**30**

**verified through confirmatory sampling. For wastes that were generated from November 1991**  **through February 2007, as defined in CCP-AK-ORNL-50 1, 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 rela ted to AK that is discussed above. A copy**  **of the EPA Inspection Issue Tracking Form is provid ed in Attachment A-4. EPA considers this**  **concern to have been adequately addressed, and ther e are no open findings or concerns related to**  **AK resulting from this inspection.**

Baseline Approval

**EPA is approving the AK process evaluated during th is baseline inspection. This approval is**  **limited to retrievably-stored debris wastes that ar e 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 Rev ision 0.** 

AK Tiers

T1 AK changes **will require EPA review and approval prior to impl ementation, and will apply to**  **any new waste category not evaluated during the bas eline 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-R EDC-RH-HET wastes as defined**  **above, to include any containers not included in th e 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 modi fication of the OR**  **REDC-RH-HET population proposed for approval**

• **Implementation of load management for any ORNL RH w aste 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 informati on, choose to conduct a desktop review,**  **and/or confer with ORNL-CCP personnel. Upon evalua tion with or without a site inspection,** **48**

**VE must be performed by two trained and qualified v isual Examination Operators (VEOs), as**  **described in procedure CCP-TP-500.**

Documents, BDRs, and Objective Evidence Reviewed

**The following documents were among those the EPA re viewed to assess whether VE operations**  **follow the appropriate approved procedures and meet VE requirements:** 

• **CCP-TP-500, CCP Remote-Handled Waste Visual Examina tion, 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 Exa mination (VE) at ORNL,**  **Revision 0, May 14, 2008**

• **CCP-QP-002, Training and Qualification Plan, Revisi on 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, Wast e Stream OR-REDC-RH**  **HET, Revision 0, May 22, 2008**

• **CCP-TP-509, Remote-Handled Transuranic Container Tr acking, Revision 1, June 2,** 

**2008**

• **CCP-QP-005, TRU Nonconforming Item Reporting and Co ntrol, Revision 16, May 7,** 

**2008**

• **CCP-QP-008, Records Management, Revision 14, Septem ber 19, 2007** 

**Following is a complete list of all objective evide nce 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 Vis ual Examination Expert (VEE)** 

• **Letter appointing the VEE, May 02, 2007**

• **Qualification cards and training records for two Vi sual Examination Operators (VEOs)** 

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

Technical Evaluation

**(1) Overall procedural technical adequacy and implement**  **ation were assessed and found to be adequate.** 

**The VE procedure was documented in CCP-TP-500, Revi sion 7 and it contained specific**  **information on performing VE, including identificat ion of prohibited items, assignment of**  **WMPs, and technical review of VE results. During t he VE demonstration, it was noted that the**  **actual processes for WMP identification and data re cording differed from what had been**  **observed at Argonne National Laboratory (ANL) durin g 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 (VE Os) 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, Con**  **cern 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 procedur**  **e CCP-TP-500, Revision 7. ORNL-CCP’s explanation was that operators were trained to perf**  **orm these operational steps and they did not need to be included in the procedure. During the d**  **emonstration 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, Revisio**  **n 7. To ensure consistency of operations among all the CCP sites that use VE for RH TRU wast**  **es, CCP-TP-500 must be revised to include how VEOs identify and record waste items an**  **d WMPs during VE.**

Resolution: **CBFO’s response stated that they consider the writt en VE procedure to be**  **adequate, because it is supported by operator train ing. 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 do cumented 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 e**  **valuated and was found to be adequate.** 

**During the inspection, EPA observed VE of debris wa ste (S5000) removed from Cask No.**  **X10C061826 and repackaged into container No. ORRH00 015. This demonstration took place in**  **TWPC Building 7880 hot cells. Prior to beginning t he 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 perfor med the examination. The VEE was also**