supported by the calculation packages referenced in 

Section 8.2.1 

Radiological Characterization Tiers

Based on the inspection and the results discussed above, 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 evaluated 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 modification thereof*** 

• Any new waste stream not approved under this baseline or addition of containers to waste 

stream AERHDM that require changing the established radionuclide scaling factors 

• Application of new scaling factors for isotopic determination 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 ANL-CCP and CBFO whether a site 

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

review, and/or confer with CBFO and ANL-CCP personnel. 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 the changes to the documents along with the 

notification, include the following: 

• Notification to EPA that revisions of CCP-AK-ANLE-501 or CCP-TP-504 that require 

CBFO approval** are complete 

Following EPA approval, ANL-CCP will provide EPA with information concerning T2 changes 

on a quarterly basis. When notifying EPA as a T2 change that additional information is 

available, the notification should provide a brief description of the type of additional 

information. EPA will then determine whether to seek the new, additional information from 

ANL-CCP. EPA will evaluate these changes 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. Consistent with EPA’s authority under 194.24(h) EPA may 

request information relative to these changes if EPA 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 packaging 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 stream description 

• Description of the container contents including waste 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 to assess whether VE operations follow 

appropriately the implemented procedures and meet VE 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 Implementation Plan, Revision 

0D, October 30, 2003 

• VE Batch Data Report (BDR): RHANLVE060001 

A complete listing of all objective evidence that was 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 stream AERHDM 

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

Technical Evaluation

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

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

(1) Overall procedural technical adequacy and implementation 

The VE procedure, documented in CCP-TP-500, Revision 2, provided instructions to VE 

personnel for performing VE by review of existing audio/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 approximately 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 any 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 other related information if EPA deems it 

necessary to ensure continued compliance with EPA regulations. (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 change. (See Table 1, where this is included as a 

T1 change.) Additionally, using the VE process evaluated 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 evaluated. 

EPA reviewed selected data sheets contained in BDR RHANLVE060001 in conjunction with the 

audio/visual recordings to ensure consistency between 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 information 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 interviewed could not explain how they were 

able to answer certain questions on the VE data sheet, e.g., “The waste is consistent with the 

waste stream description and waste matrix code (Summary 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 the information about the waste stream 

description that was necessary to answer this question. 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 complete inventory put in place on June 15, 2006, 

at the time BDR #RHANLVE060001 was signed off on July 19, 2006. The ITR signed off on 

the checklist on July 19, 2006; however, it was then 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 were 
57

associated through the original packaging information 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 this concern to be 

closed. 

EPA requires that ANL-CCP notify EPA through a T2 change 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 from review of audio/video recordings. The 

operators reviewed existing recordings and completed 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 inventories 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 each WMP using these percentages and the 

weight of the waste contained in the cans. Operators 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 (see Attachment B.1 for a copy of this 

form) and the three aspects of this issue are presented below.

EPA Concern No. ANL-CCP-RH-VE-06-001CR, Part 1: The method of manually 

calculating the weights of Waste Material Parameters (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 the requirement to 

estimate WMP weights because it is not required by the WCPIP. Upon completion of the 

procedural modification, ANL-CCP provided EPA a copy 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 weights is not reviewed and the requirement to 

review it is not contained in any ITR checklist. Failure to do so removes the only required check 

of the calculation on which WMP quantities are based. 

Resolution: Procedure CCP-TP-500 was revised and calculation of the WMP weights no longer 

requires verification. Upon completion of the modification to CCP-TP-500, ANL-CCP provided 

EPA a copy 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. 

EPA Concern No. ANL-CCP-RH-VE-06-001CR, Part 3: VE operators are completing 

“Visual Examination Data Form” without the knowledge 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?” When questioned, a VE operator could not 

explain how he was able to answer this question. Confirmation 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 operators. 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 change notice upon completion of any 

revisions of any 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 other related information if EPA deems it necessary to ensure continued 

compliance with EPA regulations. (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 change. (See Table 1, where this is included as a 

T1 change.) Additionally, using the VE process evaluated 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 for 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 events 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 three 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 for 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 inspection. 

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 system 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 above, EPA assigns the following VE tiers. 

T1 VE changes that require EPA approval prior to implementation: 

• VE by reviewing existing audio/visual recordings for Summary waste category not 

covered by this approval 

• VE by any new process for S5000 debris wastes 
60

T2 VE changes that do not require EPA approval prior to implementation but require a brief 

description of the changes to the documents along with the notification, include the following: 

• Notification to EPA that revisions of any VE procedure that require CBFO approval are 

complete 

• Addition of new S5000 debris waste streams 

Following EPA approval, ANL-CCP will provide EPA with information concerning T2 changes 

on a quarterly basis. EPA will evaluate these changes 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. Consistent with EPA’s authority under 

194.24(h) EPA may request information relative to these changes if EPA deems the information 

is necessary to ensure continued compliance with EPA 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 separate from what is contained in this 

report is required. 

EPA is not approving RTR at ANL-CCP. ANL-CCP did not have an operational RTR unit in 

place at the time of the inspection. ANL-CCP cannot 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 approval separate from what is contained in this 

report is required. 

EPA is not approving the WWIS for entry and tracking of the waste contents of RH debris 

wastes at this time. Although the WWIS is currently 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 EPA’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. These are summarized in the preceding sections. 

The EPA inspection team members evaluated all of CBFO’s 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. 

10.1 Findings and Concerns 

The EPA did not identify any findings during the ANL-CCP inspection. The concerns identified 

during the inspection, as well as ANL-CCP’s responses, 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 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:

• The AK process for RH retrievably-stored TRU debris in one waste stream, Argonne 

National Laboratory Waste Stream No. AERHDM, as defined 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 procedures discussed in this report. 

EPA is not approving the WWIS for entry and tracking of the waste contents of RH debris 

wastes at this time. Although the WWIS is currently 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 database that has been populated with actual RH 

waste content data. The results of the T1 evaluation 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 not have an operational RTR unit in 

place at the time of the inspection. ANL-CCP cannot 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 the baseline inspection must be reported to 

and, if applicable, approved by EPA, according to Table 10. 
63

Table 10. Tiering of RH TRU WC Processes Implemented by ANL-CCP 

(Based on September 12–14, 2006 Baseline Inspection)

RH WC Process Elements ANL-CCP RH WC Process - T1 Changes ANL-CCP RH W

Acceptable Knowledge (AK) Any new waste streams not approved under this baseline; AK (1) 

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 present are not included in this waste stream approval; AK (1) 

Substantive modification(s)*** that have the potential to affect the 

characterization process to CCP-AK-ANLE-500, CCP-AK-ANLE-501 or CCP-AK-ANLE-502; AK (8) Implementation of load management for any RH waste stream; AK (16) 

Notification to EPA that 

complete for RH containstream; AK (3) 

Notification to EPA whe

documentation as a resu

Notification that updates 

following documents: 

• All future revision

CCP-ANLE-AK-5

• Listing of the refer

assembly of fuel pAK (5) 

• All future revision

AK (8) 

• CCP-AK-ANLE-5

address freeze file 

Notification to EPA that 

waste stream is completeto the WSPF including tAK (9), and AK (14) 

Notification to EPA whe

completed, prepared ann

Radiological Characterization, including Dose-To-Curie (DTC) 

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 modification thereof***; RC (8.2.2 and 8.2.3) Any new waste stream not approved under this baseline or addition of 

containers to waste stream AERHDM that require changing the established radionuclide scaling factors; RC (8.2.3) Application of new scaling factors for isotopic determination other than those documented in CCP-AK-ANLE-501; RC (8.2.2 and 8.2.3) 

Notification to EPA that 

501 or CCP-TP-504 that complete; RC (8.2.2 and 
64

Table 10. Tiering of RH TRU WC Processes Implemented by ANL-CCP 

(Based on September 12–14, 2006 Baseline Inspection)

RH WC Process Elements ANL-CCP RH WC Process - T1 Changes ANL-CCP RH W

Visual Examination (VE) VE by reviewing existing audio/visual recordings for Summary waste 

category 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 

that require CBFO approVE (3) Addition of new S5000 

Real Time Radiography (RTR) Any use of RTR requires EPA approval WIPP Waste Information System (WWIS) 

Any use of WWIS requires EPA approval prior to RH waste disposal 

* 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 

requested by EPA. 

*** Substantive modification refers to a change with the potential to affect ANL’s RH WC process, e.g., the use of an inherently different ty

the 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 Pilot Plant Hazardous Waste Facility 

Permit, NM48901 139088-TSDF, Santa Fe, New Mexico, 1989. 

U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 191, “Environmental 

Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level 

and Transuranic Radioactive Wastes.” 

U.S. Code of Federal Regulations, Title 40, Protection of Environment, Part 194, “Criteria for the 

Certification and Re-Certification of the Waste Isolation Pilot Plant’s Compliance with the 

40 CFR Part 191 Disposal Regulations.” 

U.S. Department of Energy, Title 40 CFR Part 191, Compliance Certification Application for the 

Waste Isolation Pilot Plant, DOE/CAO 1996-2184, Carlsbad, New Mexico, 1996. 

U.S. Department of Energy, Carlsbad Area Field Office, “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, SUBPART D AND C, Compliance 

Recertification Application 2004, DOE/WIPP/2004-3231. 

U.S. Department of Energy, Carlsbad Area Field Office, “Contact-Handled Transuranic Waste 

Acceptance Criteria for the Waste Isolation Pilot Plant (CH-WAC),” Revision 3, DOE/WIPP-02-

3122, Carlsbad, New Mexico, April 25, 2005. 

U.S. Department of Energy, Carlsbad Area Field Office, “Quality Assurance Program 

Description (QAPD),” DOE/CBFO-94-1012, Revision 7, Carlsbad, New Mexico, July 2005. 

U.S. Environmental Protection Agency, “Criteria for the Certification and Recertification of the 

Waste Isolation Pilot Plant’s Compliance with the Disposal Regulations: Certification Decision; 

Final Rule,” Federal Register, Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405. 

U.S. Nuclear Regulatory Commission, “Contact-Handled Transuranic Waste Authorized 

Methods for Payload Control (CH-TRAMPAC).” 
Attachments A.1 through A.3 
Revision No.: 3 AK-1 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-ANLE CCP RH-9.06-8 Inspection Required Technical Elements Procedure Location/Adequacy Verification of Activity ObjectImplementation of Characterization Methods to Satisfy DQOs (WCPIP Section 4.2) How are the following DQOs being addressed—any of these that AK is used to determine must be qualified/verified as per Section 4.3, except for the first 

bullet (defense): 

• Defense determination 

• TRU waste determination 

• RH waste determination 

• Activity determination (total and activity per 

canister) 

• Residual liquids 

• Physical form 

• Metals 

• Cellulosics, plastics, rubber 

WCPIP Rev. 0D, Section 4.2; CCPP0-002, Rev. 16. Interview of AKEs including Steve Shafer, 

Kevin Peters, Lisa Watson; examination of objective evidence. 

Examples of include but aCCP-AK-ANANLE-501 RRev. 0, CCPAERHDM, ACRR. It is anticipatrevised in the expected is thidentificationradionuclidedocuments arof those listedocuments reinspection, brevisions, mu

Qualification/Verification of AK Data (WCPIP Section 4.3)Is AK qualification/verification required because characterization information exists that was generated 

prior to an established QA Program? 

WCPIP Rev. D, Section 4.3, CCPP0-002, Rev. 16. Interview of AKEs including Steve Shafer, 

Kevin Peters, Lisa Watson; examination of objective evidence. 

Examples of include but aCCP-AK-ANCCP-AK-AN

a. If yes, what qualification approach is used and for which characterization data (e.g. Peer Review, Confirmatory Testing, Equivalent QA) 

WCPIP Rev. D, Section 4.3, CCPP0-002, Rev. 16. Interview of AKEs including Steve Shafer, 

Kevin Peters, Lisa Watson; examination of objective evidence. 

Examples of include but aCCP-AK-ANCCP-AK-AN

b. If Peer Review performed, does it follow requirements presented in Section 4.3.1 of the PIP? WCPIP Rev. D, Section 4.3, CCP- P0-002, Rev. 16. Interview of AKEs including Steve Shafer, 

Kevin Peters, Lisa Watson. 

Examples of include but aCCP-AK-ANCCP-AK-AN
Revision No.: 3 AK-2 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-ANLE CCP RH-9.06-8 Inspection Required Technical Elements Procedure Location/Adequacy Verification of Activity Object

No Peer Rev

c. If Confirmatory Testing is performed, does it follow requirements presented in Section 4.3.3 of the PIP and which methods are used? 

• 100 % VE at time of packaging 

• 10-10-all 

• Representative sample collection to confirm 

isotopic distribution 

• 100% NDA 

• DA 

• DTC 

• Other as described in a Confirmatory Testing Plan: 

- VE by review of a percentage of audio/video 

tapes 

- Analysis of representative samples for 

radiological data 

- VE/radiography of a subpopulation of waste - Qualification of existing radiological sampling 

and analytical info via modeling (e.g. ORIGEN) 

• Did the generator submit a Confirmatory Test Plan 

as described in Section 4.3.3 of the PIP? If so, has 

CBFO audited and approved the process? Did it contain the following and was it adequate: - Description of the waste stream or waste stream 

lots to which the plan applies - Explicit description of DQOs and QAOs that will be satisfied with the data being qualified - Description of 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 - Description of the confirmatory testing 

proposed, including the percentage of waste 

containers subject to confirmatory testing 

WCPIP Rev. D, Section 4.3, CCP-P0-002, Rev. 16. 

Interview of AKEs including Steve Shafer, Kevin Peters, Lisa Watson. 

Examples of include but aCCP-AK-ANANLE-500; CCP-AK-50CRR-ANLEcontainers 00CCP performall VE tapes/CTP describecontents of PQAO identifdiscussion be
Revision No.: 3 AK-3 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-ANLE CCP RH-9.06-8 Inspection Required Technical Elements Procedure Location/Adequacy Verification of Activity Object

- Description of how the tested subpopulations 

will be representative of the waste stream or waste stream lot - Quantitative acceptance criteria for determining that the AK information in question can be qualified as characterization data 

General Checklist Questions  Is the scope of the waste for which approval is sought defined? What is it? WCPIP Rev. 0D, CCP-P0-002, Rev. 16. Interview of AKEs including Steve Shafer, 

Kevin Peters, Lisa Watson. 

Examples of include but aCCP-AK-AN502. Approval souAERHDM a500. This indrums and 50 containers sodoes not incladditional 20 AK Summar

part of the w

stream to increquire EPA of any new w

 Is the waste TRU by definition as presented in the LWA? 

(P.L.102-579) 

WCPIP Rev. 0D, CCP-P0-002, Rev. 16. 

Interview of AKEs including Steve Shafer, Kevin Peters, Lisa Watson. 

Examples of include but aCCP-AK-AN501, TRU WU335, U336. CCP does nostream, but if notification iinclusion of Ccanister. 
Revision No.: 3 AK-4 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-ANLE CCP RH-9.06-8 Inspection Required Technical Elements Procedure Location/Adequacy Verification of Activity Object

Are 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 AKEs including Steve Shafer, Kevin Peters, Lisa Watson; review of objective evidence. 

Examples of include but aCCP-AK-AN501; P593, PP023, P032, 

Personnel and TrainingWho are the AK personnel? Upon interview, do they 

perform the duties presented in Attachment A, Section 3? 

Who is the Site Project Manager (SPM)? Upon interview, do they perform the duties presented in Attachment A, Section 3? Who is the Site Project Quality Assurance Officer (SPQAO)? Upon interview, do they perform the duties 

presented 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 of 

the PIP 

• Site-specific training relative to the contents of the 

site’s waste streams 

• Determining radiological contents of individual 

containers 

WCPIP Rev. D Attachment A; CCPP0-002, Rev. 16; CCP-QP-001, Rev. 20 

Interview of AKEs including Steve Shafer, Kevin Peters, Lisa Watson, Larry Porter, A.J. Fisher; review of objective evidence. 

Examples of include but aQualification including resShafer. Lisa interview, asknowledgeabWCPIP. 

Compiling AK Documentation and Defining the Waste Stream(s)AK documentation must be compiled. What documents have been compiled? Are they among the following: 

• Published documents/controlled databases 

WCPIP Rev. D Attachment A Interview of AKEs 

including Steve Shafer, Kevin Peters, Lisa Watson, Review of AK 

Examples of include but aCCP-AK-AN501, Source 
Revision No.: 3 AK-5 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-ANLE CCP RH-9.06-8 Inspection Required Technical Elements Procedure Location/Adequacy Verification of Activity Object

• Unpublished data 

• Internal procedures and notes (log books, 

correspondence, etc) 

• Engineering Documents 

• Mission Statements 

• Other 

Documentation is among the data used to define the waste stream. Has the waste stream been adequately defined as 

per the definition of waste stream as presented in the 

WCPIP: Waste stream is a waste material generated from a single process or from an activity which is similar in material, physical form, and radiological constituents. 

Summary and AK Source Document Reference List; examination of selected objective evidence. 

AERHDM. correspondenunpublished 

by CCP that 

internal procdocuments, mAnalysis RepWaste stream that the sourcincluded sevCCP-AK-ANreference list that tracked ocompile and for use in DTdocuments fuassessment fEPA. 

Does additional documentation used to characterize waste and delineate the waste stream include the following: 

• Previous NDA, radiochemistry, dosimetry, and non 

destructive examination data 

• Waste generating procedures 

• Physical, chemical, and radionuclide inputs to the 

process 

• Time period that the process took place 

• Facilities involved 

• Types of waste generated (waste material 

parameters) 

• Process descriptions and flow diagrams 

• Packaging logs and video tapes 

• MSDS 

• Procurement records 

WCPIP Rev. D Attachment A Interview of AKEs 

including Steve Shafer, Kevin Peters, Lisa Watson; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence. 

Examples of include but aCCP-AK-AN501, Source AERHDM; UC349, U305, P032, P002, 
Revision No.: 3 AK-6 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-ANLE CCP RH-9.06-8 Inspection Required Technical Elements Procedure Location/Adequacy Verification of Activity Object

• Administrative/Process controls used as the basis 

for the absence of residual liquids 

• Container-specific information (AK data, i.e. waste

container input forms, etc). 

Were correlations made between CH and RH TRU Waste operations at a site including related CH waste characterization data? If so, are correlations documented on a Correlation and Surrogate Summary Form and is this form adequate and included in the AK Summary? 

Were correlations and similarities with the RH TRU waste operations at other generator/storage sites made, including characterization information for that RH TRU waste stream? If so, are the correlations documented on the Correlation and Surrogate Summary Form and is this form adequate and included in the AK Summary? 

WCPIP Rev. D Attachment A Interview of AKEs 

including Steve Shafer, Kevin Peters, Lisa Watson; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence. 

Examples of include but aCCP-AK-INCCP-AK-AN501, CorrelatP593, P592, If containers determined tof the drums data would band Surrogat

provided to E

Has an AK Source Document Reference list been assembled for each AK Summary/waste stream, and have references been assigned unique identifiers (Attachment 2 of Attachment A of the WCPIP? 

WCPIP Rev. D Attachment A Interview of AKEs/SPM 

including Steve Shafer, Kevin Peters, Lisa Watson; review of AK Summary and AK Source Document Reference List. 

Examples of include but aCCP-AK-ANReference LiReference lisfollow. 

Have Source Document Summaries been developed per Attachment 5 and are these adequate? Do they identify data limitations? 

WCPIP Rev. 0D Attachment A Review of Source 

Document Summaries 

Examples of include but aSee all Sourc

provided (D3

source docum
Revision No.: 3 AK-7 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-ANLE CCP RH-9.06-8 Inspection Required Technical Elements Procedure Location/Adequacy Verification of Activity Object

summary attareference thacontents and documenting 

AK-AK Discrepancy Resolution How are AK-AK discrepancy resolutions documented and does the documentation: 

• Identify the affected waste stream(s) 

• Identify all relevant AK source documents 

• State the nature of the discrepancy 

Has there been an instance where an AK-AK discrepancy 

cannot be resolved or if the resolution results in a failure of a DQO? If so, the waste cannot be shipped to WIPP without further evaluation. 

WCPIP Rev. 0D Attachment A Interview of AKEs/SPM 

including Steve Shafer, Kevin Peters, Lisa Watson, Larry Porter, Mark Doherty; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence. 

Examples of include but aAK-AK radiEPA expects record as theDR011, DR0document anresolutions. identified thu

Characterization of the Waste – DQO Assessment / Preparation of the AK Summary Report What DQOs are assigned by AK? How are each to be qualified/verified (peer review, confirmation, equivalent QA program) 

• Defense determination 

• TRU waste determination 

• RH waste determination 

• Activity determination (total and activity per 

canister) 

• Residual liquids 

• Physical form 

• Metals 

• Cellulosics, plastics, Rubber 

For each DQO related to AK, AK personnel must identify 

the DQO, supporting AK information, justify the assignments/conclusions, reference the AK Source Documents and applicable pages supporting the assessment, method of 40 CFR 194.22(b) will be qualified 

WCPIP Rev. 0D Section 4 Interview of AKEs/SPM 

including Steve Shafer, Kevin Peters, Lisa Watson, Larry Porter, Mark Doherty; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence 

Examples of include but aANLE-500 aCCP added a that addresse
Revision No.: 3 AK-8 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-ANLE CCP RH-9.06-8 Inspection Required Technical Elements Procedure Location/Adequacy Verification of Activity ObjectHave applicable DQOs been addressed as follows: 

• Has adequate review of AK information been 

performed to determine whether the waste was 

generated by defense activities or is commingled with RH TRU waste generated by defense activities? This determination will be established 

by the AK data compiled. 

• Review the AK information to determine the 

nuclear properties of the waste stream. The nuclear

properties relevant to RH TRU waste include: 

TRU activity of the waste stream greater than 100 nCi/g of waste. Is this TRU waste? Will load management take place? 

• What information is included in the AK Record 

and AK Summary to demonstrate that the waste is RH waste? Dose equivalent rate equal to or greater than 200 mrem/hr and less than 1,000 rem/hr at the surface of the payload container. 

• Does the AK record adequately present, support, 

and report activity of the 10 required radionuclides 

(TRU isotopes 238Pu, 239Pu, 240Pu, 242Pu, and 

241Am; and non-TRU isotopes 137Cs, 90Sr, 233U, 234U, and 238U)? Furthermore, does AK provide 

information to determine the total activity in each

canister? Must be less than 23 curies per liter. 

• Are AK records used to calculate, compute, or 

otherwise derive the total activity and/or TRU activity of the waste and the records? If so, were

they qualified by peer review, confirmation, or equivalent QA (see relevant checklists/analysis forthese elements, if performed)? Were data collectedunder an EPA approved program? If so, the records alone may be used to satisfy DQOs; otherwise, the above characterization objectives must be met by collecting additional data during 

packaging, etc. Were data that would be 

WCPIP Rev. 0D Section 4 Interview of AKEs/SPM 

including Steve Shafer, Kevin Peters, Lisa Watson, Mark Doherty, Larry Porter; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence 

Examples of include but aCCP-AK-AN502, CCP-AKAK-ANLE-52, CRR-ANLC331, C330, U334, U335, C332, P001, P380, P412, AK record insupporting ddata that supof waste notiwill be made than the AK EPA 10 radiorecord, and Aradiological 

performed by 

campaign ratthis analysis information. used for all vdefense detervia waste disto assess wasexamination 

performed seNote that EP

include inforstorage that wresidual liquiinundation or occurred. A

planned, but 

notification o
Revision No.: 3 AK-9 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-ANLE CCP RH-9.06-8 Inspection Required Technical Elements Procedure Location/Adequacy Verification of Activity Object

considered AK, collected and assembled under an EPA 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 information 

regarding the waste stream waste material 

parameters to provide a detailed description of the

waste stream in accordance with the format of the AK Summary Report? 

• Has AK information been used to determine the 

absence of residual liquids? This review may include waste packaging procedures and other documented administrative controls such as training records that identify control of residual liquids. It may also include previous waste characterization data or information from wastecontainer-specific packaging logs. The criterion inthe DQO is that residual liquids must be less than 1 percent by volume of the waste container. 

AK Summary Report Preparation Has an AK Summary been prepared and does it follow the format specified in Attachment 1? The report shall include the following: 

• Program and waste stream narrative 

• Sections as defined in the WCPIP 

• Detailed description of the waste stream including 

information on, for example, specific waste matrix materials and fill volumes 

• The report shall address all of the DQOs as noted 

in previous steps with appropriate justifications and references in the text 

WCPIP Rev. 0D Attachment A Interview of AKEs 

including Steve Shafer, Kevin Peters, Lisa Watson; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence 

Examples of include but aCCP-AK-ANrequired sectthe back of thArgonne, and ANLE on the List are not iAdditionallyfile change to DTC data coaccuracy is nit is expected among those is implementEPA of all re
Revision No.: 3 AK-10 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-ANLE CCP RH-9.06-8 Inspection Required Technical Elements Procedure Location/Adequacy Verification of Activity Object

500 is requir

Have the following documents been completed in addition to the AK Summary; are they available for EPA review 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 summaries 

WCPIP Rev. 0D Attachment A Interview of AKEs 

including Steve Shafer, Kevin Peters, Lisa Watson; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence. 

Examples of include but aCCP-AK-ANDocument RSurrogate SuDR013. Sou

placed on eapublished (P

document. 

Have all of these been provided to the SPM for review, as required in Section 6.7 of the WCPIP Attachment A? Did the AK personnel recommend how the SPM should assess and qualify the information? (6.8) 

WCPIP Rev. 0D Attachment A Interview of AKEs 

including Steve Shafer, Kevin Peters, Lisa Watson; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence. 

Examples of include but aCharacterizaWaste Stream with SPM incited in Sectiwas not deterrecommend hthe SPM did 

Reconciling Compiled AK Information 

Has the SPM Reviewed the AK Summary Report, AK Source Document Reference List, Correlation and Surrogate Summary Forms, the referenced source document summaries, if applicable, batch data reports from any confirmatory activities such as VE or NDA and, if applicable, supplemental data collected during repackaging using an approved technique, to determine if the AK record is reconciled and is adequate to characterize the waste stream or waste stream lot and satisfy the relevant DQOs? 

WCPIP Rev. 0D Attachment A Interview of Larry Porter; 

review of the AK Summary Report, Correlation and Surrogate Summary forms, BDRs, and other supporting verification activities. 

Examples of include but aCCP-AK-AN502, AK SouCorrelation aForms; sourcincluded for 

provided), an
Revision No.: 3 AK-11 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-ANLE CCP RH-9.06-8 Inspection Required Technical Elements Procedure Location/Adequacy Verification of Activity ObjectDiscrepancies between the AK record and confirmatory test results identified during this reconciliation process must be resolved and documented. What is the AKmeasurement discrepancy resolution process employedand is it satisfactory? Does it involve reevaluation of the AK record, reassignment of waste stream parameters, and a revision to the AK Summary Report? 

WCPIP Rev. 0D Attachment A Interview of AKEs/SPM 

including Steve Shafer, Kevin Peters, Lisa Watson, Mark Doherty, and Larry Porter; review of AK Summary and AK Source Document Reference List; examination of selected objective evidence. 

Examples of include but aWSPF, CRRthe AK Recoresults were 

performed a based on AK 

used by CCP

bolster use o

factor, assumcomparable. 

provision of 

(DTC converDTC results comparison. 

AK Accuracy 

Has the SQAO, consistent with the requirements of Section 4.1.1.2 of the WCPIP, reviewed the AK Summary Report, confirmatory test data, identified AK discrepancies, and prepared an AK Accuracy Report? This report will identify the percentage of containers that have been assigned to another SCG, as well as radiological issues. 

WCPIP Rev. 0D Attachment A Interview of A.J. Fisher; 

examination of AK Accuracy Report. 

Examples of include but aAK Accuracstream AERHconsistently 

be based both 

summary catrequired by tconcern No. and expects treconciled in may also incWCPIP chan

How did the SQAO determine what is to be considered a “significant” radiological discrepancy and is this determination technically sufficient and adequate? 

WCPIP Rev. 0D Attachment A Interview of A.J. Fisher; 

examination of AK Accuracy Report. 

Examples of include but aAK Accurac502. CCP coto CCP-AK-ANLE-500 t
Revision No.: 3 AK-12 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-ANLE CCP RH-9.06-8 Inspection Required Technical Elements Procedure Location/Adequacy Verification of Activity Object

comparison orespect to acCCP-AK-ANclarify how tused in the c

Has the AK Accuracy report been updated annually? Even if the report is only updated annually, will they continually assess AK Accuracy? 

WCPIP Rev. 0D Attachment A Interview of A.J. Fisher; 

examination of AK Accuracy Report. 

Examples of include but aAK Accurac

performed A

Provision of as they are p

Has the AK Accuracy fallen below 90%? If so, the site shall document this as a significant condition adverse to quality as defined by the CBFO QAPD. The site shallnotify the CBFO of this condition and implement appropriate corrective actions before proceeding with further characterization activities on the affected waste stream(s). 

WCPIP Rev. 0D Attachment A Interview of A.J. Fisher; 

examination of AK Accuracy Report. 

Examples of include but aAccuracy repWCPIP and it is anticipatshow that the 90%. 

Preparation of the CRRHas the SPM reviewed the qualified AK characterization information and the corresponding required DQOs anddocumented this review in an RH TRU waste AK Characterization 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 that 

support/provide the data 

• A listing of AK record discrepancy resolutions, if 

any, that are relevant to each DQO 

WCPIP Rev. 0D Attachment A; CPTP-506 Rev. 2 Review of the CRR for select ANLE RH waste 

stream; interview of Larry Porter, SPM. 

Examples of include but aWSPF and C00810, 815, 

be revised to 

recognize ideradionuclideThe CRR incthe WCPIP A
Revision No.: 3 AK-13 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-ANLE CCP RH-9.06-8 Inspection Required Technical Elements Procedure Location/Adequacy Verification of Activity Object

• Documentation, including specific references, of 

how 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 summary 

to document that liquids 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, crossreferenced to each batch data report 

• A listing of AK discrepancies generated by an AK 

qualification process and the corresponding resolutions 

• Signature of the SPM 

Has the SPM verified that the applicable QAOs (accuracy, completeness, representativeness, and comparability) associated with the AK process have been met? 

WCPIP Rev. 0D Attachment A; CCP-TP-506 Rev. 2 

Review of the CRR for select ANLE RH waste stream; interview of Larry Porter, SPM. 

Examples of include but aWSPF, CRRincluded on t

Preparation of the Waste Stream Profile Form Has the SPM completed the Waste Stream Profile Form(WSPF) (Attachment 4) based on AK characterization and confirmation results and other relevant characterization data? Is the form complete and adequate/accurate? 

WCPIP Rev. 0D Attachment A Review of the WSPF and 

related attachments; interview of Larry Porter, SPM. 

Examples of include but aDraft WSPF Summary anSee commenSummary anwas a draft v

purposes onl

final version 
Revision No.: 3 AK-14 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-ANLE CCP RH-9.06-8 Inspection Required Technical Elements Procedure Location/Adequacy Verification of Activity Object

completed anEPA also reqforthcoming that might be including the (identificatioradionuclidethis informat

Have the WSPF, the RH AK Summary Report and the Characterization Reconciliation Report, resulting from waste characterization activities, been transmitted to the Department of Energy Carlsbad Field Office (DOE/CBFO). Only RH TRU waste that is characterizedin accordance with the EPA requirements and WCPIP will be accepted for disposal at the WIPP. 

WCPIP Rev. 0D Attachment A Review of the WSPF and 

related attachments; interview of Larry Porter, SPM. 

Examples of include but aDraft WSPF, AK-ANLE-5available at t

provided the 

related attachapproved. 

Records Have the following records been generated and what is the 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 Report 

WCPIP Rev. 0D Attachment A Interview of AKEs Kevin 

Peters, Steve Shafer, Lisa Watson; examination of required references as listed (objective evidence). 

Examples of include but aCCP-AK-AN501, AK SouCorrelation adraft WSPF C, U, and P srecords for KDR011, DR0(current contAERHDM). Lisa Watson included at thMexico. 
Revision No.: 3 AK-15 

ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLIST 

EPA Inspection No.: EPA-ANLE CCP RH-9.06-8 Inspection Required Technical Elements Procedure Location/Adequacy Verification of Activity ObjectConfirmatory Test Plan

WCPIP Rev. 0D Attachment A Interview of AKEs Kevin

Peters, Steve Shafer, and Mark Doherty, and examination of objective evidence. 

Examples of include but aCCP-AK-ANrequires reviassessment dappropriate lspec data, ancomparisons inappropriatechanges in a requires provANLE-502 tchanges were implemented modification
Revision No.: 3 RC-DTC-1 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-T

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

Technical Documents/Procedures Identify all ANL-CCP documents that 

provide technical information relative to performing and documenting the 

implementation of the DTC method, including operational procedures, and indicate the current revision of each. 

Y DOE/WIPP-02-3124, Rev. 

0D 

All ANL-CCP documents were reviewed before, during, or directly following this inspection. The correct revisions for each are noted in Objective Evidence in the cell to the left in this row. 

Y D

555

p

J8

Dose-To-Curie Instruments Verify the following: 

• Specifications for the instruments 

used for dose rate measurements of RH TRU waste containers are 

provided in ANL-CCP documents 

• Performance and measurement 

control criteria for dose rate instruments have been specified and integrated in ANL-CCP operating 

procedure(s) 

• The instruments used to make dose 

rate measurements of RH containers are identified 

• The instruments identified in 

previous bullet have been 

appropriately calibrated 

• The scale used to weigh the 

containers has been calibrated and that the scale has been checked each operational day 

Y CCP-TP-504, Rev. 3, 

Section 4.1 

These technical aspects were verified by examination during the inspection 

Y C

ADAc

M

ASA

DR

3t

Verify that the instruments used for dose rate measurements of RH TRU containers are 

properly calibrated to provide data that are 

consistent with those used in the calculation of the radionuclide-specific activity. 

Y CCP-TP-504, Rev. 3, 

Section 4.1 

Calibration sheets for the ion chambers used were examined. 

Y A

R
Revision No.: 3 RC-DTC-2 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-T

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

Verify that the position of the detector relative to the waste container and any intervening shielding is consistent with that used in the calculation of the expected radiation dose. 

Y CCP-TP-504, Rev. 3, 

Section 4.1 

Detector position relative to the waste container and shielding is addressed appropriately. 

Y A

R
Revision No.: 3 RC-DTC-3 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

General Technical Requirements DTC must provide information to support the reporting of quantitative values and uncertainties for 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr and 137Cs. 

Y DOE/WIPP-02-3124, Rev. 

0D, Attachment C, Section 8.0 

Quantitative values and uncertainties for 

238Pu, 239Pu, 240Pu, 242Pu, 241Am, 233U, 234U, 238U, 90Sr, and 137Cs are reported. 

Y A

R

Verify that a waste container is classified as RH TRU only if the dose equivalent rate at the exterior of the surface of the container is 

between 200 mrem/hr and 1000 rem/hr and 

the concentration of alpha emitting TRU radionuclides is greater than 100 nCi/g waste. 

Y DOE/WIPP-02-3124, Rev. 

0D, Attachment C, Section 12.0 

All containers in RH TRU waste stream AERHDM meet the criteria for TRU (concentration of alpha-emitting TRU radionuclides greater than 100 nCi/g waste) and RH (dose equivalent rate at the exterior of the surface of the container between 200 and 1000 rem/hr). 

Y A

R

Assess the technical adequacy of the calculations involving the application of scaling factors and/or correlation techniques. 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 7.0 

The technical adequacy of the calculations involving the application of scaling factors and/or correlation techniques is addressed in Section 8.3. 

Y S

aAA

Measurements: Dose Rate and Background Verify the following: 

• Dose rates are measured four (4) times 

at a detector-to-container distance of 1 meter, with the container rotated 90° 

between each of the four 

measurements 

• The appropriate ion chamber and 

probe are used 

• The radiation field is measured at least 

two locations about the container at the mid-height of the container and a distance of 1 meter from the surface of the container. 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 7.0 

ANL-CCP Batch Data Report No. ANLRHDTC06001examined for this inspection documented technically appropriate collection of containerspecific dose rate information. 

Y A

Rc

M

AS

CCT

Verify that the background rate is measured and recorded and that actions are taken to reduce the background if the measured 

Y CCP-TP-504, Rev. 3, 

Section 4.1 

ANL-CCP Batch Data Report No. ANLRHDTC06001examined for this inspection documented technically 

Y A

Rc
Revision No.: 3 RC-DTC-4 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

background radiation levels are greater than 

one-tenth of the expected container rate. 

appropriate background measurement data. 

CT

Measurement Documentation Verify that container number, waste stream identifier, and all pertinent container-specific measurement data are entered into the “Waste Container Dose-to-Curie Conversion Record” 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) dose 

measurements 

• Expected container dose rate 

• Waste Material Type (matrix) 

Y DOE/WIPP-02-3124, Rev. 

0D; CCP-TP-504, Section 4.2 

ANL-CCP Batch Data Report No. ANLRHDTC06001examined for this inspection contained all required documentation. 

Y A

RcCA

DR

3

Verify that DTC BDR ANLRHDTC06001 contains the following items: 

• Batch Data Report Cover Sheet, 

Attachment 4 

• Batch Data Report Table of Contents, 

Attachment 5 

• Batch Data Report Narrative 

Summary, Attachment 6 

• ITR Review Checklist, Attachment 7 

• Measurement Control Report, 

Attachment 1 

• Container Data Sheet(s), Attachment 2 

• Waste Container Dose-to-Curie 

Conversion Record(s), Attachment 3 

• Copy of NCRs, if applicable 

Y CCP-TP-504, Rev. 3, 

Section 4.3 

ANL-CCP DTC Batch Data Report No. ANLRHDTC06001examined for this inspection contained all required elements. 

Y A

R
Revision No.: 3 RC-DTC-5 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

• Evidence of a review by an ITR and 

SPM, as appropriate. 

Verify that records generated in support of DTC are available for inspection. Records include the following, at a minimum: 

• Site-specific procedures developed to 

implement the DTC method 

• Technical basis for the determination 

of the waste stream’s “Standard Mix” shielding calculations for waste containers 

• Technical basis for determination of 

radionuclide scaling factors 

• TMU technical support documents 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 15.0 

All records related to DTC were available for this inspection on-site at INL and in CBFO Headquarters in Carlsbad, New Mexico. 

Y A

R
Revision No.: 3 RC-DTC-6 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

Technical Basis Verify the following: 

• Results of sampling and calculation 

form the basis for the development of radionuclide scaling factors used to convert measured dose rates to radionuclide-specific activities 

• Dose rates are measured at a distance 

of one meter from the outer surface of the waste container at the mid-height of the container 

• Calculations appropriately present the 

relationship between a container’s measured dose rate and the waste’s activity 

• Calculations account for all relevant 

container properties, specifically fill height (apparent density), waste type (matrix) and attenuation (shielding) of the container and/or liner wall 

• Calculations are performed using 

technically appropriate shielding analysis techniques 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 7.0; CCP-AK-INL-501, Rev. 0; CCP-TP-504, Rev. 3, Section 4.3 

These technical aspects were examined 

before, during, and following this 

inspection in consultation with CTAC technical personnel. 

Y C

IRRRI

Verify that waste containers contain only matrices for which the DTC methodology has 

been established. 

Verify that the type of waste (waste matrix) in each container is recorded along with the height of the waste in the container. 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 5.0 

RH waste cans contain metals (steel), concrete, or organics with a minimum of mixing of dissimilar types of materials. Fill heights are specified for all containers, i.e., less than 25% full, 25% to 66% full, 66% to 90% full, more than 90% full. 

Y A

RD

Verify that all DTC-related calculations have 

been subjected to a technical review and that 

all technical review comments and their resolutions are documented. 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 14.0 

With minor exceptions, all calculation 

packages contain evidence of a 

technical review. 

Y E

p

dsV
Revision No.: 3 RC-DTC-7 

ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspectio

Required Technical Elements Y/N Location Verification of Activity Y/N 

S

Verify that the ratio of actual measured dose rate to the calculated dose rate is used to calculate a scaling factor that is applied to the “Standard Mix” or subset thereof, that was used to estimate individual radionuclide activities. 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 11.0; CCP-TP-504, Rev. 3, Section 4.2 

The “Standard Mix” was not used to generate scaling factors for this waste stream. The technical documentation of the scaling factor development supports the use of dose rate measurements. 

Y C

IRRR

Total Measurement Uncertainty (TMU) Verify that a method for estimating total measurement uncertainty (TMU) has been developed and documented for RH TRU waste stream AERHDM. 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 13.0 

This checklist addresses the aspects of TMU attributable to DTC. The aspects of TMU related to the development and application of radionuclide scaling factors are addressed in Section 8.3. 

Y C

IRRR

TMU is based upon the propagation of uncertainties present in all aspects of radiological characterization, including DTC. 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 13.0 

TMU includes the contributions of all applicable aspects of the DTC process. 

Y C

IA

Verify that the approach for TMU determination incorporates the contributions of all applicable components of DTC, including: 

• Measured sample isotopic activities 

• Relative uncertainties associated with 

each measured radionuclide 

• Measurement of the container’s dose 

rate 

• Determination of waste mass 

• Modeling errors or biases. 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 13.0 

TMU includes the contributions of all applicable aspects of the DTC process. 

Y C

IRRR

Verify that the TMU approach has been formally submitted to CBFO for review and approval. 

Y DOE/WIPP-02-3214, Rev. 

0D, Attachment C, Section 13.0 

The TMU approach was evaluated by the CTAC Technical Specialists (D. Stuenkel and J. Oliver) during this inspection. 

Y I

RRR
Revision No.: 3 VE-1 

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspection 

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

RHVE-1 Site procedures identify required training and qualifications for RHVE 

personnel.

WCPIP, Rev. 0D, Section 4.1.2.2 CCP-QP-002, Rev. 21 

• Formal training elements include: 

project requirements, container 

identification and labeling, applicable state and federal regulations. 

• Site-specific training program: OJT, 

identification of summary category groups, WMPs, packaging configurations, residual liquids. 

Y During the on-site inspection, 

three (3) qualified operators anThe operators had received traAK-ANLE-500 for the waste AERHDM. This is a S5000 dwere also required to read the regulations and requirements. VEE for INL and spends his tiVEE is also the OJT/SME and operators. The operators passMay 22, 2006. The operators 

Summary on August 14, 2006Objective evidence:

1. Qualification cards for VE 

2. Qualification Card for SM3. VEE appointment letter, d4. List of Qualified Individu

program 

5. Attendance Sheets for CC6. Acceptable Knowledge S

Certificates for Argonne RStream – AERHDM. 

RHVE-2 Operator qualification and re-qualificationrequirements are described.

WCPIP, Rev. 0D, Section 4.1.2.2 CCP-QP-002, Rev. 21, Section 4.2.5 

• To become qualified, the RHVE operator 

must pass a comprehensive written test 

based on training objectives with a 

minimum score of 80% 

• Demonstrate capability in the presence of 

the site VEE during OJT 

• RHVE operators re-qualified every 2 

years based on continued satisfactory 

performance 

Y EPA reviewed the Qualificatio

qualified operators and the deOJT/SME and provided the Ooperators passed the required The Qualification Cards revierequired. As this program is noperators has not been requireObjective evidence:

1. Qualification cards for VE 
Revision No.: 3 VE-2 

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspection 

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

• Unsatisfactory performance – failed to 

identify prohibited item during OJT with score of less than 80% on exam 

2. Qualification Card for SM

3. VEE appointment letter, d4. List of Qualified Individu

program 

RHVE-3 Each site has a designated VE expert (VEE) 

WCPIP, Rev. 0D, Section 4.1.2.2 CCP-PO-001, Rev. 12 

• VEE designation is documented 

• VEE has knowledge of the RH TRU 

waste being characterized 

• Responsible for overall direction and 

implementation of VE at the facility 

• Certification Plan specifies the selection, 

qualification, and training requirements of VEE 

Y VEE training and designation 

site inspection. The VEE was from the SPM, dated April 17overall responsibility for the V

operators are not necessarily acontainer audio/visual recordi

and the operators have copies 

problems encountered by the o

reviewed, and resolved with thtelephonic communication. 

Objective evidence:

1. Qualification Card for VE

2. List of Qualified Individu

RHVE-4 CCP-TP-509, 

Rev. 0, Section 4.4 

• Operators review AK Tracking 

Spreadsheet to verify that correct containers examined 

• Rejected containers are placed in a 

shielded container with a CCP Hold Tag attached 

• Provide container processing information 

to SPM/VPM 

Y Prior to commencing VE oper

AK Tracking Spreadsheet to d

be examined. During the on-s

the hold tags applied to the sh331 yard, Building 331 Domecontainers from BDR RHANLcorrectly attached to each coninformation for each BDR is csystem and identifies the contnumber for rejected containerThe operators populate an ExcContainer Management”, with BDRs are uploaded to the spreaccessed by the SPM to obtain 
Revision No.: 3 VE-3 

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspection 

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

Objective evidence:

1. AK tracking spreadsheet 

AERHDM 

2. BDR # RHANLVE060003. Processing information fo

RHVE-5 Procedures and technical guidance documents 

provide complete 

instructions for performing RHVE. 

WCPIP, Rev. 0D, Sections 4.1.2, 4.1.2.1, 4.3.3 CCP-TP-500, Rev. 2, Sections 4.1-4.2, Attachment 1 

Procedures are sufficiently detailed to enable the operator to determine if a waste container meets the criteria of '194.24 with regard to identifying applicable parameters with waste 

limits [194.24, c, (4)] – demonstrate that a system of controls has been and will continue to be implemented to confirm that the total amount of each waste component that will be emplaced in the disposal system will not exceed the upper limiting value, or fall below the lower limiting value described in the introductory text of paragraph (c) of this section). 

• All existing VE tapes will be reviewed 

and the VE data will be documented 

• Existing waste container packaging 

records will be qualified by VE or RTR 

• 100% of containers will be subject to VE 

at the time of packaging 

• Waste stream description and WMC 

verified 

• Presence/absence of prohibited items 

Y In this waste stream, 44 conta

and CCP has audio/visual tapeestimates that there will be an still need to be packaged. Pacgallon cans and two cans will container. Two (2) operators generated Vreview of audio/visual recordiexisting recordings and complfrom their observations. Operawaste stream prior to processi

CCP had generated only one (that had been through project-inspection. Of the ten (10) coRHANLVE060001, four were required VE QAOs. At the end of the VE event, th

percentages to each WMP and 

these percentages and the weigcans, the weight of each WMPof the manual calculations per

perform the required check of 

the requirement to perform thiin the ITR checklist. When int

provide the basis for answerin

questions. EPA generated con001CR to address these issues
Revision No.: 3 VE-4 

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspection 

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

ANL-CCP-RH-VE-06-001CR

1. Method of manual calcula

contained within the existdocument this process in inconsistent and undocumused for this calculation. 

Resolution: CCP will remestimate WMP weights frit is not required by the W

2. ITR is required to review 

WMP weight calculations need to review the item cFailure to do so removes calculation on which WM

Resolution: When procedWMP weights will not be not require verification of 

3. Operators are filling out s

Form” items without the kthe correct decision. Exa“The waste is consistent wdescription?” When quesexplain how they were abConfirmation of waste strAK confirmation required Operator is responsible to 

part of the waste stream. 

Resolution: CCP will prooperators. 

EPA considers this concern cl

RH drums are stored in shieldis rejected, CCP/ANL personncontainer. The hold tags on alBDR # RHANLVE060001 we
Revision No.: 3 VE-5 

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspection 

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

EPA reviewed the data sheets containers 00816, 00826, 0082consistency between the writtnot identify any discrepant infThe audio/video recordings do 

being loaded into the 30-gallo

containers can be associated thinformation. This information each container. 

Objective evidence:

1. BDR # RHANLVE06000

2. List of Qualified Individu

program 

3. Attendance Sheets for CC

4. Acceptable Knowledge S

Certificates for Argonne RStream – AERHDM. 

RHVE-6 CCP-TP-500, 

Rev. 2, Section 2.4.2 

• Corrective actions are taken when 

necessary 

Y NCRs were written as needed 

containers in batch RHANLV

and 00816 were rejected becauverify that containers were freRHANL-0001-06 was issued condition. NCR NCR-RHANLcontainers 00825 and 00829 bunable to determine the prima

All of the above containers we

Objective evidence:

1. BDR # RHANLVE06000

RHVE-7 Site procedure(s) require 

WCPIP, Rev. 0D, Section 

• ITR review Attachment 2 Y The VEE signed off on the BD

the container inventories were 
Revision No.: 3 VE-6 

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspection 

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

data generation and project level reviews of Batch Data Reports (BDRs). 

4.1.2.1 CCP-TP-500, Rev. 1, ITR: Sections 4.3.5-4.3.8, Attachment 2, SPM: Section 4.4, Attachment 3 

• SPM review Attachment 3 identified by CCP and the inv

the on-site inspection. As the after the additional training pr2006 EPA generated concern address this issue. ANL-CCP-RH-VE-06-002C:

The ITR had not fully implemcomplete inventory put in placBDR #RHANLVE060001 waThe ITR signed off on the chehowever, it was then corrected inventory” requirement on AuResolution: The ITR initiated 

understood the expected criter

based on the issue at INL. At 

VE data had been revised to inthe waste items in each contaiconcern closed. The SPM checklist listed the cthe batch and also provided th

Objective evidence:

1. BDR # RHANLVE06000

RHVE- 8 CCP-TP-500, 

Rev. 2, Section 5.0 

• Lifetime/QA records – Attachments 1-5, 

Copy of NCRs 

• QA/nonpermanent records – VHS tape or 

DVD (primary and backup) 

Y Both the BDR and audio/visua

RHANLVE060001 were avaisite inspection. Two copies of are made, one being sent to th

for processing. 

Objective evidence:

1. BDR # RHANLVE06000

2. Audio/visual recordings f

BDR # RHANLVE06000
Revision No.: 3 VE-7 

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspection 

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

RHVE-9 Quality Assurance Objectives are defined and met 

WCPIP, Rev. 0D, Section 4.1.2.3 

Data Accuracy: 194.22, b, (1) the degree to which data agree 

with an acceptable reference or true value WCPIP: maintained by requiring operators to 

pass a comprehensive test with a score of 

80% and demonstrate satisfactory 

performance for initial qualification and requalification 

Data Precision: 194.22, b, (2) a measure of the mutual 

agreement between comparable data gathered or developed under similar conditions, expressed in terms of a standard deviation WCPIP: – maintained by reconciling any 

discrepancies between 2 operators (or operator and ITR) with regard to physical form of waste, absence of residual liquid Data Representativeness: 194.22, b, (3) the degree to which data 

accurately and precisely represent a characteristic of a population, a parameter, variations at a sampling point, or environmental conditions WCPIP: – Contents placed in a container will 

be described on the data forms 

Data Completeness: 194.22, b, (4) a measure of the amount of 

valid data obtained compared to the amount that was expectedWCPIP: – Relevant waste information must 

be collected and documented on a videotape 

Y Data Accuracy: 

This QAO was met by using qgenerate and review the VE dData Precision: This QAO was met by the two signing the data sheets. CCP situation where the two operatdifference in what data should also the ITR, discusses and rediscrepancies with the operatoData Representativeness: To ensure that the Data Reprethe VEE reviewed the visual reach container in the batch thaassociated with it. The SPM cthe item descriptions to ensure Data Completeness: The VEE determined that the met by reviewing the data sheinformation is present in each Data Comparability: Data Comparability QAO was training procedure (CCP-QP-0and VEE were fully qualified. was documented in the VEE aCards. 
Revision No.: 3 VE-8 

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspection 

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

and/or data form or other unalterable media Data Comparability: 194.22, b, (5) a measure of the confidence 

with which one data set can be compared to another WCPIP: – ensured by site meeting training 

requirements and complying with the minimum standards used to implement VE 

RHVE-10 VE as a method to qualify AK data 

WCPIP, Rev. 0D, Sections 4.3, 4.3.3 

194.24, c, (4) – demonstrate that a system of controls has been and will continue to be implemented to confirm that the total amount of each waste component that will be emplaced in the disposal system will not exceed the upper limiting value or fall below the lower limiting value described in the introductory text of paragraph (c) of this section. If VE is used as a qualification method for AK all of the requirements in section 4.3 and 4.3.3 are met: • Quality and reliability of the 

measurement control program under which the data were generated (QC samples included in the VE process) 

• Extent to which the data demonstrate the 

properties of interest (VE process 

generates data for all items in containers) 

• Qualification of personnel generating 

data (training records for personnel on tapes performing the original VE event) 

• Technical adequacy of the procedures 

used to generate the original data (copies 

Y • CCP uses two (2) qualifie

procedure to generate VE 

• The data sheets in BDR # 

revised approximately twVE examinations. This recontainer inventories beinreviewed by EPA at the ti

contained complete conta

• The two operators that ge

BDR (RHINLVE60001) inspection were qualified examination when they grecords for the three (3) ocomplete and available fo

• Procedure CCP-TP-500, R

performing VE by review 

recordings. The procedur
Revision No.: 3 VE-9 

ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLIST 

EPA Inspection No.: EPA-ANL-CCP-RH-9.06-8 Inspection 

Establishment of Required 

Technical Elements in 

Procedures 

Y/N 

Location Execution of Procedures Y/N Objective Evi

of original procedures) 

RHVE-11 CCP-AK-ANLE502, Rev. 0, 

Section 3.2 

Verify from the packaging records which smaller cans were placed into any particular container. 

Y Packaging records are include

container. 

Objective evidence:

1. BDR # RHANLVE06000

RHVE-12 WCPIP, Rev. 

0D, Section 2.2.3.2 

DQO for Physical Form – “Generator sites must determine the uncertainty in the estimate of the weight of the waste.” 

Y CCP SPM stated that this will 

information is entered into WW

WWIS modules are not compincluded in the scope of this inAll WMPs for debris waste w

plastic as required by the WCP
Attachments B.1 through B.3 
 

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

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. Failure 

to document this process in the procedure may lead to inconsistent and undocumented methodologies being 

used for this calculation. 

CCP Response: CCP will initiate the process to remove this requirement in the procedure to determine the 

WMP weights. The requirement is self-imposed in the procedure is not required by the PIP or the WAP. 

2. ITR is required to review all manual calculations but WMP weight calculations are not reviewed nor is 

the need to review the item contained in any ITR checklist. Failure to do so removes the only required 

check on the calculation on which WMPs quantities are based. 

CCP Response: Based on resolution to comment 1, the 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 Examination Data Form” items without the knowledge necessary 

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 answer this question. Confirmation of waste stream 

description is essential to AK confirmation as required by 40 CFR194.24 (c). Operator is responsible to 

decide if the drum examined is part of the waste stream. 

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 items seen on the video. This table is more detailed than 

Section 2.0, Waste Stream Description and, therefore, the operators were adequately verifying that the

waste items were consistent with the waste stream description. However, when the operators were asked

the question with respect to the text description given in Section 2.0, they did not give a crisp clear 

explanation. Based on the comment, CCP will provide additional training to the operators. 

B. Regulatory Reference: 40 CFR 194.24 (c) 
 

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

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 sites, 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 
 

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

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 #RHANLVE060001 was signed off on July 19, 2006. The ITR 

signed off on the checklist on July 19, 2006, however, it was then corrected to reflect the “complete 

inventory” requirement on August 25, 2006. 

CCP Response: The ITR initiated the change after he fully understood the expected criteria of “complete 

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 
 

***DRAFT*** 

Upon further analysis, the EPA issue presented here may be 

included in the EPA Inspection Report as an EPA Finding or 

Concern and can be the basis for EPA approval/disapproval

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 percentage of waste containers 

which require reassignment to a new SCG and new waste 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 waste 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 among those documents 

requiring revision when the latest revision of the WCPIP is approved. Revision of the AK Accuracy Report 

to address the above requirements may be done at that 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/A 
 

Attachment C 

EPA’s Response to Public Comments 
 

C-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 characterization program implemented by 

CCP at ANL and INL (71 FR 65488, November 8, 2006). 

All comments are reproduced here along with EPA’s response to each comment. Both ANL and 

INL Baseline Inspection Reports have been revised to reflect EPA’s response, where appropriate. 

Comment No. 1: On page 65490 of the Federal Register (FR) Notice in the 3rd column it 

references “EPA INL CCP RH Inspection Report A-98-42, II-A4-69” and the correct reference is 

A-98-49. In addition, on page 65492 of the same notice in the 1st 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 itself. 

Comment No. 2: EPA is using the Tier I and Tier II change notice process to collect additional 

information regarding a site’s waste characterization program. See Comments 9 and 10 below. 

The Tier change process is designed to notify the EPA of changes or expansions to programs 

subsequent to a Baseline Compliance Decision, not to 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 194.4(b)(2). 

Response: By requiring INL-CCP and ANL-CCP to notify EPA of the availability of new 

or additional information generated following the EPA’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 characterization 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 evaluated during the baseline and 

follow-up inspections. 

EPA’s baseline inspection approvals are not contingent on review of any additional 

information. EPA agrees that T2 reports are intended to report changes to approved 

waste characterization programs. Also, T2 change reports are not the appropriate 

mechanism to generate new information that would assist in evaluating continuing 

compliance. As described in EPA’s final modification to 194.8(b) (69 FR 42571, July16, 

2004), EPA uses its authority under §194.24(h), when it is necessary, to generate new or 

additional information to ensure continued compliance with EPA regulations. When 

reporting T2 changes reflecting updates or addition of new information to the material 

inspected during the baseline inspections, EPA expects the RH site to provide a brief 
 

C-2 

description of additions/updates to various AK and DTC documents. EPA can then 

decide whether review of this additional information under the authority of §194.24(h) is 

warrented for evaluating adequacy and continued compliance with regulatory 

requirements. EPA then will request such information. EPA have made appropriate 

modifications to the INL and ANL final baseline inspection reports to clarify our intent. 

Comment No. 3: DOE is unclear as to the reasoning that the addition 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 Baseline, 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 RH 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 the 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 identified a new RTR process at an 

approved site as a T2 change because we had evaluated the CH RTR process during 

baseline inspections at all CH sites. 

Comment No. 4: There are a number of inaccuracies in the Inspection 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 Documents Reviewed identifies 19 

containers in VE Batch Data Report (BDR) RHINLVE60001, 17 of which were 

subject to a CCP Non Conformance Report (NCR). Actually, 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 personnel 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 report 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 proposed for approval in November 

2006. (For additional discussion, see EPA’s response 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 authority 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 characterization processes are approved. The CBFO 

recommends that the EPA remove any waste stream specific approvals from process approvals 

and add an item 4 specifically detailing which waste streams are approved, as follows: 
 

C-3 

(4) Waste Stream No. ID-ANLLE-S5000 is approved for 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 Inspection Report No. 

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

Response: Waste characterization processes may change depending on the complexity of 

different waste streams. Therefore, until the RH sites generate and apply detailed 

procedures for the derivation/generation of scaling factors and other critical radiological 

characterization inputs from the analytical data and AK records, EPA must restrict its 

approval to waste streams that have demonstrated compliance during the baseline 

inspection and cannot approve entire waste categories 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 believe it is premature for EPA to 

approve the DTC process until the RH sites develop procedure(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 waste characterization programs 

initially, EPA approval was also limited to specific waste streams. The reason for a 

limited approval was that both characterization activities 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 able to approve summary waste 

categories. EPA expects that as RH waste characterization programs mature and gains 

confidence in the sites’ ability to implement the RH WCPIP and comply with regulatory 

requirements as additional waste streams are characterized, we may be able to approve 

RH waste by Summary Waste Categories. The experience gained would then justify such 

an approval and could support moving from more restrictive tiering of waste streams to 

broader approvals of RH summary waste categories. 

INL-CCP and ANL-CCP provided EPA several AK documents (CCP-AK-INL-500, CCPAK-INL-501 and CCP-AK-INL-502) that described the results 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 characterization 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 could perform the task in the same 

manner prospectively. The technical calculations and data handling that were performed 

to assess AK in support of the generation of radionuclide scaling factors were complex 

and were appropriately presented to EPA during inspection interviews and in the form of 

approximately 36 calculation packages. The calculation packages contained 
 

C-4 

considerable detail and represent the primary documentation 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 concentration 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 evaluated 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 develop 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 give a broader approval of a DTC 

process that can be applied to a waste category. 

With respect to AK, EPA does not distinguish between parts of the AK process because 

INL-CCP and ANL-CCP use AK for a continuum of characterization activities, from data 

collection through modeling and scaling factor development. The only measurement part 

of the characterization process, i.e., DTC, occurs well 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 and 8.2 of the final INL and ANL 

baseline inspection reports. Both EPA and CCP’s experience to date is limited for RH, 

i.e., essentially one waste stream at two sites, INL and ANL. As additional waste streams 

are brought forward, the need for Tier 1 change designation can be reevaluated and a 

tier adjustment could be made through the process identified in 40 CFR 194.8.

Comment No. 6: Section III.A.(1) of the Federal Register Notice references the June 1, 2006 

version (Revision 2) of CCP-AK-INL-500. Though this revision of the report was reviewed 

during the June inspection, Revision 3 of this report (dated July 7, 2006) addressing comments 

made during this inspection was presented and reviewed 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 report EPA has made 

appropriate changes to reflect Revision 3 that addresses EPA comments on the initial AK 

report made during the baseline inspection. 

Comment No. 7: Section III.A.(1) of the Federal Register Notice, and 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, 2006.” 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 debris 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 packaging. There is no further distinction 

made in this waste stream inventory. The designation of “lots” has no relevance in the 

characterization and certification process and should be deleted. As described in CCP reference 

C350 prepared for EPA during the inspections, CCP determined, and EPA agreed, that further 

segregation of the waste stream into lots based on the radiological characterization performed by 
 

C-5 

ANLE was not appropriate. References to “lots” occur 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 in “lots” by INL (and 

therefore EPA examined this historic data by the groupings provided by CCP), but EPA 

does not expect CCP to characterize this waste stream 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 characterization 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” because the references examined 

present the information in this fashion. Appropriate 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 states: “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 use of VE process for this waste until 

further notice. If CCP decides to use VE in the future, EPA inspection and approval is 

necessary.” This citation is incorrect. CCP used the VE process to characterize a total of 70 

drums of retrievably-stored RH debris waste where the 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 processes 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 processes. . .” Nowhere does the Agency’s 

mandate require or allow for the approval by EPA, on 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 eight drums) for shipment to WIPP, the Agency 

is usurping the authority of the Department of Energy (the Certifying Authority for Waste 

Characterization Activities) to approve drums for shipment 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 process but has arbitrarily restricted its use to eight 

drums. 

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

as follows: 

The VE process as defined in CCP-AK-INL-502, Central Characterization Project RH 

TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation Test 
 

C-6 

Plan for INL RH Waste Stream ID-ANLE-S5000 and implemented 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 Inspection No. EPA-INL-CCP-RH-6.06-8. 

DOE CBFO agrees the language in the VE Tiering designation in Table 2 of the Federal Register 

Notice correctly indicates what was inspected and should be approved regarding the VE process. 

DOE CBFO requests that Table 1 in the FR and the corresponding 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 recorded on audio/visual media), 

interviews with VE personnel, and review of VE personnel 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) process. 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 radiography (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 review using a better monitor. Upon 

the review of the video records for these drums, CCP revised the associated BDRs and 

after using a modified VE process (with a better monitor) CCP concluded that 60 of the 

70 containers are eligible for disposal at WIPP. DOE 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 WIPP 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 of 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 information 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 period 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 process an EPA inspector will complete a 

review of the modified VE process. CBFO will be notified of EPA’s decision, regarding 

the VE of additional drums in the waste stream. EPA’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 appropriate 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 data assembled for each drum can 

be performed to determine, in some detail, the estimated radiological content of each lot, 

recognizing that the process to develop an accurate and complete picture requires 

analysis well beyond that performed by the generator site, ANL-E (see item (1) above, 

and reference C350). This activity is also an alternative 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 and 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 could bring considerable uncertainty to 

this approach (see reference C350). This alternative 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 requests 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 comparing 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 neither 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 applicable 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 was to better understand the 

relationship between the results of the proposed characterization 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 characterized 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 has changed the T2 change to require 

the site to notify EPA when this data set is available. 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 believes that a comparison may provide 

additional insight regarding AK accuracy and help to better understand the variability of 

the characterization data, not to find a means to criticize INL-CCP’s characterization 

approach for this waste stream that this report approves. EPA has made the appropriate 

clarifications to the INL and ANL final baseline inspection reports to reflect this 

explanation. 
 

C-8 

Note that the DTC process evaluated by EPA during the 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 Inspection 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 rates 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 document 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 spectrometry 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 isotopic 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 Report 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 counterpart. The CSS could also 

add valuable information because it would provide actual assay measurement data. 

Accordingly, EPA requires that the site provide notification, 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 characterization 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 necessary, to evaluate new or additional 

information to ensure continued compliance with regulatory 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 containers 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 ratios 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 inconclusive. EPA also understands the 

potential for variations in the isotopic ratios between containers. We do not necessarily 

consider that such variations would be problematic. 

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

that NDA will not be used “because of workers’ health concerns.” This entire sentence should 

be deleted. The DTC technique is an approved technique that is being implemented at this site 

and there is no reason for addressing why another technique is not being used. 
 

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Response: We concur, the final report the text has been revised 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). This 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 not 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 containers. EPA has renamed the 

waste characterization process as “VE of audio/video media” in the Tiering tables in the 

Executive Summary and Conclusion sections of the report. 

Following the June 2006 baseline inspection, DOE provided 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 change. (For additional discussion, 

see Response to Comment No. 8, above.) Upon completion of the T1 evaluation, EPA 

may issue an approval of the modified VE process and 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 containers 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/video media records for RH waste 

containers at INL, its implementation will be subject to theT1 change procedures 

requiring EPA notification and approval prior to implementation. 

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 Inspection Report A-98-49, II-A4-70 identifies 

“...Comparison of AK versus DTC-derived radiological data 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 Report:

The stated purpose of the method employed by Argonne to estimate the radiological 

composition in individual waste containers was to address site accountability 

requirements and to comply with the maximum allowable fissile content of RH TRU 

drums. While the Argonne reported radiological content of containers in this waste 

stream was used to support the CCP waste stream delineation, RH, and TRU 

determinations, the Argonne methodology did not produce results adequate for the 

purposes of WIPP certification. For this reason, it is not appropriate to compare the 

Argonne estimates to the results of the CCP radiological characterization activities in AK 

accuracy evaluations. 
 

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For this reason, the level of accuracy can not be determined by comparing the DTC results to 

those previously estimated by ANLE and this stipulation should be deleted from the cited Tables 

and the text of the Inspection Report A-98-49, II-A4-70. 

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 WC process-T1 changes are identified for 

the addition of containers to the existing waste streams. Addition of containers to the existing 

waste streams should not be considered a change unless the addition of the containers changes 

the characteristics of the waste stream, which would 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 characterization data; 

that function is the sole responsibility of the site 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 characterization 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, 6th

paragraph) “Any changes to the WC activities from the date of the 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 tables, 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 (including scaling factor 

development, etc.) through interviews and evaluations that were applicable to a small 

sample size. It is quite possible that “new” containers would require a different approach 

to scaling factor development following a process that EPA has not inspected or 

examined. Therefore, addition of containers to the waste stream requires EPA 

notification to ensure that CCP has implemented a process 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 documented 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 prudent to limit the approval to the 

waste stream evaluated during the baseline inspection, 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 Characterization Program Implementation 

Plan (WCPIP). CBFO assumes that EPA is referring to the primary AK documents referenced 
 

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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 Summary is prepared and includes 

information pertinent to EPA compliance, EPA must be 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 appropriate clarifications to the INL and 

ANL final baseline inspection reports. 

Comment No. 16: Delete the wording: “or the use of the high range 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. Use 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 authorized 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 use 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-scale 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 neither calibrated nor source 

checked. INL-CCP personnel stated that there was no intention of using this probe in 

the foreseeable future. 

CCP-TP-504 states that, prior to use, the high range 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 such an operation would be considerably 

different from the operation observed during the inspections, and EPA wants to know 

about this in advance and have the opportunity to evaluate it prior to or during its 

application.