DOCKET NO: A-98-49; II-A4-118 

WASTE CHARACTERIZATION REPORT 

TIER 1 CHANGE: 

EVALUATION OF VISUAL EXAMINATION TECHNIQUE (VET) FOR 

REMOTE-HANDLED TRANSURANIC (RH TRU) WASTE AT 

IDAHO NATIONAL LABORATORY CENTRAL CHARACTERIZATION PROJECT 

(INL-CCP) 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

September 2009
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1.0 INTRODUCTION 

This report approves a Tier 1 (T1) change to the remote-handled (RH) transuranic (TRU) waste 

characterization (WC) program implemented by the Central Characterization Project (CCP) at 

the Idaho National Laboratory (INL). 

In accordance with 40 CFR 194.8(b), in 2006, the U.S. Environmental Protection Agency (EPA) 

inspected for a baseline approval INL-CCP’s RH TRU WC program. In January 2007, the EPA 

initially approved this program, which included visual examination (VE) of a limited number of 

RH debris waste containers (see EPA Air Docket No. A-98-49; II-A4-72). Soon after the 

January 2007 baseline approval of the INL-CCP’s RH program, EPA approved the use of VE for 

characterizing any additional RH debris waste or other TRU Summary Waste Categories (i.e., 

solids and soils/gravel) from INL as a T1 change. 

In July 2009, the Carlsbad Field Office (CBFO) verbally requested that EPA review a proposed 

T1 change in the form of adding Visual Examination Technique (VET) to the approved INLCCP RH TRU WC program. On August 11, 2009, EPA performed a T1 inspection of INLCCP’s implementation of VET for RH TRU wastes onsite at INL. This report presents the 

results of this T1 evaluation. EPA determined that the procedure and processes used at INL-CCP 

for VET of this waste stream were adequate and no concerns were identified. EPA, therefore, 

approves this T1 change. 

2.0 PURPOSE OF TIER CHANGE EVALUATIONS 

Certain changes to the WC activities from the date of the site’s baseline inspection must be 

reported to and, if applicable, approved by EPA according to the tiering requirements set forth in 

40 CFR 194.8 regulations and incorporated in the INL Baseline Final Report cited above. 

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, Federal Register notice, 

EPA must perform a single baseline inspection of a TRU waste generator site’s WC program 

(Vol. 69, No.136, pages 42571–42583, July 16, 2004). The purpose of EPA’s baseline 

inspection is to approve the site’s waste characterization program, based on 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. 

Following EPA’s baseline approval, EPA is authorized to evaluate and approve changes, if 

necessary, to the site’s approved waste characterization program by conducting additional 

inspections under the authority of 40 CFR 194.24(h). Changes requiring EPA notification and 

approval prior to implementation (T1) and those requiring post-implementation (Tier 2 or T2) 

notification are identified in the site-specific baseline inspection reports. When evaluating 

proposed T1 changes for approval, EPA may conduct a site inspection to observe first-hand the 

implementation of the change, or can opt to conduct a “desktop” review of information provided 

specific to a change. DOE may choose to characterize and dispose of, at risk of subsequent EPA 

disapproval, any previously-approved TRU waste using processes/procedures/equipment 
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implemented as T2 changes. EPA reviews T2 changes on a quarterly basis. EPA may conduct a 

continued compliance inspections to evaluate implemented T2 changes to verify adequacy 

3.0 SCOPE OF REVIEW

This T1 change review included the evaluation of information supporting the WC technique of 

VET for RH TRU wastes characterized at INL-CCP, in accordance with procedure CCP-TP-500, 

CCP Remote-Handled Waste Visual Examination, Revision 8. 

4.0 EVALUATION TEAM 

This evaluation of VET was performed by Lindsey Bender and Dorothy Gill. A complete listing 

of all individuals who participated in this T1 evaluation is provided in Table 1. 

Table 1. Evaluation Team 

Inspection Team Member Affiliation 

Lindsey Bender EPA 

Dorothy Gill S. Cohen & Associates, Inc. 

Tom Clements CWI-RH-TRU Project 

Alan Jines DOE-ID 

Rhett Bradford CTAC (CBFO Observer) 

Bruce LaRue DEQ INL Oversight Project 

Porf Martinez CTAC 

Greg Smith WTS/CCP 

Spencer Pattee WTS/CCP 

Keith Farmer CWI-RH-TRU Operations 

Irene Quintana WTS/CCP 

 

5.0 T1 EVALUATION: VET OF RH WASTE 

On August 11, 2009, EPA performed a T1 inspection of VET at INL-CCP. EPA reviewed the 

VET procedures and processes INL-CCP used for examination of RH TRU waste. The CCP 

VET procedure CCP-TP-500, CCP Remote-Handled Waste Visual Examination, Revision 8, was 

evaluated to ensure that it contained adequate operational instructions for the generation of VET 

data. EPA determined that this procedure was adequate for performing VET of RH waste. 

During the onsite inspection, EPA observed part of packaging and performance of VET of the 

contents of a 55-gallon drum, container No. IDAWAML88-064, whose contents were to be 

repackaged into two 30-gallon containers. The two 30-galllon containers were designated as 

Nos. IDAWAML88-064A and IDAWAML88-064B, and EPA observed part of the VET process 

and subsequent packaging for container No. IDAWAML88-064A. These containers were part of 

debris waste stream ID-MFC-S5400, which consists of four drums. Two Visual Examination 

Operators (VEOs) and one Visual Examination Expert (VEE) performed the VET event in Hot 

Cell 308 housed in Building CCP659. INL-CCP personnel manipulated and packaged the waste 

after VET had been completed for each waste item. One VEO observed the process through a 

hot cell window and identified each item before it was placed into the 30-gallon receiving 

container. This VEO called out waste identification information and a second VEO repeated the 
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identification information to ensure correct transfer of data. The second operator then manually 

entered the waste identification information and Waste Material Parameter (WMP) of the item 

on Attachment 1, Visual Examination Data Form, from procedure CCP-TP-500. Cameras in the 

hot cell enabled the second VEO to visually verify the first VEO’s identification. The receiving 

container was verified as empty at the start of the examination before waste was placed into it. 

The second VEO used a paper copy of procedure CCP-TP-500 to guide the process and had a 

copy of the appropriate Acceptable Knowledge Summary Report, so that the correct placement 

of containers in Waste Stream ID-MFC-S5400 could be verified. A VEE is present at every 

VET event to provide support and direction to the VEOs, if needed. 

EPA verified that the two VEOs and the VEE performing the demonstration were listed on the 

current List of Qualified Individuals (LOQI) and, therefore, were qualified to perform the 

examination in accordance with INL-CCP requirements. Additionally, EPA reviewed the 

training records for the two VEOs in the form of Qualification Cards and the letter of 

appointment for the VEE. All training records were determined to be complete. 

A completed Batch Data Report (BDR) for this waste stream was not available for review, 

because it consists of only four containers. The first container examined from this BDR was 

rejected by INL-CCP, and the demonstration drum was the second to undergo VET. However, 

EPA did review BDR No. RHINLVE090002, which contained drums from a different waste 

stream that had been examined using the same processes inspected by EPA during this onsite 

visit. The BDR had undergone data generation and project level review. VET personnel had 

generated a non-conformance report (NCR) as required, and all data sheets were complete and 

signed by both VEOs. 

6.0 FINDINGS OR CONCERNS 

EPA did not identify any findings or concerns associated with this T1 evaluation. 

7.0 CONCLUSION 

EPA determined that the procedure and processes used at INL-CCP for VET of this RH TRU 

waste stream were adequate, effective, and implemented appropriately. No findings or concerns 

were identified, and EPA approves this T1 change.