DOCKET NO: A-98-49; II-A4-164 

 

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT: 

EVALUATION OF THE CALIBRATION CHANGES TO THE HIGH EFFICIENCY 

NEUTRON COUNTER UNIT 1 AND TO THE SUPER HIGH EFFICIENCY NEUTRON 

COUNTER NONDESTRUCTIVE ASSAY SYSTEMS AT THE 

LOS ALAMOS NATIONAL LABORATORY 

CENTRAL CHARACTERIZATION PROJECT 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center of Federal Regulations 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

August 2012
i 

TABLE OF CONTENTS 

Section Page

Abbreviations, Acronyms and Initializations ................................................................................. ii

1.0  Introdcution ....................................................................................................... 1

2.0 Purpose of Tier 1 Evaluations ........................................................................... 1

3.0 Purpose of This Report ..................................................................................... 2

4.0 Scope of Evaluation .......................................................................................... 2

5.0 Evaluation Team ............................................................................................... 3

6.0 Technical Evaluation ........................................................................................ 4

6.1 High Efficiency Neutron Counter Unit 1 .......................................................... 4

6.2 Super High Efficiency Neutron Counter ........................................................... 8

7.0 Summary of Tier 1 Evaluation ........................................................................ 12 

8.0  Conclusion ....................................................................................................... 12 

 

  

ATTACHMENTS 

Attachment A Summary of LANL-CCP Contact-Handled Approvals 

Attachment B Documents Reviewed for This Evaluation 

Attachment C HENC No. 1 Replicate Testing Results 

Attachment D SuperHENC Replicate Testing Results 
ii 

ABBREVIATIONS, ACRONYMS AND INITIALIZATIONS 

Am americium 

BDR batch data report 

CBFO Carlsbad Field Office 

CCP Central Characterization Project 

CFR Code of Federal Regulations

CH contact-handled 

Ci curie 

Cs cesium 

DOE U.S. Department of Energy 

EPA U.S. Environmental Protection Agency 

Eu europium 

g gram 

g/cc grams per cubic centimeter 

HENC High Efficiency Neutron Counter 

HENC No. 1 High Efficiency Neutron Counter Unit 1 

HENC No. 2 High Efficiency Neutron Counter Unit 2 

HQ headquarters 

HS Pu heat source plutonium 

LANL Los Alamos National Laboratory 

LOQI list of qualified individuals 

MDA minimum detectable activity 

MDC minimum detectable concentration 

nCi/g nanocuries per gram 

NDA nondestructive assay 

Np neptunium 

NTP National TRU Programs 

PDP Performance Demonstration Program 

Pu plutonium 

RSD relative standard deviation 

Sr strontium 
iii 

SuperHENC Super High Efficiency Neutron Counter 

SWB standard waste box 

T1 Tier 1 

TMU Total Measurement Uncertainty 

TRU transuranic 

U uranium 

WG weapons grade 

WIPP Waste Isolation Pilot Plant 

WTS Washington TRU Solutions 
1 

1.0 INTRODUCTION 

This report supports the U.S. Environmental Protection Agency’s (EPA’s) approval of two Tier 1 

(T1) changes for nondestructive assay (NDA) systems at Los Alamos National Laboratory 

(LANL) operated by the Central Characterization Project (CCP): (1) extension of the gamma 

density range of the High Efficiency Neutron Counter (HENC), Unit 1 (HENC No. 1), requested 

by the Carlsbad Field Office (CBFO) on May 24, 2012, and (2) extension of the gamma 

calibration range for the Super High Efficiency Neutron Counter (SuperHENC), requested on 

June 4, 2012. EPA evaluated these changes during a site visit at LANL on June 20–21, 2012. 

In accordance with Title 40 of the Code of Federal Regulations (40 CFR) 194.8(b), EPA 

conducted Baseline Inspection No. EPA-LANL-CCP-05.05-8 of LANL-CCP on May 3–5, 2005. 

As a result of this baseline inspection, EPA approved the LANL-CCP waste characterization 

program with conditions and limitations as documented in the LANL baseline final inspection 

report (see EPA Docket No. A-98-49, II-A4-88). This baseline approval included two HENCs 

Unit 1 and Unit 2). In October 2011, EPA approved the SuperHENC as a T1 change (see Docket 

No. A-98-49, II-A4-153). 

LANL-CCP requested the T1 change to the HENC No. 1 baseline approval to allow HENC 

No. 1 to assay lead-lined containers in the same manner as EPA approved for HENC Unit 2 

(HENC No. 2) in November 2010. This T1 change is to extend the gamma density range of the 

SuperHENC since its initial approval in October 2011. Based on this evaluation, EPA determines 

and approves that the calibration changes for both instruments, HENC No. 2 and SuperHENC, 

are adequate to assay contact-handled (CH) transuranic (TRU) wastes in the instrument-specific 

configurations detailed in the LANL-CCP calibration reports. Changes to the approved 

components of both NDA systems must follow the tiering requirements described in the baseline 

inspection report issued for the LANL-CCP CH program (Docket No. A-98-49, II-A4-88, June 

2007). 

Attachment A lists all of EPA’s previous LANL CH approvals. 

 

2.0 PURPOSE OF TIER 1 EVALUATIONS 

Any changes to the waste characterization activities from the date of the baseline inspection must 

be specified in the LANL-CCP 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 waste characterization program and approve 

the program. EPA’s approval must be 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 Waste Isolation Pilot Plant (WIPP). An EPA inspection team conducts an onsite inspection to 

verify that the site’s system of controls is technically adequate and properly implemented. 

Following EPA’s approval of waste characterization processes evaluated during the baseline 

inspection, EPA is authorized to evaluate and approve, if necessary, changes to the site’s 

approved waste characterization program by conducting additional inspections under the 
2 

authority of 40 CFR 194.24(h). Under 40 CFR 194.24, EPA has the authority to conduct 

continued compliance inspections to verify that the site continues to use only the approved waste 

characterization processes to characterize the waste and remains in compliance with all of the 

regulatory requirements. Based on the adequacies of the waste characterization processes 

demonstrated during the baseline inspection, including all conditions and limitations, EPA 

specified which subsequent waste characterization program changes or modifications must 

undergo further EPA approval under 40 CFR 194.24. This was accomplished by assigning a tier 

level to each aspect of LANL-CCP’s characterization program. T1 activities have more stringent 

reporting requirements and require that the U.S. Department of Energy (DOE) notify EPA, and 

that EPA provide approval prior to implementation. The rule under which baseline inspections 

are conducted can be found in the Federal Register (Vol. 69, No. 136, pages 42571–42583; 

July 16, 2004). 

3.0 PURPOSE OF THIS REPORT 

This report documents the basis for EPA’s technical evaluation of the T1 change to allow HENC 

No. 1 to assay lead-lined drums and to expand the density range of the SuperHENC to assay 

lead-lined drums in standard waste boxes (SWBs). Specifically, this report does the following: 

 Describes the proposed changes to the LANL HENC No. 1 and SuperHENC systems and 

evaluates the technical aspects of the changes. 

 Provides objective evidence of outstanding findings or concerns, as applicable. 

 Describes any tests or demonstrations completed during the course of the inspection and 

their relevance to EPA’s approval decision. 

 Documents the basis for EPA’s approval of the proposed changes to both systems and 

presents the results of their technical evaluation. 

EPA’s evaluation of HENC No.1 and the SuperHENC will be conveyed to DOE separately by 

letter. More information is also on EPA’s website at 

http://www.epa.gov/rpdweb00/WIPP/inspection.html in accordance with 40 CFR 194.8(b)(3). 

4.0 SCOPE OF EVALUATION 

The scope of this evaluation included aspects of two different LANL-CCP NDA systems: 

(1) changes to the calibration of the HENC No. 1 to allow the assay of lead-lined containers and 

(2) extension of the density range for the SuperHENC, as described in this report. EPA assessed 

the personnel, practices and procedures for both systems relative to their previous approvals. 

Once EPA determined that specific aspects of the systems were unchanged, those aspects were 

not evaluated and EPA focused on the technical adequacy and documentation of the aspects of 

both systems that changed. The specific aspects of the evaluation included the following: 
3 

 Confirmation that the LANL-CCP HENC No. 1 and SuperHENC NDA systems were the 

same systems in the same operational configurations that EPA had approved previously. 

 Qualification and training for personnel responsible for the calibration, performance 

testing, operation, and data reporting and validation of HENC No. 1 and the SuperHENC. 

 LANL-CCP procedures for the calibration, operation, and data reporting and validation 

for HENC No. 1 and the SuperHENC. 

 Performance tests that LANL-CCP used to accept the operations of both systems and the 

pedigree of radionuclide sources used for calibration and performance testing. 

 Assessment of the calibrated or operational ranges of both systems in terms of 

radionuclide type and activity, and sample matrix. 

 Ability of the proposed configurations of both systems to identify and quantify the 10 

WIPP-tracked radionuclides [plutonium-238 (238Pu), 239Pu, 240Pu, 242Pu, uranium-233 

(

233U), 234U, 238U, americium-241 (241Am), strontium-90 (90Sr) and cesium-137 (137Cs)] 

and assign an uncertainty to each measured value. 

 Successful participation in the CBFO-sponsored NDA Performance Demonstration 

Program (NDA PDP). 

Attachment B identifies the objective evidence that EPA examined for its evaluation of HENC 

No. 1 and the SuperHENC. 

5.0 EVALUATION TEAM 

All personnel involved in the HENC No.1 and SuperHENC evaluation are listed in Table 1, 

along with each person’s affiliation and function for the purpose of this inspection. 

Table 1. Evaluation Personnel 

Personnel Affiliation Evaluation Function – Area of 

Expertise 

Edward Feltcorn US EPA HQ EPA Evaluation Team Leader 

Rajani Joglekar US EPA HQ EPA Inspector 

Patrick Kelly SC&A EPA Inspector, NDA 

Rose Gogliotti* SC&A EPA Inspector, NDA 

Tom Morgan DOE/CBFO NTP Representative 

Richard C. Baumann Canberra NDA Technical Support 

Joe Wachter Canberra NDA Technical Support 

Craig Simmons WTS CCP Project Manager 

Neil Dickes CCP NDA Technical Support 

Sean Stanfield Canberra NDA Technical Support 

Jared Francis Canberra NDA Technical Support 

Ron Reeves CCP Project Manager 

Joe Stepzinski CCP Vendor Project Manager 

* Was not present for the onsite inspection. 
4 

6.0 TECHNICAL EVALUATION 

EPA evaluated both systems during the site visit to LANL. Each system is described in a 

separate section below. 

6.1 High Efficiency Neutron Counter Unit 1 

(1) The design and operational history of HENC No. 1 were assessed and were found to be 

unchanged from the previous approval. 

HENC No. 1 is located at TA-54, on Pad 10 in Area G at LANL. EPA confirmed that it has not 

been relocated since EPA’s initial approval. HENC No. 1 is a multicomponent gamma 

spectrometry and passive neutron NDA system to assay WIPP-bound CH TRU waste in 55-

gallon drums without lead linings, as described in detail in previous EPA reports (see section 1.0, 

above). EPA determined that these aspects were unaffected by this T1change. For the T1 change 

to allow HENC No. 1 to assay lead-lined drums, the passive neutron modality of the system was 

not changed because the majority of activity in lead-lined drums is attributable to 241Am. This 

change affected only the HENC No. 1 gamma efficiency calibration for use with a cadmium 

filter and lead drum liner, from approximately 200 to 1,228 kiloelectron volts. 

The lead-lined containers originate in Waste Stream LA-CIN01.001. With their addition, the 

measurement configurations for HENC No. 1 within a 55-gallon drum are as follows: 

 Loose S5000 debris waste, no lead liner. 

 Thirty-five 1-gallon cans packed in five layers of seven cans each, no lead liner. 

 Thirty-five 1-gallon cans packed in five layers with a lead liner in the 55-gallon drum. 

 Thirty 1-gallon cans packed in five layers of six cans each with a hollow core in the 

center of the 55-gallon drum to keep all of the 1-gallon cans against the inside wall of the 

drum. 

The details of the lead liner for the 55-gallon drum are shown in Figure 1. Note that the figure 

dimensions may vary from actual 55-gallon drums used. 

There are no technical concerns regarding the design and operational history of HENC No. 1 for 

any of the measurement configurations. 
5 

Source: MCS-HENC#1-NDA-1005, Figure 2 

Figure 1. Lead-Lined Drum Configuration

(2) The qualifications and training for NDA personnel were evaluated and were found to be 

adequate and appropriately documented. 

EPA evaluated the CCP-LANL list of qualified individuals (LOQI) dated June 15, 2012, 

2:39 p.m., for all HENC No. 1 personnel. The training was current for all Operators, Independent 

Technical Reviewers and Expert Analysts for both HENC No. 1 and HENC No. 2. There were 

no concerns regarding the training and qualifications of HENC No. 1 personnel. 

(3) Changes to the gamma efficiency calibration to accommodate assaying lead-lined drums 

were evaluated and found to be technically adequate and appropriately documented. 

 

The gamma component has separate calibrations for energy, resolution, reference peak (pulser) 

and efficiency. The energy, resolution and reference peak calibrations had been performed 

previously and approved by EPA. Efficiency calibrations were performed initially in 2004, 

modified in 2005, and extended to 2.1 grams per cubic centimeters (g/cc) in 2007 for non-leadlined drums. A separate efficiency calibration for lead-lined drums was performed in April 2012, 

as documented in MCS-HENC#1-NDA-1005-Lead-Lined, Revision 0. The calibration used 

mixed gamma sources containing 241Am and europium-152 (152Eu) placed in five lead-lined 

55-gallon drums, each containing a different matrix as follows: (1) an empty drum (0.03 g/cc), 

(2) Homasote® (0.51 g/cc), (3) particle board (0.66 g/cc), (4) sand (1.49 g/cc) and (4) concrete 
6 

(1.79 g/cc). The highest matrix density value of 1.79 g/cc was extrapolated using modeling based 

on Canberra’s In-Situ Object Counting System (ISOCS) results, allowing the maximum to be 

extended to approximately 2.15 g/cc. The configuration of the matrix drums and the resulting 

calibration curve from all five matrices are shown in MCS-HENC#1-NDA-1005-Lead-Lined, 

Revision 0, Figures 1 and 2, respectively. EPA found minor errors in MCS-HENC#1-NDA1005-Lead-Lined, Revision 0, which were communicated to LANL-CCP. There were no 

concerns regarding the technical adequacy of the lead-lined efficiency calibration for HENC 

No.1. 

(4) The lead-lined efficiency calibration was validated using independent sources. 

LANL-CCP validated the lead-lined efficiency calibration using the lead-lined concrete matrix 

drum containing 107 g weapons grade (WG) Pu, which consisted of a 50-gram (g) WG Pu 

source, No. RANT50-1, and a 65-g WG Pu source, No. NTP0164. The assays were evaluated in 

terms of accuracy (percent recovery) and precision (percent relative standard deviation or RSD), 

using the criteria in DOE-WIPP-02-3133, Appendix A, Table 3.2. The validation assays passed 

the criteria for accuracy (±30%) and precision (<14% RSD). There were no concerns regarding 

the technical adequacy of the lead-lined efficiency calibration validation for HENC No. 1. 

(5) The lead-lined calibration was confirmed using independent sources. 

The lead-lined gamma efficiency calibration was confirmed by measuring WG or heat source 

plutonium (HS Pu) sources in a standard zero-matrix drum (No. PDP-001). Each drum was 

measured six times for a total of 48 measurements. Mass loadings of 0.6 g, 15 g, 160 g and 217 g 

were selected as representative of typical waste drums for primarily 239Pu (WG Pu) waste forms; 

mass loadings of 0.3 g, 7 g, 10 g and 18 g were selected as representative of typical waste drums 

for primarily 238Pu (HS Pu) waste forms. The measurements were performed following the 

procedure for unknown waste drums. All mass loadings passed the criteria for accuracy (±30%) 

and precision (<14% RSD) except the 0.6-gram WG Pu loading. Based on this determination, 

LANL-CCP established an administrative limit of 2 grams of total Pu; all assays that show less 

than 2 g of total Pu are subject to Expert Analyst review. There were no concerns regarding the 

technical adequacy of the lead-lined efficiency calibration confirmation for HENC No.1. 

(6) The lead-lined gamma efficiency calibration of HENC No. 1 demonstrates that the unit 

has the ability to identify and quantify the 10 WIPP-tracked radionuclides. 

The lead-lined gamma efficiency calibration of HENC No. 1 did not significantly affect the 

system’s ability to identify and quantify the 10 WIPP-tracked radionuclides, as evidenced by the 

data in MCS-HENC#1-NDA-1005-Lead-Lined, Revision 0. EPA may revisit this once a larger 

number of lead-lined drums have been assayed on HENC No. 1. There are no concerns regarding 

the ability of HENC No. 1 to identify and quantify the 10 WIPP-tracked radionuclides for the 

lead-lined drums. 
7 

(7) The total measurement uncertainty of assays performed on HENC No. 1 for lead-lined 

assays has been determined and adequately documented. 

As discussed above, addition of the lead-lined drums allows for the following 55-gallon drum 

measurement configurations for HENC No. 1: 

 Loose S5000 debris waste, no lead liner. 

 Thirty-five 1-gallon cans packed in five layers of seven cans each, no lead liner. 

 Thirty-five 1-gallons cans packed in five layers with a lead liner in the 55-gallon drum. 

 Thirty 1-gallon cans packed in five layers of six cans each with a hollow core in the 

center of the 55-gallon drum to keep all the 1-gallon cans against the inside wall of the 

drum. 

LANL-CCP considered the total measurement uncertainty (TMU) for each configuration, as 

documented in CI-MCS-HENC TMU-101, Revision 3, Addendum 1. All measurement 

configurations are expected to be very consistent in the overall matrix type. MCS-HENC TMU101, Revision 3, Addendum 1, Table 6, provides a summary of representative estimated 

uncertainties among the three configurations. The values are close, and LANL-CCP chose to 

apply the uncertainty based on the 30 1-gallon can configuration, representing the maximum 

TMU value. There are no technical concerns regarding the TMU determination for lead-lined 

assays on HENC No. 1. 

 (8) The lower limit of detection, including the minimum detectable concentration, had been 

determined and adequately documented. 

To determine the minimum detectable activities (MDAs) for seven of the 10 WIPP-tracked 

radionuclides that are measureable by gamma, measurements were performed on a lead-lined 

empty drum and a lead-lined drum filled with concrete. The NDA 2000 software calculated the 

MDAs from these measurements, and minimum detectable concentrations (MDCs) for the 

gamma modes were determined using the matrix weight using 1,800-second counting times. It is 

important to note that MDAs are variable and depend on background count times and count rate 

and matrix type. The empty drum MDC analysis shows that the system would not be able to 

distinguish between TRU and non-TRU wastes at the 100-nanocurie per gram (nCi/g) level, due 

in large part to the low net weight of the container. However, the MDC for the lead-lined 

concrete matrix shows that the system could distinguish between TRU and non-TRU waste at the 

100 nCi/g level. 
8 

(9) EPA replicate testing of HENC No. 1 was performed, evaluated and determined to be 

adequate. 

The purpose of the replicate testing performed as part of this evaluation is to provide EPA with 

an independent means to verify that HENC No. 1 can provide consistent, reproducible results for 

the determination of the quantity of 10 WIPP-tracked radionuclides (241Am, 137Cs, 238Pu, 239Pu, 

240Pu, 242Pu, 90Sr, 233U, 234U and 238U) and the TRU alpha concentration. This is normally 

accomplished by requesting that the site reassay drums that were previously characterized on the 

same system or instrument in order to demonstrate the following: 

 The instrument produces results consistent with the reported TMU by comparing the 

sample standard deviation for a number of replicate measurements taken over several 

hours or days to the reported TMU. 

 The instrument provides reproducible results over longer periods of time, such as weeks 

or months, by comparing the results of the replicate measurement(s) to the original 

reported values. 

EPA requested that LANL-CCP reassay three lead-lined drums that EPA randomly selected from 

a list of nine containers previously assayed on HENC No. 1. Each of the selected drums, Nos. 

54241, 54259 and 54262, had a valid prior assay on HENC No. 1. 

Replicate measurements for all three containers on HENC No.1 passed both statistical tests. 

There are no technical concerns regarding the ability of HENC No. 1 to provide consistent, 

reproducible results for the determination of the quantity of 10 WIPP-tracked radionuclides. 

(10) HENC No.1 had successfully participated in the CBFO-sponsored Nondestructive Assay 

Performance Demonstration Program. 

HENC No. 1 successfully participated in Cycle 18A of the CBFO NDA PDP, and LANL-CCP 

personnel were in the process of completing the analyses for Cycle 19A. There were no concerns 

regarding participation of HENC No. 1in the CBFO-sponsored NDA PDP. 

6.2 Super High Efficiency Neutron Counter 

(1) The design and operational history of the SuperHENC were assessed. 

The SuperHENC is located at TA-54, on Pad 10 in Area G. EPA confirmed that it has not been 

relocated since EPA’s initial approval in 2011. The SuperHENC is a multicomponent gamma 

spectrometry and passive neutron NDA system to assay WIPP-bound CH TRU waste in SWBs. 

The design and location of this instrument are described in detail in previous EPA reports (see 

section 1.0). EPA determined that these aspects were unaffected by this T1change. The assay 

configurations for the SuperHENC are as follows: 

 SWBs containing four 55-gallon drums of debris waste. 

 SWBs containing direct-loaded debris waste. 
9 

The majority of the activity of the higher density wastes that required this T1 change is 

attributable to 241Am; therefore, the passive neutron modality of the system was not changed. 

This T1 change affected only the two SuperHENC gamma detectors, whose density ranges were 

extended to 2.5 g/cc. The two SuperHENC gamma detectors use composite tin-copper filters. 

The detectors were physically removed from the system and sent to the Canberra factory in 

Meriden, CT, where they were characterized for use with the ISOCS software. This allows a 

variety of adjustments to the detectors to address changes in measurement geometry, matrix 

density, source-to-detector distance and so forth, based on modeling. There are no technical 

concerns regarding the design and operational history of the SuperHENC. 

(2) The qualifications and training for NDA personnel were evaluated and were found to be 

adequate and appropriately documented. 

EPA staff evaluated the CCP-LANL LOQI dated June 15, 2012, 2:39 p.m., for all SuperHENC 

personnel. The training was current for all Operators, Independent Technical Reviewers and 

Expert Analysts for the SuperHENC. There were no concerns regarding the training and 

qualifications of SuperHENC personnel. 

(3) Changes to the gamma efficiency calibration to accommodate the higher density assays 

were evaluated and found to be technically adequate and appropriately documented. 

 

The SuperHENC gamma detectors have separate calibrations for energy, resolution and 

reference peak (pulser). The energy, resolution and reference peak calibrations had been 

performed previously and approved by EPA. The efficiency calibrations performed initially in 

2011 were modified in 2012 by incorporating the results of ISOCS modeling of the detectors at 

higher densities. This produced the calibration curve shown in LANL-SHENC3-NDA-1004, 

Figure 3, which is a composite of measured data from 2011 and 2012 ISOCS data. This extends 

the upper density limit to 2.5 g/cc. 

The initial SuperHENC efficiency calibration used mixed gamma sources containing 241Am and 

152Eu in different SWBs containing each of the following five matrices: (1) empty (0.0 g/cc), 

(2) cardboard (0.152 g/cc), (3) cardboard/plywood (0.297 g/cc), (4) cardboard/high density 

poly/plywood (0.58 g/cc) and (5) plywood/low density poly (0.788 g/cc). These produced the 

initial upper density limit of 1.0 g/cc, which was extrapolated using ISOCS modeling, as 

described above, to derive an upper limit of approximately 2.5 g/cc. There were no concerns 

regarding the technical adequacy of the lead-lined efficiency calibration for the SuperHENC. 

(4) The higher density calibration was confirmed using independent weapons grade and heat 

source plutonium sources. 

The gamma efficiency calibration was confirmed by measuring WG or HS Pu sources in a 

standard zero-matrix SWB. Mass loadings for WG Pu were 0.1316 g, 0.6114 g, 30.0 g, 114.8 g, 

192.7 g and 272.7 g. HS Pu mass loadings were 7.0 g and 17.07 g and both were decay corrected 

to March 2011. Each mass loading was measured six times. All gamma WG Pu and HS Pu mass 

loading measurements passed the criteria for accuracy (±30%) and precision (<14% RSD). 
10 

Based on this determination, there were no concerns regarding the technical adequacy of the 

lead-lined efficiency calibration confirmation for the SuperHENC. 

(5) The high-density gamma efficiency calibration of the SuperHENC has the ability to 

identify and quantify the 10 WIPP-tracked radionuclides. 

The high-density gamma efficiency calibration of the SuperHENC did not significantly affect the 

system’s ability to identify and quantify the 10 WIPP-tracked radionuclides. EPA may revisit 

this once a larger number of high-density drums have been assayed on the SuperHENC. There 

are no concerns regarding the ability of the SuperHENC to identify and quantify the 10 WIPPtracked radionuclides for the lead-lined drums. 

(6) The total measurement uncertainty of assays of high-density containers performed on the 

SuperHENC has been determined and appropriately documented. 

The determination of TMU for the SuperHENC is documented in CI-SHENC-TMU-102, 

Revision 3, September 19, 2011. The gamma evaluation includes the propagation of both random 

and systematic uncertainties. Random uncertainties are derived from counting statistics and are 

calculated by the analysis software. Systematic uncertainties include those related to source 

distribution effects and matrix non-homogeneities. It is assumed that individual uncertainty 

components are statistically independent, allowing them to be added in quadrature. The primary 

sources of uncertainty in the gamma analysis include counting statistics, interferences from other 

radionuclides present, matrix non-homogeneity, isotopic measurement uncertainty background 

fluctuations, calibration source uncertainties, source distribution within the matrix, and selfabsorption. These are discussed in detail in CI-SHENC-TMU-102, Section 4. There are no 

technical concerns regarding the determination and documentation of TMU for the LANL-CCP 

SuperHENC. 

(7) The lower limit of detection, including the minimum detectable concentration, had been 

determined and appropriately documented. 

To determine the MDAs for the 10 WIPP-tracked radionuclides, sets of three replicate 

measurements were performed on one surrogate matrix SWB without radioactive sources. NDA 

2000 software calculated the MDAs from these measurements, and the MDAs were then used to 

calculate the MDCs based on the matrix’s net weight; in this case, the matrix was plywood and 

cardboard. MDCs calculated in this way are shown in LANL-SHENC3-NDA-1003, Revision 4, 

Table 7a. Only measured values that exceeded the reported lower limit of detection for a 

measurement will be reported and used in calculations of derived quantities, such as total TRU 

alpha activity and TRU alpha activity concentration. None of these aspects are affected by the 

higher density assays. There are no technical concerns regarding the technical derivation and 

application of lower limits of detection for higher density assays on the SuperHENC. 
11 

(8) EPA replicate testing of the SuperHENC was performed, evaluated and found to be 

adequate. 

The purpose of the replicate testing performed as part of this evaluation is to provide EPA with 

an independent means to verify that the SuperHENC can provide consistent, reproducible results 

for the determination of the quantity of 10 WIPP-tracked radionuclides (241Am, 137Cs, 238Pu, 

239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U and 238U) and the TRU alpha concentration. This is normally 

accomplished by requesting that the site reassay drums that were previously characterized on the 

same system or instrument in order to demonstrate the following: 

 The instrument produces results consistent with the reported TMU by comparing the 

sample standard deviation for a number of replicate measurements taken over several 

hours or days to the reported TMU. 

 The instrument provides reproducible results over longer periods of time, such as weeks 

or months, by comparing the results of the replicate measurements to the original 

reported values. 

EPA requested that LANL-CCP reassay three containers that EPA randomly selected from a list 

of nine containers previously assayed on the SuperHENC. Each container had a valid prior assay 

on the SuperHENC. 

The t-test on SWB No. SB10069 (see Attachment D) resulted in a significant flag for 238Pu and a 

highly significant flag for neptunium-237 (237Np), both a result of the difference between the 

original measurement value and the average of the five replicate measurements. This was caused 

by a relatively low activity of the nuclide in the box. Precision among the replicates for this 

measurement was still good. 237Np is not a WIPP-tracked radionuclide; the differences among 

the values in absolute terms are small; and the decay of large concentrations of 241Am can 

produce variability in the 237Np content as were observed here. Therefore, the 237Np flags are of 

minimal concern. 

The t- test on SWB Container No. SB10084 (see Attachment D) resulted in significant flags for 

238Pu, 240Pu and 242Pu, as a result of the difference between the original measurement values and 

the averages of the five replicate measurements. In each instance the original measurement and 

sample averages were close, yet the RSD percents of the samples were tight (<3.25%). 

The t- test on SWB Container No. SB10102 (see Attachment D) resulted in a significant flag for 

239Pu as a result of the difference between the original measurement value and the average of the 

five replicate measurements. Precision among the replicates for this measurement was still good. 

There are no technical concerns regarding the ability of HENC No. 1 to provide consistent, 

reproducible results for the determination of the quantity of 10 WIPP-tracked radionuclides. 
12 

(6) The SuperHENC had successfully participated in the CBFO-sponsored Nondestructive 

Assay Performance Demonstration Program. 

Successful participation in Primary Box Cycle B11A of the NDA PDP, dated February 2012, is 

documented in the CBFO scoring report for this cycle. There were no concerns regarding 

participation of SuperHENC in the CBFO-sponsored NDA PDP. 

7.0 SUMMARY OF TIER 1 EVALUATION 

Findings and Concerns

The EPA inspection team did not identify any findings or concerns related to HENC No.1 or the 

SuperHENC during this T1 evaluation. 

Tiering Changes

Based on the results of this T1 evaluation, EPA has not revised the T1 and T2 designations 

assigned during the LANL-CCP baseline approval. Upon approval, the lead-lined operational 

mode of HENC No. 1 and the new density range for the SuperHENC will be added to the 

LANL-CCP tiering summary. 

Approval

Based on the results of this T1 evaluation, EPA approves the expansion of the calibration range 

of HENC No. 1 to accommodate lead-lined drums and the new density range of the SuperHENC, 

consistent with the limitations described in this report. 

8.0 CONCLUSION 

Based on this evaluation, EPA determines and approves that the calibration changes for both 

instruments, HENC No. 2 and SuperHENC, are adequate to assay contact-handled (CH) 

transuranic (TRU) wastes in the instrument-specific configurations detailed in the LANL-CCP 

calibration reports. Changes to the approved components of both NDA systems must follow the 

tiering requirements described in the baseline inspection report issued for the LANL-CCP CH 

program (Docket No. A-98-49, II-A4-88, June 2007). 
A-1 

ATTACHMENT A 

SUMMARY OF LANL-CCP CONTACT-HANDLED APPROVALS 

Approved Activity EPA Inspection Number, Approval Dates Docket Number 

LANL-CCP CH Baseline Approval LANL-CCP-05.06-8 — June 21, 2007 A-98-49, II-A4-88 

T1 Change – Extension of range for the High 

Efficiency Neutron Counter No. 2 October 28, 2007 A-98-49; II-A4-91 

T1 Change – Extension of range for the High 

Efficiency Neutron Counter No. 1 December 7, 2007 A-98-49, II-A4-95 

T1 Change – Assay of lead-lined drums on 

the High Efficiency Neutron Counter No. 2 November 10, 2010 A-98-49, II-A4-139 

T1Change – Addition of the SuperHENC October 28, 2011 A-98-49, II-A4-153 
B-1 

ATTACHMENT B 

DOCUMENTS REVIEWED FOR THIS EVALUATION 

CCP-TP-059, CCP Operating the Super High Efficiency Neutron Counter (SuperHENC) Using 

NDA 2000, Revision 1, September 19, 2011 

CCP-TP-063, CCP Operating the High-Efficiency Neutron Counter Using NDA2000, Revision 

13, April 11, 2011 

CCP-TP-064, CCP Calibrating the High Efficiency Neutron Counter and the Super High 

Efficiency Neutron Counter Using NDA 2000, Revision 6, April 6, 2011 

CCP-TP-103, CCP Data Reviewing, Validating, and Reporting Procedure for the High 

Efficiency Neutron Counter and the Super High Efficiency Neutron Counter Using NDA2000, 

Revision 10, August 30, 2011 

CCP- LANL List of Qualified Individuals (LOQI), JUNE 15, 2012, July 27, 2011, and 

August 11, 2011 

CI-HENC-TMU-101, Total Measurement Uncertainty for the HENC#1 with Integral Gamma 

Spectrometer, June 19, 2012 

CI-SHENC-TMU-102, Total Measurement Uncertainty for the Los Alamos SuperHENC with 

Gamma Spectroscopy, Revision 3, September 19, 2011 

CSM-01-06, Idaho National Laboratory Central Characterization Facility Standard Waste Box 

Matrix Surrogate Inspection Summary Report, September 18, 2006 

HENC No. 1 BDR Nos. 1LANDA1581, June 8, 2012, 1LANDA1582, June 8, 2012, and 

1LANDA1584, June 8, 2012 

LANL-HENC2-TMU-101, Total Measurement Uncertainty for the HENC #2 with Integral 

Gamma Spectrometer, Revision 0, April 10, 2006 

MCS-HENC#1-NDA-1005-Lead-Lined, Lead Lined Calibration Report for the HENC #1 

Including Passive Neutron and Gamma Spectrometer, Revision 0, May l7, 2012 

LANL-SHENC3-NDA-1004, Calibration Report for the SuperHENC at Los Alamos National 

Laboratory Including Passive Neutron and Gamma Spectrometer Calibration and Confirmation, 

Revision 3, May 17, 2012, and Revision 4, June 15, 2012 

Memorandum from Michael R. Brown, Carlsbad Field Office, to Tom Morgan, Carlsbad Field 

Office, Scoring Report – Supplemental Box Cycle B10C of the Nondestructive Assay 

Performance Demonstration Program, September 12, 2011 
B-2 

Memorandum from Michael R. Brown, Carlsbad Field Office, to Distribution, Scoring Report – 

Primary Box Cycle B11A of the Nondestructive Assay Performance Demonstration Program, 

February 22, 2012 

SuperHENC BDR Nos. 3LANDA0069, June 13, 2012, and 3LANDA0070, June 14, 2012 
C-1 

ATTACHMENT C.1 

HENC No. 1 Replicate Testing Results for Container No. 54241 (Lead-Lined 55-Gallon Dr

Replicate #3 Replicate #4 

Reported Absolute Relative Reported Absolute Relative Report

Quantity of Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) N/A N/A 234U Activity (Ci) N/A N/A 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 4.40E-01 1.61E-01 3.66E-01 4.12E-01 1.50E-01 3.64E-01 4.39E-239Pu Activity (Ci) 4.86E+00 1.64E+00 3.37E-01 4.69E+00 1.58E+00 3.37E-01 4.99E+240Pu Activity (Ci) 1.17E+00 4.29E-01 3.67E-01 1.13E+00 4.13E-01 3.65E-01 1.20E+242Pu Activity (Ci) 9.11E-03 3.33E-03 3.66E-01 8.77E-03 3.21E-03 3.66E-01 9.34E-241Am Activity (Ci) 1.86E+01 6.60E+00 3.55E-01 1.96E+01 6.96E+00 3.55E-01 1.89E+90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 9.44E+04 2.56E+04 2.71E-01 9.73E+04 2.69E+04 2.76E-01 9.59E+

Instrument: HENC1 Container: 54241 

Original Measurement Replicate #1 

Reported Absolute Relative Reported Absolute Relative Reporte

Quantity of Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) N/A N/A 234U Activity (Ci) N/A N/A 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 4.26E-01 1.56E-01 3.66E-01 4.28E-01 1.56E-01 3.65E-01 4.09E-0239Pu Activity (Ci) 4.84E+00 1.63E+00 3.37E-01 4.87E+00 1.64E+00 3.37E-01 4.66E+0240Pu Activity (Ci) 1.17E+00 4.27E-01 3.65E-01 1.17E+00 4.29E-01 3.67E-01 1.12E+0242Pu Activity (Ci) 9.07E-03 3.32E-03 3.66E-01 9.12E-03 3.33E-03 3.65E-01 8.72E-0241Am Activity (Ci) 1.91E+01 6.77E+00 3.55E-01 2.02E+01 7.15E+00 3.54E-01 1.98E+090Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 9.61E+04 2.62E+04 2.73E-01 1.00E+05 2.76E+04 2.76E-01 9.77E+0
C-2 

Instrument: HENC1 Container: 54241 

Original Measurement Sample Relative 

Reported Absolute Relative Sample Standard Standard 

Quantity of Interest Value Uncertainty Uncertainty Mean Deviation Deviation 2 Pr(x 233U Activity (Ci) N/A N/A N/A N/A N/A 234U Activity (Ci) N/A N/A N/A N/A N/A 238U Activity (Ci) N/A N/A N/A N/A N/A 238Pu Activity (Ci) 4.26E-01 1.56E-01 3.66E-01 4.26E-01 1.46E-02 3.43E-02 3.51E-02 1.0239Pu Activity (Ci) 4.84E+00 1.63E+00 3.37E-01 4.81E+00 1.37E-01 2.85E-02 2.83E-02 1.0240Pu Activity (Ci) 1.17E+00 4.27E-01 3.65E-01 1.16E+00 3.27E-02 2.82E-02 2.35E-02 1.0242Pu Activity (Ci) 9.07E-03 3.32E-03 3.66E-01 9.01E-03 2.61E-04 2.90E-02 2.47E-02 1.0241Am Activity (Ci) 1.91E+01 6.77E+00 3.55E-01 1.94E+01 6.57E-01 3.38E-02 3.77E-02 1.090Sr Activity (Ci) N/A N/A N/A N/A N/A 137Cs Activity (Ci) N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 9.61E+04 2.62E+04 2.73E-01 9.71E+04 2.09E+03 2.16E-02 2.55E-02 1.0Quantity of Interest 2 Test t-Test 233U Activity (Ci) Not Applicable Not Applicable 234U Activity (Ci) Not Applicable Not Applicable 238U Activity (Ci) Not Applicable Not Applicable 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Not Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) Not Applicable Not Applicable 137Cs Activity (Ci) Not Applicable Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
C-3 

ATTACHMENT C.2 

HENC No. 1 Replicate Testing Results for Container No. 54259 (Lead-Lined 55-Gallon Dr

Instrument: HENC1 Container: 54259 

Original Measurement Replicate #1 

Reported Absolute Relative Reported Absolute Relative Reporte

Quantity of Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) N/A N/A 234U Activity (Ci) N/A N/A 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 1.36E-01 7.19E-02 5.29E-01 1.34E-01 6.95E-02 5.19E-01 1.36E-0239Pu Activity (Ci) 5.02E+00 2.58E+00 5.14E-01 4.97E+00 2.49E+00 5.01E-01 5.04E+0240Pu Activity (Ci) 1.17E+00 6.24E-01 5.33E-01 1.16E+00 6.04E-01 5.21E-01 1.18E+0242Pu Activity (Ci) 6.76E-05 3.60E-05 5.33E-01 6.68E-05 3.48E-05 5.21E-01 6.78E-0241Am Activity (Ci) 5.73E+00 2.01E+00 3.51E-01 6.00E+00 2.09E+00 3.48E-01 5.93E+090Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 4.20E+04 1.16E+04 2.76E-01 4.27E+04 1.15E+04 2.69E-01 4.28E+0

Replicate #3 Replicate #4 

Reported Absolute Relative Reported Absolute Relative Reporte

Quantity of Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) N/A N/A 234U Activity (Ci) N/A N/A 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 1.34E-01 7.12E-02 5.31E-01 1.33E-01 7.07E-02 5.32E-01 1.40E-239Pu Activity (Ci) 4.94E+00 2.55E+00 5.16E-01 4.92E+00 2.53E+00 5.14E-01 5.18E+240Pu Activity (Ci) 1.16E+00 6.18E-01 5.33E-01 1.15E+00 6.14E-01 5.34E-01 1.21E+242Pu Activity (Ci) 6.65E-05 3.56E-05 5.35E-01 6.62E-05 3.54E-05 5.35E-01 6.97E-241Am Activity (Ci) 5.75E+00 2.01E+00 3.50E-01 6.15E+00 2.15E+00 3.50E-01 5.78E+90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 4.17E+04 1.15E+04 2.76E-01 4.30E+04 1.18E+04 2.74E-01 4.29E+
C-4 

Original Measurement Sample Relative 

Reported Absolute Relative Sample Standard Standard 

Quantity of Interest Value Uncertainty Uncertainty Mean Deviation Deviation 2 Pr(x 233U Activity (Ci) N/A N/A N/A N/A N/A 234U Activity (Ci) N/A N/A N/A N/A N/A 238U Activity (Ci) N/A N/A N/A N/A N/A 238Pu Activity (Ci) 1.36E-01 7.19E-02 5.29E-01 1.35E-01 2.79E-03 2.06E-02 6.04E-03 1.0239Pu Activity (Ci) 5.02E+00 2.58E+00 5.14E-01 5.01E+00 1.05E-01 2.10E-02 6.67E-03 1.0240Pu Activity (Ci) 1.17E+00 6.24E-01 5.33E-01 1.17E+00 2.39E-02 2.04E-02 5.86E-03 1.0242Pu Activity (Ci) 6.76E-05 3.60E-05 5.33E-01 6.74E-05 1.42E-06 2.11E-02 6.22E-03 1.0241Am Activity (Ci) 5.73E+00 2.01E+00 3.51E-01 5.92E+00 1.64E-01 2.77E-02 2.67E-02 1.090Sr Activity (Ci) N/A N/A N/A N/A N/A 137Cs Activity (Ci) N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 4.20E+04 1.16E+04 2.76E-01 4.26E+04 5.26E+02 1.23E-02 8.23E-03 1.0Quantity of Interest 2 Test t Test 233U Activity (Ci) Not Applicable Not Applicable 234U Activity (Ci) Not Applicable Not Applicable 238U Activity (Ci) Not Applicable Not Applicable 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Not Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) Not Applicable Not Applicable 137Cs Activity (Ci) Not Applicable Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
C-5 

ATTACHMENT C.3 

HENC No. 1 Replicate Testing Results for Container No. 5462 (Lead-Lined 55-Gallon Dr

Instrument: HENC1 Container: 54262 

Original Measurement Replicate #1 

Reported Absolute Relative Reported Absolute Relative Reporte

Quantity of Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) N/A N/A 234U Activity (Ci) N/A N/A 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 2.10E-01 1.02E-01 4.86E-01 2.00E-01 9.55E-02 4.78E-01 2.09E-0239Pu Activity (Ci) 7.77E+00 3.64E+00 4.68E-01 7.38E+00 3.40E+00 4.61E-01 7.71E+0240Pu Activity (Ci) 1.82E+00 8.89E-01 4.88E-01 1.72E+00 8.31E-01 4.83E-01 1.80E+0242Pu Activity (Ci) 1.05E-04 5.12E-05 4.88E-01 9.93E-05 4.79E-05 4.82E-01 1.04E-0241Am Activity (Ci) 8.55E+00 2.87E+00 3.36E-01 8.50E+00 2.86E+00 3.36E-01 8.52E+090Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 6.77E+04 1.74E+04 2.57E-01 6.57E+04 1.67E+04 2.54E-01 6.73E+0

Replicate #3 Replicate #4 

Reported Absolute Relative Reported Absolute Relative Reporte

Quantity of Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) N/A N/A 234U Activity (Ci) N/A N/A 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 2.14E-01 1.04E-01 4.86E-01 2.12E-01 1.02E-01 4.81E-01 2.10E-239Pu Activity (Ci) 7.91E+00 3.69E+00 4.66E-01 7.82E+00 3.64E+00 4.65E-01 7.75E+240Pu Activity (Ci) 1.85E+00 9.02E-01 4.88E-01 1.83E+00 8.88E-01 4.85E-01 1.81E+242Pu Activity (Ci) 1.06E-04 5.20E-05 4.91E-01 1.05E-04 5.12E-05 4.88E-01 1.04E-241Am Activity (Ci) 8.91E+00 3.00E+00 3.37E-01 8.85E+00 2.97E+00 3.36E-01 8.46E+90Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 6.97E+04 1.79E+04 2.57E-01 6.90E+04 1.76E+04 2.55E-01 6.73E+
C-6 

Original Measurement Sample Relative 

Reported Absolute Relative Sample Standard Standard 

Quantity of Interest Value Uncertainty Uncertainty Mean Deviation Deviation 2 Pr(x 233U Activity (Ci) N/A N/A N/A N/A N/A 234U Activity (Ci) N/A N/A N/A N/A N/A 238U Activity (Ci) N/A N/A N/A N/A N/A 238Pu Activity (Ci) 2.10E-01 1.02E-01 4.86E-01 2.09E-01 5.39E-03 2.58E-02 1.11E-02 1.0239Pu Activity (Ci) 7.77E+00 3.64E+00 4.68E-01 7.71E+00 2.02E-01 2.61E-02 1.23E-02 1.0240Pu Activity (Ci) 1.82E+00 8.89E-01 4.88E-01 1.80E+00 4.97E-02 2.76E-02 1.25E-02 1.0242Pu Activity (Ci) 1.05E-04 5.12E-05 4.88E-01 1.04E-04 2.57E-06 2.48E-02 1.01E-02 1.0241Am Activity (Ci) 8.55E+00 2.87E+00 3.36E-01 8.65E+00 2.14E-01 2.47E-02 2.22E-02 1.090Sr Activity (Ci) N/A N/A N/A N/A N/A 137Cs Activity (Ci) N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 6.77E+04 1.74E+04 2.57E-01 6.78E+04 1.58E+03 2.33E-02 3.29E-02 1.0Quantity of Interest 2 Test t Test 233U Activity (Ci) Not Applicable Not Applicable 234U Activity (Ci) Not Applicable Not Applicable 238U Activity (Ci) Not Applicable Not Applicable 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Not Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) Not Applicable Not Applicable 137Cs Activity (Ci) Not Applicable Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
D-1 

ATTACHMENT D.1 

SuperHENC Replicate Testing Results for Container No. SB10084 

Instrument: SuperHENC Container: SB10084 

Original Measurement Replicate #1 

Reported Absolute Relative Reported Absolute Relative Reporte

Quantity of Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) N/A 8.05E-03 1.63E-03 2.02E-01 234U Activity (Ci) 1.27E-04 2.05E-05 1.61E-01 1.09E-04 1.86E-05 1.71E-01 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 6.11E-01 2.09E-01 3.42E-01 5.10E-01 1.76E-01 3.45E-01 5.05E-0239Pu Activity (Ci) 7.39E+00 2.52E+00 3.41E-01 7.60E+00 2.59E+00 3.41E-01 7.45E+0240Pu Activity (Ci) 1.76E+00 5.99E-01 3.41E-01 1.96E+00 6.68E-01 3.41E-01 1.93E+0242Pu Activity (Ci) 2.33E-04 8.27E-05 3.55E-01 2.52E-04 8.93E-05 3.54E-01 2.50E-0241Am Activity (Ci) 4.58E+00 9.23E-01 2.02E-01 4.71E+00 6.18E-01 1.31E-01 5.28E+090Sr Activity (Ci) N/A 9.53E-06 1.38E-06 1.45E-01 3.58E-0137Cs Activity (Ci) N/A 9.53E-06 1.38E-06 1.45E-01 3.58E-0TRU Alpha Conc. (nCi/g) 1.37E+04 2.62E+03 1.91E-01 1.41E+04 2.62E+03 1.86E-01 1.44E+0

Replicate #3 Replicate #4 

Reported Absolute Relative Reported Absolute Relative Reporte

Quantity of Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) 9.13E-03 1.71E-03 1.87E-01 N/A 234U Activity (Ci) 1.99E-04 2.92E-05 1.47E-01 N/A 238U Activity (Ci) 2.48E-05 4.29E-06 1.73E-01 N/A 238Pu Activity (Ci) 4.49E-01 1.56E-01 3.47E-01 4.58E-01 1.57E-01 3.43E-01 4.58E-0239Pu Activity (Ci) 7.17E+00 2.44E+00 3.41E-01 7.50E+00 2.52E+00 3.36E-01 7.55E+0240Pu Activity (Ci) 1.88E+00 6.41E-01 3.41E-01 1.90E+00 6.41E-01 3.38E-01 1.97E+0242Pu Activity (Ci) 2.42E-04 8.58E-05 3.55E-01 2.48E-04 8.71E-05 3.51E-01 2.54E-0241Am Activity (Ci) 4.45E+00 5.85E-01 1.32E-01 5.04E+00 6.70E-01 1.33E-01 4.54E+090Sr Activity (Ci) 9.52E-06 1.37E-06 1.44E-01 3.02E-06 5.06E-07 1.68E-01 2.45E-0137Cs Activity (Ci) 9.52E-06 1.37E-06 1.44E-01 3.02E-06 5.06E-07 1.68E-01 2.45E-0TRU Alpha Conc. (nCi/g) 1.33E+04 2.47E+03 1.86E-01 1.42E+04 2.56E+03 1.80E-01 1.38E+0
D-2 

Original Measurement Sample Relative 

Reported Absolute Relative Sample Standard Standard 

Quantity of Interest Value Uncertainty Uncertainty Mean Deviation Deviation 2 Pr(x 233U Activity (Ci) N/A 8.59E-03 7.64E-04 8.89E-02 #VALUE! #V234U Activity (Ci) 1.27E-04 2.05E-05 1.61E-01 1.54E-04 6.36E-05 4.13E-01 9.64E+00 1.9238U Activity (Ci) N/A 2.48E-05 N/A N/A N/A 238Pu Activity (Ci) 6.11E-01 2.09E-01 3.42E-01 4.76E-01 2.90E-02 6.10E-02 7.75E-02 9.9239Pu Activity (Ci) 7.39E+00 2.52E+00 3.41E-01 7.45E+00 1.68E-01 2.26E-02 1.78E-02 1.0240Pu Activity (Ci) 1.76E+00 5.99E-01 3.41E-01 1.93E+00 3.83E-02 1.99E-02 1.64E-02 1.0242Pu Activity (Ci) 2.33E-04 8.27E-05 3.55E-01 2.49E-04 4.60E-06 1.85E-02 1.24E-02 1.0241Am Activity (Ci) 4.58E+00 9.23E-01 2.02E-01 4.80E+00 3.49E-01 7.26E-02 5.71E-01 9.690Sr Activity (Ci) N/A 5.62E-06 3.59E-06 6.38E-01 #VALUE! #V137Cs Activity (Ci) N/A 5.62E-06 3.59E-06 6.38E-01 #VALUE! #VTRU Alpha Conc. (nCi/g) 1.37E+04 2.62E+03 1.91E-01 1.40E+04 4.28E+02 3.06E-02 1.07E-01 9.9Quantity of Interest 2 Test t Test 233U Activity (Ci) #VALUE! Not Significant 234U Activity (Ci) Highly Significant Not Significant 238U Activity (Ci) Not Applicable Not Applicable 238Pu Activity (Ci) Not Significant Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Significant 242Pu Activity (Ci) Not Significant Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) #VALUE! Not Significant 137Cs Activity (Ci) #VALUE! Not Significant TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
D-3 
D-4 

ATTACHMENT D.2 

SuperHENC Replicate Testing Results for Container No. SB10069 

Instrument: SuperHENC Container: SB10069 

Original Measurement Replicate #1 

Reported Absolute Relative Reported Absolute Relative Reporte

Quantity of Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) N/A N/A 234U Activity (Ci) 1.41E-04 2.00E-05 1.42E-01 1.05E-04 1.57E-05 1.50E-01 1.12E-0238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 1.82E-01 6.41E-02 3.52E-01 2.31E-01 8.10E-02 3.51E-01 2.25E-0239Pu Activity (Ci) 2.03E+00 7.05E-01 3.48E-01 2.24E+00 7.76E-01 3.47E-01 2.26E+0240Pu Activity (Ci) 5.14E-01 1.79E-01 3.48E-01 5.90E-01 2.05E-01 3.47E-01 5.93E-0242Pu Activity (Ci) 7.93E-05 2.86E-05 3.61E-01 9.13E-05 3.30E-05 3.61E-01 9.00E-0241Am Activity (Ci) 1.69E+00 2.23E-01 1.32E-01 1.88E+00 3.78E-01 2.01E-01 1.84E+090Sr Activity (Ci) 6.53E-06 8.97E-07 1.37E-01 N/A 137Cs Activity (Ci) 6.53E-06 8.97E-07 1.37E-01 N/A TRU Alpha Conc. (nCi/g) 4.13E+03 7.13E+02 1.73E-01 4.61E+03 8.32E+02 1.81E-01 4.59E+0

Replicate #3 Replicate #4 

Reported Absolute Relative Reported Absolute Relative Reporte

Quantity of Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) N/A N/A 234U Activity (Ci) 1.53E-04 2.17E-05 1.42E-01 1.55E-04 2.20E-05 1.42E-01 1.42E-238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 2.18E-01 7.65E-02 3.51E-01 2.41E-01 8.42E-02 3.49E-01 2.11E-239Pu Activity (Ci) 2.18E+00 7.56E-01 3.47E-01 2.17E+00 7.53E-01 3.47E-01 1.97E+240Pu Activity (Ci) 5.62E-01 1.95E-01 3.47E-01 6.20E-01 2.15E-01 3.47E-01 5.35E-242Pu Activity (Ci) 8.49E-05 3.07E-05 3.62E-01 9.54E-05 3.45E-05 3.62E-01 8.26E-241Am Activity (Ci) 1.82E+00 2.40E-01 1.32E-01 1.76E+00 2.32E-01 1.32E-01 1.87E+90Sr Activity (Ci) 6.12E-06 8.51E-07 1.39E-01 6.38E-06 8.82E-07 1.38E-01 6.27E-137Cs Activity (Ci) 6.12E-06 8.51E-07 1.39E-01 6.38E-06 8.82E-07 1.38E-01 6.27E-TRU Alpha Conc. (nCi/g) 4.47E+03 7.67E+02 1.72E-01 4.48E+03 7.67E+02 1.71E-01 4.28E+
D-5 

Original Measurement Sample Relative 

Reported Absolute Relative Sample Standard Standard 

Quantity of Interest Value Uncertainty Uncertainty Mean Deviation Deviation 2 Pr(x 233U Activity (Ci) N/A N/A N/A N/A N/A 234U Activity (Ci) 1.41E-04 2.00E-05 1.42E-01 1.33E-04 2.34E-05 1.75E-01 5.47E+00 2.4238U Activity (Ci) N/A N/A N/A N/A N/A 238Pu Activity (Ci) 1.82E-01 6.41E-02 3.52E-01 2.25E-01 1.16E-02 5.14E-02 1.31E-01 9.9239Pu Activity (Ci) 2.03E+00 7.05E-01 3.48E-01 2.16E+00 1.15E-01 5.32E-02 1.06E-01 9.9240Pu Activity (Ci) 5.14E-01 1.79E-01 3.48E-01 5.80E-01 3.25E-02 5.60E-02 1.32E-01 9.9242Pu Activity (Ci) 7.93E-05 2.86E-05 3.61E-01 8.88E-05 5.12E-06 5.76E-02 1.28E-01 9.9241Am Activity (Ci) 1.69E+00 2.23E-01 1.32E-01 1.83E+00 4.77E-02 2.60E-02 1.83E-01 9.990Sr Activity (Ci) 6.53E-06 8.97E-07 1.37E-01 6.26E-06 1.31E-07 2.09E-02 4.23E-02 9.7137Cs Activity (Ci) 6.53E-06 8.97E-07 1.37E-01 6.26E-06 1.31E-07 2.09E-02 4.23E-02 9.7TRU Alpha Conc. (nCi/g) 4.13E+03 7.13E+02 1.73E-01 4.49E+03 1.31E+02 2.93E-02 1.35E-01 9.9Quantity of Interest 2 Test t Test 233U Activity (Ci) Not Applicable Not Applicable 234U Activity (Ci) Not Significant Not Significant 238U Activity (Ci) Not Applicable Not Applicable 238Pu Activity (Ci) Not Significant Significant 239Pu Activity (Ci) Not Significant Not Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Not Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) Not Significant Not Significant 137Cs Activity (Ci) Not Significant Not Significant TRU Alpha Conc. (nCi/g) Not Significant Not Significant 
D-6 

ATTACHMENT D.3 

SuperHENC Replicate Testing Results for Container No. SB10102 

Instrument: SuperHENC Container: SB10102 

Original Measurement Replicate #1 

Reported Absolute Relative Reported Absolute Relative Reporte

Quantity of Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) N/A N/A 234U Activity (Ci) N/A N/A 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 3.47E-01 1.15E-01 3.30E-01 4.59E-01 1.52E-01 3.31E-01 3.64E-0239Pu Activity (Ci) 7.47E+00 2.39E+00 3.20E-01 7.34E+00 2.39E+00 3.25E-01 7.15E+0240Pu Activity (Ci) 1.86E+00 5.98E-01 3.22E-01 1.85E+00 6.03E-01 3.26E-01 1.78E+0242Pu Activity (Ci) 3.36E-04 1.09E-04 3.25E-01 3.88E-04 1.27E-04 3.28E-01 1.71E-0241Am Activity (Ci) 5.21E+00 6.98E-01 1.34E-01 5.67E+00 7.43E-01 1.31E-01 5.42E+090Sr Activity (Ci) N/A N/A 137Cs Activity (Ci) N/A N/A TRU Alpha Conc. (nCi/g) 1.47E+04 2.54E+03 1.73E-01 1.52E+04 2.55E+03 1.68E-01 1.46E+0

Replicate #3 Replicate #4 

Reported Absolute Relative Reported Absolute Relative Reporte

Quantity of Interest Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 233U Activity (Ci) N/A N/A 6.80E-234U Activity (Ci) 2.14E-04 3.09E-05 1.44E-01 1.47E-04 2.32E-05 1.58E-01 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 3.78E-01 1.25E-01 3.30E-01 3.71E-01 1.23E-01 3.32E-01 3.89E-239Pu Activity (Ci) 7.22E+00 2.31E+00 3.20E-01 7.28E+00 2.33E+00 3.20E-01 7.24E+240Pu Activity (Ci) 1.81E+00 5.83E-01 3.22E-01 1.85E+00 5.96E-01 3.22E-01 1.91E+242Pu Activity (Ci) 1.76E-04 5.72E-05 3.25E-01 1.76E-04 5.69E-05 3.24E-01 1.85E-241Am Activity (Ci) 4.38E+00 5.76E-01 1.31E-01 4.41E+00 5.80E-01 1.32E-01 4.75E+90Sr Activity (Ci) N/A N/A 1.31E-137Cs Activity (Ci) N/A N/A 1.31E-TRU Alpha Conc. (nCi/g) 1.37E+04 2.43E+03 1.78E-01 1.38E+04 2.46E+03 1.78E-01 1.41E+
D-7 

Original Measurement Sample Relative 

Reported Absolute Relative Sample Standard Standard 

Quantity of Interest Value Uncertainty Uncertainty Mean Deviation Deviation 2 Pr(x 233U Activity (Ci) N/A 6.80E-03 N/A N/A N/A 234U Activity (Ci) N/A 1.81E-04 4.74E-05 2.62E-01 #VALUE! #V238U Activity (Ci) N/A N/A N/A N/A N/A 238Pu Activity (Ci) 3.47E-01 1.15E-01 3.30E-01 3.92E-01 3.85E-02 9.81E-02 4.51E-01 9.7239Pu Activity (Ci) 7.47E+00 2.39E+00 3.20E-01 7.25E+00 7.06E-02 9.74E-03 3.49E-03 1.0240Pu Activity (Ci) 1.86E+00 5.98E-01 3.22E-01 1.84E+00 4.90E-02 2.66E-02 2.68E-02 1.0242Pu Activity (Ci) 3.36E-04 1.09E-04 3.25E-01 2.19E-04 9.45E-05 4.31E-01 3.00E+00 5.5241Am Activity (Ci) 5.21E+00 6.98E-01 1.34E-01 4.93E+00 5.90E-01 1.20E-01 2.86E+00 5.890Sr Activity (Ci) N/A 1.31E-06 N/A N/A N/A 137Cs Activity (Ci) N/A 1.31E-06 N/A N/A N/A TRU Alpha Conc. (nCi/g) 1.47E+04 2.54E+03 1.73E-01 1.43E+04 6.22E+02 4.36E-02 2.40E-01 9.9Quantity of Interest 2 Test t Test 233U Activity (Ci) Not Applicable Not Applicable 234U Activity (Ci) #VALUE! Not Significant 238U Activity (Ci) Not Applicable Not Applicable 238Pu Activity (Ci) Not Significant Not Significant 239Pu Activity (Ci) Not Significant Significant 240Pu Activity (Ci) Not Significant Not Significant 242Pu Activity (Ci) Not Significant Not Significant 241Am Activity (Ci) Not Significant Not Significant 90Sr Activity (Ci) Not Applicable Not Applicable 137Cs Activity (Ci) Not Applicable Not Applicable TRU Alpha Conc. (nCi/g) Not Significant Not Significant