DOCKET NO: A-98-49; II-A4-161

WASTE CHARACTERIZATION INSPECTION REPORT

FINAL APPROVAL

EPA BASELINE INSPECTION NO. EPA-SRS-CCP-RH-08.11-8 OF THE CENTRAL CHARACTERIZATION PROJECT REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION

PROGRAM FOR THE SAVANNAH RIVER SITE: August 30–September 1, 2011, and December 6–7, 2011

U.S. Environmental Protection Agency Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

April 2012i TABLE OF CONTENTS

Section Page

Acronyms and Initializations ......................

................................................... ................................ iii

1.0 Executive Summary .................................

................................................... ........................ 1

2.0 Purpose of Inspections ............................

................................................... ......................... 4

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

................................................... ........................ 5

4.0 Scope of Inspection ...............................

................................................... ........................... 6

5.0 Inspection-Related Definitions ....................

................................................... .................... 7

6.0 Personnel .........................................

................................................... ................................. 7

7.0 Performance of the Inspection .....................

................................................... .................... 7
7.1 Savannah River Site Background ....................

................................................... .... 7
7.2 Inspection Process Overview .......................

................................................... ........ 8

8.0 Technical Evaluation ..............................

................................................... ......................... 9
8.1 Programmatic Requirements and Acceptable Knowledge ..................................... 9
8.2 Radiological Characterization .....................

................................................... ....... 25
8.3 Real-Time Radiography .............................

................................................... ........ 37

9.0 Response to Comments ..............................

................................................... .................... 41

10.0 Summary of Results ................................

................................................... ....................... 41
10.1 Environmental Protection Agency Findings and Concer ns .................................. 41
10.2 Conclusions .......................................

................................................... ................. 41

11.0 References ........................................

................................................... .............................. 43ii ATTACHMENTS

Attachment A: Documents Reviewed During the Baselin e Inspection Attachment B: Inspection Personnel List Attachment C: EPA Inspection Issue Tracking Form No . SRS-CCP-RH-AK-11-01CR

LIST OF TABLES

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by SRSCCP ...............................................

................................................... .............................. 3
Table 2. Batch Data Reports Examined .......................

................................................... ........... 10
Table 3. Summary of Traceability Analysis...................

................................................... ......... 22
Table 4. Objective Evidence of Training for AK Personnel ...

................................................... 23
Table 5. MCS/ISOCS Replicate Data ..........................

................................................... ........... 31
Table 6. Summary of RH Determinations ......................

................................................... ......... 34
Table 7. Overall Uncertainty of Example Drum SR510588 ...... ................................................ 36

LIST OF FIGURES

Figure 1. Characterization and Qualification Process ........

................................................... ...... 13 Figure 2. Flow Diagram of the Characterization Process for SR -RH-FBL.01............................ 27iii ACRONYMS AND INITIALIZATIONS

%RSD percent relative standard deviation
AK acceptable knowledge
AKE Acceptable Knowledge Expert
AKSR acceptable knowledge summary report

Am americium
ASME American Society of Mechanical Engineers

Ba barium
BDR batch data report
BGR burial ground record
CAR corrective action report

CBFO Carlsbad Area Field Office
CCP Central Characterization Project

CFR Code of Federal Regulations

CH contact-handled

Ci curie
CIS Characterization Information Summary

Cm curium

Co cobalt
CRR Characterization Reconciliation Report

Cs cesium
CSSF Correlation and Surrogate Summary Form

CTAC CBFO Technical Assistance Contractor
DA destructive assay

DL detection limit
DOE U.S. Department of Energy
DQO data quality objective
DR discrepancy resolution

DTC dose-to-curie
EPA U.S. Environmental Protection Agency
Eu europium

FR Federal Registeriv

FSN File Sequence Number
HLW high-level waste
HPGe high-purity germanium detector

hr hour
ISOCS In Situ Object Counting System
ITR Independent Technical Reviewer
LANL Los Alamos National Laboratory

LLW low-level waste
LOQI list of qualified individuals

LWA WIPP Land Withdrawal Act

m meter MCNP5 Monte Carlo N-Particle Transport Code RSICC C omputer Code

Collection, Oak Ridge National Laboratory

MCS Mobile Characterization Services
MDA minimum detectable activity
MGA Multi-Group Analysis
mR/hr milliRoentgen per hour
mrem/hr millirem per hour
NABC Non Destructive Assay Box Counter

nCi nanocurie
NCR nonconformance report
NDA nondestructive assay
Np neptunium
NQA Nuclear Quality Assurance

NWPA Nuclear Waste Policy Act

ORIA Office of Radiation and Indoor Air
Pu plutonium
PUREX plutonium/uranium extraction
QA quality assurance
QAO quality assurance objectives
QC quality control
RC radiological characterization
rem/hr rem per hourv

RH remote-handled
RTR real-time radiography
SCG Summary Category Group SF scaling factor
SNF spent nuclear fuel
SPM Site Project Manager

Sr strontium

SRNL Savannah River National Laboratories

SRS Savannah River Site

T1 Tier 1

T2 Tier 2

Th thorium

Tl thallium
TMU Total Measurement Uncertainty

TRU transuranic

U uranium

VE visual examination
WCPIP Waste Characterization Program Implementation Plan, Revision 2
WDS WIPP Waste Data System WG Pu weapons-grade plutonium

WIPP Waste Isolation Pilot Plant

WMC waste matrix code
WMP waste material parameter
WRM working reference material

WSPF Waste Stream Profile Form
WTS Washington TRU Solutions
Y yttrium1

1.0 EXECUTIVE SUMMARY

This report discusses the U.S. Environmental Protec tion Agency’s (EPA’s) final approval of a single remote-handled (RH) transuranic (TRU) debris waste stream characterized using the waste characterization program implemented by the Central Characterization Project (CCP) at the Savannah River Site (SRS). In accordance with Title 40 of the Code of Federal Regulations (40 CFR), Section 194.8(b), EPA inspected SRS-CCP’s RH TRU waste characterization program at SRS in Aiken, South Carolina. Baseline Inspection N o. EPA-SRS-CCP-RH-08.11-8 took place on August 30–September 1, 2011, with a follow-up in spection on December 6–7, 2011, at SRS. Upon this EPA approval, the U.S. Department of Ener gy (DOE) can emplace the SRS-CCP RH TRU debris waste stream discussed in this report in the Waste Isolation Pilot Plant (WIPP).

EPA issued a proposed approval decision notice on F ebruary 24, 2012 (77 FR 11112-11115). Along with this proposed approval, EPA announced a 45-day public comment period which closed on April 9, 2012. EPA did not receive any co mments. As a result, EPA is finalizing the proposed approval of SRS-CCP’s RH TRU waste charact erization program for debris waste (S5000) along with the conditions and limitations i dentified in Table 1 and as discussed in this report. DOE is approved to emplace SRS-CCP RH TRU d ebris waste as discussed in this report in the Waste Isolation Pilot Plant (WIPP).

The inspection’s scope included one RH TRU waste st ream, SR-RH-FBL.01, consisting of debris waste from the FB-Line at SRS. The waste was generated by glovebox operations, decontamination, housekeeping, and maintenance and construction activities conducted from 1975 through 1984. This inspection evaluated: the u se of acceptable knowledge (AK); dose-tocurie (DTC) in conjunction with radionuclide-specif ic scaling factors derived in part by measurement with the In Situ Object Counting System (ISOCS) and historical assays of containers from the contact-handled (CH) counterpart waste stream at SRS, SRW027-FB-Pre86-C; and real-time radiography (RTR) to confirm th e physical form and waste material parameters (WMP) of waste drums.

EPA approves the SRS-CCP waste characterization pro gram implemented to characterize RH debris waste from Waste Stream SR-RH-FBL.01 that wa s evaluated during the baseline inspection process and the results for which are do cumented in this report. This final approval includes the following:

(1) The AK process for RH TRU debris waste streams that have companion 1 CH debris
waste streams (2) The radiological characterization of eight drums in Waste Stream SR-RH-FBL.01 using DTC and scaling factors generated through use of th e ORTEC/ISOCS prior to the baseline inspection and historical assays of compan ion (see footnote1) CH debris waste streams for assigning radionuclide values, accordin g to the limitations discussed in Section 8.2 of this report

1 A companion CH waste stream has the same summary c ategory group, same waste stream definition, and same radiological and physical properties as the su bject RH waste stream. In this case, the only diffe rence between containers in the companion CH waste stream and tho se in the subject RH waste stream is the waste’s ex ternal dose rate; i.e., less than or greater than 200 millirem per hour (mrem/hr), which makes the waste CH or RH, respectively.2

(3) The radiological characterization process using DTC and scaling factors generated through use of the Mobile Characterization Services (MCS)/ISOCS and historical assays of companion (see footnote1) CH debris waste stream s for assigning radionuclide values for RH waste, as documented in CCP-AK-SRS-581, Revi sion 1, supported by the calculation packages (or equivalent documentation), and subject to the limitations discussed in Section 8.2 of this report
(4) The RTR process to identify WMPs and the physical f orm of RH TRU debris waste

This baseline approval of SRS-CCP’s RH TRU waste ch aracterization program allows SRS-CCP to characterize RH waste from Waste Stream SR-RH-FB L.01 in accordance with the conditions and restrictions discussed in this report and summa rized in Table 1 below. From now on additional debris waste stream(s) having a companio n (see footnote 1) CH waste stream(s) may be disposed of at the WIPP provided that an approve d radiological scaling factor development process is used.

Use of the MCS/ISOCS is limited to the generation o f scaling factors for specific radionuclides, i.e., the activity ratios of plutonium (Pu) isotope s plutonium-239 ( 239 Pu), plutonium-240 ( 240 Pu) and plutonium-241 ( 241 Pu) to americium-241 ( 241 Am). Further, use of the MCS/ISOCS for determining the scaling factor for plutonium-238 ( 238 Pu) or for direct quantification of any radionuclide is prohibited.

A Tier 1 (T1) change approval is necessary when:

• The radiological scaling factors development proces s used for characterizing RH debris waste differs from the process approved;

• An RH TRU debris waste stream characterized for WIP P disposal does not have a companion (see footnote 1) CH waste stream;

• An RH TRU non-debris waste stream from the solids ( S3000) or soils and gravel (S4000) summary category groups is characterized for WIPP d isposal; or

• The ORTEC/ISOCS is used for RH debris waste charact erization in the future.

EPA must verify compliance with 40 CFR 194.24 befor e waste may be emplaced in the WIPP, as specified in Condition 3 of EPA’s certification of the WIPP’s compliance with disposal regulations for TRU radioactive waste [63 Federal Register (FR) 27354 and 27405, May 18, 1998]. EPA Baseline Inspection No. EPA-SRS-CCP-RH-0 8.11-8 was performed in accordance with the provisions of 40 CFR 194.8(b), as issued i n a July 16, 2004, FR notice (Vol. 69, No. 136, pp. 42571–42583).3Table 1. Tiering of RH TRU Waste CharacterizationProcesses Implemented by SRS-CCP (April 2012)(Based on August 20–September 1, 2011, and December6–7, 2011, Baseline Inspection)RH WasteCharacterization ProcessElementsSRS-CCP RH Waste Characterization Process – T1 ChangesSRS-CCP RH Waste Characterization Process – T2 Changes*Acceptable KnowledgeAny new RH S3000 or S4000 waste stream (AK Summary)Any new RH S5000 waste stream that does nothave a companion CH wastestream (AK Summary)Substantive modification(s)** to CCP-AK-SRS-580 orCCP-AK-SRS-582 thathave the potential to affect the characterization process (AK2, AK6)Any new RH S5000 waste stream that doeshave a companion CH waste stream(AK Summary)Notification to EPA:•Upon completion of revisions to CCP-AK-SRS-580, CCP-AK-SRS-582,CCP-TP-005, or nonconformance and corrective actionprocedures thatrequire CBFO approval*** (AK2, AK5, AK6)•Upon completion of revisions to any CCP-TP-005 attachments, includingwhen Attachment 4 is generated to reflect the updated AKSR SourceDocument Reference List (AK5, AK11)•When the final or revised WSPF, CIS, CRR and related attachments areavailable and upon completion of any subsequent revisions to thesedocuments (AK10)•When AK accuracy reports are completed, prepared annually at a minimum(AK11)•When Add Container Memoranda have been prepared (AK5)•When additional discrepancy resolution reports andnonconformance reportshave been prepared (AK4)Radiological Characterization,including Dose-to-CurieUse of the MCS/ISOCS to provide any information other than the relativedeterminations of239Pu,240Pu and241Pu to241Am (RC2)Future use of the ORTEC/ISOCS for any RH TRU waste(RC2)Application of a new scaling factor processes for isotopic determination other thanthose documented in CCP-AK-SRS-581, Revision 1 (applies to new RH wastestreams and to the addition of containers to an approved waste stream) (RC1, RC4,RC5)Substantive modification(s)** to CCP-TP-504 or CCP-AK-SRS-581 that have thepotential to affect the characterization process (RC4, RC5)Any new RH waste stream characterized using an approved scaling factor processfor isotopic determination (RC Summary)Notification to EPA upon completion of revisions toCCP-AK-SRS-581 orCCP-TP-504 that require CBFO approval*** (RC1, RC5)Notification to EPA when calculation package(s) CCP-SRS-44, or equivalentrecord(s), are available (RC Summary)Real-Time Radiography RTR by any new process (RTRSummary)Notification to EPA upon completion of changes to RTR procedure(s) that requireCBFO approval*** (RTR1)Addition of a new SCG to any approved RTR process (RTR2)Notes:* SRS-CCP will report all T2 changes to EPA every three months.**Substantive modificationrefers to a change with the potential to affect SRS-CCP’s RH waste characterization process; e.g., the use of an inherently different type ofmeasurement instrument or the use of probes not described in CCP-TP-504, excluding changes related solely to safety or to address administrative concerns.*** Notification to EPA is not necessary when document updates are editorial in nature or are requiredsolely to address administrative concerns.4

2.0 PURPOSE OF INSPECTIONS

On May 18, 1998, EPA certified that the WIPP would comply with the radioactive waste disposal regulations in 40 CFR Part 191. In that ce rtification, EPA also included Condition 3, which states that “the Secretary shall not allow sh ipment of any waste from...any waste generator site other than [Los Alamos National Labo ratory (LANL)] for disposal at the WIPP until the Agency has approved the processes for cha racterizing those waste streams for shipment using the process set forth in §194.8.” The approva l process described in 40 CFR 194.8 requires DOE to (1) provide EPA with information on AK 2 for waste streams proposed for disposal at the WIPP and (2) implement a system of controls used to confirm that the total amount of each waste component that will be emplaced in the WIPP w ill not exceed limits identified in the WIPP Compliance Certification Application.

The rule applying to this baseline inspection can b e found in the FR (Vol. 69, No. 136, pp. 42571–42583, July 16, 2004). Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, FR notice, EPA must perform a baseli ne inspection of a TRU waste generator site’s waste characterization program. The purpose of the baseline inspection is to approve the site’s waste characterization program based on the demonstration that the program’s components, with applicable conditions and limitati ons, can adequately characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes destined for disposal at the WIPP. An EPA inspection team conducts an on-sit e inspection to verify that the site’s system of controls is technically adequate and properly im plemented. Specifically, EPA’s inspection team verifies compliance with 40 CFR 194.24(c)(4), which states the following:

Any compliance application shall: . . . Provide inf ormation which demonstrates that a system of controls has been and will continu e to be implemented to confirm that the total amount of each waste component that will be emplaced in the disposal system will not exceed the upper limiting value or fall below the lower limiting value described in the introductory text o f paragraph of this section. 3 The system of controls shall include, but shall not be limited to: measurement; sampling; chain of custody records; record keeping systems; waste loading schemes used; and other documentation.

In other words, the purpose of the baseline inspect ion is to implement the requirements of 40 CFR Part 194 by assessing whether DOE sites that characterize TRU waste prior to disposal at the WIPP are capable of characterizing and track ing the waste. EPA may also conduct followup inspections to address issues remaining from the baseline inspection or to seek further clarification/discussion related to waste character ization processes evaluated during a baseline

2 As of the FR notice of July 16, 2004, EPA has repl aced the term process knowledge with acceptable knowledge . Acceptable knowledge refers to any information ab out the process used to generate waste, material inputs to the process, and the time period during w hich the wastes were generated, as well as data res ulting from the analysis of waste conducted prior to or separate fr om the waste certification process authorized by an EPA certification decision to show compliance with Cond ition 3 of the certification decision.

3 The introductory text of 40 CFR 194.24(c) states, “For each waste component identified and assessed pursuant to [40 CFR 194.24(b)], the Department shal l specify the limiting value (expressed as an upper or lower limit of mass, volume, curies, concentration, etc.) , and the associated uncertainty (i.e., margin of e rror) for each limiting value, of the total inventory of such wast e proposed for disposal in the disposal system.”5

inspection. By approving the CCP-implemented waste characterization systems and processes at SRS-CCP for RH debris waste, EPA confirms that it h as evaluated the capabilities of systems and processes implemented by the site to accomplish two tasks: (1) identification and measurement of waste components, such as Pu, that m ust be tracked for compliance 4 and (2) confirmation that the waste in any given contai ner has been properly identified as belonging to the group of approved waste streams.

3.0 PURPOSE OF THIS REPORT

This report documents the basis for EPA’s baseline approval and explains the results of Baseline Inspection No. EPA-SRS-CCP-RH-08.11-8 in terms of f indings or concerns. Specifically, this report does the following:

• Describes the SRS-CCP approved waste characterizati on systems

• Delineates a specific set of approved RH wastes

• Provides objective evidence supporting the approval basis for all waste characterization systems

• Identifies all relevant system limitations and/or c onditions for each waste characterization system and/or waste containers that are subject to this approval

Any changes to the waste characterization activitie s from the date of the baseline inspection must be reported to and, if applicable, approved by EPA, according to Table 1. Please note that most T1 and Tier 2 (T2) changes listed in Table 1 are fo llowed by a reference to the section of this report where the technical basis for that T1 or T2 designation is presented; T1 or T2 changes listed in Table 1 without a reference are meant to clarify the scope of the approval.

T1 changes will require EPA review and approval pri or to implementation and will apply to any new waste category groups or equipment types that w ere not evaluated during the baseline inspection.

SRS-CCP must report and submit documentation on T1 changes when they are ready for EPA review. Upon initial review, EPA will inform SRS-CC P and the Carlsbad Area Field Office (CBFO) whether a site inspection is necessary. EPA may request additional information, choose to conduct a desktop review, and/or confer with SRS -CCP personnel. Upon evaluation with or without a site inspection, EPA will issue a decisio n. Only upon receiving EPA written approval may SRS-CCP implement T1 changes.

4 The potential contents of a single waste stream or group of waste streams determine which processes c an adequately characterize the waste. For example, if AK suggests that the waste form is heterogeneous, t he site should select the matrix-appropriate radiological characte rization technique to obtain adequate radionuclide measurements. Visual Examination (VE) serves to confirm and quant ify waste components, such as cellulosics, rubbers, plastics, and metals. Once the nature of the waste has been c onfirmed, characterization techniques quantify sele cted radionuclides in the waste. In some cases, a TRU wa ste generator site may be able to characterize a ra nge of heterogeneous waste streams or only a few. A site’s stated limits on the applicability of proposed was te characterization processes govern the scope of EPA’ s inspection.6

EPA will notify the public of the results of its ev aluations of T1 and T2 changes established as part of the SRS-CCP final approval through the EPA website and by sending emails to the WIPPNEWS list. All T1 changes must be submitted for approval before their implementation and will be evaluated by EPA. SRS-CCP must submit T 2 changes that have been implemented four times a year, at the end of each fiscal quarte r.

The DOE documents that EPA reviewed for this evalua tion are cited throughout the report and are listed in Attachment A. Any of these documents can be requested from the following address:

Manager, National TRU Program Carlsbad Field Office U.S. Department of Energy P.O. Box 3090 Carlsbad, NM 88221-3090

EPA’s final approval decision regarding the SRS

- CCP RH waste characterization program will be conveyed to DOE separately by letter following E PA’s review of public comments received responding to the approval discussed in this report . In accordance with 40 CFR 194.8(b)(3), this information is also available on EPA’s website at w ww.epa.gov/radiation/wipp.

4.0 SCOPE OF INSPECTION

The scope of Baseline Inspection No. EPA-SRS-CCP-RH -08.11-8 included the technical adequacy of the waste characterization systems used by SRS-CCP to characterize RH TRU Waste Stream SR-RH-FBL.01. The EPA inspection team evaluated these systems with respect to their ability to perform the following:

• Provide adequate documentation regarding the origin and classification of the RH TRU wastes proposed for disposal at WIPP using AK.

• Identify and quantify the activities and associated uncertainties of the 10 WIPP-tracked radionuclides [ 241 Am, cesium-137 ( 137 Cs), 238 Pu, 239 Pu, 240 Pu, plutonium-242 ( 242 Pu), strontium-90 ( 90 Sr), uranium-233 ( 233 U), uranium-234 ( 234 U) and uranium-238 ( 238 U)] and other TRU radionuclides using a combination of ISOCS measurements, AK, and DTC with the application of radionuclide-specific s caling factors.

• Assign WMPs correctly for RH retrievably stored deb ris waste that was repackaged using RTR.

During an inspection, EPA does not approve characte rization data; that function is the sole responsibility of the entity being evaluated, in th is case, SRS-CCP. EPA evaluates the site’s waste characterization processes to characterize RH TRU debris waste. The SRS-CCP evaluation consisted of reviewing training records and intervi ewing waste characterization personnel to assess their understanding of: (a) EPA regulations governing TRU waste characterization activities and EPA’s approval of TRU waste for WIPP disposal; (b) waste characterization processes implemented and available as alternatives ; and (c) SRS-CCP’s documentation and record-keeping procedures. In addition, the EPA eva luation focused on observing equipment7

operations and waste characterization practices at SRS controlled by site procedures, and on inspecting records related to each of the waste cha racterization processes within the inspection’s
scope.

An important aspect of this evaluation is the objec tive evidence documenting the effectiveness of the waste characterization processes. Objective evi dence typically takes the form of batch data reports (BDRs), AK accuracy reports, and RTR record s. Site-specific waste characterization process documents can also serve as objective evide nce. During this inspection, EPA selected samples of each of these items, based on the number and variety of items each waste characterization process produced, consistent with standard auditing techniques. Based on its evaluation of the waste characterization processes in conjunction with objective evidence, EPA determined the technical adequacy of these processe s and associated records within the inspection’s scope.

DOE’s Remote-Handled Waste Characterization Program Implementation Plan (WCPIP), DOE WIPP-02-3124, Revision 2, was effective as of April 21, 2011. EPA requires that all CCP RH TRU waste characterization activities, including th e preparation of documentation and the documents themselves, be in conformance with the la test version of the WCPIP. All mention of the WCPIP in this report refers specifically to DOE WIPP-02-3124, Revision 2.

5.0 INSPECTION-RELATED DEFINITIONS

During the course of an inspection, EPA inspectors may encounter items or activities that require further inquiry for their potential to adversely af fect waste characterization and/or isolation within the repository. The two main categories rele vant to waste characterization inspections are identified below:

• Finding : A determination that a specific item or activity does not conform to 40 CFR 194.24(c)(4). A finding requires a response from CBFO prior to site approval.

• Concern : A judgment that a specific item or activity may o r may not have a negative effect on compliance and, depending on the magnitud e of the issue, may or may not require a response. A concern requiring a response requires a response from CBFO prior to site approval.

6.0 PERSONNEL

EPA and its support personnel conducted interviews with SRS-CCP personnel in several disciplines during two site visits to SRS. The memb ers of the EPA inspection team and CBFO, SRS, and SRS-CCP personnel contacted are listed in Attachment B.

7.0 PERFORMANCE OF THE INSPECTION

7.1 Savannah River Site Background

SRS is located near Aiken, South Carolina. SRS was constructed during the early 1950s to produce the basic materials used in the fabrication of nuclear weapons, primarily tritium and8

239 Pu, in support of the national defense program. Its main focus has been to develop technical solutions to support national security and to count er national and international threats. Site activities support national needs in the area of nu clear weapons, nonproliferation and assessments, military technologies and applications , energy and infrastructure assurance, and homeland security.

Waste Generation Activities

Waste Stream SR-RH-FBL.01 originated in the FB-Line between January 1975 and December 1984. The FB-Line is in the F-Canyon at SRS and was constructed in 1951–1953, when its first mission was the production of weapons-grade plutoni um (WG Pu) 5 in 1954. Later FB-Line functions were the concentration and purification o f Pu and recovering Pu from scrap. The waste stream was generated by maintenance and routine hou sekeeping operations and other activities. Wastes were not intentionally segregated by process area, and low-level waste (LLW), CH waste, and RH TRU waste were generated. CH TRU debr is generated by FB-Line operations are in Waste Stream SR-W027-FB-Pre86C, and RH TRU debri s are in Waste Stream SR-RHFLB.01.

7.2 Inspection Process Overview

EPA conducted Baseline Inspection No. EPA-SRS-CCP-R H-08.11-8 of SRS-CCP’s program to characterize RH TRU wastes on two occasions from Au gust through December 2011. This inspection had the scope described in Section 4.0 f or the purpose of determining the site’s compliance with 40 CFR 194.24. The inspection was c onducted in the following steps:

(1) Obtaining and reviewing site procedures, reports, a nd other technical information related to RH waste characterization activities used to cha racterize SRS-CCP Waste Stream SR-RH-FBL.01
(2) Preparing technical questions prior to the inspecti on based on the activities cited in (1) above
(3) Interacting with CBFO and SRS-CCP personnel to arra nge inspection logistics
(4) Evaluating SRS-CCP’s implementation of waste charac terization processes for adequacy and demonstrating compliance with 40 CFR 194.24 req uirements
(5) Conducting the baseline inspection at SRS to verify the technical adequacy and/or qualifications of RH waste characterization personn el, procedures, processes and equipment, as documented in SRS-CCP records
(6) Observing the execution of the ISOCS and DTC proces ses at SRS during two site visits
(7) Evaluating the development of radionuclide-specific scaling factors
(8) Evaluating the correlations of containers for the p urpose of identifying common attributes

5 Weapons-grade plutonium is defined as material that is approximately 93% 239 Pu and 6% 240 Pu with trace amounts of 238 Pu, 241 Pu and 242 Pu.9

(9) Communicating all pertinent information to CBFO and SRS-CCP personnel
(10) Conducting entrance, exit and daily briefings for C BFO and SRS-CCP management personnel
(11) Obtaining and reviewing SRS-CCP documents that were revised and/or created in response to EPA concern after the inspection
(12) Issuing the inspection report and proposed/final ap proval

8.0 TECHNICAL EVALUATION

Sections 8.1 through 8.3 of this report detail the three technical areas assessed during this inspection:

• AK

• Radiological characterization

• RTR

8.1 Programmatic Requirements and Acceptable Knowledge

EPA examined the programmatic requirements and AK p rocess and associated information to determine whether SRS-CCP demonstrated compliance w ith 40 CFR 194.8 requirements for RH Waste Stream SR-RH-FBL.01.

Waste Characterization Element Description

As part of the inspection, EPA reviewed the adequac y of the following aspects of the use of AK for RH waste characterization by SRS-CCP:

• Inspection scope and waste stream identification

• Identification of the WCPIP waste characterization process

• Certification Plan and other WCPIP documentation

• WCPIP waste qualification pathway

• Data management reviews, validation activities, dat a reporting, and records retention

• AK personnel training

• Waste Stream Profile Form (WSPF) and related attach ments

• Nonconformance and discrepancy resolution documenta tion

• Waste stream definition including radiological and physical characteristics

• Verification that the subject waste is of defense o rigin and is not LLW, high-level waste (HLW), or spent nuclear fuel (SNF)

• Role of AK in the characterization methodology, inc luding support of scaling factors10

• AK procedure and implementation, including attachme nts [AK accuracy, Characterization Reconciliation Reports (CRRs), Cor relation and Surrogate Summary Forms (CSSFs)]

• AK summary report (AKSR) and associated source docu ments

• AK data traceability

• Attainment of data quality objectives (DQOs)

Documents and Batch Data Reports Reviewed

Source documents, attachments, forms and other data were provided to EPA and were reviewed, as applicable. The list of all documentation examin ed is in Attachment A. The BDRs examined are listed in Table 2.

Table 2. Batch Data Reports Examined

Drum No. RTR BDR DTC BDR
SR504233 SR4RTR0173 SRSRHDTC11002 SR510588 SR4RTR0173 SRSRHDTC11002 SR512002 SR4RTR0173 SRSRHDTC11002 SR501028 SR4RTR0173 SRSRHDTC11002 SR504242 SR4RTR0173 SRSRHDTC11002 SR526627 SRSRTR0425 SRSRHDTC11001 SR504196 SRSRTR0425 SRSRHDTC11001 SR513217A SRSRTR0425 SRSRHDTC11001 SR118870 SRSRTR0425 SRSRHDTC11001

Technical Evaluation

EPA evaluated the adequacy of AK information specif ic to Waste Stream SR-RH-FBL.01 as described in CCP-AK-SRS-581, Revision 0, and CCP-AK -SRS-580, Revisions 1, 2 and 3. EPA also evaluated WCPIP programmatic requirements rela ted to Waste Stream SR-RH-FBL.01 characterization activities.

(1) The scope of CBFO’s baseline inspection request and waste stream designation were examined for Waste Stream SR-RH-FBL.01 and found to be adequate (WCPIP, Section 3.0, p. 13). 6

The purpose of a baseline inspection is to evaluate the adequacy, implementation and effectiveness of the technical processes used to ch aracterize WIPP-bound TRU waste. EPA inspectors evaluated the scope of the inspection th at DOE presented for clarity and focus. DOE is seeking EPA approval of SRS-CCP’s approach. SRS-CCP implemented waste characterization processes to characterize RH TRU debris (S5000) Was te Stream SR-RH-FBL.01, as described in the AKSR and Radiological Characterization Report. EPA reviewed CBFO’s scope and agreed that it is limited to Waste Stream SR-RH-FBL.01, as characterized using the approach presented

6 The WCPIP references are examples and are not mean t to be an exhaustive list. Many of these requirements are discussed in several places within the WCPIP.11

in CCP-AK-SRS-581, Revision 0. The scope of DOE’s b aseline inspection request laid out SRS-CCP’s RH waste characterization approach in suf ficient detail.

The WCPIP defines the waste stream as waste materia l that is (1) generated from a single process/activity and (2) similar in material, physi cal form, and radiological properties. EPA examined the containers that were characterized acc ording to the method described in CCP-AKSRS-581, Revision 0, and described in CCP-AK-SRS-58 0, Revisions 1, 2 and 3, to determine whether the waste stream was adequately defined.

The AKSR (Revision 3) states that the waste stream is currently composed of nine 7 containers that originated at the FB-Line and were generated a nd packaged between January 1975 and December 1984. The F-Canyon was constructed at SRS in 1951–1953 and contains the FB-Line, which began production of WG Pu in 1954 (References D020 and D035). The FB-Line functions were (1) conversion of dilute Pu solutions from the 221-F Canyon Building into highly purified Pu metal and (2) recovery of WG Pu from scrap produ ced in the FB-Line and shipped to SRS. Five processing operations took place along the FB- Line: cation exchange, precipitation filtration, drying, reduction and finishing (Refere nces C021, C025, C027 and C028). The waste stream was generated by maintenance and routine hou sekeeping operations that included sump cleaning, glovebox and equipment (e.g., furnace, hy draulic lift) repair, filter replacement, cabinet window and glove changeout, filter repair, cabinet sweepings, sump cleanouts, cabinet wipedowns, spill/leak cleanups, absorption of liqui ds, and other activities (References C021, C022, C026, C031, C032, C056, C067, C071, D035 and D037). Waste generated by these activities included plastics, personnel protective equipment, routine laboratory and job control waste, rubber gloves, and metals and floor sweeping s. This produced low-level, CH, and RH TRU wastes that were not intentionally segregated b y process area. CH TRU debris generated by FB-Line operations are in Waste Stream SR-W027-FB-P re86C, and RH TRU debris are in Waste Stream SR-RH-FLB.01.

Other nuclear material was processed in the FB-Line in addition to WG Pu (Reference CCP-AKSRS-2, Revision 13). Occasional “months-long” campa igns were conducted to produce special isotopic blends, including mixtures that were eleva ted in 240 Pu. Scrap recovery campaigns also processed 242 Pu, 241 Am, curium-244 ( 244 Cm) and 240 Pu oxide, as well as Lawrence Livermore mixed oxide and Hanford oxide scrap. Special recove ry accounted for approximately 15% of the FB-Line operations in the 1970s and consisted of va rious “special isotopic composition” materials. The FB-Line occasionally managed resin w aste that potentially contained fission products that were not adequately removed during ea rly processing activities (References C021, C026, C027, C032, D013, D020, D033 and D037).

The AKSR and related source documents indicate that Waste Stream SR-RH-FBL.01 was generated from the same general processes as the pr eviously approved CH Waste Stream SR-W027-FB-Pre86-C, from which the RH containers we re segregated. EPA evaluated the radiological and physical compositions of drummed w aste [Item (7)] and found them to be adequately defined for radiological and physical as pects. EPA’s analysis showed that the

7 SNL-CCP was unable to develop scaling factors for one of the nine drums it presented initially; there fore, most documentation pertaining to Waste Stream SR-RH -FBL.01. The rest of this report, therefore, descri be the waste stream as containing eight containers.12

selected drums are traceable to the FB-Line operati ons [Item (12)]. Based on this information, EPA determined that the waste stream is adequately defined.

(2) The Certification Plan, including a description of the waste characterization process, was examined and found to be complete and technically a dequate (WCPIP, Section 3, pp. 14– 15).

The Certification Plan is presented in CCP-AK-SRS-5 82, Revisions 0 and 1. The WCPIP states that the Certification Plan must describe the proce ss for certification of the waste stream, including a description of the characterization met hods selected (WCPIP, Section 4.1) and AK qualification method(s) (WCPIP, Section 5.0). The W CPIP requires that the Certification Plan include, at a minimum, the following:

• Description of AK qualification and/or characteriza tion methods selected to meet the DQOs, including the justification for the selection of the methods

• Description of the quality assurance objectives for the selected methods

• Detailed description of any characterization and te sting method not included in the WCPIP; the description of the method must be suffic ient to allow for CBFO approval prior to implementation of the method

• Summary of the program documents to be prepared dur ing the characterization and/or qualification methods selected for the waste stream

EPA reviewed the Certification Plan to evaluate com pliance with these document requirements, as well as the waste characterization requirements consolidated in the WCPIP from 40 CFR Parts 191 (Subparts B and C) and 194 and the WIPP Land Withdrawal Act (LWA) (Public Law 102- 579). EPA found that the plan included the necessar y components but required revision to clarify statements and make the content technically accurat e. Revisions identified by EPA included, but were not limited to:

• Removal of unnecessary language pertaining to DQOs and AK accuracy, if AK is not used to satisfy the DQO

• Clarification of the confirmatory testing plan cont ents and approach

• Clarification of waste stream size and generation d ate

SRS-CCP revised the Certification Plan to address E PA concerns (CCP-AK-SRS-582, Revision 1). Notification to EPA when formal revisi ons of the Certification Plan are available is a T2 change. Substantive modification(s) that have the potential to affect the characterization process are a T1 change. (See Table 1.) EPA suggest s that SRS-CCP RH AK personnel discuss with EPA any significant contemplated changes with the potential to affect characterization outcome. This will ensure that SRS-CCP does not tak e actions that may jeopardize SRS RH approval.13

(3) The waste qualification pathway was identified and the selected approach and documentation were adequate (WCPIP, Figure 2, p.15, and Sections 5.0–5.4).

40 CFR 194.24(c)(3)–(5) states that a system of con trols must be implemented to characterize waste components, and that this system must comply with quality assurance (QA) requirements found at 40 CFR 194.22. If AK is used to quantify c omponents, its use must also comply with §194.22, which states that data collected prior to implementation of the WIPP-specific QA program must be qualified by peer review, corrobora ting data, confirmatory testing, or demonstration that a QA program equivalent to Ameri can Society of Mechanical Engineers (ASME) NQA-1 requirements was in place at the time of characterization. EPA’s characterization requirements in 40 CFR 194.24 are presented in Figure 1, generated by EPA.

Figure 1. Characterization and Qualification Proces s * AK data must be qualified if used to quantify par ameters [§194.24(c)(3)]

Yes No

Qualification not required Qualify by Peer

Review, Equivalent QA, Confirmatory Testing, or Corroborating Data AK NDA, DA, or

DTC VE or RTR WDS Other, including programmatic controls System of Controls to Characterize Waste [40 CFR 194.24(c)(4)]

Are data obtained under approved QA program?* [§194.24(c)(3), (5)]14

The system of controls used to characterize waste i ncludes:

• AK for waste stream determination, defense determin ation, SNF, and HLW;

• Radiological characterization: radiological composi tion [nondestructive assay (NDA)];

• RTR: physical composition;

• WIPP Waste Data System (WDS) (data transfer); and

• Programmatic controls, including development of the appropriate plans and documents.

SRS-CCP used the ISOCS system and CH NDA data to de velop scaling factors for DTC. Because EPA had not previously approved the ISOCS, SRS-CCP prepared a Test Plan (CCP-AK-SRS-585, Revision 0) to support this system , discussed in Section 8.2 of this report. EPA examined the qualification approach and approve d its use for this SRS RH debris waste stream. The RTR system used by SRS-CCP was previous ly approved by EPA, as was the WDS system.

The characterization and qualification pathways use d by CCP are adequately defined. The Test Plan and Radiological Characterization Report are e valuated in Section 8.2 of this report.

(4) Example nonconformance documentation and discrepanc y resolutions were examined and found to be adequate (WCPIP, Section 3.4.2.3, p . 24).

SRS-CCP provided one example, Nonconformance Report (NCR) No. NCR-RHSRS-2940-11, that segregated “nonconforming” container No. SR504 196 because drum-specific radionuclide scaling factors had not yet been developed (CCP-AK- SRS-581, Revision 0). The NCR was adequately prepared.

SRS-CCP referenced two discrepancy resolution (DR) documents in the AKSR: DR001 and DR008 (CCP-TP-005, Revision 23, Attachment 11). DR0 01 dealt with discrepant dates for the drum culvert limit change from 0.1 curie (Ci) per p ackage to 0.5 Ci per drum. DR008 addressed erroneous application of the ignitable and reactive hazardous waste numbers based on the presence of calcium. EPA also examined DR documents for the analogous CH Waste Stream SR-W027-FB-Pre86-C (References DR3, DR3, DR6 and DR 009). The DRs were adequately prepared. Notification to EPA of the availability o f additional DR reports and NCRs is a T2 change. (See Table 1.)

(5) The Acceptable Knowledge Procedure was examined and found to be adequate and appropriately implemented (WCPIP, Section 4.1, pp. 32–33).

CCP-TP-005, Revision 22, integrated WCPIP, Revision 0d, Appendix A, requirements. CCP-TP005, Revision 23, clarified what constitutes a form al record to resolve a CBFO Corrective Action Report (CAR) 11-043. Revision 23 was effective June 30, 2011, but Revision 22 was in place at the time the AKSR and preliminary supporting work w ere prepared. EPA accepts the use of CCP-TP-005, Revision 22, as the appropriate revisio n for preparation of CCP-TP-005 attachments, but future changes to any attachments or documents should be prepared in accordance with the version of CCP-TP-005 in place at the time the changes are made.15

CCP-TP-005, Revision 22, includes 15 attachments an d requires development and maintenance of an AK tracking spreadsheet that presents a runni ng compilation of drums within each waste stream. Attachments 5, 9 and 12 are not relevant to EPA’s inspection. SRS-CCP prepared Attachments 1, 2, 3, 4, 6, 7, 8, 11, 13, 14 and 15 for Waste Stream SR-RH-FBL.01.

Attachment 1 was adequate. Adequate examples of Att achments 2 (Reference C018) and 3 were provided. Attachments 6 and 7 are addressed under I tem (7) below. Preparation of Attachment 10 was not yet required for this waste s tream. Attachment 11 is the DR form and is addressed in Item (4), and Attachment 12 is address ed in Item (6). Attachment 13 is adequate and AK accuracy (Attachment 14) is addressed under Item (11). Attachments 4, 8 and 15 are discussed below.

Attachment 4 did not include the “U” AK source docu ments cited in the radiological characterization report. SRS-CCP prepared a revised source document list (Attachment 4) in accordance with CCP-TP-005, Revision 23, that inclu ded these missing references. Also, CCP-TP-005, Revision 23, clarified CCP’s document p resentation and retention practices. Only those documents cited in the AKSR are presented in the AKSR reference list. Attachment 4 includes all references in the AKSR reference list as well as other references examined, but only those source documents cited in the AKSR will be pl aced in CCP Records. References examined and identified by CCP but not cited in the AKSR wil l not be available through CCP Records. Original records that were obtained from sites will be retained at the generator sites. References created by CCP, such as Attachment 3, will be retai ned as CCP QA records. While it is understood that these changes to CCP-TP-005 are mea nt to clarify the document presentation and records processes, EPA is concerned that this m ay encourage sites to present fewer references in the AKSRs, reduce the number of refer ences cited in Attachment 4, and limit access to cited references. EPA expects CCP to main tain Attachment 4 as a thorough and complete listing of all pertinent documents examine d for a waste stream or group of waste streams, including references presented in radiolog ical characterization reports, regardless of whether those references are presented on AKSR refe rence lists. Regardless of who retains supporting documents, EPA expects CCP to be able to provide a copy of any reference included in Attachment 4 at EPA’s request and to do so in a timely manner, i.e., during the course of an inspection. EPA views the AK process as an importan t system of controls, and documentation of successful AK source document acquisition and revie w is a critical aspect of the AK process.

CCP implemented a new approach to documenting drums within each waste stream. Attachment 8 will now contain all drums identified at the time of AKSR approval but will not be updated as in the past. Instead, SRS-CCP will gener ate Add Container Memoranda that document the addition and removal of containers fro m the waste stream and will place them in a single source document in the AK record. Therefore, Attachment 8, associated Add Container Memoranda, and the AK Tracking Spreadsheet together provide the full drum history and current waste stream inventory. SRS-CCP has not yet prepare d an Add Container Memorandum for Waste Stream SR-RH-FLB.01, so Attachment 8 and the AK Tracking Spreadsheet adequately document the drum inventory.

Attachment 15 is the CSSF. The completed form prepa red by SRS-CCP indicates that all of the characterization information, including program man agement, process information, waste16

generation, handling and waste management, apply eq ually to Waste Streams SR-RH-FBL.01 and SR-W027-FB-Pre86-C. The CSSF also states that, although the combined assay data for CH drums were used to develop estimated RH radionuclid e weight percentages, the actual percentages for each RH container would be determin ed by assay. These RH and CH waste streams will be characterized using different assay systems, and the AKSR states that the radiological information it presents is “an estimat e of what is to be expected once the radiological characterization method is implemented .” See Item (7) for additional information about the radiological characteristics of Waste Str eam SR-RH-FBL.01. Attachment 15 is adequate.

Notification to EPA when the abovementioned attachm ents are revised and updated is a T2 change. Notification to EPA when Add Container Memo randa have been prepared is a T2 change. Notification to EPA upon completion of revi sions to AK procedures (including CCP-TP005 and nonconformance and corrective action proced ures) is also a T2 change. (See Table 1.)

(6) The Acceptable Knowledge Summary Report was examine d, along with the reference list and associated source documents, and found to be ad equate (WCPIP, Section 4.1, p. 31).

EPA reviewed the AKSR (CCP-TP-005, Revision 23, Att achment 12) and found it to be deficient in several areas, including:

• Support for radiological characterization

• Identification of processes performed in the FB-Lin e that affect the radiological characteristics of the waste stream

• Identification of the waste stream size and waste g eneration dates versus waste packaging dates

• Explanation of the waste material parameter calcula tions

• Description of radiological characteristics and ori gin of the observed isotopic distribution

• Presentation of qualification and characterization processes in AKSR, Section 6

• Historic waste generation and management informatio n

SRS-CCP revised the AKSR (Revisions 2 and 3) to add ress EPA’s concerns. CCP-AK-SRS-580, Revision 3, adequately addresses EPA’s concerns. No tification to EPA when additional revisions of the AKSR are available is a T2 change. Substanti ve modification(s) that have the potential to affect the characterization process are a T1 change . (See Table 1.)

(7) Descriptions of the radiological and physical prope rties of the waste stream were examined and found to be adequate following revisio n of the acceptable knowledge summary report (WCPIP, Section 3.0, p. 13).

Waste Stream SR-RH-FBL.01 consists of debris and in cludes heterogeneous materials from operations, maintenance and housekeeping. SRS-CCP a ssigned Waste Matrix Code (WMC) S5400, Heterogeneous Debris, to Waste Stream SR-RH-FBL.01, which differs from the17

WMC S5300 assigned to the companion (see footnote 1 ) CH waste stream. The AKSR states that the reassignment is based on review of container do cumentation specific to Waste Stream SRRH-FBL.01 that showed a wider range of materials in RH waste than anticipated, based on CH information. This explanation is reasonable. Accord ing to DOE/LLW-217, DOE Waste Treatability Group Guidance (DOE 1995, References M051, M052, M054 and M055), treatability is assigned based on volume percent, b ut CCP-TP-005, Attachment 6 (WMP Memorandum), does not include volumetric informatio n. SRS-CCP stated that the RTR results provide verification of the assigned WMC, so the in formation is not presented in the Attachment 6 WMP Memorandum. This explanation is re asonable.

SRS-CCP indicated that the WMP estimates in the AKS R were based on the CH waste stream, but EPA questioned this because the data presented in the AKSR (Revision 1) reflected the RH-specific WMPs presented in Attachment 6 and did not mirror the CH waste stream physical description. SRS-CCP revised the AKSR to clarify th at AKSR Table 2 was created from Waste Stream SR-RH-FBL.01 RTR data that show the average waste stream composition is as follows:

• 59.5% iron-based metals and alloys

• 0.60% aluminum-based metals and alloys

• <0.1% other metals

• 5.67% other inorganic materials

• 1.16% cellulosics

• 8.70% rubber

• 24.38% plastics

• <0.1% other organic matrices and inorganic matrices

• No soils or gravel

The stream averages (by weight) 34.24% organic wast e and 65.77% inorganic waste. The physical composition of the waste stream is adequat ely defined.

The AKSR states that the FB-Line produced WG Pu dur ing the time of waste generation (1975– 1984; References C021, C024, C027, C044, C045, C072 , D008 and D037). The standard weapons-grade isotopic mix associated with the FB-L ine based on mass is:

• 92–94% by weight 239 Pu

• 5.8-6% by weight 240 Pu

• Less than 1% 238 Pu, 241 Pu, 241 Am (progeny of 241 Pu) and 242 Pu

The AKSR also states that this distribution was ver ified by 1982–1986 mass spectrometry data (Reference C026). Interviews with FB-Line personnel and site documentation confirm the production of WG Pu from 1971 to 1984 (References C 025, C026, C029, C067 and D030). SRS-CCP used the NDA results from 6,884 drums from associated CH Waste Stream SR-W027- FB-Pre86-C to develop an overall isotopic distribut ion that was applied to RH Waste Stream SRRH-SRS-581. The distribution by weight, shown in Ta ble 5 of the AKSR, is reproduced below:

• 238 Pu (0.04%) • 234 U (0.03%)

• 239 Pu (85.33%) • 235 U (0.20%)18

• 240 Pu (6.64%) • 238 U (5.31%)

• 241 Pu (0.24%) • 232 Th (1.41%)

• 242 Pu (0.07%) • 237 Np (0.14%)

• 241 Am (0.46%) • 208 Tl (0.07%)

• 233 U (0.01%) • 244 Cm (0.06%)

The AKSR Table 5 distribution is not representative of WG Pu. EPA asked SRS-CCP to explain this apparent discrepancy in light of statements in the AKSR that indicated only WG Pu was managed in the FB-Line during RH waste generation. EPA pointed out that the SR-W027-FBPre86-C AKSR identifies several months-long scrap r ecovery campaigns that were performed in the FB-Line and that contributed radionuclides othe r than WG Pu to the process lines. For example, the Recovery Unit in the FB-Line processed materials ranging from 2% to 20% 240 Pu; before 1980, the process material may have containe d up to 20% 240 Pu. A “High Pu Isotope” campaign was performed as well, as was at least one campaign that dealt with higher quantities of 241 Am (CCP-AK-SRS-2, Revision 13; References C21, C24, C27 and DR3). EPA identified other campaigns performed in the FB-Line between 19 72 and 1979 that processed material other than WG Pu including 242 Pu, 241 Am and 244 Cm (CCP-AK-SRS-2, Revision 13).

SRS-CCP revised the AKSR to address these campaigns and explain the isotopic distribution presented in AKSR Table 5. Additionally, EPA obtain ed the original spreadsheets used to generate AKSR Table 5 and was able to reproduce the values presented in AKSR Table 5 and in CCP-TP-005, Attachment 7. EPA concluded that the AK SR, as revised, adequately represents the physical and potential radiological composition of the RH waste stream.

(8) The waste stream information was examined and indic ates that the waste stream does not contain spent nuclear fuel or high-level waste (WCP IP, Section 2.2.7, p. 12).

The LWA prohibits the disposal at WIPP of SNF and H LW as defined by the Nuclear Waste Policy Act (NWPA). The NWPA and DOE M435.1-1 8 state that SNF is “fuel that has been withdrawn from a nuclear reactor following irradiat ion, the constituent elements of which have not been separated by reprocessing... . [However,] test specimens of fissionable material irradiated for research and development only, and n ot production of power or plutonium, may be classified as waste, and managed in accordance with the requirements of this Order when it is technically infeasible, cost prohibitive, or would increase worker exposure to separate the remaining test specimens from other contaminated ma terial.” The NWPA defines HLW as “the highly radioactive material resulting from the repr ocessing of spent nuclear fuel, including liquid waste produced directly in reprocessing and any sol id material derived from such liquid waste that contains fission products in sufficient concen trations, and other highly radioactive material that the commission, consistent with existing law, determines by rule requires permanent isolation.”

The AKSR states that Waste Stream SR-RH-FBL.01 cons ists of debris generated during Pu separation and purification processes for weapons m anufacturing. The Pu was recovered from Pu-nitrate solutions from various sources, includin g scrap delivered to SRS from other DOE

8 DOE M435.1-1 is DOE’s Radioactive Waste Management Manual.19

facilities and SNF rods. Two distinct operations ar e associated with the recovery of Pu from SNF: the plutonium/uranium extraction (PUREX) proce ss and production of WG Pu from the resulting Pu-nitrate solution. Waste produced durin g the PUREX stage is HLW and contains nearly all of the fission products that were in the SNF (References D016 and D035). PUREX process waste is not included in Waste Stream SR-RH -FBL.01. Waste produced during the Pu-production stage is the subject of this review a nd is not HLW; it was not produced directly from reprocessing the SNF and it does not contain h igh concentrations of fission products.

The F-Canyon as a whole did manage SNF and generate HLW while processing SNF to recover Pu. Waste Stream SR-RH-FBL.01 contains FB-Line debr is from operations and maintenance associated with processing and purifying WG Pu meta l. Fragments of SNF are not present in the debris, so the waste stream does not contain SNF. N early all of the fission products were removed from the Pu-nitrate solution before it ente red the FB-Line, and Pu-production wastes were never managed as HLW; therefore, Waste Stream SR-RH-FBL.01 does not contain HLW (References D016 and D035). The PUREX process waste s are not included in Waste Stream SR-RH-FBL.01.

(9) The waste stream information was examined and indic ates that the waste stream has defense pedigree (WCPIP, Section 2.2.7, p. 12).

TRU waste must be defense-related in order to quali fy for disposal at WIPP. The scope of this inspection is limited to the debris waste produced during Pu-production operations and maintenance activities in the FB-Line. The FB-Line mission since 1954 was to produce WG Pu for use in atomic weapons manufacturing (Reference D020). Defense nuclear materials production is one of the activities listed in the N WPA and, therefore, waste produced by activities in the FB-Line are defense-related in or igin. As discussed in Item (7), the FB-Line periodically participated in special recovery campa igns and may have produced non-WG Pu. Some of these campaigns were for other defense-rela ted research and development activities. According to DOE, when any defense-related and nond efense-related wastes are comingled and cannot be separated, these materials can be classif ied as defense waste. Therefore, Waste Stream SR-RH-FBL.01 has a defense pedigree (References D01 3, D016, D029, D035 and D054)

(10) The Waste Stream Profile Form and attached Characte rization Reconciliation Reports were examined and found to be adequate (WCPIP, Sect ion 3.4.2.1, p. 22).

SRS-CCP provided EPA with the draft WSPF, CRR, and Characterization Information Summary (CIS) on July 26, 2011. The WCPIP explicitly lists the required contents of the WSPF and the CRR. The WCPIP does not require the CIS; however, S RS-CCP has elected to combine the once-separate EPA and New Mexico Environmental Depa rtment WSPFs. Therefore, a CIS must be prepared and may be used in conjunction with the WSPF to meet all of the EPA requirements as documented in WCPIP. A Summation of Aspects acco mpanies the CIS; SRS-CCP provided it to EPA on August 30, 2011.

EPA examined the draft documents and found that som e revisions were necessary. The draft WSPF initially provided to EPA had been adapted fro m a WSPF for a different waste stream and required revision to correct all of the site and wa ste stream references. The WSPF also did not20

list the BDRs supporting waste stream characterizat ion (as required by the WCPIP), instead referencing the CIS. The draft CIS, however, did no t include the DTC BDRs. SRS-CCP revised the CIS to include the DTC BDRs. The WSPF, CIS and CRR are draft documents and, therefore, do not include the Site Project Manager (SPM) signa ture and date. The revised draft WSPF and CIS and the draft CRR are complete and adequate.

Notification to EPA of the availability of the fina l WSPF, CIS, CRR and any revisions to these documents and their attachments (e.g., Summation of Aspects) are T2 changes. (See Table 1.)

(11) The AK accuracy report and Correlation and Surrogat e Summary Form were examined and found to be adequate (WCPIP, Section 4.1, p. 30 , and Section 3.2.2, pp. 17–19).

EPA examined the draft AK accuracy report and found that it initially did not adequately address the following WCPIP requirements:

AK accuracy will be determined by assessing the per centage of waste containers that require reassignment to a new Summary Category Group or new waste stream based on the reevaluation of AK or on obtain ing testing, sampling and/or analysis data. It will also identify the percentage of containers for which there are significant discrepancies in radionuclide informati on between the AK record and measured values.

Therefore, EPA expects that the AK accuracy evaluat ion will include, among other evaluations, a comparison of the measured radionuclides and those expected based on AK. The AK accuracy report for Lot 1 of Waste Stream SR-RH-FBL.01 did n ot initially include an evaluation of the radionuclide distribution. EPA discussed this with SRS-CCP representatives, who revised the accuracy report to indicate that all eight containe rs are consistent with the anticipated radionuclide composition.

A few other clarification revisions were also neces sary to bring the AK accuracy report into full compliance with the WCPIP. As discussed for the Cer tification Plan in Item (2) above, AK accuracy does not evaluate whether the specific DQO s were met, and discussion of AK accuracy in terms of the DQOs gives the impression that AK i s used to meet all of the DQOs. Also, the AK accuracy report needed revision to clarify that not all of the AK was qualified. EPA discussed these issues with SRS-CCP representatives , who revised the AK accuracy report to remove reference to the DQOs and to clarify that no t all of the information in CCP-AK-SRS-502 was used to qualify AK.

SRS-CCP provided a revised draft AK accuracy report that reflects those changes and is adequate. Notification to EPA when AK accuracy repo rts are completed, prepared annually at a minimum, is a T2 change. (See Table 1.)

Waste Stream SR-RH-FBL.01 consists of RH containers that were originally classified as CH Waste Stream SR-WO27-FB-Pre86-C. Assay data from th is CH waste stream were used to estimate the radionuclide distribution in the AKSR. Therefore, a CSSF was required. EPA reviewed the CSSF and found it to be adequate. Noti fication to EPA of revision to the CSSF21

(CCP-TP-005, Attachment 15) or preparation of an ad ditional CSSF is a T2 change. (See Table 1.)

(12) Drum data are adequately traceable and are in the A K record (WCPIP, Sections 3.4.4.1, p. 20; 3.4.2.2, p. 23; and 4.1, pp. 29–34).

As discussed in Item (1), Waste Stream SR-RH-FBL.01 was produced and packaged during normal FB-Line operation and maintenance activities from 1975 to 1984. The drums were then stored at the Radioactive Waste Burial Grounds. SRS personnel were required to complete the Radioactive Waste Burial Ground records (BGRs) for each drum. The BGRs included such information as the assigned unique File Sequence Nu mber (FSN), the generating facility, waste volume, isotopic quantity, and a brief description (References P009 and P010). The BGRs are the earliest record of the drums in Waste Stream SR -RH-FBL.01. They clearly indicate that the drums originated in the FB-Line but do not provide any further information about the specific activities that produced each waste container.

EPA reviewed the records and determined that the dr ums proposed for emplacement in the WIPP facility as Waste Stream SR-RH-FBL.01 are traceable from the FB-Line to the burial ground and more recently through SRS prescreening and SRS-CCP characterization. Table 3 presents a summary of the traceability information reviewed. T he drums continued to be referenced by their FSNs throughout repackaging and characterization. A ll information summarized in Table 3, except for the two NCRs, is in the AK record as Ref erence M052.

(13) Acceptable knowledge training was examined and foun d to be adequate (WCPIP, Section 4.1, p. 32).

The WCPIP requires that characterization personnel responsible for compiling AK, characterizing RH TRU waste streams using the AK pr ocess, and assessing the AK characterization shall be qualified and trained to:

• The WCPIP

• The characterization program nonconformance and cor rective action process

• Site-specific training relative to the site’s waste streams (e.g., current AKSRs)

• Determining the radiological contents of individual containers

Through interviews and discussions, EPA was able to conclude that the SRS-CCP AK Experts (AKEs) are current with respect to the training req uirements listed above. Table 4 lists the objective evidence that EPA reviewed documenting th at the AKEs associated with Waste Stream SR-RH-FBL.01 are adequately trained to the elements listed above.22Table 3. Summary of Traceability AnalysisDrum No.BGR DateDrum TimelinesSR510588 4/10/80 Vented andpurged 1/21/04RTR quickscreen 6/19/04 –prohibited itemsfoundRepackaged7/9/08CCP RTR4/27/11 (BDRSR4RTR0173)SR504233 11/13/75 RTR quickscreen 11/1/03and 6/28/08Vented andpurged 11/3/03Vented andclosed 7/2/08CCP RTR4/27/11 (BDRSR4RTR0173)SR526627 12/11/84 RTR quickscreen 5/23/04and 4/9/06Repackaged11/9/06CH VE 11/9/06;NCR-SRS-1137-06 for wrongWMC –resolution to useas isCH radioassay,isotope list,MGA analysis3/2/07Headspace gasdrum sample3/8/076/8/09 NCRSRS-0533-09 forsurface dose rate9> 200 mrem/hr –reject reassign asRHCCP RTR4/26/11 (BDRSRSRTR0425)SR118870 3/13/80 RTR quickscreen 5/31/06 –prohibited itemsfoundTransferred toF-Canyon10/10/06Repackaged10/28/06Repackaged7/1/08 and splitinto 3 drums:118870 (only RHdrum), 118870A,118870B118870BRepackaged1/9/10 and splitinto 2 drums:118870B,118870C (bothCH)CCP RTR4/26/11 (BDRSRSRTR0425)9In this report the termdose rateis expressed in mrem/hr or mR/hr, which, while technically incorrect, are commonly used by DOE and CCP TRUgenerators. These terms are used throughout this report for convenience.23 Table 4. Objective Evidence of Training for AK Pers onnel

Name WCPIP Nonconformance and Corrective Action Process (CCP-QP-005) Site-Specific

Training Determining

Radiological Contents of Containers Current

Revision of CCP-TP-005

Mark Doherty Qual Card Qual Card CCP Document Control Screenshot Briefing R23: Briefing and Att. 5, 6, 7, 8, 15

Jason Montoya Qual Card Qual Card Email Statement Briefing R23: Briefing and Att. 1, 4
Steve Schafer Qual Card Qual Card Email Statement Briefing R23: Briefing

(14) Data quality objectives were evaluated and found to be adequately met (WCPIP, Section 3.4.2, p. 22).

The WCPIP identifies the following DQOs that must b e addressed:

Defense Waste, HLW and SNF Determination (Regulator y Basis: LWA) : This is required to ensure that the waste stream was generated by atomi c energy defense activities, is not HLW, and is not SNF. These are addressed in CCP-AK-SRS-580, Revision 2, and CCP-AK-SRS-582, Revision 1, as discussed in Items (9) and (8) above

.
Radioactive Properties (Regulatory Basis: LWA, EPA Certification of the WIPP) :

• TRU Waste Determination: Waste must contain more than 100 nanocuries (nCi) o f TRU isotopes per gram of waste.

• RH Waste Determination: Surface dose rate must be equal to or greater than 200 mrem/hr and less than 1,000 rem/hr.

• Activity Determination: The total waste inventory can be no more than 5.1 m illion Ci of RH TRU; activity limit per canister is 23 Ci per li ter; and all radionuclides important to release calculations must be tracked.

These three DQOs are addressed in CCP-AK-SRS-581, R evision 1, as discussed in Section 8.2 below.

Physical Properties (Regulatory Basis: EPA Certific ation of the WIPP) :

• Liquids: The absence of liquids in excess of 1% must be con firmed.

• Physical Form: The physical form of the waste to delineate the wa ste stream as required by the final certification rule must be determined.

These two DQOs concerning the waste’s physical form and the presence of liquids are discussed in Items (7) and (12) above and documented in RTR B DRs SR4RTR0173 and SRSRTR0425.24

EPA determined that the documents cited above suppo rted that all DQOs were achieved.

Summary of Acceptable Knowledge Findings and Concer ns

The EPA evaluation team did not identify any AK-rel ated findings or concerns. There are no open issues related to AK resulting from this inspe ction.

Tier 1 Acceptable Knowledge Changes

The following AK changes are T1 changes:

• Any new RH S3000 or S4000 waste stream

• Any new RH S5000 waste stream that does not have a companion (see footnote 1) CH
waste stream

• Substantive modification(s) to CCP-AK-SRS-580 or CC P-AK-SRS-582 that have the potential to affect the characterization process

Tier 2 Acceptable Knowledge Changes

The following AK changes are T2 changes:

• Any new RH S5000 waste stream that does have a companion (see footnote 1) CH waste
stream

• Notification to EPA is required:

o Upon completion of revisions to CCP-AK-SRS-580, CCP -AK-SRS-582, CCP-TP005, or nonconformance and corrective action proced ures that require CBFO approval

o Upon completion of revisions to any CCP-TP-005 atta chments, including when Attachment 4 is generated to reflect the updated AK SR Source Document Reference List

o When the final or revised WSPF, CIS, CRR and relate d attachments are available and upon completion of any subsequent revisions to thes e documents

o When AK accuracy reports are completed, prepared an nually at a minimum

o When Add Container Memoranda have been prepared

o When additional discrepancy resolution reports and nonconformance reports have been prepared

Baseline Acceptable Knowledge Approval

Based on this inspection, EPA approves the AK proce ss evaluated during this baseline inspection. The approval is limited to RH TRU debri s waste streams that have companion (see25

footnote 1) CH debris waste streams. Any additional RH waste resulting from characterization of the associated CH waste stream may be added to Wast e Stream SR-RH-FBL.01 provided specific conditions are met, as discussed in Sectio n1.0 above. Also, additional waste streams, beyond the waste stream that EPA evaluated as part of the baseline inspection, may be disposed of at the WIPP provided that they are debris waste streams and have a companion (see footnote 1) CH waste stream. When SRS-CCP characterizes for disposal any new RH TRU debris waste stream that does not have a companion (see footnote 1) CH waste stream or any RH TRU waste from the other two SCGs (solids and soils and grave l), EPA approval as a T1 change is
necessary.

8.2 Radiological Characterization

Waste Characterization Element Description

EPA evaluated the radiological characterization of SRS-CCP RH Waste Stream SR-RH-FBL.01 in terms of its technical adequacy, as supported by the program’s documents, procedures and controls, and the knowledge and understanding of th e personnel involved in the RH waste characterization program. During this RH inspection , the EPA inspection team evaluated the following elements of the SRS-CCP radiological char acterization program:

• ISOCS and DTC measurements made at SRS in June and August 2011, respectively

• Development of DTC correlations for 55-gallon drums based on MCNP5 modeling of the drum’s gamma dose rate using a one-Ci source of 241 Am, assumed to be the main contributor to the dose

• Derivation of radionuclide scaling factors using is otopic ratios found through ISOCS assays and isotopic distributions from historical a ssays of Waste Stream SR-W027-FBPre86-C

• Representativeness and technical adequacy of the an alytical data used to support the scaling factors

Each of these is discussed in the sections that fol low.

Documents Reviewed

All SRS-CCP RH radiological characterization docume nts that EPA reviewed to support this inspection are listed in Attachment A.

Technical Evaluation

The EPA inspection team evaluated the following asp ects:

(1) The overall radiological characterization process a nd its documentation were evaluated and found to be adequate.26

The radiological characterization process for Waste Stream SR-RH-FBL.01 differs from the RH characterization that EPA has observed at other CCP sites. Typically, the RH characterization process has included the collection and laboratory analysis of representative waste samples to determine the waste’s radionuclide composition (iso topics). Isotopic information forms the basis of radionuclide-specific scaling factors, i.e., tec hnically supported relationships between specific radionuclides and an easily measured gamma-emitting radionuclide, typically 137 Cs. Application of the DTC process requires scaling factors to dete rmine the radionuclide contents of each waste container.

The SRS-CCP RH radiological characterization progra m incorporated five main aspects:

• Historical information (AK) for CH Waste Stream SR- W027-FB-Pre86-C, as summarized in CCP-AK-SRS-580 and associated source documents

• Development of scaling factors for 239 Pu, 240 Pu and 241 Pu 10 to 241 Am based on ISOCS
measurements

• Development of scaling factors for 238 Pu, 233 U, 234 U, 238 U, 137 Cs and 90 Sr based on past assays of the RH waste stream’s CH counterpart, Was te Stream SR-W027-FB-Pre86-C

• MCNP5 modeling to determine the amount of 241 Am in each drum

• Direct exposure rate measurements (DTC) of each was te drum

The EPA inspection team prepared a flow diagram to accurately reflect this process, shown in Figure 2. EPA determined that the radiological char acterization process for Waste Stream SR-RH-FBL.01 was technically adequate and appropria tely documented. Any new RH waste stream not approved to date or the addition of cont ainers to Waste Stream SR-RH-FBL.01 that requires changing the established process of radiol ogical characterization from what is documented in CCP-AK-SRS-581, Revision 1, is a T1 c hange. (See Table 1.) Any change to CCP-AK-SRS-581 that requires CBFO approval is a T2 change. (See Table 1.)

10 EPA does not usually evaluate 241 Pu because it is neither a TRU radionuclide nor a W IPP-tracked radionuclide. However, 241 Pu accumulates over the time period of interest to this inspection, due to its 14.4-year half life, and it is the progenitor of 241 Am, which is the denominator of the scaling factor for all radionuclides.27

Figure 2. Flow Diagram of the Characterization Proc ess for SR-RH-FBL.01

Yes

Yes No No Select 12 drums from CH Waste Stream SR-W027-FB-Pre86-C. Each drum should have > 1 Ci Am-241 and be within theoperating range of the ISOCS (SRS-RH585 & SRS Submittal #061611)

Select an additional drum for each failed drum

Failure to prove concept for Pu-238: Pu-238 cannot be characterized based on ISOCS data Model dose rate using MCNP5 at 1 m from the mid-height elevation of a drum containing a 1-Ci Am-241 source uniformly distributed. This is done for each drum using its calculated waste density (SRS-RH-43 & SRS-RH-44)

Determine Am-241 content of each drum 

### Proof of Concept Execute DTC

No

Container-specific values for 10 WIPP-tracked radionuclides, Pu-241 and U-235 (BRD Nos. SRSRHDTC11001 & SRSRHDTC11002) 

### 1

3

Measure the isotopics for each RH drum on the ISOCS to determine the ratio of Pu-239, Pu-240 and Pu-241 (SRS Submittal #061711)



### 4 Assumptions/Definitions

• Scaling factor= (Activity of Radionuclide X)

. (Activity of Am-241 )

• RH Waste Stream SR-RH-FBL.01 has an isotopic distribution equivalent to CH Waste

Stream SR-W027-FB-Pre86-C

• All NDA measurements have been collected on WIPP-approved NDA equipment and are valid, i.e., meet appropriate performance criteria and are of drums containing > 1 Ci

Am-241

• All ISOCS measurements are acceptable, i.e., meet the performance criteria and are significantly above the system’s DL to allow
their use. Use AK data to derive Am-241 based scaling factor for Pu-242 and Pu-239 from their average ratio in the subset of SR-W027- FB-Pre86-C drums that containmore than 1 Ci of Am-241 (SRSRH-41) Sr-90 is not measured. It is reported in 1:1 ratio with Cs-137. This ratio was carried through as the Sr-90/Cs-137 scaling factor (SRS-RH-41)

U-234 is not measured. It is reported in 46.2:1 ratio with U-235. This ratio was applied to the U-235 MDA values to derive an upper estimate (SRS-RH-41) 

### 2

Proof of Concept: ISOCS can be used to develop Am-241 scaling factors for Pu-239, Pu-240 and Pu-241 Are 90% of comparisons within a factor of 2? (Post-Confirmation Test Memorandum) Are all values greater than 1.5 times the system’s MDA? Are criteria for ISOCS met? Assay selected 12 CH drums on approved CH NDA instrument Assay selected 12 CH drums on ISOCS (CCP-TP-139) Take 1 m dose rate reading at 0 ̊, 90 ̊, 180 ̊ and 270 ̊ for each drum in
waste stream (BRD Nos. SRSRHDTC11001 & SRSRHDTC11002)

Average 4 readings to develop the average dose rate for each drum

Use scaling factors to determine the amount of Cs-137, Sr-90, U-233, U-234, U-235, U-238 and Pu-238 in each container Multiply the ratios of Pu-239, Pu-240 and Pu-241 to Am-241 by the Am-241 activity for each container Use AK data from CH stream to determine the average ratio of Cs-137, U-233, U-235, U-238, and Pu-238 to Am-241 (SRS-RH-41) 

### Develop Scaling Factors for RH Drums

Calculations & Results28

(2) Use of the In Situ Object Counting System to derive isotopic ratios (scaling factors) was found to be correctly implemented and appropriately documented.

In Situ Object Counting System Description

An ISOCS is a portable assembly consisting of a gam ma detector, a cryostat, and supporting electronics. These components are installed on a mo veable cart, which can be positioned in proximity to the item being measured—in this case, an RH waste drum. The ISOCS software contains predetermined geometries that can be appli ed to a variety of sizes and shapes in the field without moving the item. These aspects provide two important advantages for using the ISOCS in the field.

First, the source-to-detector distance for a specif ic item is determined in the field based on the item’s external dose rate, allowing the user to opt imize the measurement efficiency. When measuring a number of items, a user can get close t o a low-dose-rate waste container and far from a high-dose-rate container with minimum adjust ments, addressing potentially problematic issues like excessive dead time associated with RH TRU drums.

Second, the predetermined geometries allow a user t o essentially derive an efficiency calibration for each item in the field by matching field condit ions with an established geometry without repositioning or manipulating the item. Because the system’s use is not tied to a specific waste configuration, the ISOCS has considerable flexibili ty; i.e., the same unit could measure a 5-gallon pail, a 30-gallon drum, or a 55-gallon dru m with minor adjustments in the field. Limitations include background interferences from o ther radionuclide-bearing items in the area as well as typical measurement control issues.

In Situ Object Counting System Background

An ISOCS instrument has never been used to assay WI PP-bound RH TRU waste drums. Like other NDA instruments in CH programs, the ORTEC/ISO CS is not a direct characterization method; it is used exclusively for obtaining the re lative ratios of 239 Pu, 240 Pu and 241 Pu to 241 Am. To demonstrate the ISOCS capabilities, SRS-CCP deve loped Test Plan CCP-AK-SRS-585, Revision 0, in which the results of drums that were assayed on an EPA-approved NDA system would be compared to ISOCS results for the same rad ionuclides. Specifically, 12 drums from CH Waste Stream SR-W027-FB-Pre86-C that each contai ned at least one Ci of 241 Am and had been assayed on the Box Segmented Gamma System or t he Segmented Gamma System 11 were assayed on the ORTEC/ISOCS. The ISOCS results were compared with the CH NDA values, and reasonable agreement between the measurements c onfirmed the ability of the ORTEC/ISOCS to obtain relative ratios of 238 Pu, 239 Pu, 240 Pu and 241 Pu to 241 Am (i.e., develop scaling factors for these radionuclides).

There was no ISOCS unit available for EPA to inspec t during the August 2011 visit. EPA returned to SRS in December 2011 to inspect two dif ferent ISOCS units at SRS-CCP, both located in the E Area, Building 643-43E, adjacent t o the Non Destructive Assay Box Counter

11 The Box Segmented Gamma System is the gamma compon ent of the NABC. EPA had previously approved both the box segmented and segmented syste ms for assaying CH TRU wastes at SRS.29

(NABC), in an area shielded by 55-gallon drums of w ater. EPA observed the set up and execution of both ISOCS units, referred to as the O RTEC/ISOCS and the MCS/ISOCS, and evaluated both units and their supporting documenta tion as described separately below. Tim Carlton operated both ISOCS units; the ORTEC/ISOCS was operated under the direction of Ray Dewberry, a Savannah River National Laboratory (SRN L) employee.

ORTEC/In Situ Object Counting System

The ORTEC/ISOCS unit uses an older coaxial germaniu m detector with Canberra ISOCS software. It was used to develop scaling factors fo r all eight drums of Waste Stream SR-RHFBL.01. SRS-CCP stated that this is the only time t he ORTEC/ISOCS will be used in the WIPP program, and, accordingly, EPA’s evaluation of this instrument was retrospective (i.e., to assess it in terms of its ability to support only the datafor the eight drums in Waste Stream SR-RHFBL.01 and not its future use). SRS-CCP initially i ntended to use ORTEC/ISOC to develop scaling factors of 238 Pu, 239 Pu, 240 Pu and 241 Pu to 241 Am. Therefore, SRS-CCP compared the ratios (scaling factors) obtained from the ORTEC/IS OCS with the previously preformed NDA assays. The scaling factor comparisons were deemed acceptable if 90% were within a factor of two, as established by SRS-CCP and documented in CC P-AK-SRS-585, Revision 0.

The scaling factor comparisons for 239 Pu, 240 Pu and 241 Pu were acceptable, and the scaling factors for these radionuclides to 241 Am can be determined from ISOCS measurements. Only half of the
238 Pu ratios were acceptable, and 238 Pu did not meet the test criterion. Accordingly, th e test failed to establish the ISOCS as a valid means of calculat ing the 238 Pu scaling factor. Therefore, the
238 Pu scaling factor for these eight RH drums must be established from the isotopic distributions of SR-W027-FB-Pre86-C, as discussed in Item (3) bel ow.

EPA observed the unit’s operation and determined th at it was technically adequate to collect data to support the development of radionuclide scaling factors for 239 Pu, 240 Pu and 241 Pu. The instrument had been calibrated prior to use in 2005 , as documented in WSRC-TR-2005-00431, Revision 0. Before collecting data for these eight RH drums, SRS-CCP conducted performance checks and backgrounds, evaluated them against esta blished operational criteria, and recorded them in the ISOCS logbook. The system was operated in accordance with SRNL Procedure ADS-2460, although SRS-CCP Procedure CCP-TP-139, Re vision 3, was revised before the December 2011 inspection to include a provision for the ORTEC/ISOCS. All appropriate measurement controls were performed and documented in the ISOCS log book. Replicate testing was not performed for the ORTEC/ISOCS unit. ISOCS v alues were documented in two batch reports, 12 MCS ISOCS Report, ISOCS DTC-RH Waste Drums, SRS Sub mittal #061611 and MCS ISOCS Report, ISOCS DTC-RH Waste Drums, SRS Submitt al #061711

.
The ORTEC/ISOCS is not approved for assaying any ad ditional containers, and future use of this instrument to characterize any RH TRU wastes is a T 1 change. (See Table 1.)

12 The titles of these reports indicate that they doc ument operation of the MCS/ISOCS, which is not the case; they document operation of the ORTEC/ISOCS.30

MCS/In Situ Object Counting System

The MCS/ISOCS uses a high-purity germanium (HPGe) d etector with Canberra’s ISOCS/LabSOCS software packages and is mounted on a cart like the ORTEC/ISOCS. EPA observed the unit’s operation and determined that i t was technically adequate to collect data to support the development of radionuclide scaling fac tors for 239 Pu, 240 Pu and 241 Pu. The instrument had been calibrated prior to use at Canb erra Industries in 2010, as documented in ISOCS/LabSOCS Detector Calibration Report, ACK#6732 8, Detector Model BE5025, S/N 4480

. The calibration was verified at SRS in November 201 1, as documented in ISOCS Calibration Verification Detector #4480. Operation of the MCS/I SOCS is controlled by SRS-CCP Procedure CCP-TP-139, Revision 4. Measurements on the MCS/ISO CS were not used as the measurement of record for any waste drums in this waste stream as of the date of the December 2011 site visit, and EPA did not evaluate any BDRs or batch reports of MCS/ISOCS data.

If future drums are discovered to be RH during the processing of CH Waste Stream SR-W027- FB-Pre86-C, EPA expects that these containers will be characterized using the MCS/ISOCS. No measurements of record have been performed to date on the MCS/ISOCS; therefore, if the first measurements of record are for Waste Stream SR-RH-F BL.01, EPA expects that batch reports or other documentation showing the first MCS/ISOCS mea surements of record and the results of any performance testing done to support those measu rements be provided when available. Use of the MCS/ISOCS to provide any information other than the relative determinations of 239 Pu, 240 Pu and 241 Pu to 241 Am observed during this baseline inspection is a T1 change. (See Table 1.)

Replicate Testing - MCS/In Situ Object Counting Sys tem

To obtain objective evidence on the precision of th e MCS/ISOCS, EPA required SRS-CCP to perform replicate measurements. Due to the nature o f the ISOCS equipment and the end use of the data it generates, EPA specified that SRS-CCP a ssay a standard drum with measurable quantities of 239 Pu, 240 Pu, 241 Pu and 241 Am without changing the measurement configuration i n any way between measurements. This technique is des igned to assess only the reproducibility (precision) of the ISOCS itself. 13

Precision is a quality associated with a set of mea surements and refers to the way in which repeated measurements of the same quantity conform to each other. Precision is determined by the dispersion of the measurements around their cen tral value. An instrument is precise if the set of measurements it generates for the same conditions is very reproducible. Because it was no t possible to reproduce exactly the same conditions e ach time the ISOCS was set up and used, precision was defined in this context as the degree of agreement among a group of measurements of the same source for a particular application of the ISOCS unit . Specifically, a particular application of the ISOCS unit was defined as once an ISOCS unit was set up at SR S and deemed ready to take valid measurements of RH waste contai ners, as specified by SRS-CCP procedures. The ISOCS then measured an item of known value, i.e ., a radionuclide standard in a 55-gallon drum that is traceable to the national standards ba se. The item had to contain sufficient quantities of 239 Pu, 240 Pu, 241 Pu and 241 Am to provide statistically significant values for these radionuclides

13 Interoffice Correspondence from R. Gogliotti and P . Kelly to Ed Feltcorn, RE: Replicate Testing Protocol for System at SRS-CCP Using a Standard Dru m, November 18, 2011.31

when the operators followed the same procedure as w as used to assay the eight drums in RH Waste Stream SR-RH-FBL.01. Because an ISOCS was use d to establish the ratio of Pu isotopes (excluding 238 Pu) to 241 Am, the parameter of interest was the ratio of radi onuclide X to 241 Am, where X is 239 Pu, 240 Pu or 241 Pu.

The MCS/ISOCS unit and the standard drum were set u p in the same manner as the original eight RH drums in RH Waste Stream SR-RH-FBL.01. Six measurements were taken. Each measurement was of the same source in the same loca tion without any modifications to the system’s geometry. These measurements were used to derive three ratios: 239 Pu/ 241 Am,
240 Pu/ 241 Am, and 241 Pu/ 241 Am. The ratios were used to calculate the percent r elative standard deviation (%RSD) according to the equation below:

Where:

s = measured standard deviation of the ratio Ci X /Ci 14 241 Am from each respective ISOCS device

n = number of replicates

μ = known standard deviation of the ratio Ci X /Ci 241 Am from the standard drum
Χ 2 0.05, n -1 = critical value of the upper 5% tail of the one-si ded chi squared distribution with n -1

degrees of freedom

On December 5-6, 2011, SRS-CCP used the MCS/ISOCS t o perform six replicate assays of a 55- gallon drum containing 203.68 g Total Pu. The singl e drum contained 12 discrete WG Pu working reference material (WRM) standards of varyi ng gram values, all of which had been fabricated by LANL and were traceable to the nation al standards base. On December 6, 2011, EPA observed the operation of the MCS/ISOCS in the same configuration as was used for the replicate analyses, and SRS-CCP supplied the replic ate data to EPA on December 7, 2011. EPA evaluated the precision of the replicate data using the %RSD equation above, as summarized in Table 5. The replicate testing of the MCS/ISOCS met EPA’s acceptance criterion for precision of <14% (for six replicates) and provided sufficien t objective evidence to support use of the ISOCS for the determination of radionuclide scaling factors.

Table 5. MCS/ISOCS Replicate Data

Run Number 239 Pu/ 241 Am 240 Pu/ 241 Am 241 Pu/ 241 Am
1 7.28 1.31 13.2 2 7.56 1.41 13.9 3 7.66 1.44 13.9 4 7.56 1.40 13.8 5 7.69 1.54 13.9 6 7.81 1.48 14.3 Average Ratio 7.59 1.43 13.83 Standard Deviation 0.180 0.078 0.356 True Value 12.92 3.08 46.06 %RSD 1.39% 2.53% 0.77%

14 Activity can be expressed in Ci or radionuclide-sp ecific disintegrations.32

(3) Use of nondestructive assay data from CH Waste Stre am SR-W027-FB-Pre86-C to develop scaling factors for uranium isotopes and fi ssion products was found to be technically adequate and correctly documented.

SRS Waste Stream SR-W027-FB-Pre86-C is the CH equiv alent of RH Waste Stream SR-RHFBL.01, and all eight 55-gallon drums in SR-RH-FBL. 01 were originally generated and managed as part of the CH waste stream. They fell o ut of the waste stream when drum contact dose readings met or exceeded the contact dose rate limits of 200 milliRoentgen per hour (mR/hr). As such, these drums are assumed to have t he same ratios of radionuclides as the CH drums but in larger concentrations. This assumption is the basis for using historical CH assays to derive the ratios of 233 U, 234 U, 238 U, 137 Cs and 90 Sr to 241 Am. Approximately 6,900 CH assay records from SR-W027-FB-Pre86-C were available at t he time of inspection. Of these assays, a subset of 251 assay records were selected, which ar e the only containers in SR-W027-FB-Pre86- C that contained over one Ci of 241 Am. This subset was used because it is assumed that they would most accurately reflect the distribution of r adionuclides in the eight drums in the SR-RHFBL.01 waste stream. In this subset, the total quan tity of each radionuclide was summed to represent the total quantity of that radionuclide i n the subset. When an assay did not have detectable levels of a radionuclide, the average mi nimum detectable activity (MDA) for that radionuclide was applied to that sample. MDAs do no t represent a sample’s true radionuclide concentration; however, their use allows an upper e stimate of a drum’s content so as to not underestimate true averages because of the measurem ent system’s limitations. Only a handful of assays measured 234 U. To accurately estimate its average quantity, the average MDA of 235 U was applied at a ratio of 46.2 to 1 when no reported va lues existed. The total was divided by the number of assays (251), to develop the average quan tity of each radionuclide in the subset. The NDA system does not directly measure 90 Sr; its contribution is inferred by assuming a 1-to -1 ratio with 137 Cs. These values were then corrected for decay and 241 Am in-growth to the reference date of March 9, 2007, which is the weigh ted average of CH assays done between March 8, 2002, and December 11, 2008. The ratios of the average values of the uranium isotopes and fission products to the average 241 Am were then determined. These values served as the scaling factors for the respective radionuclides.

(4) Computer modeling to develop the dose-to-curie corr elation was evaluated and was found to be adequate.

SRS-CCP used the MCNP5 computer code to develop DTC correlation for a 55-gallon drum filled with debris waste and its external dose rate at one meter. This was based on the assumption that a one-Ci source of 241 Am was uniformly distributed within the drum and th at the only significant gamma emitter in the drum was 241 Am. Specifically, the contributions of europium-154 ( 154 Eu), cobalt-60 ( 60 Co) or other gamma emitters in the drum were neglig ible. This provided the container-specific correlation of measured dose rate and 241 Am content to drum density. Two drums, Nos. SR512002 and SR526627 , did not have poly-liners, which was taken into account in MCNP5 modeling. Each drum’s M CNP5 results are documented in DTC Values and Gamma Sensitivity Studies , Calculation Package SRS-RH-43. The use of any alternate scaling factor determination methods othe r than those documented in CCP-AK-SRS-581, Revision 1, is a T1 change. (See Ta ble 1.)33

(5) Execution and documentation of the dose-to-curie te chnique was assessed and found to be adequate.

EPA observed the DTC technique on August 30, 2011, in the DTC alcove located in Area E, Pad 4, for Drum No. SR526627. 15 The DTC process for the actual drums in the waste stream was performed on April 26 and 27, 2011, as documented i n DTC BDR Nos. SRSRHDTC11001 and SRSRHDTC11002. The SRS-CCP DTC operators were Tim C arlton, Ron Whitson and Todd Shepley, all three of whom were listed in the curre nt RH program SRS list of qualified individuals (LOQI) dated August 16, 2011. The next CCP trainings for the three DTC operators are due in April 2013, May 2012 and April 2013.

The DTC personnel began by performing the operation al check on WEIGHTRONIX Scale No. 26738, which was last calibrated on August 15, 2011, and is due for recalibration in August 2012. SRS personnel weighed the drum, and CCP opera tors recorded the weight. The weights were recorded on the Measurement Control Report (CC P-TP-504, Attachment 1) and summarized in the operational log book.

DTC personnel performed the source checks for the T hermo Scientific Model FH 40 G Dose Rate Measuring Unit with FHZ 612 Probe (Serial No. 921) attached to Probe No. XC0677. This instrument is different from the unit FHZ612 (Seria l No. 831) attached to Probe No. XC0673, which was used for the DTC measurements that were p erformed on SR-RH-FBL.01. This is because the calibration of the initial probe was du e between the measurement and the witnessing of the process demonstration. SRS-CCP replaced the instrument instead of recalibrating the detector.

The daily source checks were preformed with a 60 Co sealed source with an activity of 1.1 Ci on the reference date May 1, 1996. The ambient backgro und was measured, source checks were performed for the high and low ranges, and all meas urements were recorded on the Measurement Control Report and summarized in the operational lo g book; EPA inspectors received a copy of the log book entry page. DTC personnel consulted CCP Operator Aid: OA-SRS-0153, Revision 2, 8-30-11 , which listed tolerances for the test drum weights , scale error, operational ranges for the Geiger Mueller Probes and acceptance criteria f or the source checks. DTC operators took a background reading while all containers were in a s hielded position. SRS-CCP provided a copy of the Measurement Control Report to EPA; it includ ed all pertinent information. Measurements were made in four locations on the drum’s circumfer ence (0 ° , 90 ° , 180 ° and 270 ° ), and all measurements were recorded on the Container Data Sh eet (CCP-TP-504, Revision 11, Attachment 2), a copy of which was provided to EPA. Contact dose rates for each of the three drums exceeded 200 mrem/hr, which was inferred by m ultiplying the one-meter readings by 18 to correct for the difference in measurement distan ces. All contact dose rate readings greatly exceeded three times the measured background of 0.2 mR/hr. The measurements and all accompanying parameters were acceptable, and copies of the Measurement Control Report and the Container Data Sheet for all drums are containe d in DTC BDR Nos. SRSRHDTC11001 and SRSRHDTC11002.

15 Container No. SR526627 is not part of SR-RH-FBL.01 and technically is not within the scope of this inspection. However, EPA observed the DTC process a s a demonstration of the execution of Procedure CCP -504.34

The use of any alternate radiological characterizat ion procedure other than DTC (CCP-TP-504) with scaling factors established by the procedures documented in CCP

- AK

- SRS

- 581, Revision 1, or substantive modification thereof, is a T1 change . (See Table 1.) Any change to CCP-TP-504 that requires CBFO approval is a T2 change. (See Ta ble 1.)

(6) Radionuclide documentation in dose-to-curie batch d ata reports was assessed and found to be adequate.

The DTC results for all containers were documented in two BDRs, SRSRHDTC11001 and SRSRHDTC11002. The EPA inspection team verified tha t both BDRs included the following:

• SPM Checklist, Attachment 8

• BDR Cover Sheet, Attachment 4

• BDR Table of Contents, Attachment 5

• BDR Narrative Summary, Attachment 6

• Independent Technical Reviewer (ITR) Review Checkli st, Attachment 7

• Measurement Control Report with all parameters acce ptable

• Container Data Sheets

• Concentrations and corresponding uncertainties for all WIPP-tracked radionuclides

• Waste Container DTC Conversion Records with all req uired parameters, Attachment 3

• Evidence of signatures by the ITR on Attachment 7 a nd an SPM on Attachment 8

• Type of waste in each container (organic and inorga nic) in Attachment 3

• TRU determination for all containers in Attachment 3

• Correct revision of CCP-TP-504 (i.e., Revision 11)

The BDRs were technically adequate.

(7) Remote-handled determinations were evaluated and fo und to be adequate.

Contact dose rates were measured by SRS personnel, and SRS-CCP provided the dose rate survey sheets for all eight drums. EPA reviewed the se SRS records that indicated each container in the waste stream was RH, i.e., had a contact dos e rate in excess of 200 mrem/hr. The contact dose rate readings for all eight containers represe nt the values at a distance of 5 centimeters, which is adequate for our purposes. The values are shown in Table 6, below.

Table 6. Summary of RH Determinations

Drum Number Contact Dose

Rate (mrem/hr) Measurement Date SR510588 225 6/26/2008 SR512002 360 12/19/2009 SR501028 502 7/19/2008 SR504233 1210 12/19/2009 SR504242 200 8/13/2009 SR513217A 210 12/12/2008 SR526627 200 12/14/2009 SR118870 360 12/14/200935

(8) TRU determinations were evaluated and were found to be adequate.

DTC BDRs SRSRHDTC11001 and SRSRHDTC11002 contained activity and mass values with the associated uncertainties for the 10 WIPP-tracke d radionuclides plus other radionuclides, as appropriate. In all cases, the TRU alpha concentrat ion exceeded 100 nCi per gram.

(9) The technical basis and documentation of Total Meas urement Uncertainty were evaluated and found to be adequate.

The development of Total Measurement Uncertainty (T MU) for Waste Stream SR-RH-FBL.01 is based on the propagation of uncertainties present i n the determination of the waste stream’s radiological constituents. These aspects are assume d to be independent, which allows them to be added in quadrature. 16 The TMU determination included contributions of th e following:

• 241 Am DTC correlation—MicroShield® Version 5 code, Mic roShield® modeling, and waste density uncertainties

• 241 Am activity measurement—dose rate measurement uncer tainty and uncertainty due to the contribution of other gamma-emitting radionucli des

• Scaling factor uncertainty—ISOCS modeling uncertain ties, waste density uncertainties, scaling factor uncertainty in CH data

A general treatment of TMU for SR-RH-FBL.01 is pres ented in CCP-AK-SRS-581, Revision 1, Section 6, and the detailed treatment of TMU is pro vided in Uncertainty Analysis for SR-RHFBL.01 , Calculation Package SRS-RH-42, Revision 1 (Refere nce U002). The overall uncertainties are consistent with what EPA has obse rved for RH determinations at other RH TRU generator sites. TMU varies slightly from drum to drum because scaling factors are developed on an individual drum basis. An example o f the overall uncertainty for drum No. SR510588 from SR-RH-FBL.01 is provided in Table 7 below.

16 Adding in quadrature is a standard statistical tec hnique that allows one to combine the square root o f the sum of each contributor to uncertainty squared, res ulting in a lower value than what would be obtained if the values were simply added. For example, the TMU for 239 Pu is derived by taking the square root of (25.0%) 2 plus (10%) 2 plus (26.2%) 2 plus (5.4%) 2 plus (28.1%) 2 , which equals 47.21%, which is less than the value obtained by simply adding the values (i.e., less than 94.7%, as shown in Table 7).36 Table 7. Overall Uncertainty of Example Drum SR5105 88

Radionuclide Uncertainty

in Dose Rate Measurement MCNP5

Code Uncertainty Uncertainty

of ISOCS SF Uncertainty

in SF Derived from CH Data Uncertainty

in Waste Density Uncertainty

in Waste Distribution TMU

U-233 25.0% 10% NA 52.0% 4.6% 21.9% 62.7% U-234 25.0% 10% NA 77.3% 4.6% 21.9% 84.9% U-235 25.0% 10% NA 73.3% 4.6% 21.9% 81.2% U-238 25.0% 10% NA 64.7% 4.6% 21.9% 73.6 % Pu-238 25.0% 10% NA 90.4% 4.6% 21.9% 96.9% Pu-239 25.0% 10% 26.2% NA 5.4% 28.1% 47.2% Pu-240 25.0% 10% 28.2% NA 3.0% 25.2% 46.5% Pu-241 25.0% 10% 27.7% NA 3.4% 25.0% 46.1% Pu-242 25.0% 10% NA 234.0% 4.6% 21.9% 236.7% Am-241 25.0% 10% 0% NA 4.6% 21.9% 35.0% Sr-90 25.0% 10% NA 366.7% 4.6% 21.9% 368.4% Cs-137 25.0% 10% NA 366.7% 4.6% 21.9% 368.4% Y-90 25.0% 10% NA 366.7% 4.6% 21.9% 368.4% Ba-137m 25.0% 10% NA 366.7% 4.6% 21.9% 368.4%

Summary of Radiological Characterization Findings a nd Concerns

The EPA inspection team did not identify any findin gs or concerns related to radiological characterization. There are no open issues related to radiological characterization resulting from this inspection.

Tier 1 Radiological Characterization Changes

The following radiological characterization changes are T1 changes:

• Use of the MCS/ISOCS to provide any information oth er than the relative determinations of 239 Pu, 240 Pu and 241 Pu to 241 Am

• Any future use of the ORTEC/ISOCS for any RH TRU wa ste

• Application of new scaling factor processes for iso topic determination other than those documented in CCP-AK-SRS-581, Revision 1 (applies t o new RH waste streams and to the addition of containers to an approved waste str eam)

• Substantive modification(s) to CCP-TP-504 or CCP

- AK

- SRS

- 581 that have the potential to affect the characterization process

Tier 2 Radiological Characterization Changes

The following radiological characterization changes are T2 changes:

• Any new RH waste stream characterized using an appr oved scaling factor process for isotopic determination37

• Notification to EPA upon completion of revisions to CCP-AK-SRS-581 or CCP-TP504 that require CBFO approval

• Notification to EPA when calculation package(s) CCP -SRS-44, or equivalent record(s), are available

Radiological Characterization Baseline Approval

Based on this inspection, EPA approves the radiolog ical characterization of eight drums in Waste Stream SR-RH-FBL.01 using DTC and scaling factors g enerated through use of the ORTEC/ISOCS prior to the baseline inspection and hi storical assays of companion (see footnote 1) CH debris waste streams for assigning radionucli de values according to the limitations in Section8.2 of this report. EPA also approves the ra diological characterization process using DTC and scaling factors generated through use of the MC S/ISOCS and historical assays of companion (see footnote 1) CH debris waste streams for assign ing radionuclide values for RH waste, as documented in CCP-AK-SRS-581, Revision 1, and suppo rted by the calculation packages (or equivalent documentation) referenced in this report , and subject to the limitations in Section 8.2 of this report.

This is the first time that an ISOCS was used for c haracterization of WIPP-bound RH TRU waste. Under this approval, use of the MCS/ISOCS is limited to the generation of specific radionuclide ratios, i.e., the activity of Pu isoto pes 239 Pu, 240 Pu and 241 Pu to 241 Am. SRS-CCP may not measure 238 Pu in this manner and must instead quantify 238 Pu based on appropriate AK (including necessary AK qualification) or another E PA-approved characterization technique. Under this approval, the MCS/ISOCS may not be used to directly quantify any radionuclides. The sole purpose of the MCS/ISCOS will be to develo p ratios (scaling factors) for 239 Pu, 240 Pu and 241 Pu to 241 Am. The ORTEC/ISOCS is not approved for use beyond the eight containers that were the subject of this baseline approval.

8.3 Real-Time Radiography

Waste Characterization Element Description

As part of the inspection of the RTR activities, th e EPA inspection team focused on overall procedural technical adequacy and implementation, a s well as the identification of WMPs and prohibited items, in reviewing the following RTR el ements:

• Documentation of RTR activities through use of an a pproved procedure

• Proper execution of RTR activities

• Management oversight and independent review of RTR activities

• Training of RTR personnel

The RTR facility uses radiography to help determine the following aspects of TRU waste characterization:

• Types and amounts of WMPs

• Confirmation of the WMC38

• Presence or absence of prohibited items

• Demonstration of capability testing for operators o n the RTR system using specifically placed items

Documents, Batch Data Reports and Objective Evidenc e Reviewed

SRS-CCP provided source documents, attachments, for ms and other data to EPA, which reviewed them as applicable. The list of all docume ntation examined is in Attachment A to this report.

The following is a complete list of all objective e vidence the EPA team evaluated during the inspection:

• Written and audio/visual recording of RTR events fo r selected drums contained in Batch Data Report Nos. SR4RTR0173 and SRSRTR0425

• Written and audio/visual recordings of training con tainer NDE-Training-11 for selected RTR operators

• Completed and signed Training Container Evaluation Data Sheet

• RTR Operator/ITR qualification cards

• Qualification cards and training records for three RTR operators/ITRs

• LOQI for the SRS RH RTR program, dated April 25, 20 11

Technical Evaluation

During the baseline inspection, the EPA inspection team evaluated the technical elements of the RTR process that are summarized as follows:

(1) Overall procedural technical adequacy and implement ation were considered and were found to be acceptable.

The RTR procedure, documented in CCP-TP-053, Revisi on 11, Standard Real-Time Radiography (RTR) Inspection Procedure , contained specific information on performing nonintrusive radiography, including operational set up and checkout, identification of prohibited items, assignment of WMPs and estimation of weights and volumes, confirmation of WMCs, input of data, issuance of NCRs, and technical revi ew of radiography results. This procedure was written specifically for RTR of CH waste but was us ed to characterize the RH waste contained in the BDRs listed above. EPA determined that all pert inent WCPIP requirements had been met using this procedure. Notification to EPA upon comp letion of changes to RTR procedure(s) that require CBFO approval is a T2 change. (see Table 1)

.39

(2) Characterization of waste material parameters and p rohibited items was assessed and was found to be acceptable.

Procedure CCP-TP-053, Revision 11, requires that ra diography audio/visual recording equipment verification be performed at the beginnin g of every shift in which drums are subject to examination. EPA inspectors confirmed adherence to verification requirements through review of written BDRs and audio/video tapes. At th e beginning of a shift, and before examining any waste containers, the operator runs a scan on t he lines-pair resolution test gauge to determine that images are clearly visible. The two BDRs revie wed had acceptable lines-pair tests recorded for the days that RTR took place.

For each container undergoing examination, the oper ator makes an audio/video recording of the RTR event. Before beginning the radiography process , the operator notes the drum number and the date and time on the audio/video recording. The examination of the drum begins at the top of the drum, where the operator identifies the seal an d vent. The drum rotates through 360 degrees so that all objects inside a drum are visible from all sides. The operator can zoom both in and out and increase or decrease the scan energy in order t o compensate for varying densities in the material being examined. During examination, the op erator also “rocks” the drum to determine the presence of free liquids.

The waste stream being processed was SR-RH-FBL-01, which is a debris (S5000) waste stream. There is a standardized weight table (Table 3) in C CP-TP-053, Revision 11, that provides weights for commonly encountered waste items. WMP w eight estimates are made and recorded on the data sheet.

As part of the inspection, the EPA team reviewed RT R data, both audio/visual and written, for containers SR504233, SR512002, SR118870 and SR52662 7. The first two containers are from BDR No. SR4RTR0173, and the last two are from BDR N o. SRSRTR0425

. EPA determined that the quality control (QC) samples, independent observation, and replicate scan performed were appropriate and that information on the audio/ visual recording matched the written RTR record (BDR). Addition of a new SCG to the approved RTR process i s a T2 change. (See Table 1.)

(3) EPA ascertained that documentation of radiography p rocedures was adequate.

Radiography procedures are well defined and the doc uments are controlled. During the inspection, the EPA team reviewed the adequacy and implementation of all radiography-related procedures. QC examinations were performed as requi red by the procedure. In Batch SRSRTR0425, an independent observation was performe d on container SR526627 and a replicate scan was performed on container SR513217A ; in Batch SR4RTR0173, an independent observation was performed on container SR512002 and a replicate scan was performed on container SR504233. There were no nonconformances r eported for these two batches. The BDRs the EPA examined had been reviewed at the data-gene ration level (by the ITR) and project level (by the SPM) as required.40

(4) Training of radiography personnel was performed in accordance with CCP procedures.

The EPA team reviewed documentation of the training container examinations for selected radiography personnel. The inspectors viewed the au dio/visual recording for the latest training drum for an RTR ITR and RTR operator during the ins pection. Training records reviewed indicate that only personnel trained in accordance with CCP procedures were operating the RTR equipment.

Summary of Real-Time Radiography Findings and Conce rns

The EPA team did not identify any findings and or c oncerns during the inspection.

Tier 1 Real-Time Radiography Changes

The following RTR change is a T1 change:

• RTR by any new process

Tier 2 Real-Time Radiography Changes

The following RTR changes are T2 changes:

• Changes made to RTR procedure(s) that require CBFO approval

• Addition of a new SCG to any approved RTR process

Following this approval, on a quarterly basis, SRS- CCP will provide information concerning T2 changes. If new RTR equipment is in use, EPA inspec tion may be necessary. EPA will evaluate changes and communicate with SRS-CCP regarding whet her the changes raise any concerns and require SRS-CCP response, or whether SRS-CCP can co ntinue to implement the changes.

Real-Time Radiography Baseline Approval

The baseline conditions that the EPA inspection tea m evaluated during this inspection consisted of RTR of RH TRU S5000 debris wastes to identify WM Ps and the physical form using the following:

• Trained personnel, RTR operator/ITR and subject mat ter expert

• Approved and controlled operating procedures CCP-TP -053, Revision 11; CCP-QP-002, Revision 31; and CCP-TP-028, Revision 6

• RTR records and supporting data, CCP-TP-053 and CCP -TP-001 review checklists, operator training records and BDRs

Based on this inspection, EPA approves SNL-CCP to p erform RTR of RH TRU waste according to procedure CCP-TP-053.41

9.0 RESPONSE TO COMMENTS

On February 24, 2012, when announcing the proposed approval of SRS-CCP’s RH TRU waste characterization program for debris waste (S5000), EPA sought public comment on the proposed decision (See 77 FR 11112-11115). EPA public commen t period spanned over 45 days and ended on April 9, 2012. EPA did not receive any pub lic comment on the proposed decision and the docketed inspection report (A-98-49; II-A4-156)

.

10.0 SUMMARY OF RESULTS

10.1 Environmental Protection Agency Findings and Concer ns

EPA did not identify any findings or concerns durin g the baseline inspection related to the processes SRS-CCP implemented to characterize RH TR U debris Waste Stream SR-RH-FBL.01. No issues resulting from this baseline inspection r emain open at this time.

10.2 Conclusions

This final approval is based on EPA’s baseline insp ection conducted at SRS in September and December of 2011. EPA evaluated SRS-CCP’s RH waste characterization program for eight drums of debris Waste Stream SR-RH-FBL.01and determ ined it to be technically adequate.

The final approval includes the following:

• The AK process for RH -TRU debris waste streams tha t have companion (see footnote 1) CH debris waste streams

• The radiological characterization of eight drums in Waste Stream SR-RH-FBL.01 using DTC and scaling factors generated through use of th e ORTEC/ISOCS prior to the baseline inspection and historical assays of compan ion (see footnote 1) CH debris waste streams for assigning radionuclide values according to the limitations in Section 8.2 of this report

• The radiological characterization process using DTC and scaling factors generated through use of the MCS/ISOCS and historical assays of companion (see footnote 1) CH debris waste streams for assigning radionuclide va lues for RH waste, as documented in CCP-AK-SRS-581, Revision 1, supported by the calcul ation packages (or equivalent documentation) referenced in this report, and subje ct to the limitations in Section 8.2 of this report

• The RTR process to identify WMPs and the physical f orm of RH TRU debris waste

This baseline approval of SRS-CCP’s RH TRU waste ch aracterization program will allow SRSCCP to characterize RH waste from Waste Stream SR-R H-FBL.01 in accordance with the conditions and restrictions discussed in this repor t and summarized in Table 1. After this EPA baseline approval of the SRS-CCP RH waste character ization program, additional debris waste stream(s) having a companion (see footnote 1) CH wa ste stream(s) may be disposed of at the WIPP provided that an approved radiological scaling factor development process is used.42

Use of the MCS/ISOCS is limited to the generation o f scaling factors for specific radionuclides, i.e., the activity ratios of Pu isotopes 239 Pu, 240 Pu and 241 Pu to 241 Am. Further, use of the MCS/ISOCS for determining the scaling factor for 238 Pu or for direct quantification of any radionuclide is prohibited.

A T1 change approval is necessary when:

• The radiological scaling factors development proces s used for characterizing RH debris waste differs from the process approved;

• An RH TRU debris waste stream characterized for WIP P disposal does not have a companion (see footnote 1) CH waste stream;

• An RH TRU non-debris waste stream from the solids ( S3000) or soils and gravel (S4000) summary category groups is characterized for WIPP d isposal; or

• The ORTEC/ISOCS is used for RH debris waste charact erization in the future.43

11.0 REFERENCES

U.S. Environmental Protection Agency, “Criteria for the Certification and Recertification of the Waste Isolation Pilot Plant’s Compliance with the D isposal Regulations: Certification Decision; Final Rule,” Federal Register , Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405.

U.S. Code of Federal Regulations, Title 40

, Protection of Environment , Part 191, “Environmental Radiation Protection Standards for Management and D isposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes.”

U.S. Code of Federal Regulations, Title 40

, Protection of Environment , Part 194, “Criteria for the Certification and Re-Certification of the Waste Iso lation Pilot Plant’s Compliance with the 40 CFR Part 191 Disposal Regulations.”

U.S. Department of Energy, Office of Environmental Management, “Radioactive Waste Management Manual,” DOE M435.1-1, July 9, 1991, Cha nge 1: June 19, 2001.

U.S. Department of Energy, Carlsbad Field Office, “ Remote Handled TRU Waste Characterization Program Implementation Plan,” DOE/ WIPP-02-3214, Revision 0D, Carlsbad, New Mexico, October 30, 2003.

U.S. Department of Energy, Carlsbad Field Office, “ Remote Handled TRU Waste Characterization Program Implementation Plan,” DOE/ WIPP-02-3214, Revision 2, Carlsbad, New Mexico, April 21, 2011.

U.S. Department of Energy, Title 40 CFR Part 191, C ompliance Certification Application for the Waste Isolation Pilot Plant, DOE/CAO 1996-2184, Car lsbad, New Mexico, 1996.

U.S. Department of Energy, Title 40 CFR Part 191, S UBPART D AND C, Compliance Recertification Application 2004, DOE/WIPP/2004-323 1.

U.S. Department of Energy, “DOE Waste Treatability Group Guidance,” DOE/LLW-217, INEL-Lockheed Idaho Technologies, Idaho Falls, Idah o, 1995

U.S. Department of Energy, “Remote-Handled Transura nic Waste Authorized Methods for Payload Control (RH-TRAMPAC),” Carlsbad, New Mexico

.A-1 ATTACHMENT A: DOCUMENTS REVIEWED

CCP Calculation Package: SRS RH TRU Radiological Ch aracterization, J. Vance, SRS-RH-41, Revision 0, August 4, 2011

CCP Calculation Package: Determination of Scaling F actors for SRS-580 Drums, J. Holderness, SRS-RH-41, Revision 1, September 13, 2011

CCP Calculation Package: Uncertainty Analysis for S R-RH-FBL.01, J. Holderness, SRS-RH-42, Revision 0, July 31, 2011, and Revision 1, Septembe r 14, 2011

CCP Calculation Package: DTC Values and Gamma Sensi tivity Studies, J. Holderness, SRS-RH43, Revision 0, July 30, 2011

CCP Calculation Package: DTC and Related Calculatio ns for SR-RH0FBL.01, J. Holderness, SRS-RH-44, Revision 0, August 3, 2011

CCP Calculation Package: SRS RH TRU Radiological Ch aracterization, J. Holderness, SRS-RH44, Revision 1, October 25, 2011

Calibration Verification Report for the ISOCS Detec tor # 4480 at the Savannah River Site, B. Gillespie, Revision 0, November 9, 2011

CCP-AK-SRS-2, Central Characterization Project Acce ptable Knowledge Summary Report for Savannah River Site SR-W027-FB-Pre86-C, Revision 13 , September 16, 2010

CCP-AK-SRS-580, Central Characterization Project Ac ceptable Knowledge Summary Report for Savannah River Site Remote-Handled Transuranic Waste, Waste Stream: SR-RH-FBL.01, Revision 1, June 22, 2011, Revision 2, August 26, 2 011, and Revision 3, October 4, 2011

CCP-AK-SRS-581, Central Characterization Project Re mote-Handled Transuranic Radiological Characterization Technical Report for Savannah Rive r Site Remote-Handled Transuranic Debris Waste, Waste Stream: SR-RH-FBL.01, Revision 0, Augu st 11, 2011, and Revision 1, November 1, 2011

CCP-AK-SRS-582, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance for SRS Waste Stream: SR -RH-FBL.01, Revision 0, July 6, 2011, and Revision 1, November 9, 2011

CCP-AK-SRS-585, Central Characterization Project Ac ceptable Knowledge Radionuclide Distribution Test Program for Savannah River Site R emote-Handled FB LINE DEBRIS WASTE, Waste Stream: SR-RH-FBL.01, Revision 0, June 2, 2011

CCP-QP-002

, Revision 31

, CCP Training and Qualification Plan

, April 21, 2011

CCP-QP-005, Revision 20

, TRU Nonconforming Item Reporting and Control

, April 26, 2011

CCP-QP-008

, Revision 19, CCP Records Management

, August 02, 2011A-2

CCP-TP-002, Attachment 2, CCP Waste Stream Profile Form, Waste Stream SR-RH-FBL.01, Draft for Audit Purposes, Provided July 21, 2011, a nd August 31, 2011

CCP-TP-005, Attachment 1, Acceptable Knowledge Docu mentation Checklist, June 16, 2011, and August 31, 2011

CCP-TP-005, Attachment 4, Acceptable Knowledge Sour ce Document Reference List, June 16, 2011, and August 31, 2011,

CCP-TP-005, Attachment 6, Waste Form, Waste Materia l Parameters, Prohibited Items, and Packaging, May 24, 2011, and September 6, 2011

CCP-TP-005, Attachment 7, Radionuclides, May 24, 20 11

CCP-TP-005, Attachment 8, Waste Containers, June 14 , 2011

CCP-TP-005, Attachment 13, CCP Waste Stream Charact erization Checklist, Draft, Provided July 21, 2011

CCP-TP-005, Attachment 15, CCP TRU Waste Correlatio n and Surrogate Summary Form, May 24, 2011

CCP-TP-028

, Revision 6, CCP Radiographic Test Drum and Training Container C onstruction

, December 29, 2010

CCP-TP-053, Revision 11, CCP Standard Real-Time Rad iography (RTR) Inspection Procedure, July 20, 2011

CCP-TP-139, Revision 3, CCP In Situ Object Counting System Nondestructive Assay Operating Procedure, May 4, 2011

CCP-TP-508, Revision 7, CCP Standard Real-Time Radi ography (RTR) Inspection Procedure, April 21, 2011

Characterization Information Summary, Waste Stream SR-RH-FBL.01, Draft, Provided July 21, 2011, and November 29, 2011

Characterization Reconciliation Report for Waste St ream SR-RH-FBL.01, Draft for Audit Purposes, Provided July 21, 2011

DTC BDR Nos. SRSRHDTC11001, August 17, 2011, and SR SRHDTC11002, August 18, 2011

Interoffice Correspondence, from Irene Quintana to CCP Records Custodian, Acceptable Knowledge Accuracy Report: Savannah River Site Wast e Stream Number SNL-HCF-S5400-RH, Lot 1, Draft for Audit Purposes Only, July 18, 2011

Interoffice Correspondence from R. Gogliotti and P. Kelly to Ed Feltcorn, RE: Replicate Testing Protocol for System at SRS-CCP Using a Standard Dru m, November 18, 2011A-3

ISOCS/LabSOCS Detector Characterization Report, Can berra Industries, Inc., August 10, 2010

List of Qualified Individuals (LOQI) Savannah River Site, April 25, 2011, August 16, 2011, and December 1, 2011

MCS ISOCS Report ISOCS DTC – CH Waste Drums, SRS Su bmittal Nos. #061611, June 16, 17, and 30, 2011, and #061711, June 17, 20, and 21, 2011

Memorandum from J. Vance to Irene Quintana, Analysi s of ISOCS Confirmation Test Results for SRS Debris RH TRU Waste Stream, September 13, 2 011

NCRs: NCR-RHSRS-2940-11, NCR-SRS-0533-09, and NCR-S RS-1137-06

OA-SRS-0153, Revision 2, CCP DTC Operator Aid, Augu st 30, 2011

Post-Confirmation Testing Memorandum: Analysis of I SOCS Confirmation Test Results for SRS Debris RH TRU Waste Stream, J. Vance, July 29, 2011

QC Limits for the MCS ISOCS System at the Savannah River Site, Bruce Gillespie, November 18, 2011

Qualification cards and training records for M. Doh erty, J. Montoya and S. Schafer, provided August 31, 2011

Qualification cards and training records for RTR an d DTC operators/ITRs

SRNL Procedure ADS-2460, Revision 0, Gamma Assays U sing ORTEC’s Isotopic Program, February 16, 2011

RTR BDR Nos. SR4RTR0173 and SRSRTR0425

VSDS Standard Map RSLS Surveys: SWIN-M-20090813-26, SWIN-M-20081212-4, SWIN-M-20080626-5, SWIN-M-20080719-2, SWIN-M-200912 14-9, and SWIN-M-20091219-1

WSRC-TR-2005-00431, Revision 0, Nondestructive Assa y Efficiency Calibration of HPGe Detectors for the ORTEC “Isotopic” Method, SNRL, Ra ymond Sigg, Vito Casella and Raymond Dewberry, September 2005

C018, Record of Communication – Interview with M.P. Rodriquez, FB-Line Engineer, W.G. Estill, January 10, 2002

C021, Record of Communication – Interview with Chip Harris, J. Whitworth, S. Fevig, G. Lunsford, January 10, 2002

C022, Record of Communication – Interview of Jeff O vercash by Stephanie Fevig and David Guerin, Stephanie Fevig and David Guerin, January 1 1, 2002

C024, Interview with Joe Stapf, Process Engineer an d MC&A Shipping Supervisor at FB-Line, 1978–1982, W.G. Estill, January 14, 2002A-4

C025, Record of Communication – Interview with Ed M oore, J. Whitworth, S. Fevig, G. Lunsford, January 10, 2002

C026, Record of Communication for Interview with Le s Sonnenberg, Former FB-Line Mechanical Engineer, J. Whitworth and S. Fevig, Jan uary 10, 2002

C027, Record of Communication for Interview with A. Gibbs, SRS Solid Waste Management, J. Whitworth and S. Fevig, January 15, 2002

C028, Record of Communication – Interview of Charle y Williams, J. Whitworth and S. Fevig, January 15, 2002

C029, Record of Communication for Interview with D. Rogers, Former FB-Line Operator and Supervisor, J. Whitworth and S. Fevig, January 15, 2002

C031, Record of Communication – Interview with Rich ard Runnels, Process Engineer at FB-Line 1986-87, W.G. Estill, January 16, 2002

C032, Record of Communication – Interview with John Crim, J. Whitworth and S. Fevig, January 17, 2002

C044, Letter from O.M. Morris to M.G. O’Rear, “TRU Waste Data Update Request,” O.M. Morris, March 6, 1985

C045, Letter from C.M. Morris to C.G. Halsted, TRU Waste Annual Call for Data,” C.M. Morris, May 17, 1984

C056, Record of Communication: Interview with Super visor Harry Smiley regarding FB-Line Waste from 1970–86, W. Estill, January 28, 2002

C067, Record of Communication for Written Response to Interview Questions from R. Burns, Former FB-Line Engineer, J. Whitworth and S. Fevig, January 15, 2002

C071, Record of Communication – Interview of FB-Lin e Personnel, J. Harrison, J. Whitworth, January 16, 2001

C072, Memo from N. Dienes to Distribution List re: Specifications for Plutonium Shipped to the Rocky Flats Plant, Albuquerque Operations Office, M arch 22, 1985

D008, Savannah River TRU Waste Inventory Workoff Pl an, SRS, DPSP-86-1, July 15, 1986

D013, Safety Analysis – 200 Area Savannah River Pla nt Burial Ground Operations, Science Applications International Corporation, DPSTSA-200- 10, SUPP-8, October 1988

D016, History of Du Pont at the Savannah River Plan t, William P. Bebbington, 1990

D020, 200-Area Safety Analysis, SAIC, SRS, DPSTSA-2 00-10, Supp-9, April 1988A-5

D029, Savannah River Site Solid Waste Management Fa cility Safety Analysis Report, Westinghouse Savanna River Company, Aiken, SC, WSRC -SA-22, Revision 2 draft, November 25, 1998

D030, Savannah River Site Transuranic Waste Program , J.A. Blankenhorn, Solid Waste Management Operations, SWE-SWE-96-0195, Revision 0, May 15, 1997

D033, The FB-Line Facility – A Training Aid Documen t, DPST-86-449, September 1986

D035, The Purex Process, J.B. Starks, Separation Te chnology Department, DPSU 77-11-1, January 1977

D037, Systems Analysis – 200 Area Savannah River Pl ant: JB-Line Operations, D.H. Stoddard and R.V. Slates, DPSTSY-200-10, May 1978

D054, Works Technical Report for January, February 1977, DPSPs 77-1-1, 77-1-2, Savannah River Plant, January 1977, February 1977

DR001, Discrepancy Resolution: Drum/Culvert Limit C hange, D. Guerin, October 19, 2002

DR3, Discrepancy Resolution: Radionuclides, J. Whit worth, October 16, 2002

DR6, Discrepancy Resolution: Physical Form, Julia W hitworth, October 19, 2002

DR008, Acceptable Knowledge Source Document Discrep ancy Resolution, Calcium Reactivity, J. Harrison, July 18, 2006

DR009, Discrepancy Resolution for Discrepant Drum i n SR-W027-FB-Pre86-C Waste Stream, Lisa Price-Watson, January 24, 2008

M051, Calculation of WMPs for SRS RH Waste Stream S R-RH-FBL-01, Mark Doherty, March 25, 2009

M052, RH Container Data, 1975 to 2008

M054, Memo to File from Mark Doherty re: Revision o f the Calculation of WMPs for SRS RH Waste Stream SR-RH-FBL.01, Mark Doherty, May 24, 20 11

M055, CCP RTR Data to Support Revised WMP Calculati on, Various Authors, April 2011

P009, Packing TRU Waste and Sealing in 55-Gallon Dr ums, DPSOL 241-FH-40, Revision 1, July 1977

P010, Savannah River Plant Radiation and Contaminat ion Control/Management of Solid Radioactive Waste, E.I. Du Pont de Nemours and Co, DPSOP 40, Various Revisions, 1976-1977

U001, CCP Calculation Package: SRS-580 Scaling Fact or Development, Jene Vance, SRS-RH41, Revision 0, August 4, 2011, Revision 1, Septemb er 13, 2011A-6

U002, CCP Calculation Package: SRS-580 Uncertainty Analysis, J. Vance, SRS-RH-42, Revision 0, August 4, 2011, Revision 1, September 1 4, 2011

U003, CCP Calculation Package: SRS-580 DTC Derivati on for Am-241, J. Vance, SRS-RH-43, Revision 0, August 4, 2011

U004, CCP Calculation Package: DTC and Related Calc ulations for SR-RH-FBL.01, J. Vance, SRS-RH-44, Revision 0, August 8, 2011, Revision 1, October 25, 2011

U005, CCP Calculation Package: SRS-580 Reporting Re quirements Evaluation, J. Vance, SRS-RH-45, Revision 0, August 14, 2011

U007, CCP Calculation Package: Dose Rate Contributi on from Other Radionuclides, J. Holderness, SRS-RH-46, Revision 0, September 14, 2011B-1

ATTACHMENT B: PERSONNEL CONTACTED DURING INSPECTION

Personnel Name Affiliation Area of Expertise, Function Aug Dec
Ed Feltcorn U.S. EPA ORIA Inspection Team Leader  
Rajani Joglekar U.S. EPA ORIA Inspection Team Membe r Connie Walker* SC&A Inspection Team, AK  Kira Darlow SC&A Inspection Team, AK  Dorothy Gill* SC&A Inspection Team, VE  Rose Gogliotti SC&A Inspection Team, Radiological C haracterization   Patrick Kelly SC&A Inspection Team, RC, AK   Amir Mobasheran* SC&A Inspection Team, Radiological Characterization  Jim Holderness CCP Consultant Radiological Characte rization  Derek Ott CCP Radiological Characterization  Marcus A. Pinzel DOE/CBFO RH Waste Manager, RC  David A. McCoy CCP DTC Operator, RC 
Paul Gomez CBFO/CTAC Observer  Todd Shepley MCS/CCP DTC Operator   Ronald Whitson MCS DTC Operator  Mark Doherty CCP-TechSpecs AK Expert  Kevin Peters WTS/CCP AK Expert 
Joe Harvill CCP/WTS DTC/NDA   Buddy Fussel CCP V. Project Manager  Steve Mise WTS Quality Engineer  Steve Schafer CCP-TechSpecs SRS-CCP AK Expert 
Court Fesmire DOE Observer  Irene Quintana WTS-CCP RH Site Project Manager  
Jene Vance * † WTS-CCP Radiological Characterization 
Lee Fox SRNS STR  Joe Stepzinski CCP VPM 
Ronald D. Reeves WTS/CCP NDA  Tom Morgan NTP/DOE CBFO Observer 
Pat Tilman WTS/CCP VPM 
Tom Cochran DOE/FR Observer  Ray Dewberry SRNL Radiological Characterization  Bruce Gillespie Canberra NDA  Tim Carlton CCP ISOCS Lead Operator  * Performed evaluations via desk-top review. † Contacted by phone