30 

verified through confirmatory sampling. For wastes that were generated from November 1991 

through February 2007, as defined in CCP-AK-ORNL-501, the use of AK to determine DQOs 

was acceptable and meets the fundamental intent of the WCPIP. 

Summary of AK Findings and Concerns

The EPA inspection team identified one concern related to AK that is discussed above. A copy 

of the EPA Inspection Issue Tracking Form is provided in Attachment A-4. EPA considers this 

concern to have been adequately addressed, and there are no open findings or concerns related to 

AK resulting from this inspection. 

Baseline Approval

EPA is approving the AK process evaluated during this baseline inspection. This approval is 

limited to retrievably-stored debris wastes that are currently stored at ORNL and will be 

repackaged into 55-gallon drums, and were generated between November 1991 and February 

2007 in the REDC, as defined in CCP-AK-ORNL-500 Revision 0. 

AK Tiers

T1 AK changes will require EPA review and approval prior to implementation, and will apply to 

any new waste category not evaluated during the baseline inspection. These include the 

following: 

• Any new waste streams including pre-1991 RH debris waste not approved under this 

baseline 

• Modification of the approved population of the OR-REDC-RH-HET wastes as defined 

above, to include any containers not included in the CCP-AK-ORNL-501, Revision 1 

analysis 

• Modification(s) or current revisions of: 

o CCP-AK-ORNL-500 (AKSR) 

o CCP-AK-ORNL-501 (Radiological Characterization) or CCP-AK-ORNL-502 

(CTP) 

o AK Accuracy Reports 

o Correlation and Surrogate Summary Form 

o The Waste Stream Profile Form to accompany any modification of the ORREDC-RH-HET population proposed for approval 

• Implementation of load management for any ORNL RH waste stream 

ORNL-CCP must report and submit documentation on T1 changes when it is ready for EPA 

review. Upon initial review, EPA will inform ORNL-CCP and CBFO whether a site inspection 

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

and/or confer with ORNL-CCP personnel. Upon evaluation with or without a site inspection, 
48 

VE must be performed by two trained and qualified visual Examination Operators (VEOs), as 

described in procedure CCP-TP-500. 

Documents, BDRs, and Objective Evidence Reviewed

The following documents were among those the EPA reviewed to assess whether VE operations 

follow the appropriate approved procedures and meet VE requirements: 

• CCP-TP-500, CCP Remote-Handled Waste Visual Examination, Revision 7, 

February 27, 2008 

• CCP Standing Order, CCP-SO-ORNL-003, Documentation of Liner Information in the 

Final Container from Remote-Handled (RH) Visual Examination (VE) at ORNL, 

Revision 0, May 14, 2008 

• CCP-QP-002, Training and Qualification Plan, Revision 26, February 7, 2008 

• CCP-AK-ORNL-502, RH Waste Certification Plan for 40 CFR Part 194 Compliance and 

Confirmation Test Plan for ORNL REDC RH Waste, Waste Stream OR-REDC-RHHET, Revision 0, May 22, 2008 

• CCP-TP-509, Remote-Handled Transuranic Container Tracking, Revision 1, June 2, 

2008 

• CCP-QP-005, TRU Nonconforming Item Reporting and Control, Revision 16, May 7, 

2008 

• CCP-QP-008, Records Management, Revision 14, September 19, 2007 

Following is a complete list of all objective evidence that the EPA inspection team evaluated 

during the inspection: 

• Visual Examination BDRs RHORVE080001, RHORVE080002, RHORVE080003, 

RHORVE080004 

• NCR-RHORNL-0001-08 

• List of currently qualified VE personnel 

• Qualification card and training records for the Visual Examination Expert (VEE) 

• Letter appointing the VEE, May 02, 2007 

• Qualification cards and training records for two Visual Examination Operators (VEOs) 

• Required Reading Report, CCP-AK-ORNL-500 Training 
49 

Technical Evaluation

(1) Overall procedural technical adequacy and implementation were assessed and found to be 

adequate. 

The VE procedure was documented in CCP-TP-500, Revision 7 and it contained specific 

information on performing VE, including identification of prohibited items, assignment of 

WMPs, and technical review of VE results. During the VE demonstration, it was noted that the 

actual processes for WMP identification and data recording differed from what had been 

observed at Argonne National Laboratory (ANL) during a T1 evaluation (see Docket No. A-98-

49; II-A4-102). At the ANL T1 RH VE evaluation, EPA generated a formal concern, because 

the operational steps taken by the VE operators (VEOs) were not described in CCP-TP-500, the 

operating procedure that controlled this activity. EPA presented this as a concern on an EPA 

Inspection Issue Tracking Form, as discussed below (see Attachment A.4 of this report for a 

copy of this form). 

EPA Inspection Issue Tracking Form, Issue No. ORNL-CCP-RH-VE-08-004CR: During 

EPA’s T1 inspection of RH VE operations at ANL, Concern EPA-ANL-CCP-RH-VE/T1-08-

001C was generated because the operational details of how the VEOs identified and recorded 

data were not included in the VE operating procedure CCP-TP-500, Revision 7. ORNL-CCP’s 

explanation was that operators were trained to perform these operational steps and they did not 

need to be included in the procedure. During the demonstration of VE at ORNL-CCP, the 

operational steps executed by the VEOs were totally different than those observed at ANL and 

were not contained in procedure CCP-TP-500, Revision 7. To ensure consistency of operations 

among all the CCP sites that use VE for RH TRU wastes, CCP-TP-500 must be revised to 

include how VEOs identify and record waste items and WMPs during VE. 

Resolution: CBFO’s response stated that they consider the written VE procedure to be 

adequate, because it is supported by operator training. EPA accepted this determination because 

all waste WMPs are reported as “plastic” for RH TRU debris waste. 

Status of Concern: This concern is closed. 

VE as performed by two trained VEOs is suitable for Waste Stream OR-REDC-RH-HET, 

retrievably-stored RH TRU S5000 debris waste, as documented in CCP-TP-500, Revision 7. 

Any change to a VE procedure(s) that requires CBFO approval is a T2 change. (See Table 1, 

where this is included as a T2 change.) 

(2) Characterization of WMPs and prohibited items was evaluated and was found to be 

adequate. 

During the inspection, EPA observed VE of debris waste (S5000) removed from Cask No. 

X10C061826 and repackaged into container No. ORRH00015. This demonstration took place in 

TWPC Building 7880 hot cells. Prior to beginning the VE, the operators verified that the cask 

was on the AK tracking spreadsheet and was eligible for processing. An audio/visual recording 

of the VE was not required, because two VEOs performed the examination. The VEE was also