EPA DOCKET NO. A-98-49, II-A4-121 

 

WASTE CHARACTERIZATION INSPECTION REPORT 

EPA UNANNOUNCED CONTINUED COMPLIANCE INSPECTION 

EPA-ORNL-CCP-CH-RH-UA-06.09-24 

OF THE CENTRAL CHARACTERIZATION PROJECT 

 WASTE CHARACTERIZATION PROGRAM 

AT THE OAK RIDGE NATIONAL LABORATORY 

 

June 24–25, 2009 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

November 2009
i 

CONTENTS 

1.0 Introduction ......................................................................................................................... 1

2.0 Inspection Purpose .............................................................................................................. 1

3.0 Inspection Scope ................................................................................................................. 1

4.0 Background ......................................................................................................................... 2

5.0 Personnel ............................................................................................................................. 2

6.0 Performance of the Inspection............................................................................................. 3

6.1 Radiological Characterization................................................................................. 4

6.1.1 Evaluation.................................................................................................... 4

6.1.2 Concerns...................................................................................................... 7

6.1.3 Conclusion................................................................................................... 7

6.2 Real-Time Radiography (RTR) for CH TRU Wastes............................................. 7

6.2.1 Evaluation.................................................................................................... 7

6.2.2 Concerns...................................................................................................... 7

6.2.3 Conclusion................................................................................................... 8

6.3 Visual Examination (VE) for RH TRU Waste........................................................ 8

6.3.1 Evaluation.................................................................................................... 8

6.3.2 Concerns...................................................................................................... 8

6.3.3 Conclusion................................................................................................... 8

6.4 Container Management ........................................................................................... 9

6.4.1 Evaluation.................................................................................................... 9

6.4.2 Concerns.................................................................................................... 10

6.4.3 Conclusion................................................................................................. 10

7.0 Summary of Results .......................................................................................................... 10

7.1 Summary of Concerns........................................................................................... 10

7.2 Conclusion............................................................................................................. 11
1 

1.0 INTRODUCTION 

This report describes results of the U.S. Environmental Protection Agency (EPA)’s unannounced 

continued compliance inspection at the Oak Ridge National Laboratory (ORNL). On June 24-

25, 2009, under the authority of 40 CFR 194.21(a)(1), the EPA performed Inspection EPAORNL-CCP-CH-RH-UA-06.09-24, an unannounced inspection of the transuranic (TRU) waste 

characterization program of the Central Characterization Project (CCP) at the ORNL at Oak 

Ridge, Tennessee. This inspection focused on the following technical aspects of the ORNL-CCP 

waste characterization program for contact-handled (CH) and remote-handled (RH) TRU waste: 

• Radiological characterization for RH TRU wastes 

• Nondestructive examination (NDE) - Real-Time Radiography (RTR) for CH TRU wastes 

and Visual Examination (VE) for RH TRU wastes 

• Chain of custody practices including waste container certification for tracking and 

shipment of both CH and RH TRU wastes 

The EPA inspection team evaluated selected aspects of the areas listed above by conducting 

interviews with ORNL-CCP personnel, observing processes, and reviewing documents and 

records. The EPA inspection team did not identify any concerns and there are no open issues at 

ORNL-CCP as a result of this inspection. The EPA inspection team determined that the ORNLCCP waste characterization programs for CH and RH TRU wastes continue to function in 

compliance with the requirements of 40 CFR Part 194. 

2.0 INSPECTION PURPOSE 

The purpose of this inspection was to evaluate the continued compliance of the technical 

processes implemented by ORNL-CCP for characterizing S5000 retrievably stored CH and RH 

TRU debris waste. 

3.0 INSPECTION SCOPE 

The following waste characterization components of the system of controls implemented by 

ORNL-CCP were evaluated under the inspection authority described in 40 CFR 194.8(b): 

• Radiological characterization – Dose-to-Curie (DTC) measurements conducted at the 

TWPC1

 and calculation of WIPP-tracked radionuclides using scaling factors 

• NDE – RTR and VE 

• Chain of custody process including waste container certification for shipment and 

tracking of direct loaded and overpacked (due to container integrity) containers 

 

1

 TWPC is the Transuranic Waste Processing Center, the facility at ORNL where CH and RH TRU wastes are 

processed. 
2 

As part of the inspection, EPA reviewed objective evidence and verified that the ORNL-CCP 

waste characterization program continues to perform waste characterization in compliance with 

the requirements of 40 CFR Part 194. 

4.0 BACKGROUND 

EPA had conducted two baseline inspections at ORNL-CCP and these provided the basis for 

EPA’s approval of the ORNL-CCP waste characterization program for both CH and RH TRU 

wastes. Additionally, EPA approved two Tier 1 changes at ORNL for their CH waste 

characterization program; all EPA approvals of the CH and RH waste characterization programs 

at ORNL-CCP are shown in Table 1. EPA performs unannounced inspections of approved CH 

and RH TRU waste characterization programs to observe and document that the program 

continues to operate in compliance with 40 CFR Part 194. 

Table 1. EPA Approvals of ORNL-CCP CH & RH Waste Characterization Programs 

EPA Inspection Number Approval Dates CH or RH Public Docket No. 

Baseline CH Inspection ORNL-CCP-CH-11.07-8 August 2008 CH A-98-49; II-A4-103 

Baseline RH Inspection ORNL-CCP-RH-06.08-8 February 2009 RH A-98-49; II-A4-111 

Tier 1, Extension of Density Range for SGS October 2008 CH A-98-49; II-A4-108 

Tier 1, Extension of Range for IPAN/DWAS January 2009 CH A-98-49; II-A4-109 

Tier 1, Addition of S4000 Soils, Waste Stream ORNFS-CH-SOILS2

October 2009 CH A-98-49; II-A4-117 

5.0 PERSONNEL 

The EPA inspection team consisted of the personnel shown in Table 2. 

Table 2. EPA Inspection Team Members 

Name Affiliation Inspection Role 

Mr. Ed Feltcorn . EPA ORIA EPA Inspection Team Lead 

Rajani Joglekar EPA ORIA EPA Inspection Team Inspector 

Ms. Lindsey Bender EPA ORIA EPA Inspection Team Observer 

Ms. Dorothy Gill SC&A, Inc. Technical Inspector, VE & RTR 

Mr. Patrick Kelly SC&A, Inc. Technical Inspector, DTC 

The EPA inspection team interviewed and obtained information and/or inspection support from 

the ORNL-CCP, ORNL and DOE personnel listed in Table 3. 

 

2

 The ORNL CH T1 approval for soils occurred after this unannounced continued compliance inspection and is 

included for completeness. 
3 

Table 3. Personnel Interviewed During Inspection

Name Affiliation 

Ron Reeves WTS-CCP 

Pat Tilmon WTS-CCP 

Jim Moore DOE 

Bob McKay TWPC 

Fred Heacker TWPC 

J.R. Stroble DOE-CBFO 

Jeri Miles WTS-CCP 

Hillari Neely WTS-CCP 

Michael Gracey WTS-CCP 

L.A. Thompson TWPC 

Micael Sensibaugh WTS-CCP 

Joe Harvill WTS-CCP 

Jim Kopotic DOE-EM 

Shane Miles WTS-CCP 

Rick Farr DOE 

6.0 PERFORMANCE OF THE INSPECTION 

Background 

The logistics of an unannounced inspection are different from a scheduled inspection at a TRU 

generator site. Because site personnel do not know an inspection will be occurring on a given 

day, certain aspects of the site’s waste characterization program may not be available for 

evaluation. Waste characterization systems of interest to the EPA inspection may not be 

operational and key personnel may not be available, particularly since CCP personnel move 

among the DOE TRU sites and are not tied to a specific site. However, on this inspection, key 

personnel in the areas of radiological characterization, VE, RTR and container management were 

available. 

In preparation for a scheduled inspection, the EPA technical inspectors typically obtain and 

review the latest revisions of key procedures and reports in the preparation of inspection 

checklists. For an unannounced inspection, EPA technical inspectors prepare using what they 

know to be the latest revisions of these documents. However, these documents may have been 

revised or superceded without EPA’s knowledge. This may require the EPA inspection team to 

modify or adjust the inspection’s scope on short notice on site. For this inspection, for the most 

part, the operating procedures for radiological characterization, RTR and VE that the EPA 

inspection team used to prepare were the current versions. 

Logistics 

On Wednesday, June 24, 2009, at approximately 8:00 am, EPA inspectors met with ORNL 

management and ORNL-CCP staff responsible for TRU waste for a pre-inspection 
4 

conference/kick-off meeting at the TWPC located on the Oak Ridge Reservation to explain the 

inspection’s scope and provide a copy of the inspection plan. The EPA inspectors then met with 

personnel from ORNL-CCP to schedule inspection activities specific to the technical areas of 

radiological characterization, RTR, VE and container management. Following these meetings, 

the EPA inspection team personnel divided into two groups: (1) radiological characterization, 

and (2) RTR, VE, both of which were accompanied by appropriate ORNL-CCP and other 

personnel. These two technical areas were evaluated on June 24 and the morning of June 25, 

2009. In mid-morning of June 25, 2009, the EPA inspection team as a whole evaluated container 

management. A post-inspection EPA Briefing/Close-Out Meeting was held on the afternoon of 

June 25, 2008. The EPA inspection team provided an oral summary of the inspection to ORNLCCP and ORNL personnel. 

6.1 Radiological Characterization 

6.1.1 Evaluation 

The EPA inspection team evaluated three aspects of the ORNL-CCP RH radiological 

characterization program: 1) the DTC measurement process; 2) RTR of CH and VE of RH and 

3) RH and CH container tracking. 

Dose-to-Curie (DTC) Measurement

The EPA inspection team observed the dose rate measurement process in TWPC Building 7880 

during the inspection. All radiation dose rate measurements were made as described in 

CCP-TP-504 and all drum operations were controlled remotely using a series of cameras and 

manipulators. The EPA inspection team verified that the operational details of the DTC process 

had not changed since the baseline approval and observed the DTC process for container 

No. ORRH00037. The EPA inspection team addressed the following items related to DTC: 

• Was the current revision of the appropriate ORNL-CCP procedure available in the 

ORNL-CCP DTC Alcove? 

- CCP-TP-054, Revision 8, dated 4-23-09 was present and available to the DTC 

Operator. 

• Were entries in the system’s operation notebook current and appropriate for June 24, 

2009? 

- Operational Log for RH DTC, Control Number RH-DTC-ORNL-002, CY 2009, 

TWPC Building No. 7880 Process Building contained the appropriate entries as 

required by CCP-TP-504. 

• Were the appropriate gamma probes used for the DTC measurements and did each have a 

current calibration? 

- FHZ 612 Low Range Probe XC00672 and FHZ High Range Probe 177 were used and 

both had stickers indicating a current calibration.

• Was the background determination performed and recorded? 
5 

- A background of 0.094 mR/hr was recorded prior to performing DTC. 

• Were source checks performed and recorded for both probes? 

- A reading of 76.8 mR/hr was recorded for a source whose acceptance range was 66.8 

– 100 mR/hr; a reading of 1120 mR/hr was recorded for a source whose acceptance 

range was 862 – 1290 mR/hr. 

• Were four measurements taken and recorded for the RH container? 

- Four measurements of 9.1 mR/hr, 11.5 mR/hr, 8.85 mR/hr and 11.3 mR/hr were taken 

and recorded on the form from CCP-TP-504, Attachment 2. 

• Were all required surveys/checks performed, recorded and evaluated prior to beginning 

the DTC process? 

- Measurements were taken at the DTC Alcove shield door and on contact with the 

cask, a Thermo Model ESM FH 40G Ratemeter with a Model FHZ 512 probe was 

used to record the gamma dose in the DTC Alcove. 

• Was the waste container being measured during this inspection within ORNL’s approved 

waste stream? 

- Container No. ORRH00037 contained S5000 debris waste from the Post-1991 period 

of ORNL waste stream OR-REDC-RH-HET. 

• Was the appropriate scale used to determine the container’s weight and did it have a 

current calibration? 

- The scale was No. WIPP-120 with a tolerance of ± 1 kg, and it was last calibrated on 

2-15-08 and this calibration expired on 2-12-10. 

• Whether the individuals observed performing the DTC analysis during this inspection 

were qualified and listed on the current List of Qualified Individuals (LOQI)? 

- Ronald K. Whitson, Mike W. Fryeberger and Anthony Presely were all listed on the 

current LOQI; the ORNL-CCP DTC operator (M. Fryberger) recorded all required 

information in Operational Log Book RH-ORNL-DTC001 and worked from the 

current revision of CCP-TP-504. 

All aspects of the DTC process that the EPA inspection team observed were adequate. 

Calculation of Concentrations of WIPP-Tracked Radionuclides

The EPA inspection team determined that the radionuclide scaling factors that were evaluated in 

depth during the baseline inspection had not changed, with one minor exception discussed 

below. Next, the EPA inspection team examined the spreadsheet containing the radionuclidespecific scaling factors and determined that it was the correct version, ORNL DTC-Mark-HFIR, 

Version 4, Addendum 4, SCO 1000. The EPA inspection team evaluated the execution of the 

radiological characterization process as documented in DTC Batch Data Report (BDR) Nos. 

ORRHDTCC08005, ORRHDTCC08006, and ORRHDTCC09007. BDRs Nos. 

ORRHDTCC08005 and ORRHDTCC08006 contained Non Conformance Report (NCR) No. 

NCR-RHORNL-0500-09, related to an overstatement of the container’s curie content due to an 
6 

incorrect accounting for gamma scatter within the DTC Alcove. As a result of the NCR, the 

above cited two BDRs were changed and contained superceded Waste Container Dose-to-Curie 

Conversion Records. The EPA inspection team also reviewed a revision of calculation package 

Nos. ORNL-RH-23 (Revision 4), ORNL-RH-07 Revision 2), ORNL-RH-11 (Revision 4) and 

ORNL-RH-23 (Revision 4) that were prepared to address this. ORNL-CCP provided a copy of a 

memorandum dated February 2, 2009 from J. Vance that documented the nature and extent of 

the changes. All documentation was acceptable. The EPA inspection team verified that all three 

DTC BDRs contained the following information for each RH TRU container: 

• Cask number and container number 

• Waste stream designation 

• Waste net weight and material type 

• Measured dose rates from four quadrants and the calculated average dose rate in mR/hr 

• Scaling factor in curies per mR/hr 

• Activity and mass values and uncertainties for the 10 WIPP-tracked radionuclides in 

curies and grams, respectively 

• Activity and mass values and uncertainties for other TRU radionuclides (243Am, 244Cm, 

245Cm, and 246Cm) in curies and grams, respectively 

• TRU alpha activity and concentration 

• Plutonium equivalent curies (PE Ci) in curies 

• Fissile gram equivalents (FGE) in grams 

• Decay heat in watts 

• Volume activity in curies per liter 

 

The DTC BDRs and the revised calculation packages were acceptable. 

Determination of RH and TRU Status

The determinations that RH containers meet the definition of TRU wastes (TRU alpha activity 

concentration greater than 100 nCi/g) and RH waste (contact dose equivalent rate in excess of 

200 mrem/hr) were examined, as discussed below. 

TRU Determination: The three DTC BDRs that were evaluated contained values for the 10 

WIPP-tracked and other TRU radionuclides at concentrations greater than 100 nCi/g in all cases. 

Any drum whose results indicated a TRU concentration less than 100 nCi/g was accompanied by 

an NCR, as appropriate. 

 

RH Determination: The three DTC BDRs that were evaluated contained objective evidence of 

the RH determination for all containers. Any drum whose results indicated a contact dose 

equivalent rate of less than 200 mrem/hr was accompanied by an NCR, as appropriate. 
7 

Both the TRU and RH determinations were acceptable.

6.1.2 Concerns 

There were no concerns relative to any aspect of the ORNL-CCP RH radiological 

characterization process identified during this inspection. 

6.1.3 Conclusion 

The EPA inspection team concluded that ORNL-CCP continues to perform radiological 

characterization of RH TRU waste in a manner that is compliant with the requirements of 

40 CFR Part 194 and EPA’s 2007 baseline approval. 

6.2 Real-Time Radiography (RTR) for CH TRU Wastes 

6.2.1 Evaluation 

Prior to and during EPA’s on-site inspection, the EPA NDE technical lead reviewed the ORNLCCP RTR processes and procedures for examination of CH waste. Procedure CCP-TP-053, 

Revision 6, CCP Real-Time Radiography (RTR) Inspection Procedure, was reviewed to ensure it 

continued to contain sufficient operational instructions to ensure the generation of reliable RTR 

data. EPA determined the procedure to be adequate.

The EPA inspection team observed the RTR examination of drum No. X10C9313137A, 

contained in BDR OR-RTR6-0205. Two operators, L. Smith and S. Smith, performed RTR by 

reviewing an electronic image remotely while rotating the drum on the turntable and moving the 

imaging equipment vertically along the sides of the container. These actions are intended to 

provide a comprehensive assessment of the drum’s contents and the operator increased or 

decreased the x-ray device voltage to compensate for waste items with different densities. As the 

examination progressed, the operator identified and called out each waste item, which was 

confirmed by a second operator who was viewing the same RTR event on a separate screen. The 

second operator recorded waste items and the Waste Material Parameter (WMP) of each item on 

the electronic data sheet CCP-TP-053, Attachment 2. The EPA inspection team verified that the 

two operators were listed on the current LOQI and were qualified to perform the examination. 

At the conclusion of the examination, the operators verified that the waste met the waste stream 

description and Waste Matrix Code (WMC). The absence of prohibited items was recorded and 

WMP weights were estimated and recorded. 

BDR Nos. OR-RTR6-0195, OR-RTR6-0189, and OR-RTR6-0191 were reviewed for 

completeness and accuracy. All BDRs contained a valid RTR Measurement Control Report 

(Attachment 1, CP-TP-053), data sheets, completed Independent Technical Reviewer and 

completed SPM Project Level Validation Checklist and Summary. 

6.2.2 Concerns 

The EPA inspection team did not identify any concerns relative to RTR during this inspection. 
8 

6.2.3 Conclusion 

EPA concluded that CCP at ORNL continues to perform RTR examinations in a manner that is 

compliant with the requirements of 40 CFR Part 194 and EPA’s 2007 baseline approval. 

6.3 Visual Examination (VE) for RH TRU Waste 

6.3.1 Evaluation 

Prior to and during EPA’s on-site inspection, the EPA NDE technical lead reviewed the ORNLCCP VE process and procedures for examination of RH TRU waste. Procedure CCP-TP-500, 

Revision 8, CCP Remote-Handled Waste Visual Examination, is used to perform VE and the 

EPA inspection team reviewed it to verify that it continues to provide adequate and complete 

instructions. EPA did not identify any issues with this procedure. VE of RH waste is performed 

in the hot cell in Room 231, Building 7880. The VE Operators are employed by EnergX3

 but are 

trained to ORNL-CCP procedures, and they operate the hot cell manipulator arms and complete 

the required data sheet (CCP-TP-500, Revision 8, Attachment 1, Visual Examination Data 

Form). The EPA inspection team observed two operators performing VE and both were listed on 

the current LOQI. A CCP VE Expert (VEE) was present at each VE event to oversee the process 

and provide technical assistance, as needed. 

Waste was unloaded into the hot cell from casks and repackaged into 55-gallon (208-liter) 

drums. Waste from one cask may be packaged into several drums, depending on the physical 

form of the waste and other considerations. The EPA inspection team observed part of the VE 

process for drum No. ORRH00033. At the start of the VE process, the receiving drum was 

verified as being empty and it was fitted with a wide-neck funnel to facilitate waste loading and 

reduce spillage. ORNL-CCP personnel stated that the hot cell smoke detector had been isolated 

because dust generated during drum loading set off the alarm. After identification of the waste 

and agreement between the two operators regarding the pertinent waste details, the waste was 

loaded into the drum and the appropriate waste-related information was entered electronically 

into the VE data form. 

The EPA inspection team reviewed three VE BDRs, Nos. RHORVE090009, RHORVE090011 

and RHORVE090013. These BDRs were complete and had been reviewed at both data 

generation and project levels. NCR-RH-ORNL-0501-09 and NCR-RH-ORNL-0502-09 were 

associated with BDR Nos. RHORVE090009, RHORVE090011 and both NCRs had been 

dispositioned appropriately. 

6.3.2 Concerns 

The EPA inspection team did not identify any concerns relative to RTR during this inspection. 

6.3.3 Conclusion 

 

3

 EnergX is the operating contractor for the TWPC. 
9 

The EPA inspection team concluded that CCP-ORNL continues to perform VE in a manner that 

is compliant with the requirements of 40 CFR Part 194 and EPA’s 2007 baseline approval. 

6.4 Container Management 

6.4.1 Evaluation 

Prior to and during EPA’s on-site inspection, the EPA inspection team reviewed the processes 

and procedures used by ORNL-CCP to manage containers of CH and RH waste at the ORNL 

site. The EPA inspection team evaluated CH and RH wastes processes separately, as reported 

below. 

Contact-Handled (CH) Waste 

ORNL-CCP manages CH waste in accordance with procedure CCP-TP-068, Revision 5, CCP 

Container Management at the Idaho National Laboratory (INL) and TRU Waste Processing 

Center (TWCP). The EPA inspection team determined that this procedure was adequate and 

complete. As part of the inspection, EPA randomly chose two containers from the EnergX 

TWCP container list to verify that the containers were in the location specified on that list. 

ORNL-CCP does not have its own database for container tracking but uses the ORNL database, 

WICS4

. Containers are tracked by location and not by position. The EPA inspection team 

established that container Nos. X10C0506154DD and X10C9312368A were located in the 

CHMB5

 storage facility as reported on the container list. Within the CHMB facility, fully 

characterized containers that are awaiting shipment to WIPP are segregated from other 

containers by an expandable metal fence. ORNL-CCP personnel stated that waste handling 

personnel retrieving containers for shipment only take those located within the metal fence. The 

EPA inspection team verified that Hold tags had been placed on container No. X10C9311943A 

for an NDA-related NCR (NCR-ORNL-0132-09), and container No. X10C9311283A for an 

NCR related to the presence of liquids (NCR-ORNL-0636-09). Both containers were labeled 

appropriately and the documentation regarding all CH containers was adequate. 

Remote-Handled (RH) Waste

ORNL-CCP manages RH waste in accordance with procedure CCP-TP-500, Revision 2, CCP 

Remote-Handled Transuranic Container Tracking. The EPA inspection team determined that 

this procedure was adequate and complete. According to the baseline approval, ORNL-CCP is 

approved to characterize and ship wastes from RH waste stream No. OR-REDC-RH-HET that 

were generated after 1991, known as the Post-1991 or Mark 42 wastes. The EPA inspection 

team chose to verify the disposition of all RH containers from the approved portion of this waste 

stream that had been characterized and shipped to date. ORNL-CCP personnel stated that a total 

of thirty-six 55-gallon (208-liter) containers had been loaded with RH TRU wastes in the 

Building 231 Hot Cell. EPA requested a detailed break down of the disposition of these thirtysix containers and ORNL-CCP provided the following information: 

 

4

 WICS is the Waste Information Control System. 

5

 CHMB is the Contact Handled Marshalling Building at the TWPC. 
10 

• ORNL-CCP has shipped twelve containers to WIPP in three shipments of four drums 

each and these have been interred in the repository (subtotal of 12 containers). 

• Three drums were determined to not contain TRU wastes, i.e., they had TRU 

concentrations of less than 100 nCi/g, and ORNL-CCP indicated that they were classified 

as low-level waste (LLW) and they had been removed from the hot cell; this was 

appropriately noted on NCR-RHORNL-0050-09 (subtotal of 15 containers). 

• Three drums were determined to contain CH TRU wastes, i.e., they had an external dose 

rate of less than 200 mRem/hr6

 and are still in the hot cell although ORNL-CCP 

personnel stated that these would be returned to the host site; this was appropriately noted 

on NCR-RHORNL-0503-09 (subtotal of 18 containers). 

• Six containers were on hold due to an NCR related to an excessive neutron dose rate; this 

was appropriately noted on NCR-RHORNL-0502-08 and NCR-RHORNL-0504-09 

(subtotal of 24 containers). 

• Six containers were determined to belong to an earlier part of waste stream OR-REDCRH-HET, the Pre-SETF7

 period, which was not approved for shipment to WIPP, and 

these are on hold (subtotal of 30 containers). 

• Six containers required repackaging and were being held (total of 36 containers) 

The documentation regarding all thirty-six containers was adequate. 

6.4.2 Concerns 

The EPA inspection team did not identify any concerns relative to the management and tracking 

of CH and RH containers by CCP-ORNL. 

6.4.3 Conclusion 

The EPA inspection team concluded that CCP-ORNL continues to manage and track CH and RH 

TRU waste containers in a manner that is compliant with the requirements of 40 CFR Part 194. 

7.0 SUMMARY OF RESULTS 

7.1 Summary of Concerns 

The EPA inspection team did not identify any concerns during this inspection. Based on this 

unannounced inspection of ORNL-CCP, there are no open issues in any of the technical areas 

evaluated related to CH or RH TRU wastes. 

 

6

 The criterion for RH versus CH TRU wastes is often stated as a dose rate expressed in units of millirem per 

hour (mRem/hr). In a strict technical sense this should be called an external dose equivalent rate, however, usage of 

the term dose rate is common throughout CCP documents. 

7

 SETF is the Solvent Test Extraction Facility. 
11 

7.2 Conclusion 

The EPA inspection team evaluated selected aspects of the following waste characterization 

areas at ORNL-CCP: 

• Radiological characterization for RH TRU wastes by DTC 

• NDE - RTR for CH TRU wastes 

• NDE- VE for RH TRU wastes 

• Container management for CH or RH TRU wastes 

Based on the results of this inspection, EPA determined that the ORNL-CCP waste 

characterization programs for CH and RH TRU wastes continue to comply with the requirements 

of 40 CFR Part 194.