EPA DOCKET NO. A-98-49, II-A4-186 

WASTE CHARACTERIZATION INSPECTION 

CONTINUED COMPLIANCE AND TIER 1 CHANGE REPORT 

EPA INSPECTION OF THE CENTRAL CHARACTERIZATION PROGRAM 

WASTE CHARACTERIZATION PROGRAM 

AT THE OAK RIDGE NATIONAL LABORATORY 

AND MODIFICATION OF THE MOBILE CHARACTERIZATION SERVICES 

IQ3 NONDESTRUCTIVE ASSAY SYSTEM 

February 4–6, 2014 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

May 2014 
i 

TABLE OF CONTENTS 

1.0 Executive Summary ............................................................................................................ 1

2.0 Resuming Transuranic Waste Characterization Activities at Oak Ridge National 

Laboratory ........................................................................................................................... 7

3.0 Purpose of Continued Compliance Inspections .................................................................. 8

4.0 Purpose of Tier 1 Evaluations ............................................................................................. 9

5.0 Purpose of This Report ....................................................................................................... 9

6.0 Scope of This Inspection ................................................................................................... 10

7.0 Inspection Personnel ......................................................................................................... 10

8.0 Technical Evaluation ........................................................................................................ 10

8.1 Acceptable Knowledge ......................................................................................... 10

8.1.1 Technical Evaluation: Contact-Handled Waste ........................................ 11

8.1.2 Technical Evaluation: Remote-Handled Waste ........................................ 16

8.1.3 Acceptable Knowledge Findings and Approval ....................................... 20

8.2 Nondestructive Assay – Contact-Handled Waste ................................................. 20

8.2.1 Technical Evaluation: Mobile Characterization Services IQ3 System ..... 21

8.2.2 Nondestructive Assay Findings and Approval ......................................... 24

8.3 Dose-To-Curie – Remote-Handled Waste ............................................................ 25

8.3.1 Technical Evaluation ................................................................................ 25

8.3.2 Dose-to-Curie Findings and Approval ...................................................... 26

8.4 Nondestructive Examination ................................................................................. 27

8.4.1 Technical Evaluation: Contact-Handled Real-Time Radiography ........... 28

8.4.2 Technical Evaluation: Remote-Handled Visual Examination .................. 31

8.4.3 Nondestructive Examination Findings and Approval ............................... 32

9.0 Findings and Concerns ...................................................................................................... 32

10.0 Conclusions ....................................................................................................................... 33

LIST OF TABLES 

Table 1. Tiering of Contact-Handled Transuranic Waste Characterization Processes 

Implemented by ORNL-CCP .......................................................................................................... 4

Table 2. Tiering of Remote-Handled Transuranic Waste Characterization Processes 

Implemented by ORNL-CCP .......................................................................................................... 5
ii 

ATTACHMENTS 

Attachment A.1 Approval Summary for ORNL-CCP Contact-Handled Waste Characterization 

Program 

Attachment A.2 Approval Summary for ORNL-CCP Remote-Handled Waste Characterization 

Program 

Attachment B List of Documents Reviewed for This Inspection 

Attachment C Inspection Personnel 

Attachment D.1 AK Continued Compliance Inspection Checklist: Waste Stream OR-ISTPCH-HET 

Attachment D.2 AK Continued Compliance Inspection Checklist: Waste Stream OR-NFS-CHSoil 

Attachment D.3 AK Continued Compliance Inspection Checklist: Waste Stream OR-REDCRH-HET 

Attachment E NDA Continued Compliance Inspection Checklist: IQ3 

Attachment F.1 Replicate Testing Data for Drum No. X10CSATN02241L 

Attachment F.2 Replicate Testing Data for Drum No. NFS0419D 

Attachment F.3 Replicate Testing Data for Drum No. NFS0478A 

Attachment G Dose-to-Curie Continued Compliance Inspection Checklist 

Attachment H NDE Continued Compliance Inspection Checklist: CH RTR 

Attachment I NDE Continued Compliance Inspection Checklist: RH VE 

Attachment J EPA Inspection Issue Tracking Form, Concern No. ORNL-CCP-CC-RTR2014-01C, FINAL 

Attachment K EPA Inspection Issue Tracking Form, Concern No. ORNL-CCP-CC-RTR2014-02CR, FINAL 
iii 

ACRONYMS AND ABBREVIATIONS 

% R percent recovery 

% RSD percent relative standard deviation 

σ sigma 

μR/hr microroentgen per hour 

χ

2

 chi-squared 

AK acceptable knowledge 

AKE Acceptable Knowledge Expert 

AKSR acceptable knowledge summary report 

Am americium 

ASTM American Society for Testing and Materials 

Att. Attachment 

BDR batch data report 

Bk berkelium 

BKG background 

CBFO Carlsbad Field Office 

CCP Central Characterization Program 

CE Cognizant Engineer 

Cf californium 

CFR Code of Federal Regulations 

CH contact-handled 

Ci curie 

Ci% curie percent 

CIS characterization information summary 

Cm curium 

CPR cellulosics, plastic and rubber 

CRR characterization reconciliation report 

Cs cesium 

CSSF correlation and summary surrogate form 

CTAC Carlsbad Technical Assistance Contractor 

D&D decontamination and decommissioning 
iv 

DOE U.S. Department of Energy 

DQO data quality objective 

DR discrepancy resolution 

DTC dose-to-curie 

DVD digital video disk 

EA Expert Analyst 

EM Environmental Management 

EPA U.S. Environmental Protection Agency 

Es einsteinium 

FGA flame gas analysis 

Fm fermium 

FWHM full width at half maximum 

FY fiscal year 

g gram 

g/cm3 grams per cubic centimeter 

GM Geiger Mueller 

HFIR High Flux Isotope Reactor 

HLW high-level waste 

HWN Hazardous Waste Number 

IPAN Integrated Passive Active Neutron 

IRML Isotope Research Materials Laboratory 

ISTP Isotope Program facilities 

ITR Independent Technical Reviewer 

kg kilogram 

LLD lower limit of detection 

LLW low-level waste 

LO Lead Operator 

LOQI list of qualified individuals 

MCS Mobile Characterization Services 

MGA multigroup analysis 

MGA-U multigroup analysis-uranium 

mR/hr milliroentgen per hour 

mrem/hr millirem per hour 
v 

N/A not applicable 

nCi nanocuries 

nCi/g nanocuries per gram 

NCR nonconformance report 

NDA nondestructive assay 

NDE nondestructive examination 

NFS Nuclear Fuel Services 

Np neptunium 

NTP National TRU Programs 

NTPC National TRU Program Certification 

NWP Nuclear Waste Partnership, LLC 

OJT on-the-job training 

ORIA Office of Radiation and Indoor Air 

ORNL Oak Ridge National Laboratory 

PDP Performance Demonstration Program 

Pu plutonium 

QA quality assurance 

QAO quality assurance objective 

QC quality control 

R Roentgen 

R&D research and development 

RDS radioassay data sheet 

REDC Radiochemical Engineering and Development Center 

RH remote-handled 

RSD relative standard deviation 

RTR real-time radiography 

SCG summary category group 

SD source document 

SETF Solvent Extraction Test Facility 

SGS segmented gamma scanner 

SME Subject-Matter Expert 

SNF spent nuclear fuel 

SPM Site Project Manager 
vi 

Sr strontium 

SRS Savannah River Site 

T1 Tier 1 

T2 Tier 2 

TMU total measurement uncertainty 

TRAMPAC Trupact Authorized Methods for Payload Control 

TRU transuranic 

TWPC TRU Waste Processing Center 

U uranium 

VE visual examination 

VEE Visual Examination Expert 

VHS Video Home System 

VJT VJ Technologies 

VPM vendor project manager 

WAC Waste Acceptance Criteria 

WAI Wastrem Advantage Incorporated 

WAP Waste Acceptance Plan 

WCPIP Waste Characterization Program Implementation Plan 

WDS Waste Data System 

WIPP Waste Isolation Pilot Plant 

WMC waste matrix code 

WMP waste material parameter 

WSPF waste stream profile form 

WWIS WIPP Waste Information System 
1 

1.0 EXECUTIVE SUMMARY 

This report supports the U.S. Environmental Protection Agency’s (EPA’s or the Agency’s) 

determination that the Central Characterization Program’s (CCP’s)1

 transuranic (TRU) waste 

characterization program at the U.S. Department of Energy (DOE) Oak Ridge National 

Laboratory (ORNL) continues to be technically adequate and in compliance with EPA’s disposal 

regulations at 40 CFR 194.24. Based on the results of this continued compliance inspection, 

ORNL-CCP can resume characterization of TRU wastes intended for disposal at the Waste 

Isolation Pilot Plant (WIPP). This report also supports EPA’s approval of a Tier 1 (T1) change 

for modifications to the Mobile Characterization Services (MCS) IQ3 nondestructive assay 

(NDA) system. 

In 2008, ORNL-CCP began operating waste characterization programs for contact-handled (CH) 

and remote-handled (RH) TRU wastes at ORNL in Oak Ridge, Tennessee. DOE suspended 

waste characterization activities at ORNL in June 2011. In November 2013, the Carlsbad Field 

Office (CBFO) informed EPA that ORNL-CCP resumed waste characterization activities on 

October 1, 2013 and CBFO notified EPA that ORNL-CCP would be ready for an inspection in 

January 2014. After evaluating ORNL-CCP’s documented resumption process EPA concluded 

that a new baseline inspection and approval would not be necessary. Instead, EPA would conduct 

a continued compliance inspection in accordance with Title 40 of the Code of Federal 

Regulations (40 CFR) 194.24(h). See section 2.0 of this report for a complete description of 

ORNL-CCP’s waste characterization resumption and requirements. 

On January 7, 2014, CBFO also requested two T1 changes to the ORNL-CCP CH TRU waste 

characterization program. CBFO requested: (1) EPA approval of a T1 change to approve 

modifications made to the MCS IQ3 NDA system2

 and (2) EPA approval of a T1 change to 

include summary category group (SCG) S3000 waste in ORNL-CCP’s CH waste 

characterization program. EPA determined that the scope of the MCS IQ3 T1 evaluation 

overlapped significantly with the scope of the continued compliance inspection and decided to 

conduct the inspection and evaluation concurrently. EPA determined that the S3000 T1 

evaluation scope was sufficiently separate from the continued compliance inspection scope and 

the T1 evaluation warranted a separate report. 

On February 4–6, 2014, EPA evaluated samples of the following waste characterization 

activities: 

• Acceptable knowledge (AK) for two CH waste streams and one RH waste stream. 

• MCS IQ3 NDA system for characterizing CH TRU waste.

• Dose-to-curie (DTC) for RH TRU waste. 

• Real-time radiography (RTR) for CH TRU waste. 

• Visual Examination (VE) for RH TRU debris waste. 

 

1

 The Central Characterization Program was formerly known as the Central Characterization Project. 

2

 EPA initially approved the MCS IQ3 at ORNL-CCP as a T1 change in March 2010 (see EPA Docket No. 

A-98-49; II-A4-125). 
2 

Based on the results of this T1 evaluation and continued compliance inspection, EPA approves 

ORNL-CCP’s modifications to the MCS IQ3, and confirms that the ORNL-CCP CH and RH 

TRU waste characterization programs in the configuration observed during this inspection are 

consistent with the limitations described in the baseline inspection reports (see EPA Docket Nos. 

A-98-49; II-A4-103, dated August 21, 2008, and A-98-49; II-A4-111, dated February 3, 2009) 

and subsequent EPA T1 approvals. Attachments A.1 and A.2 summarize all of EPA’s approvals 

of the ORNL-CCP CH and RH TRU waste characterization programs. Henceforth, EPA will use 

results of this joint T1 evaluation and continued compliance inspection to support the 

streamlined T1 evaluation and decision process discussed in section 3.0 of this report. 

Based on this inspection and T1 evaluation, EPA made several changes to the CH and RH tiering 

designations, as shown in Tables 1 and 2. Any use of VE to characterize CH waste is a new T1 

change. During the 2008 baseline inspection, EPA approved ORNL-CCP to use VE to 

characterize CH waste; however, EPA did not include this process in the continued compliance 

inspection scope because ORNL-CCP is not currently prepared to use or demonstrate the CH VE 

process. Since EPA did not observe and review the CH VE process during the continued 

compliance inspection, the CH VE process must be approved in the future as a separate T1 

evaluation. 

EPA also made substantive changes to the Tier 2 (T2) designations in AK, NDA and 

nondestructive examination (NDE) for both the CH and RH waste characterization programs at 

ORNL. These changes to the T2 requirements are necessary to make the ORNL-CCP tiering 

designations consistent with the requirements at other CH TRU sites and to support the 

streamlined process for conducting T1 evaluations. The changes are: 

1. DOE needs to submit to EPA of a list of all AK Experts (AKEs) and Site Project 

Mangers (SPMs) who performed work in these roles for the ORNL-CCP waste 

characterization program during the previous quarter. This is a new CH and RH AK T2 

change (see Tables 1 and 2). 

2. DOE needs to submit to EPA of a list of all NDA personnel who performed work during 

the previous quarter is a new NDA T2 change (see Table 1). Specifically, the list must 

include all operators, Expert Analysts (EAs) and Independent Technical Reviewers 

(ITRs). 

3. DOE needs to submit to EPA of a list of all DTC personnel who performed work during 

the previous quarter is a new radiological characterization T2 change (see Table 2). 

Specifically, the list must include all operators, EAs and ITRs. 

4. DOE needs to submit to EPA of a list of all NDE (RTR and VE) personnel who 

performed work during the previous quarter is a new CH and RH NDE T2 change (see 

Tables 1 and 2). Specifically, the list must include all VE and RTR operators, ITRs and 

Visual Examination Experts (VEEs). 

5. DOE needs to notify EPA upon completion of or substantive modification to CCP-TP005, Attachments 4, 6, 7 and 8 and/or associated memoranda, including “Add Container” 

memoranda is a modified CH AK T2 change that clarifies and combines existing 

requirements (see Table 1). 
3 

6. DOE needs to notify EPA upon completion of or revisions to all discrepancy resolution 

(DR) reports. This is a modified RH AK T2 change (see Table 2). 

EPA also revised the tiering tables to remove duplicate entries and ensure completeness and 

consistency with recent EPA continued compliance and T1 approval reports. Tables 1 and 2 

show the substantive T1 and T2 changes for CH and RH in bold text. T1 and T2 changes that 

were initiated during the CH and RH baseline and subsequent T1 approvals remain in effect. The 

language in Tables 1 and 2 regarding AK documentation applies to all ORNL-CCP waste 

streams. 

EPA did not identify any findings during this continued compliance inspection. EPA identified 

two concerns related to RTR: Concern No. 1, which identified areas of weakness in the RTR test 

and traning container process, did not require a response while Concern No. 2, which identified 

practices regarding the evaluation of the results of training container which were not adequate, 

required a response. ORNL-CCP responded adequately to Concern No. 2 and EPA considers 

both concerns closed. The concerns are discussed in section 8.4.1 of this report and included as 

Attachments J and K. 

This report serves as EPA’s public notification of the results of the continued compliance 

inspection. This information will be provided through the EPA website and by sending emails to 

the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3). 
4 

Table 1. Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented b

(Based on November 13–15, 2007, Baseline Inspection and Subsequent Tier 1 Evaluations, Update

Process Elements ORNL-CCP CH Waste Characterization Process – T1 Changes ORNL-CCP CH Waste Characteriz

Acceptable Knowledge, including Load Management 

Any new waste category other than retrievably stored debris and 

soils/gravel (i.e., solids or any type of newly generated waste) 

Load management 

Submission of a list of active ORNL-CC

Notification to EPA upon completion of o

• AK accuracy reports (annually, at a mi

• AK-AK and AK-NDA/NDE Discrepan

• WSPFs and related attachments (e.g., C

streams, including change notices 

• AKSRs (new and updated versions) 

• CCP-TP-005, Attachments 4, 6, 7 an

memoranda, including “Add Contain

• Site AK procedures requiring CBFO a

Nondestructive Assay New equipment or substantive physical modifications** to approved 

equipment

Extension of or changes to approved calibration range for approved equipment 

Submission of a list of ORNL-CCP NDA performed work during the previous quNotification to EPA upon substantive mod

• Software for approved equipment 

• Operating ranges upon CBFO approva• Site NDA procedures requiring CBFO 

Real-Time Radiography None Submission of a list of ORNL-CCP RTR 

performed work during the previous quNotification to EPA upon: 

• New equipment or substantive physica

equipment 

• Substantive modification** to site RTR 

approval 

Visual Examination and Visual Examination Technique 

Any use of visual examination Submission of a list of ORNL-CCP VE o

that performed work during the previou

WIPP Waste Data System Load management Notification to EPA upon substantive mod

procedures requiring CBFO approval 

New T1s, T2s and significant modifications to existing T1s or T2s are in bold text; T1s or T2s that were only revised for style are not shown in 

* ORNL-CCP will report all T2 changes to EPA every three months. ** “Substantive modification” refers to a change with the potential to affect ORNL-CCP’s CH waste characterization processes or documentat

that are solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act, or that are editoriaaddress administrative concerns. EPA may request copies of new references that DOE adds during a document revision. 
5 

Table 2. Tiering of Remote-Handled Transuranic Waste Characterization Processes Implemented b

(Based on June 30–July 2, 2008, Baseline Inspection and Subsequent Tier 1 Evaluations, Updated 

Process Elements ORNL-CCP RH Waste Characterization Process – T1 Changes ORNL-CCP RH Waste Characteri

Acceptable Knowledge Any new waste streams not approved under the baseline 

Modification of the approved population of the OR-REDC-RH-HET 

wastes to include any containers not included in the CCP-AKORNL-501, Revision 3 analysis 

Substantive modification** to the AKSR (e.g., CCP-AK-ORNL500), certification test plan (e.g., CCP-AK-ORNL-502), correlation and surrogate summary form, AK accuracy report and waste stream 

profile form Implementation of load management 

Submission of a list of active ORNL-CC

Notification to EPA upon availability of o• AKSRs and certification test plans (e.g., 

ORNL-502) 

• Correlation and surrogate summary form • AK accuracy reports (annually, at a min• The waste stream data package for wast

the WSPF, including the CRR and CIS 

Notification to EPA upon availability of o• CCP-AK-ORNL-002 • Add container memoranda • Documentation of RH sample reclassifie

confirmatory analyses via NDA 

• DRs or data limitation information • Site AK procedures requiring CBFO app

Radiological Characterization, including Dose-to-Curie 

Application of new scaling factors for isotopic determination other than those documented in CCP-AK-ORNL-501, Revision 3 

Use of any alternate radiological characterization procedure other 

than DTC, with established scaling factors as documented in CCPTP-504 

Any new waste stream not approved under the baseline or addition of containers to Waste Stream OR-REDC-RH-HET that requires changing the established radionuclide scaling factors in CCP-AKORNL-501, Revision 3 Substantive modification** of EPA-approved procedures or radiological characterization technical reports (e.g., CCP-TP-504, 

CCP-AK-ORNL-501) 

Submission of a list of ORNL-CCP DTC performed work during the previous quNotification to EPA upon: • Nonsubstantive modification** to proce

reports (e.g., CCP-TP-504, CCP-AK-OR

• Results from any RH TRU containers th

NDA 

Visual Examination Implementation of VE by any system other than two operators 

performing VE (i.e., viewing a previously recorded VE event)

Submission of a list of ORNL-CCP VE othat performed work during the previouNotification to EPA upon: • Substantive modification** to site VE p

• Characterization of SCG S3000 or S400
6 

Process Elements ORNL-CCP RH Waste Characterization Process – T1 Changes ORNL-CCP RH Waste Characteri

Real-time Radiography Any use of real-time radiography WIPP Waste Data System None Notification to EPA upon substantive mod

• Site WDS procedures requiring CBFO a• The Excel spreadsheet titled WWIS Dat

and Certification 

New T1s, T2s and significant modifications to existing T1s or T2s are in bold text; T1s or T2s that were only revised for style are not shown in 

* ORNL-CCP will report all unmarked T2 changes to EPA every three months. ** “Substantive modification” refers to a change with the potential to affect ORNL-CCP’s RH waste characterization processes or documentat

are solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act; or that are editorial in n

administrative concerns. EPA may request copies of new references that DOE adds during a document revision. 
7 

2.0 RESUMING TRANSURANIC WASTE CHARACTERIZATION ACTIVITIES AT 

OAK RIDGE NATIONAL LABORATORY 

From June 2011 to September 2013, DOE suspended TRU waste characterization activities at 

ORNL due to funding limitations and other DOE-wide priorities. During this period of activity 

suspension, CBFO Quality Assurance (QA) Program staff continued to perform annual audits of 

ORNL-CCP to evaluate and recertify that the TRU waste characterization program remained 

compliant with DOE Order 450.1,3

 which requires TRU waste generator sites to comply with 

various Federal and State-mandated environmental, health and safety requirements. 

ORNL-CCP resumed TRU waste characterization activities at ORNL on October 1, 2013. CBFO 

informed EPA of the resumption in November 2013 and also notified EPA that ORNL-CCP 

would be ready for a continued compliance inspection in January 2014. Subsequently, CBFO 

provided documents that supported the ORNL-CCP TRU waste characterization program 

resumption process.4

 

Per documentation provided by CBFO, ORNL-CCP resumed TRU waste characterization 

activities using previously EPA-approved processes. ORNL-CCP: 

• Implemented the latest revisions of CCP’s waste characterization procedures. While the 

ORNL-CCP TRU program was suspended, CCP continued to update and revise waste 

characterization procedures to support waste characterization programs at other TRU 

sites. EPA evaluated and concurred with the revised procedures as part of the continued 

compliance inspections conducted at other active TRU sites. 

• Resumed active use of the same ORNL-based AK, radiological and physical 

characterization systems that EPA evaluated and approved during the baseline 

inspections and subsequent T1 evaluations listed in Attachments A.1 and A.2 of this 

report. 

In addition, 40 CFR 194.24(h) authorizes EPA to conduct a continued compliance inspection at 

TRU sites when deemed necessary to ensure that the site-implemented CH and RH TRU waste 

characterization programs continue to be effective, appropriate and technically adequate. Given 

the above rationale, EPA concluded that a new baseline inspection and approval was not 

necessary. EPA informed CBFO and ORNL-CCP that: 

• EPA would conduct a continued compliance inspection of ORNL-CCP’s CH and RH 

TRU waste characterization programs prior to any waste emplacement at the WIPP. 

 

3

 DOE O 450.1, Environmental Protection Program, U.S. Department of Energy Office of Environment, 

Safety and Health, January 15, 2003. 

4

 CBFO provided the following documents to EPA to explain and support ORNL-CCP’s waste 

characterization program resumption: 

• CCP Restart Integrated Schedule, TRU Waste Processing Center, September 19, 2013 

• CCP-TWPC Return Narrative 

• CCP-PO-027, CCP/TRU Waste Processing Center/Oak Ridge National Laboratory Interface Document, 

Revision 5, October 2, 2013 

• Programmatic Change Request, CBFO 13-061, August 1, 2013 
8 

• ORNL TRU waste may not be shipped to WIPP for disposal until: 

o CBFO completes a susscessful recertification audit.

o CBFO obtains the New Mexico Environment Department’s approval. 

o EPA reviews CBFO’s ORNL-CCP’s draft recertification memorandum. 

o CBFO transmits the recertification memorandum to ORNL-CCP. 

 CBFO fulfilled the first two sub-bullets above in January 2014 and April 2014, repectively. 

3.0 PURPOSE OF CONTINUED COMPLIANCE INSPECTIONS 

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

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

characterization program (Vol. 69, No. 136, pages 42571–42583, July 16, 2004). The purpose of 

EPA’s baseline inspection is to approve the site’s waste characterization program, based on a 

demonstration that the program’s components, with applicable conditions and limitations, can 

adequately characterize TRU wastes and comply with the regulatory requirements imposed on 

TRU wastes destined for disposal at the WIPP. 

Following EPA’s baseline approval, EPA has the authority to conduct continued compliance 

inspections to verify that the site (1) continues to use only the approved waste characterization 

processes to characterize the waste and (2) remains in compliance with all the regulatory 

requirements. EPA is also authorized to evaluate and approve changes, if necessary, to the site’s 

approved waste characterization program by conducting additional inspections under the 

authority of 40 CFR 194.24(h). 

In November 2012, DOE, DOE contractor staff, EPA and EPA contractor staff discussed DOE’s 

TRU site cleanup goals through 2016 and ways to improve EPA’s evaluation and decision 

process to support DOE sites’ state-mandated cleanup needs. As a result of this discussion, EPA 

finalized a streamlined evaluation and decision process that includes an annual EPA continued 

compliance inspection at each active, EPA-approved TRU waste site. The annual continued 

compliance inspections will cover the common elements of waste characterization processes that 

are not expected to vary significantly on a waste stream or T1 change basis. Examples of the 

common characterization elements are personnel training, procedures and equipment 

capabilities. Each site is also required to provide changes to waste characterization elements in 

conjunction with the quarterly T2 change reports for EPA review. The quarterly review of the 

common elements will be independent of EPA’s approvals of T1 change requests and will ensure 

that the waste characterization elements of each active site’s TRU program continue to remain in 

compliance with EPA WIPP requirements at 40 CFR 194.8 and 24. 

The results of this continued compliance inspection and the review of quarterly T2 changes 

submitted since the February 2014 inspection will be the basis for EPA’s evaluation of any 

ORNL-CCP T1 change requests submitted before the next EPA continued compliance 

inspection. Thus, EPA will focus on only those waste characterization components that are 

critical to the specific T1 change request, evaluation and approval (e.g., waste-stream-specific 

AK records). In addition, EPA may not revisit the elements discussed in this report until the next 

continued compliance inspection, at the Agency’s discretion. 
9 

4.0 PURPOSE OF TIER 1 EVALUATIONS 

Certain changes to the waste characterization activities from the date of the site’s baseline 

inspection must be reported to and, if applicable, approved by EPA according to the tiering 

requirements set forth in 40 CFR 194.8 regulations and incorporated into the ORNL-CCP CH 

and RH baseline final reports (see EPA Docket Nos. A-98-49; II-A4-103 and A-98-49; 

II-A4-111). 

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

(Vol. 69, No. 136, pages 42571–42583), EPA must perform a single baseline inspection of a 

TRU waste generator site’s waste characterization program. The purpose of EPA’s baseline 

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

that the program’s components, with applicable conditions and limitations, can adequately 

characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes 

destined for disposal at the WIPP. 

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

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

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

approval prior to implementation (T1) and those requiring post-implementation notification (T2) 

are identified in the site-specific baseline inspection reports. When evaluating proposed T1 

changes for approval, EPA may conduct a site inspection to observe at first hand the 

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

specific to a change. DOE may choose to characterize and dispose of any previously approved 

TRU waste using processes, procedures or equipment implemented as T2 changes at risk of 

subsequent EPA disapproval. EPA reviews T2 changes on a quarterly basis and may conduct 

continued compliance inspections to evaluate implemented T2 changes to verify adequacy. 

5.0 PURPOSE OF THIS REPORT 

This report documents the basis for EPA’s decision to maintain the approval of the ORNL-CCP 

waste characterization program for CH and RH TRU wastes, as well as EPA’s decision to 

approve the modifications to the MCS IQ3 NDA system. Specifically, this report: 

• Describes the selected elements of the ORNL-CCP waste characterization systems 

evaluated during this continued compliance inspection and T1 evaluation. 

• Identifies all areas where waste characterization systems have changed relative to what 

was approved during the baseline inspection and other subsequent EPA T1 evaluations 

and assesses the impact, if any, of those changes. 

• Provides objective evidence to support the basis for EPA’s continued approval of all 

waste characterization systems. 

• Provides objective evidence to support the basis for EPA’s decision to approve the 

modifications to the MCS IQ3 NDA system. 

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

T1 evaluation and their relevance to EPA’s approval decision. 
10 

The DOE documents that EPA reviewed for this inspection and T1 evaluation are cited 

throughout the report and are listed in Attachment B. Any of these documents can be requested 

from the following address: 

Carlsbad Field Office 

Manager, National TRU Program 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

6.0 SCOPE OF THIS INSPECTION 

The scope of this continued compliance inspection included the evaluation of selected elements 

of the waste characterization systems in use at ORNL-CCP to characterize CH and RH TRU 

wastes that were approved during the baseline inspections and subsequent T1 evaluations. Waste 

characterization activities evaluated included AK for Waste Streams OR-NFS-CH-SOIL, ORISTP-CH-HET and OR-REDC-RH-HET; the MCS IQ3 NDA system5

 for CH waste 

characterization and the DTC system for RH waste characterization; RTR operations for multiple 

CH SCGs; and VE operations for RH debris waste characterization. 

7.0 INSPECTION PERSONNEL 

EPA and its support personnel conducted interviews with ORNL-CCP waste characterization 

personnel in several disciplines. The personnel contacted represented a sample of the TRU waste 

characterization staff. The EPA inspection team and ORNL-CCP personnel contacted are listed 

in Attachment C, with their affiliations and areas of expertise or function. 

8.0 TECHNICAL EVALUATION 

Sections 8.1 through 8.4 of this report detail the four technical areas assessed during this 

inspection: AK, NDA, DTC and NDE, consisting of RTR and VE. EPA completed inspection 

checklists based on responses of ORNL-CCP waste characterization personnel to EPA queries 

and other documentation (see Attachments D, E and G–I). When evaluating future T1 change 

requests and concurring with quarterly T2 change submissions, EPA may use these checklists to 

supplement its review. 

8.1 Acceptable Knowledge (AK) 

EPA evaluated ORNL-CCP’s continued compliance with EPA-approved AK procedures for CH 

and RH TRU waste characterization. ORNL-CCP’s CH AK characterization program has been 

EPA-approved for SCG S5000 (heterogeneous debris) waste and SCG S4000 (soils). EPA 

selected one waste stream from each approved SCG (OR-ISTP-CH-HET and OR-NFS-CHSOIL) to review as representative samples of the ORNL-CCP CH AK waste characterization 

program. The AK checklists used for this inspection are included as Attachments D.1 and D.2. 

 

5

 The scope of the T1 evaluation of the MCS IQ3 overlaps significantly with the scope of the NDA 

continued compliance inspection. EPA decided to conduct the T1 evaluation and continued compliance inspection 

concurrently and perform the inspection/T1 evaluation as an expanded NDA continued compliance inspection. 
11 

ORNL-CCP’s RH AK characterization program is EPA-approved for SCG S5000 

(heterogeneous debris) waste. EPA reviewed the only approved ORNL-CCP RH waste stream 

(OR-REDC-RH-HET) during this inspection. The AK checklist used for this inspection is 

included as Attachment D.3. 

8.1.1 Technical Evaluation: Contact-Handled Waste 

(1) EPA examined select Central Characterization Program procedures and found them to be 

adequate. 

EPA reviewed several CCP procedures for AK documentation, training of AKEs and disposition 

of nonconformances for technical sufficiency and scope. Specifically, EPA reviewed: 

• CCP-QP-002, Revision 35, “Training and Qualification Plan,” June 6, 2013. 

• CCP-QP-005, Revision 23, “Nonconforming Item Reporting and Control,” June 25, 

2013. 

• CCP-TP-002, Revision 26, “Reconciliation of DQOs and Reporting Characterization 

Data,” June 19, 2013. 

• CCP-TP-005, Revision 26, “CCP Acceptable Knowledge Documentation,” August 12, 

2013. 

The changes made between Revision 25 and Revision 26 of the AK procedure (CCP-TP-005) 

directly impact the comparison of NDA measurement results to AK-expected radionuclide 

values and indirectly impact the AK accuracy evaluation process. Revision 26 no longer requires 

CCP personnel to compare drum-specific isotopic ratios against the range of isotopic values 

expected in the AK. CCP personnel explained that this change was done for two reasons: (1) the 

isotopic ratio comparison made sense for streams composed of very specific radiological 

compositions like those from Rocky Flats, but is not useful for waste streams with a more varied 

composition like those originating from the ORNL Isotope Program, and (2) the range of 

isotopic values predicted by AK for each individual drum, which is based on historical 

documents with varying degrees of quality and completeness, is provided to help the NDA EAs 

understand the waste stream; it is not expected to be binding. CCP personnel also stated that 

none of their upper-tier process-governing documents require the comparison against expected 

ranges of values and that this change brings the radionuclide comparison process in line with the 

waste material parameter comparison process. 

Revision 26 requires CCP personnel to perform a waste stream or waste stream lot comparison 

of the two most prevalent radionuclides and expected radionuclides identified by AK against 

NDA results, but the AK procedure no longer explicitly requires that any comparisons be made 

on a drum-by-drum basis. CCP personnel explained that AK predicts the two most prevalent 

radionuclides on a waste stream basis; therefore, the comparison should also be conducted at the 

waste stream or lot level. CCP personnel also explained that while the AK procedure does not 

require a drum-by-drum comparison to AK for the expected radionuclides, the shipping 

requirements specify that all of the radionuclides contributing to 95% of the radiological hazard 

for each payload container be identified in AK. As a result of these shipping requirements, which 
12 

are outside EPA’s purview, the drum-by-drum comparison of radionuclides present with the list 

of AK-expected radionuclides will still take place. 

Implementation of CCP-TP-005, Revision 26, AK-NDA comparison requirements will be 

apparent in the certification checklists and any corresponding AK re-evaluations. These changes 

will likely reduce the number and frequency of AK re-evaluations, which may result in artificial 

AK accuracy determinations of 100%. ORNL-CCP has not yet completed any certification 

checklists for either Waste Stream OR-ISTP-CH-HET or Waste Stream OR-NFS-CH-SOIL. 

EPA will review certification checklists during a future inspection to evaluate the implemented 

impact of the CCP-TP-005 revisions. 

EPA found that all four procedures listed above adequately reflect the requirements of 

40 CFR 194. Procedure implementation is evidenced by adequate preparation and maintenance 

of the required documentation, as reviewed below. Notification to EPA upon completion of or 

substantive modification to site AK procedures requiring CBFO approval remains a T2 change 

(see Table 1). 

(2) EPA verified that the acceptable knowledge characterization process for containers, 

including acceptable knowledge assembly, compilation and verification, was adequately 

implemented. 

EPA evaluated ORNL-CCP’s completion of each of the 15 attachments associated with CCP 

procedure CCP-TP-005 (which covers AK documentation) for each of the two sample waste 

streams. 

EPA found that ORNL-CCP AKEs correctly completed all applicable CCP-TP-005 attachments 

using the correct revision of each form. EPA established the correct revision by comparing the 

procedure’s effective date to the date the AKE signed the attachment. EPA will continue to 

monitor the use of appropriate attachment revisions. EPA expects that all ORNL-CCP waste 

characterization personnel are aware of and have access to the current revision of all controlled 

CCP documents. 

CCP-TP-005, Attachment 13, is an example form for completing the characterization checklists. 

ORNL-CCP has elected not to use the actual CCP-TP-005 form. The requirements in CCP-TP005, Attachment 13, have changed with recent revisions to CCP-TP-005, but ORNL-CCP has 

not completed any certification checklists since CCP revised the procedure. EPA will review 

certification checklists during a future inspection to verify that all required elements are 

included. 

(3) EPA verified that waste traceability was adequately demonstrated. 

EPA randomly selected seven containers from Waste Stream OR-ISTP-CH-HET and three 

containers from Waste Stream OR-NFS-CH-SOIL. These containers are traceable from their 

building of generation or source manufacture through ORNL-CCP characterization (as 

applicable). 
13 

(4) EPA assessed the acceptable knowledge summary reports and found them to be adequate. 

EPA evaluated the AK summary report (AKSR) for each sample waste stream for inclusion of 

sufficient information, supported by appropriate source documents, to support the following 

statements: 

• All waste within the waste stream was generated from a single process/activity. 

• All waste within the waste stream is similar in material and physical form. 

• The radiological properties of the waste stream are adequately described. 

• All of the waste in the waste stream is defense in origin.6

• None of the waste in the waste stream is high-level waste (HLW).3

• None of the waste in the waste stream is spent nuclear fuel (SNF).3

ORNL-CCP provided CCP-AK-ORNL-008, Revision 1, as the AKSR for Waste Stream ORISTP-CH-HET, and CCP-AK-ORNL-001, Revision 8, as the AKSR for Waste Stream OR-NFSCH-SOIL. Upon review of CCP-AK-ORNL-001, Revision 8, EPA found the explanation for the 

subject waste being neither HLW nor SNF to be incomplete and insufficient. To address this 

deficiency, ORNL-CCP revised CCP-AK-ORNL-001 and provided Revision 9 of the document 

to EPA. EPA found CCP-AK-ORNL-008, Revision 1, and CCP-AK-ORNL-001, Revision 9, to 

be adequate. Explanations and source documents supporting each of the above statements are 

included in the checklists in Attachments D.1 and D.2 to this report: 

• Waste Stream OR-ISTP-CH-HET: Attachment D.1, checklist items AKCH-16–AKCH19 and AKCH-21–AKCH-23, summarizes the information provided in the AKSR CCPAK-ORNL-008, Revision 1. 

• Waste Stream OR-NFS-CH-SOIL: Attachment D.2, checklist items AKCH-16–AKCH19 and AKCH-21–AKCH-23, summarizes the information provided in the AKSR CCPAK-ORNL-001, Revision 9. 

Notification to EPA upon completion of or revisions to all AKSRs remains a T2 change (see 

Table 1). 

(5) EPA evaluated waste stream profile form preparation and completeness and found them 

to be adequate. 

EPA reviewed the waste stream profile forms (WSPFs), including the characterization 

information summaries (CISs) and summations of aspects, for Waste Stream OR-ISTP-CH-HET 

and Waste Stream OR-NFS-CH-SOIL and found them to be complete and adequate. 

(6) EPA assessed acceptable knowledge personnel training and found it to be adequate. 

EPA reviewed complete qualification cards for all of the AKEs identified on reviewed AK 

documents or identified by ORNL-CCP as working with the ORNL-CCP CH TRU waste 

characterization program: Chris Chancellor, Charles Allen Dickerson, Trey Greenwood, Jeff 

 

6As defined by U.S. Code, Title 42, “The Public Health and Welfare,” Chapter 108, “Nuclear Waste Policy

Act of 1982.” 
14 

Harrison, Jason Montoya, Kevin Peters, Steve Schafer and Travis Smith. EPA also reviewed 

complete SPM qualification cards for Rich Kantrowitz, Jake Knox, Laura Nelson, Beverly 

Schrock, Daniel Wade, Roger Whiteaker and Candice Weston. EPA verified Mr. Peters’, Mr. 

Harrison’s, and Ms. Schrock’s skills and knowledge of the current versions of the procedures 

listed in Item (1) above by interview during the evaluation. EPA verified current training for the 

other listed personnel7

 by reviewing the Assigned Reading Reports. 

EPA found the training records for the personnel listed above to be complete and adequate. EPA 

will review training records for any additional personnel supporting ORNL-CCP CH waste 

characterization during a future T1 evaluation, as part of a new quarterly T2 change submission 

or during the next continued compliance inspection. 

Submission to EPA of a list of AKEs and SPMs who performed work in these roles for the 

ORNL-CCP CH waste characterization program in the previous quarter is a new T2 change (see 

Table 1). EPA added this requirement to ensure that EPA has a complete picture of ORNL-CCP 

waste characterization activities, which will inform the scope of AK components evaluated 

during future T1 change evaluations. 

(7) EPA assessed nonconformance and discrepancy resolution documentation and found it to 

be adequate. 

EPA reviewed sample nonconformance reports (NCRs) associated with each waste stream and 

found that they were adequately prepared. EPA also reviewed the most recent DR reports 

associated with each sample waste stream and found them to be adequately prepared. 

Notification to EPA upon completion of or substantive modification to DR reports is a revised 

T2 change. EPA revised this T2 requirement to make the ORNL-CCP tiering designations 

consistent with the requirements at other CH TRU sites and to reflect current T2 reporting 

practices (see Table 1).

(8) EPA assessed acceptable knowledge accuracy and found it to be adequate. 

EPA reviewed the latest annual AK accuracy report for both waste streams, prepared in March 

2012 to assess AK accuracy for containers certified for WIPP-emplacement by ORNL-CCP 

during March–June 2011. The SPM indicated that while the CCP characterization activities at 

ORNL were suspended during 2012, CCP prepared the report for a CBFO QA recertification 

audit. CCP must prepare AK accuracy reports annually for any waste stream that was 

characterized during the previous year, regardless of characterization status at the time the report 

is written. The March 2012 AK accuracy reports were correctly prepared using CCP-TP-005, 

Revision 24. ORNL-CCP will complete the next AK accuracy reports by January 2015. 

The AK accuracy report for Waste Stream OR-ISTP-CH-HET shows an AK accuracy of 100%, 

even though the AK characterization checklist indicates that the two prevalent radionuclides 

 

7

 Candice Weston and Chris Chancellor signed some of the documentation associated with Waste Stream 

OR-NFS-CH-SOIL but are no longer active in the ORNL-CCP program. EPA reviewed their qualification cards to 

ensure that they were qualified during the time that they signed the documentation, but EPA did not review any 

documentation concerning their knowledge of the current procedure revisions. 
15 

identified by AK do not agree with those obtained through assay. The SPM indicated that 

forthcoming reports will likely take into account the disagreement between NDA and AK with 

respect to the two most prevalent radionuclides; however, the changes to CCP-TP-005 [discussed 

above in Item (1)] may result in the disagreement not being addressed until the waste stream is 

fully characterized. Based on these questions, EPA will revisit the discussion about the 

meaningfulness of AK accuracy calculations during a future inspection or evaluation. 

Notification to EPA upon completion of or substantive modification to AK accuracy reports 

(annually, at a minimum) remains a T2 change (see Table 1). 

(9) EPA assessed communication between acceptable knowledge and nondestructive assay 

personnel and found it to be adequate. 

EPA reviewed the current NDA memorandum for each of the sample waste streams, evaluated 

the memoranda for completeness and compared the memoranda with the AKSRs. ORNL-CCP 

revised the NDA memorandum for Waste Stream OR-ISTP-CH-HET in 2013. CCP-AK-ORNL008, Revision 1, does not contain all of the relevant information presented in the NDA 

memorandum. This inconsistency does not affect compliance; the AKE stated that he will revisit 

the NDA memorandum and include relevant AK information in forthcoming revisions of the 

AKSR. The NDA memorandum for Waste Stream OR-NFS-CH-SOIL was last revised in 2010. 

EPA found the level of detail and precision in the NDA memoranda to be adequate. 

Notification to EPA upon completion of or substantive modification to AK-NDA memoranda 

remains a T2 change (see Table 1). 

(10) EPA found load management to be not applicable. 

The WIPP waste acceptance criteria allow payload management such that a payload container 

may include drums that measure less than 100 nanocuries per gram (nCi/g) so long as the 

payload in total is greater than 100 nCi/g. The AKSR for each waste stream selected for payload 

management must include an estimate of the total waste volume and percentage of the waste 

volume that is above and below100 nCi/g. Each container selected for payload management must 

also contain at least one TRU isotope whose activity exceeds the lower limit of detection (LLD) 

of the radioassay system used to characterize the waste, and each container may only be 

overpacked into a payload container with other containers from the same TRU waste stream. 

ORNL-CCP does not expect to perform load management for any of the sample waste streams 

reviewed during this inspection. 

Notification to EPA upon implementation of load management for waste streams other than 

those discussed in AKSR CCP-AK-ORNL-009 remains a T2 change (see Table 1). 

(11) EPA evaluated compliance with tiering requirements and found it to be adequate. 

T2 notification to EPA upon completion of or substantive modification to the waste-streamspecific documents listed in Table 1 is required on a quarterly basis. EPA compared the revision 

dates of documents provided during this continued compliance inspection with the fiscal year 
16 

(FY) 2014 first quarter T2 notification report provided to EPA by CBFO in order to verify 

ORNL-CCP’s T2 reporting process since resuming operations. 

EPA found that ORNL-CCP appropriately reported T2 changes as applicable. The tiering 

changes identified during the ORNL-CCP CH baseline inspection and subsequent T1 evaluations 

remain in effect and are included as Table 1 of this document. 

Summary of Acceptable Knowledge for Contact-Handled Waste 

EPA did not identify any findings or concerns related to AK for CH waste as a result of this 

continued compliance inspection. 

Submission to EPA of a list of all AKEs and SPMs who performed work during the previous 

quarter is a new AK T2 change, and notification of availability of new or revised CCP-TP-005, 

Attachments 4, 6, 7 and 8 and/or associated memoranda, including “Add Container” memoranda 

is a modified AK T2 change that clarifies and combines existing requirements (see Table 1). 

8.1.2 Technical Evaluation: Remote-Handled Waste 

(1) EPA examined select Central Characterization Program procedures and found them to be 

adequate. 

EPA reviewed several CCP procedures for AK documentation, training of AKEs and disposition 

of nonconformances for technical sufficiency and scope. Specifically, EPA reviewed: 

• CCP-QP-002, Revision 35, “Training and Qualification Plan,” June 6, 2013. 

• CCP-QP-005, Revision 23, “Nonconforming Item Reporting and Control,” June 25, 

2013. 

• CCP-TP-002, Revision 26, “Reconciliation of DQOs and Reporting Characterization 

Data,” June 19, 2013. 

• CCP-TP-005, Revision 26, “CCP Acceptable Knowledge Documentation,” August 12, 

2013. 

These procedures adequately reflect applicable requirements of 40 CFR 194.24. ORNL-CCP 

provided an assigned reading list acknowledging training of AKEs and SPMs to the most recent 

version of each of these procedures. Also, adequate procedure implementation is evidenced by 

preparation and maintenance of required documentation associated with these procedures, as 

reviewed below. In addition, AKEs and SPMs were trained to the most recent version of the 

Remote-Handled TRU Waste Characterization Program Implementation Plan (WCPIP), which 

documents DOE’s approach to characterize RH waste in compliance with 40 CFR 194.24. WIPP 

Waste Acceptance Criteria and WIPP Waste Analysis Plan proficiency, which contribute to 

DOE’s demonstrated system of controls, was demonstrated by RH AKEs and SPMs. 

Notification to EPA upon completion of or substantive modification to site AK procedures 

requiring CBFO approval remains a T2 change (see Table 2). 
17 

(2) EPA verified that ORNL-CCP adequately implemented the acceptable knowledge 

characterization process for containers, including acceptable knowledge assembly, 

compilation and verification. 

EPA evaluated ORNL-CCP’s completion of each of the applicable attachments associated with 

CCP procedure CCP-TP-005 (which addresses the AK process) for Waste Stream OR-REDCRH-HET. Several add-container memoranda were appended to CCP-TP-005, Attachment 8. The 

containers listed on CCP-TP-005, Attachment 8, together with those on the add-container 

memoranda represent all containers added to the waste stream, but Attachment 8 did not include 

all memos and two memos from a different waste stream were inadvertently attached. EPA 

discussed this observation with the ORNL-CCP AKE who will rectify and monitor revision of 

Attachment 8. EPA will continue to verify Attachment completeness and adequacy because these 

demonstrate adequate process implementation. 

Notification to EPA upon completion of or substantive modification to add-container 

memoranda remains a T2 change (see Table 2). Notification to EPA upon completion of or 

nonsubstantive modification to the correlation and surrogate summary form remains a T2 change 

(see Table 2). 

(3) EPA verified that ORNL-CCP adequately demonstrated waste traceability. 

EPA randomly selected two containers from Waste Stream OR-REDC-RH-HET, Lot 29. Lot 29 

is the first drum lot characterization lot assigned after ORNL-CCP resumed characterization 

activities. These containers are traceable from their building of generation through ORNL-CCP 

characterization. 

(4) EPA assessed the acceptable knowledge summary report and found it to be adequate. 

EPA evaluated the AKSR for Waste Stream OR-REDC-RH-HET for inclusion of sufficient 

information, supported by appropriate source documents, to support the following statements: 

• All waste within the waste stream was generated from a single process/activity. 

• All waste within the waste stream is similar in material and physical form. 

• All waste within the waste stream has similar radiological properties. 

• All of the waste in the waste stream is defense in origin.8

• None of the waste in the waste stream is HLW.5

• None of the waste in the waste stream is SNF.5

EPA found that the provided AKSR (CCP-AK-ORNL-500, Revision 3) did not initially 

adequately demonstrate the exclusion of SNF and HLW because ORNL-CCP based the 

argument on references that drew different conclusions. The ORNL-CCP AKE modified the 

AKSR (CCP-AK-ORNL-500, Revision 4) to better explain DOE’s determination that SNF and 

HLW are absent from the waste stream. Explanations and source documents supporting each of 

the above statements are included in the checklist in Attachment D.3 to this report. 

 

8As defined by U.S. Code, Title 42, “The Public Health and Welfare,” Chapter 108, “Nuclear Waste Policy

Act of 1982.” 
18 

Notification to EPA upon completion of or revisions to all AKSRs remains a T2 change (see 

Table 2). 

(5) EPA evaluated waste stream profile form preparation and completeness and found both 

aspects to be adequate. 

EPA reviewed the WSPF for Waste Stream OR-REDC-RH-HET, including the CISs and 

summations of aspects. EPA found these documents to be adequate. 

Notification to EPA upon modification of the WSPF package remains a T2 change (see Table 2). 

(6) EPA assessed acceptable knowledge personnel training and found it to be adequate. 

EPA reviewed qualification cards and assigned reading reports, which showed that ORNL-CCP 

AKEs and SPMs are trained to previous and current versions of the procedures listed in Item (1) 

of this section, including the WCPIP. Personnel records examined included those for the AKEs 

Steve Schafer, Kevin Peters and Lisa Watson and SPMs Dave Moody, Irene Joo and Laura 

Nelson. Training records for the personnel listed above are complete and adequate. EPA will 

review training records for any additional personnel supporting RH waste characterization during 

a future T1 evaluation, as part of a new quarterly T2 change submission or during the next 

continued compliance inspection. 

Submission to EPA of a list of AKEs and SPMs who performed work in these roles for the 

ORNL-CCP RH waste characterization program in the previous quarter is a new T2 change (see 

Table 2). EPA added this requirement to ensure that EPA has a complete picture of ORNL-CCP 

waste characterization activities, which will inform the scope of AK components evaluated 

during future T1 change evaluations. 

(7) EPA assessed nonconformance and discrepancy resolution documentation and found it to 

be adequate. 

EPA reviewed sample NCRs associated with waste stream OR-REDC-RH-HET and found that 

ORNL-CCP adequately prepared the documents. EPA also reviewed DR reports associated with 

the waste stream and found them to be adequately prepared. ORNL-CCP generated these NCRs 

and DR reports prior to the 2011 suspension of waste characterization activities. 

Notification to EPA upon completion of or substantive modification to DR reports is a new T2 

change. EPA added this T2 requirement to make the ORNL-CCP tiering designations consistent 

with the requirements at other RH TRU sites and to reflect current T2 reporting practices (see 

Table 2).

(8) EPA assessed acceptable knowledge accuracy and found it to be adequate. 

EPA reviewed AK accuracy reports for Lots 1–28 and 1–29 to ensure that the draft AK accuracy 

report for Lots 1–29 adequately integrated new information and the previous accuracy results. 

The roll-up adequately reflected addition of Lot 29 containers. ORNL-CCP prepared the Lots 1–

28 AK accuracy report when CCP was not active at the site; the AKE and SPM indicated that 

they prepared the accuracy report to address interim audit requirements. 
19 

Notification to EPA upon completion of or substantive modification to AK accuracy reports 

(annually, at a minimum) remains a T2 change (see Table 2). 

(9) EPA evaluated the certification plan and identification of data quality objectives in the 

certification plan, and found them to be adequate. 

The certification plan (CCP-AK-ORNL-502, Revision 4) did not adequately address the 

determination of SNF and HLW, including development of AK data quality objectives (DQOs) 

associated with identification of SNF and HLW. CCP revised the certification plan to address 

this deficiency (CCP-AK-ORNL-502, Revision 5) and provided the revised report to EPA during 

the continued compliance inspection. Other than this change, EPA found the certification plan to 

be complete and adequate. 

Notification to EPA upon availability of nonsubstantive modifications to certification plans 

remains a T2 change (see Table 2). 

(10) EPA found load management not applicable to this waste stream. 

ORNL-CCP does not perform load management for Waste Stream OR-REDC-RH-HET. 

Notification to EPA upon implementation of load management for ORNL-CCP RH waste 

streams remains a T1 change (see Table 2). 

(11) EPA evaluated compliance with tiering requirements and found it to be adequate. 

T2 notification to EPA upon completion of or substantive modification to the waste-streamspecific documents listed in Table 2 is required on a quarterly basis. EPA compared the revision 

dates of documents provided during this continued compliance inspection with the FY 2014 first 

quarter T2 notification report provided to EPA by CBFO in order to verify ORNL-CCP’s T2 

reporting process since resuming operations. 

EPA found that ORNL-CCP did not provide T2 notification for the correlation and summary 

surrogate form (CSSF) for Waste Stream OR-REDC-RH-HET (dated 11/26/2013) during the 

same quarter that the document was signed (FY 2014, first quarter) because the CSSF was placed 

in records the following reporting quarter. EPA discussed the requirement that documents be 

reported the same quarter they are signed with ORNL-CCP personnel and determined that this 

oversight was an isolated event. EPA expects that notification of the revised CSSF will be 

included in the T2 notification report for FY 2014, second quarter. The tiering changes identified 

during the ORNL-CCP RH baseline inspection and subsequent T1 evaluations remain in effect 

and are included as Table 2 of this document. 

Summary of Acceptable Knowledge for Remote-Handled Waste 

EPA did not identify any findings or concerns related to AK for RH waste as a result of this 

continued compliance inspection. 
20 

Submission to EPA of a list of all AKEs and SPMs who performed work during the previous 

quarter is a new AK T2 change and notification of availability of all completed DRs is a revised 

T2 change (see Table 2). 

8.1.3 Acceptable Knowledge Findings and Approval 

Summary of Acceptable Knowledge Findings and Concerns

EPA did not identify any findings or concerns related to AK as a result of this continued 

compliance inspection. 

Acceptable Knowledge Approval

Submission to EPA of a list of AKEs and SPMs who performed work in these roles for the 

ORNL-CCP waste characterization program during the previous quarter is a new T2 change for 

both CH and RH waste characterization programs (see Tables 1 and 2). EPA added this 

requirement to ensure that EPA has a complete picture of ORNL-CCP waste characterization 

activities, which will inform the scope of AK components evaluated during future T1 change 

evaluations. Notification to EPA upon completion of or revisions to all DRs is a revised RH T2 

change. EPA added this requirement to make the ORNL-CCP tiering designations consistent 

with the requirements at other sites (see Table 2).

Based on the results of this evaluation and the data examined, EPA determines that ORNL-CCP 

demonstrated continued AK characterization compliance. 

8.2 Nondestructive Assay (NDA) – Contact-Handled Waste 

The purpose of this inspection was to confirm the continued compliance of NDA as part of the 

ORNL-CCP waste characterization program. ORNL-CCP’s NDA program consists of the MCS 

IQ3, which EPA approved initially during a T1 evaluation in February 2010 (see EPA Docket 

No. A-98-49; II-A4-125, dated March 24, 2010). Prior to resuming TRU waste characterization 

operations in 2013, ORNL-CCP replaced gamma detectors and recalibrated the IQ3, actions 

which constituted a T1 change. EPA decided to evaluate this proposed T1 change and continued 

compliance inspection concurrently, the results of which are presented below. Details of the IQ3 

system that EPA evaluated at ORNL during this inspection are provided in the NDA checklist in 

Attachment E. 

This inspection focused on the following: 

• Confirmation that the ORNL-CCP IQ3 system was the same as what EPA approved 

initially and that its design and technical capabilities had not changed significantly since 

EPA’s last inspection. 

• Adequacy of the current revisions of the ORNL-CCP NDA procedures and documents. 

• Operational and maintenance history of the IQ3 system since resuming TRU waste 

characterization operations at ORNL-CCP. 

• Knowledge, understanding and training status of ORNL-CCP NDA personnel. 
21 

• Applicability of the IQ3 system’s current configuration to assay the waste types that 

ORNL-CCP was processing in terms of physical form and radionuclides. 

• Replicate testing of the IQ3 to verify that the system can provide reproducible results for 

the determination of the quantity of 10 WIPP-tracked radionuclides [americium-241 

(

241Am), cesium-137 (137Cs), plutonium-238 (238Pu), 239Pu, 240Pu, 242Pu, strontium-90 

(

90Sr), uranium-233 (233U), 234U and 238U] and the TRU alpha concentration. The 

replicate spreadsheets are in Attachments F.1 through F.3. 

8.2.1 Technical Evaluation: Mobile Characterization Services IQ3 System 

The following aspects of the IQ3 were evaluated during this inspection. 

(1) The IQ3 nondestructive assay system is the same system that was approved previously. 

The IQ3 system is housed in trailer number NDA-IQ3-01 located in Building 79880 MW at the 

TRU Waste Processing Center (TWPC) at ORNL. This system has not been moved since EPA’s 

initial approval in February 2010. Between May 2011 and October 2013, ORNL only used the 

IQ3 for non-WIPP assays and recalibrated the system in 2012, following replacement of several 

coaxial detectors and electronic upgrades. EPA confirmed that this is the IQ3 system that was 

approved initially. Other than the detector replacements and the electronic upgrades, there have 

been no substantive hardware or software changes to this system since EPA’s initial approval of 

the IQ3. EPA Inspectors observed IQ3 Operator Maria Steade assay container No. 

X10CSATN02241L, part of Waste Stream OR-REDC-HET-2A, the third of the five EPA 

replicate assays [see (8) below] during this inspection. EPA did not identify any concerns 

regarding the ORNL-CCP IQ3 system. 

(2) EPA assessed the design and operational range of the IQ3 and found them to be adequate 

for the wastes currently being assayed. 

The date of the last IQ3 batch data report (BDR) that ORNL-CCP produced prior to suspending 

WIPP operations is May 18, 2011. The date of the first NDA BDR generated by the IQ3 since 

resumption of WIPP operations at ORNL is December 3, 2013. Since the resumption date, 

ORNL-CCP has assayed 187 drums,9

 which have been compiled into a total of 30 BDRs. All of 

the 30 BDRs consist of 55-gallon drums from Waste Stream OR-REDC-CH-HET, as 

documented in CCP-AK-ORNL-002 NDA Memorandum. The density range of the current IQ3 

calibration is 1.639 grams per cubic centimeter (g/cm3), which adequately covers the physical 

aspects of the ORNL-CCP waste stream. 

EPA reviewed IQ3 BDR No. OR-IQ3-0224 and found that it adequately documented the assays 

of 55-gallon drums. ORNL-CCP appropriately recorded all daily performance measurements, all 

of which were in control. Specifically, ORNL-CCP evaluated background, daily performance, 

resolution (full width at half maximum or FWHM), and energy calibration (gain) checks, as 

evidenced in the IQ3 daily operational logbook and BDRs. ORNL-CCP also established and 

 

9

 The exact number of IQ3 assays is not clear; however, ORNL-CCP has performed successful assays of 

187 drums. ORNL-CCP deems all 187 assays adequate to characterize WIPP-bound TRU wastes and all assays were 

subject to EPA’s evaluation during this inspection.
22 

documented all warning and control limits [2 and 3 sigma (σ) limits] for all parameters, as 

appropriate. 

EPA observed that IQ3 personnel had available and were using the current revisions of the 

operating procedure, CCP-TP-047, Revision 12. All aspects of the IQ3 operation were 

acceptable. 

(3) ORNL-CCP performed and documented system calibration and calibration confirmation 

of the IQ3 system, as required. 

EPA verified that the system had a new calibration in January 2012, which included peak shape, 

energy and efficiency determinations. Wastren Advantage Incorporated (WAI) performed these 

calibrations under contract to ORNL using WAI procedures. ORNL-CCP evaluated and accepted 

these calibrations after determining they were compliant with WIPP criteria, as documented in 

the CCP Oak Ridge Interface Plan, CCP-PO-027. These calibrations are described in MCS-IQ3-

CALIB-2012. ORNL also performed calibration verification measurements, which are 

documented in MCS-IQ3-CAL-CONF-RPT 2013-01. Upon completion of the calibration 

measurements, ORNL-CCP put the IQ3 into regular use, as documented in the IQ3 operational 

logbook. 

Two of the ORNL-CCP calibration reports that EPA reviewed did not present a clear description 

of the technical details of the calibration. ORNL-CCP revised these documents following 

discussions with EPA technical personnel and the revised documents addressed all aspects of the 

calibration and calibration verification. EPA did not identify any concerns regarding the 

calibration and calibration verification of the ORNL-CCP IQ3 system. 

(4) Determination and documentation for the total measurement uncertainty for the IQ3 

system are adequate. 

The technical determination of total measurement uncertainty (TMU) of assays performed on the 

IQ3 had been documented in detail in a 2009 ORNL-CCP TMU report. The EPA inspection 

team verified that they did not make any substantive changes to this report and that the TMU 

values in the IQ3 BDRs were consistent with expectations based on the 2009 report. The EPA 

inspection team noted that the TMU document should be updated to reflect the specific 

prohibition regarding the use of the attenuated assay mode. EPA did not identify any concerns 

regarding the technical adequacy and documentation of TMU for the IQ3 system. 

(5) ORNL-CCP determined and documented the lower limit of detection of the IQ3 system, 

as required. 

The ORNL-CCP report MCS-IQ3-CAL-CONF-RPT, Revision 0, documents the ability of the 

IQ3 to discriminate between TRU and non-TRU wastes to meet the 100 nCi/g criterion. This 

report notes that the LLD values that are provided are in fact conceptual, and that actual values 

will be higher. The ORNL-CCP EA will evaluate those assays where the LLD values exceed 100 

nCi/g and reject all values that cannot be unambiguously assigned as TRU. EPA did not identify 

any concerns regarding the technical adequacy and documentation of LLD values for the IQ3 

system. 
23 

(6) The IQ3 system participated in drum cycle 20C of the CBFO-sponsored performance 

demonstration program, as required. 

The IQ3 system assayed four Performance Demonstration Program (PDP) drums for PDP Cycle 

20C: metals, combustibles, sludge and glass. CBFO provided results for this cycle to EPA on 

February 24, 2014, indicating that the IQ3 passed all criteria for the four drums assayed. 

(7) EPA assessed personnel training and found it to be adequate. 

All NDA personnel associated with the calibration, operation, and data review and approval of 

the IQ3 had current training in the applicable areas, as evidenced by the list of qualified 

individuals (LOQI) dated February 3, 2014, that was provided during the inspection. 

(8) ORNL-CCP performed EPA replicate testing of the IQ3 system. EPA evaluated the 

results and found them to comply with the criteria for the Environmental Protection 

Agency Replicate Testing Protocol. 

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

an independent means to verify that the IQ3 can provide reproducible results for the 

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

240Pu, 242Pu, 90Sr, 233U, 234U and 238U) and the TRU alpha concentration.10 This is accomplished 

by the IQ3 reassaying drums it previously measured to demonstrate the system’s ability to do the 

following: 

• Produce results consistent with the reported TMU by comparing the sample standard 

deviation for a number of replicate measurements taken over several hours or days to the 

reported TMU. 

• Provide reproducible results over longer periods of time, such as weeks or months, by 

comparing the results of the replicate measurements to the original reported values. 

As part of this inspection, EPA requested that ORNL-CCP reassay three drums that EPA 

randomly selected from a list of drums previously assayed on the IQ3. ORNL-CCP reassayed 

Drum Nos. X10CSATN02241L, NFS0419D and NFS0478A five times and compared the results 

to the original assay data. Two statistical tests, a chi-squared (χ

2

) test and a t test, were 

performed. Data and results of the statistical analyses are included in Attachments F.1 through 

F.3. The χ

2

 test, which is also known as the goodness-of-fit test or the chi-squared test for 

independence, is used to show how observed data compare with data we would expect to obtain 

according to a specific hypothesis. EPA applied it in this instance to show if the replicate 

measurements differed from the expected original measurement. The t test is a statistical tool that 

is used to tell if two sets of data are statistically different from one another. EPA applied it to the 

replicate data to see if there are statistically significant differences between the original assay 

values and the average of the five replicate measurements. 

 

10 Revision 2 of the Environmental Protection Agency Replicate Testing Protocol provides the details of the 

replicate testing assay protocol and data evaluation. 
24 

For Drum Nos. X10CSATN02241L, NFS0419D and NFS0478A, the χ

2

 test showed that the 

observed variances in the replicate measurements are less than or equal to the reported 

uncertainties within the statistical limits of the test. The t test for Drum Nos. X10CSATN02241L 

and NFS0419D also showed no statistically significant differences between the original assay 

values and the average of the five replicate measurements. 

The t test for Drum No. NFS0478A showed a statistically significant difference between the 

original assay value and the average of the five replicate measurements for 137Cs and 90Sr. The 

137Cs and 90Sr values are correlated in that 90Sr is quantified by scaling it to the drum’s measured 

137Cs content. The Significant flag indicates that the variances in the replicate measurements for 

this container were greater than the reported uncertainties relative to the limits of the test and that 

there was a statistically significant difference between the original assay (2.96x10-07Ci) and the 

average of the replicate measurements (4.43x10-07 Ci) of 137Cs. It is important to keep these in 

mind when evaluating replicate data and to realize that Significant results are not always 

representative of true measurement issues. 

There are several possible reasons for the Significant differences in 137Cs and 90Sr replicate 

values versus original values. ORNL-CCP indicated that the background was most probably 

enhanced due to other containers with higher 137Cs content on the five replicate assays. The 

actual amount of 137Cs detected is small, on the order of 296 nCi for the initial assay versus 443 

nCi for the mean of the five replicates. Although the software identified this variance as 

Significant, this does not necessarily indicate a measurement issue that warrants additional 

attention at this time. 

There are no concerns regarding the replicate testing for the IQ3. 

8.2.2 Nondestructive Assay Findings and Approval 

Summary of Nondestructive Assay Findings and Concerns 

EPA did not identify any findings or concerns for NDA at ORNL-CCP. 

Nondestructive Assay Approval

There are no changes to the T1 designations for NDA as a result of this continued compliance 

inspection and T1 evaluation. Submission to EPA of a list of all NDA personnel who performed 

work during the previous quarter is a new NDA T2 change (see Table 1). Specifically, the list 

must include all operators, EAs and ITRs. EPA added this requirement to ensure that EPA has a 

complete picture of ORNL-CCP waste characterization activities, which will inform the scope of 

NDA components evaluated during future T1 change evaluations. 

Based on the results of this evaluation and the data examined, EPA determines that ORNL-CCP 

demonstrated continued compliance with the EPA-approved waste characterization program for 

all NDA systems. 
25 

8.3 Dose-To-Curie (DTC) – Remote-Handled Waste 

EPA approved the DTC technique initially during the RH baseline inspection in February 2011 

(EPA Docket No. A-98-49; II-A4-111). 

8.3.1 Technical Evaluation 

EPA evaluated ORNL-CCP’s continued compliance with EPA-approved DTC procedures for 

RH waste characterization. The checklist used for this inspection is included in Attachment G. 

(1) EPA observed the dose-to-curie technique and found it to be adequate. 

EPA observed the ORNL-CCP DTC operations in the DTC Alcove of Building No. 7880, 

Process Building of the TWPC at ORNL. When resuming operation on November 26, 2013, 

ORNL-CCP DTC personnel performed the source checks for Thermo Scientific Model FH 40 G 

Dose Rate Measuring Unit with Geiger Mueller (GM) FHZ 612 Probe (Instrument No.) attached 

to Probe No. XC0761 (S/N 1098). Using 137Cs source No. A9-136, they performed ten replicate 

measurements for both the high and low ranges, and these data were used to derive initial control 

limits for the system’s daily performance checks. 

On February 5, 2014, EPA observed DTC personnel begin operations by performing the 

operational check on Scale No. SD2-03, which is due for recalibration on December 13, 2014. 

DTC personnel performed this check with a weight of 158.6 kilograms (kg) using CCP operator 

aid OA-ORNL-0131-13. The operator recorded the weight on the measurement control report 

(CCP-TP-504, Revision 14, Attachment 2) and summarized this activity in the operational 

logbook, Operational Logbook for Remote Handled Operations, Control No. CCP-RH-ORNLDTC-002, Calendar Year 2014, ORNL Building 7800, Process Building.

The DTC operational logbook listed tolerances for the test drum weights, scale error, operational 

ranges for the GM probes and acceptance criteria for source checks. ORNL-CCP DTC operators 

took a background dose reading of 0.065 milliroentgen per hour (mR/hr)11 while all containers 

were in a shielded position, followed by source checks for the high and low ranges, and all 

measurements were recorded on the measurement control report and summarized in the 

operational logbook. 

DTC personnel controlled all drum operations remotely using a series of cameras and 

manipulators, and all ORNL-CCP personnel that EPA observed were working to the current 

revisions of ORNL-CCP procedures. A Thermo Model ESM FH 40G Ratemeter with a Model 

FHZ 512 probe measured the gamma dose rate for RH Container No. ORRH-00685 in the DTC 

Alcove and the ORNL-CCP DTC operator (D. Crosby) recorded this information in the 

operational log book. There was a Ludlum Model 12-4 Ratemeter attached to a REM Ball inside 

 

11 Rem or millirem is a unit of dose equivalent, which is often commonly called dose or when it is 

expressed per unit time, a dose rate. The criterion for RH determination is expressed in terms of a dose rate in rem, 

which, while technically incorrect, is commonly used. Additionally, gamma measurements which technically 

represent exposure in Roentgens (R) are commonly misstated in rem. In this report, the terms dose and dose rate are 

used in place of the technically correct term dose equivalent or dose equivalent rate, and the terms roentgen (R) and 

rem are used interchangably. The actual differences among these values for the purpose of this report are negligible. 
26 

the DTC alcove, which recorded the neutron component of the container’s dose rate. The neutron 

value is not part of the DTC process but is needed to assess the container’s status relative to the 

RH criterion. 

EPA observed an overhead crane lift Drum No. ORRH-00685 onto the DTC assembly, where 

DTC personnel weighed the container and recorded the gross weight. Gamma (and neutron) 

measurements were made and after the first measurement, the container was rotated 90o and this 

was repeated until a total of four measurements were made, noted as R1 through R4, as specified 

in CCP-TP-504, Revision 14. The four measurement values were expressed in mR/hr, as follows: 

R1 – 8.53; R2 – 8.33; R3 – 7.34; R4 – 8 (all measurements are gamma only). The DTC Operator 

recorded all measurements on the container data sheet (CCP-TP-504, Revision 14, Attachment 

2), a copy of which was provided to EPA. The dose rate measurements (gamma plus neutron) of 

each of the RH drums in the three DTC BDRs indicated contact values in excess of 200 mR/hr in 

all cases. 

EPA did not identify any concerns regarding the technical adequacy and documentation of DTC 

operations at ORNL-CCP. 

(2) EPA assessed the dose-to-curie batch data report and found it to be adequate. 

ORNL-CCP provided DTC BDR No. ORRHRTC13001 that contained assay results for seven 

containers. The BDR contained all applicable elements, including documentation of the 

containers’ status as RH TRU waste. EPA did not identify any concerns regarding the DTC 

BDR. 

(3) EPA assessed the training for dose-to-curie personnel and found it to be adequate. 

ORNL-CCP provided the LOQI dated January 21, 2014, for DTC documenting that all DTC 

personnel were appropriately trained. The ORNL-CCP DTC operators are Ronald Whitson, 

Daniel Crosby and Chad Gerlock, and all were listed on the current LOQI. There were no 

concerns regarding the training for ORNL-CCP DTC personnel. 

8.3.2 Dose-to-Curie Findings and Approval 

Summary of Dose-to-Curie Findings and Concerns 

EPA did not identify any findings or concerns for DTC at ORNL-CCP. 

Dose-to-Curie Approval

There are no changes to the T1 designations for DTC as a result of this continued compliance 

inspection. Submission to EPA of a list of all DTC personnel who performed work during the 

previous quarter is a new DTC T2 change (see Table 2). Specifically, the list must include all 

operators, EAs and ITRs. EPA added this requirement to ensure that EPA has a complete picture 

of ORNL-CCP waste characterization activities, which will inform the scope of DTC 

components evaluated during future T1 change evaluations. 
27 

Based on the results of this evaluation and the data examined, EPA determines that ORNL-CCP 

demonstrated continued compliance with the EPA-approved waste characterization program for 

DTC. 

8.4 Nondestructive Examination (NDE) 

EPA evaluated ORNL-CCP’s continued compliance with EPA-approved NDE procedures for 

CH and RH TRU waste characterization. ORNL-CCP’s CH NDE characterization program is 

EPA-approved for RTR for SCG S5000 (heterogeneous debris) and SCG S4000 (soils) and VE 

for SCG S5000 waste. ORNL-CCP did not provide EPA with any information about VE for CH 

waste; therefore, EPA only reviewed RTR for CH waste during this continued compliance 

inspection. The RTR checklist used for this inspection is included as Attachment H. 

ORNL-CCP’s RH NDE characterization program is EPA-approved for VE on SCG S5000 

waste. The AK checklist used for this inspection is included as Attachment I. 

Real-Time Radiography and Visual Examination Procedures 

EPA reviewed the following procedures as part of this inspection: 

• CCP-PO-001, CCP Transuranic Waste Characterization Quality Assurance Project Plan, 

Revision 21, May 31, 2013

• CCP-PO-002, CCP Transuranic Waste Certification Plan, Revision 27, May 31, 2013

• CCP-QP-002, CCP Training and Qualification Plan, Revision 35, June 6, 2013

• CCP-TP-028, CCP Radiographic Test Drum and Training Container Construction, 

Revision 8, June 17, 2013

• CCP-TP-500, CCP Remote-Handled Waste Visual Examination, Revision 13, April 21, 

2013 

• CCP-TP-053, CCP CH Standard Real-Time Radiography Inspection Procedure, Revision 

9, September 30, 2010 

• CCP-TP-053, CCP CH Standard Real-Time Radiography Inspection Procedure, Revision 

10, March 4, 2011 

• CCP-TP-053, CCP CH Standard Real-Time Radiography Inspection Procedure, Revision 

11, July 20, 2011 

• CCP-TP-053, CCP CH Standard Real-Time Radiography Inspection Procedure, Revision 

14, September 25, 2013 

• CCP-QP-005, CCP TRU Nonconforming Item Reporting and Control, Revision 23, June 

25, 2013 

• CCP-TP-001, CCP Project Level Data Validation and Verification, Revision 21, June 6, 

2013 
28 

The procedures continue to comply with 40 CFR 194. Notification to EPA upon substantive 

modification to site NDE procedures requiring CBFO approval remains a T2 change (see Tables 

1 and 2). 

8.4.1 Technical Evaluation: Contact-Handled Real-Time Radiography 

1) EPA observed ORNL-CCP perform a real-time radiography demonstration and found it 

to be adequate. 

On February 4, 2014, ORNL-CCP demonstrated the RTR process for debris container 

X10CSATN02002J from BDR No. OR-RTR6-0461, Waste Stream OR-REDC-CH-HET. 

ORNL-CCP performed the demonstration using unit RTR6, housed in Building 7880-J. The

operator had already performed the necessary equipment checks prior to EPA’s arrival. The 

operator properly examined the container’s contents and entered characterization data into the 

electronic data sheet. The operator determined that the waste matched the waste stream 

description and verified the waste matrix code (WMC). No prohibited items were found in the 

container. After the demonstration, EPA reviewed the container data sheets and determined that 

they had been completed correctly and signed by the RTR operator. The operator adequately 

used procedure CCP-TP-053 to guide the examination.

2) EPA examined real-time radiography characterization records and found them to be 

adequate. 

EPA reviewed the audio/visual and written records for selected containers from BDR Nos. ORRTR6-0437, OR-RTR6-0440, OR-RTR7-0002, OR-RTR7-0007 and OR-RTR7-0008. EPA 

determined that the records were complete and generated in accordance with CCP procedures.

An image quality check had been performed prior to each RTR event for the BDRs examined 

and the required quality control (QC) examinations had been performed. Operators had properly 

examined each container’s contents and entered characterization data into an electronic data 

sheet. The containers reviewed included those with SCG S5000 (debris) and SCG S4000 (soil) 

waste. The operators determined that the waste matched the waste stream description and 

verified the WMC. The operators did not identify any prohibited items in the containers from the 

reviewed BDRs. 

ORNL-CCP reviewed the data at the data generation and SPM levels; the reviews were recorded 

on the appropriate forms from CCP-TP-053 and CCP-TP-001. 

EPA determined that ORNL-CCP continues to generate and report compliant RTR data in 

accordance with written procedures. 

3) EPA examined the real-time radiography training records and found them to be adequate 

after receiving ORNL-CCP’s response to Concern No. ORNL-CCP-ORNL-RTR-02CR. 

EPA reviewed training records for selected RTR operators, including Qualification Cards and 

Test and Training container examination records. EPA wrote Concern No. ORNL-CCP-ORNLRTR-01C not requiring a response, regarding the written inventories made for test and training 

containers, which is reproduced in full in Attachment J. The issue as presented in the concern is 

as follows: 
29 

Procedure CCP-TP-028, CCP Radiographic Test Drum and Training Container 

Construction, Attachment 1, item No. 11, requires that a "Leaded glove or leaded 

apron" be added to the container. However, this attachment is meant to provide an 

exact inventory for the container and should be specific for the items added. CCP 

should consider changing how this information is recorded on the inventory so 

that no uncertainty is attached to its contents. 

EPA also identified Concern No. ORNL-CCP-ORNL-RTR-02CR that required a response, 

regarding operator training/test container record requirements, which is reproduced in full in 

Attachment K. The issue as presented in the concern is as follows:

EPA is concerned that the processes used to evaluate an RTR operator's continued 

job performance do not demonstrate the sucessful examination of unknown 

containers. This concern is based on the following:

(1) Operators are not required to generate a written record when examining a 

Training Container as they would for a routine waste container or a Test 

container. This is an historical practice without any regulatory basis. 

(2) A Lead Operator observes the operator's performance during the Training 

Container evaluation but does not possess an inventory for the Training 

Container and cannot assess whether items are missed. 

(3) The operator is considered successful in the test if he/she identifies all 

Summary Category Groups and all prohibited items. There is no 

requirement for the operator to identify all waste items as they would for a 

routine waste container. 

(4) The NDE Cognizant Engineer (CE) also evaluates the performance but 

there are no records generated regarding if missed items are brought to the 

attention of the operator by CE to provide objective evidence of continued 

training in this circumstance. 

Starting in 2005, EPA has identified issues related to NDE training several times. EPA 

has listed the concern numbers correlated to each instance of an NDE-related concern 

below: 

• SRS-CCP-RTR-05-003CR 

• HAN-RTR-07-006CR (not a CCP issue) 

• ORNL-CCP-CH-RTR-07-004C 

• INL-CCP-CH-VE-T1-004CR 

• INL-CCP-CH-VE-T1-005CR 

• ORNL-CCP-CH-RTR-09-001CR 

• INL-CCP-RH-T1-Lot 2-RTR-01C 

• INL-CCP-CC-2013-01C 

• INL-CCP-CC-2013-02CR 

• ORNL-CCP-CC-RTR-01C (this inspection) 
30 

EPA requests that CBFO review these concerns with a view to developing an integrated, 

complete, and long-term response that would assess the on-going adequacy of NDE 

training within the WIPP program.

CBFO responded to this concern on February 20, 2014, on behalf of ORNL-CCP. CBFO 

provided an explanation for each of the four components of the concern and provided a draft 

revision of procedure CCP-QP-002 to correspond with the resolutions described in the response. 

EPA reviewed the responses and the proposed procedural revisions and found that CBFO and 

CCP have adequately addressed the issues. CBFO provided the final revised procedure, CCPQP-002, Revision 36, to EPA on April 17, 2014, and provided examples of training conducted 

per the revised procedure to EPA on May 2, 2014. 

The example training records consisted of training digital video disks (DVDs) and written 

records for three operators. The Training Container Data & Evaluation Sheets recorded the items 

missed by operators during the examinations to demonstrate that these omissions were brought to 

the attention of each applicable operator. EPA considers this response to adequately demonstrate 

that Item (4) of Concern No. ORNL-CCP-ORNL-RTR-02CR has been addressed, even though 

all three operators missed an item of cellulosics, plastic and rubber (CPR) material (2 missed 

rubber gloves and 1 missed a section of rope). EPA will continue to monitor RTR operator 

training and training records at future inspections. EPA considers this concern to be closed. 

EPA determined that RTR operators continue to be trained in accordance with CCP procedures 

and that training records were readily available for review. EPA reviewed the LOQI and 

determined that the operator performing the on-site RTR demonstration was properly trained and 

qualified. 

Summary of Contact-Handled Real-Time Radiography Findings and Concerns 

EPA did not identify any findings for CH RTR at ORNL-CCP. 

EPA generated a concern not requiring a response, Concern No. ORNL-CCP-CC-RTR-01C, and 

a concern requiring a response, Concern No. ORNL-CCP-CC-RTR-02CR, for RTR training. 

ORNL-CCP responded adequately to the concern requiring a response and EPA considers both 

issues to be closed.

Contact-Handled Real-Time Radiography Approval 

There are no changes to the T1 designations for CH RTR as a result of this continued compliance 

inspection. Submission to EPA of a list of all CH RTR personnel who performed work during 

the previous quarter is a new CH RTR T2 change (see Table 1). Specifically, the list must 

include all operators and ITRs. EPA added this requirement to ensure that EPA has a complete 

picture of ORNL-CCP waste characterization activities, which will inform the scope of CH RTR 

components evaluated during future T1 change evaluations. 

Based on the results of this inspection and the data examined, EPA determined that ORNL-CCP 

demonstrated continued compliance with the EPA-approved waste characterization program for 

CH RTR. 
31 

8.4.2 Technical Evaluation: Remote-Handled Visual Examination (VE) 

1) EPA observed ORNL-CCP perform a visual examination demonstration and found it to 

be adequate. 

During the on-site visit, EPA observed the VE examination of container No. ORRH00697, BDR 

No. ORNLRHVE14008. The demonstration took place in a TWPC facility hot cell, the waste 

being physically manipulated by ORNL-site personnel, under the direction of two CCP VE 

operators. The VEE was present at the time of the examination. The VE operators directed the 

ORNL-site personnel and examined, identified and recorded each waste item placed in the 55-

gallon receiving drum. Waste Material Parameters (WMPs) were identified in accordance with 

procedure CCP-TP-500 and recorded on procedure CCP-TP-500, Attachment 1, Visual 

Examination Data Forms. The WMC and Waste Stream identification were verified and 

operators signed and dated the data sheets as required by the procedure. The operators verified 

that no prohibited items were loaded into the receiving container. The operators used procedure 

CCP-TP-500, Revision 13, to guide the VE process. EPA reviewed the container data sheets 

generated during the demonstration and determined that they had been completed correctly and 

signed by the VE operators. 

2) EPA examined visual examination characterization records and found them to be 

adequate. 

EPA reviewed RH VE BDR Nos. ORNLRHVE13001, ORNLRHVE13002, ORNLRHVE13003, 

ORNLRHVE13004, ORNLRHVE13005 and ORNLRHVE13006. EPA determined that 

characterization records were complete and properly processed. EPA verified that VE data were 

generated and recorded in accordance with CCP procedures. The VE operators recorded the 

WMP of each waste item, verified the WMC and confirmed the absence of prohibited items. 

Two operators signed the data sheets as required by procedure CCP-TP-500. No NCRs had been 

generated for the containers in the BDRs. Review of the latest LOQI demonstrated that the 

operators performing the on-site demonstration were properly trained and qualified. 

3) EPA examined the visual examination training records and found them to be adequate. 

The EPA inspectors reviewed training records for selected operators. The qualification cards and 

other training records were complete and available for review. 

EPA determined that RH VE operators and VEEs continued to be trained in accordance with 

CCP procedures and that training records are available for review. 

Summary of Remote-Handled Visual Examination Findings and Concerns 

EPA did not identify any findings or concerns for RH VE at ORNL-CCP. 

Remote-Handled Visual Examination Approval 

There are no changes to the T1 designations for RH VE as a result of this continued compliance 

inspection. Submission to EPA of a list of all RH VE personnel who performed work during the 

previous quarter is a new RH VE T2 change (see Table 2). Specifically, the list must include all 
32 

operators, VEEs and ITRs. EPA added this requirement to ensure that EPA has a complete 

picture of ORNL-CCP waste characterization activities, which will inform the scope of RH VE 

components evaluated during future T1 change evaluations. 

Based on the results of this inspection and the data examined, EPA determined that ORNL-CCP 

demonstrated continued compliance with the EPA-approved waste characterization program for 

RH VE. 

8.4.3 Nondestructive Examination Findings and Approval 

Summary of Nondestructive Examination Findings and Concerns 

EPA did not identify any findings for NDE at ORNL-CCP. EPA generated a concern not 

requiring a response, Concern No. ORNL-CCP-CC-RTR-01C, and a concern requiring a 

response, Concern No. ORNL-CCP-CC-RTR-02CR, for CH RTR training. ORNL-CCP 

responded adequately to the concern requiring a response and EPA considers both issues to be 

closed. 

Nondestructive Examination Approval

Based on the results of this inspection and the data examined, EPA determines that ORNL-CCP 

demonstrated continued compliance with the EPA-approved waste characterization program for 

the CH RTR and RH VE systems. EPA did not review any documentation for CH VE during this 

inspection; therefore, ORNL-CCP is not approved to resume use of the CH VE process to 

characterize waste for emplacement at the WIPP facility. ORNL-CCP must notify EPA prior to 

using VE to characterize CH waste and seek EPA approval as a T1 change. 

Based on this inspection, there is one change to the NDE CH T1 designations and one new NDE 

T2 change: 

• Any use of VE to characterize CH waste is a new T1 change (see Table 1). 

• Submission to EPA of a list of all NDE (RTR and VE) personnel who performed work 

during the previous quarter is a new NDE T2 change (see Tables 1 and 2). Specifically, 

the list must include all RH and CH VE and RTR operators, ITRs and VEEs. 

9.0 FINDINGS AND CONCERNS 

EPA identified two concerns during this continued compliance inspection and T1 evaluation, 

both in the area of NDE. One concern required a response, which ORNL-CCP provided to EPA 

and the other concern did not require a response. EPA considers both concerns to be closed. 

EPA did not identify any findings during the ORNL-CCP continued compliance inspection or T1 

evaluation. EPA generated a concern not requiring a response, Concern No. ORNL-CCP-CCRTR-01C, and a concern requiring a response, Concern No. ORNL-CCP-CC-RTR-02CR, for 

CH RTR training. ORNL-CCP responded adequately to the concern requiring a response and 

EPA considers both issues to be closed. 
33 

10.0 CONCLUSIONS 

Changes to Tiering 

Based on this inspection and T1 evaluations, there are several changes to the CH and RH tiering 

designations. Any use of VE to characterize CH waste is a new T1 change. During the 2008 

baseline inspection, EPA did approve ORNL-CCP to use VE to characterize CH waste; however, 

this process was not included in the continued compliance inspection scope because at the time 

of the inspection, ORNL-CCP was not currently using or prepared to demonstrate the CH VE 

process. Since EPA did not observe and review the CH VE process during the continued 

compliance inspection, EPA must approve this process in the future as a separate T1 evaluation. 

In addition, EPA made substantive changes to the T2 designations in AK, NDA and NDE for 

both the CH and RH waste characterization programs: 

1. Submission to EPA of a list of all AKEs and SPMs who performed work in these roles 

for the ORNL-CCP waste characterization program during the previous quarter is a new 

CH and RH AK T2 change (see Tables 1 and 2). 

2. Submission to EPA of a list of all NDA personnel who performed work during the 

previous quarter is a new NDA T2 change (see Table 1). Specifically, the list must 

include all operators, Expert Analysts (EAs) and ITRs. 

3. Submission to EPA of a list of all DTC personnel who performed work during the 

previous quarter is a new RH radiological characterization T2 change (see Table 2). 

Specifically, the list must include all operators, EAs and ITRs. 

4. Submission to EPA of a list of all NDE (RTR and VE) personnel who performed work 

during the previous quarter is a new CH and RH NDE T2 change (see Tables 1 and 2). 

Specifically, the list must include all VE and RTR operators, ITRs and VEEs. 

5. Notification to EPA upon completion of or substantive modification to CCP-TP-005, 

Attachments 4, 6, 7 and 8 and/or associated memoranda, including “Add Container” 

memoranda is a modified CH AK T2 change that clarifies and combines existing 

requirements (see Table 1). 

6. Notification to EPA upon completion of or revisions to all DR reports is a modified RH 

AK T2 change (see Table 2). 

The T2 changes listed above are necessary to make the ORNL-CCP tiering designations 

consistent with the requirements at other CH TRU sites and to support the streamlined process 

for conducting T1 evaluations (see section 3.0). EPA also revised the tiering tables to ensure 

completeness and consistency with recent EPA T1 approval reports. Tables 1 and 2 show the 

substantive T1 and T2 changes for CH and RH in bold text. T1 and T2 changes that were 

initiated during the CH and RH baseline and subsequent T1 approvals remain in effect. The 

language in Tables 1 and 2 regarding AK documentation applies to all ORNL-CCP waste 

streams. 
34 

Approval 

EPA determined that the ORNL-CCP waste characterization program activities continue to be 

technically adequate and in compliance with 40 CFR 194.24. EPA also approves ORNL-CCP’s 

modifications to the MCS IQ3, consistent with the limitations specified in this report. The scope 

of the compliance and T1 decision is based on EPA’s inspection completed February 4–6, 2014.

EPA will use results of this continued compliance inspection to support the streamlined T1 

evaluation and decision process discussed in section 3.0 of this report. The results of this 

continued compliance inspection and the review of quarterly T2 changes submitted since the 

February 2014 inspection will be the basis for EPA’s evaluations of any ORNL-CCP T1 change 

requests until the next EPA continued compliance inspection. As a result, EPA will only focus 

on the significant waste characterization components of the T1 change request that are critical to 

a specific approval (e.g., waste-stream-specific AK records). In addition, EPA may not revisit the 

elements discussed in this report until the next continued compliance inspection, at the Agency’s 

discretion. 
A-1 

ATTACHMENT A.1: APPROVAL SUMMARY FOR ORNL-CCP CONTACTHANDLED WASTE CHARACTERIZATION PROGRAM 

Approved Activity EPA Inspection Number, 

Approval Dates EPA Docket Number 

ORNL-CCP CH Baseline Approval EPA-ORNL-CCP-CH-11.07-8, 

August 21, 2008 A-98-49, II-A4-103 

T1 Change – Extension of the Calibration and Density 

Ranges for the SGS NDA System October 8, 2008 A-98-49; II-A4-108 

T1 Change – Extension of the Passive Mode 

Calibration Range for the DWAS/IPAN SGS January 8, 2009 A-98-49, II-A4-109 

T1 Change – Addition of SCG S4000 October 7, 2009 A-98-49, II-A4-117 

Unannounced Continued Compliance Inspection November 23, 2009 A-98-49, II-A4-121 

T1 Change – Addition of the MCS IQ3 NDA System 

and Visual Examination March 30, 2010 A-98-49, II-A4-125 

T1 Change – Addition of NFS Trench B Soils to Waste

Stream OR-NFS-CH-SOIL March 23, 2011 A-98-49; II-A4-144 
A-2 

ATTACHMENT A.2: APPROVAL SUMMARY FOR ORNL-CCP REMOTE-HANDLED 

WASTE CHARACTERIZATION PROGRAM 

Approved Activity EPA Inspection Number, 

Approval Dates EPA Docket Number 

ORNL-CCP RH Baseline Approval EPA-ORNL-CCP-RH-06.08-8, 

February 3, 2009 A-98-49, II-A4-111 

T1 Change – Addition of SETF Waste to Waste 

Stream OR-REDC-RH-HET November 16, 2009 A-98-49; II-A4-120 

Unannounced Continued Compliance Inspection November 23, 2009 A-98-49, II-A4-121 

T1 Change – Addition of Pre-SETF Waste to Waste 

Stream OR-REDC-RH-HET April 21, 2010 A-98-49, II-A4-124 
B-1 

ATTACHMENT B: LIST OF DOCUMENTS REVIEWED FOR THIS INSPECTION 

CH AK 

Common to both CH waste streams: 

AKE Qualification Card, Charles Allen Dickerson, September 7, 2010, and June 16, 2011 

AKE Qualification Card, Jason Montoya, September 30, 2008, and June 16, 2011 

AKE Qualification Card, Jeff Harrison, December 3, 2002, and June 22, 2011 

AKE Qualification Card, Kevin Peters, June 16, 2011

AKE Qualification Card, Steve Schafer, June 16, 2011 

AKE Qualification Card, Travis Smith, June 16, 2011

AKE Qualification Card, Trey Greenwood, June 16, 2011 

Assigned Reading Report, CCP-QP-002, Revision 35, printed February 18, 2014 

Assigned Reading Report, CCP-QP-005, Revision 23, printed February 18, 2014 

Assigned Reading Report, CCP-TP-002, Revision 26, printed February 18, 2014 

Assigned Reading Report, CCP-TP-005, Revision 26, printed February 18, 2014 

CCP-QP-002, CCP Training and Qualification Plan, Revision 35, June 6, 2013 

CCP-QP-005, CCP TRU Nonconforming Item Reporting and Control, Revision 23, June 25, 

2013 

CCP-TP-002, CCP Reconciliation of DQOs and Reporting Characterization Data, Revision 26, 

June 19, 2013 

CCP-TP-005, CCP Acceptable Knowledge Documentation, Revision 26, August 12, 2013 

CH SPM Qualification Card, Beverly Schrock, June 23, 2010, revised February 5, 2014 

CH SPM Qualification Card, Daniel Wade, October 23, 2013 

CH SPM Qualification Card, Jake Knox, October 23, 2013 

CH SPM Qualification Card, Laura Nelson, June 21, 2010 

CH SPM Qualification Card, Rich Kantrowitz, May 2, 2006, and Addendum J – Oak Ridge 

National Laboratory Qualification Card, January 2, 2008 

CH SPM Qualification Card, Roger Whiteaker, May 3, 2012 

Fiscal Year 2014 First Quarter Tier 2 Notification Report, January 22, 2014 
B-2 

OR-ISTP-CH-HET 

Acceptable Knowledge Accuracy Report: Oak Ridge National Laboratory Waste Stream Number 

OR-ISTP-CH-HET, Heterogeneous Debris Waste, Lots 1 through 3, May 22, 2012 

C034, Memo to file re: Documentation of Density-Related Activities Conducted in the Isotopic 

Research Materials Laboratory (IRML) at ORNL, J.R. Trabalka, July 16, 1999 

C087, Interview with Jack Collins: Historical Operations and Waste Management at Building 

9204-3 at Y-12, Tom Krause, May 18, 2005 

C089, Interview with Joe Devore: Historical Operations and Waste Management at Building 

3028, Tom Krause, May 10, 2005 

C096, Interview with Tom Miner: Historical Operations and Waste Management at Building 

3028, Tom Krause, May 18, 2005 

C097, Interview with Tom Miner: Historical Operations and Waste Management at Building 

3038, Tom Krause, May 18, 2005 

CCP Waste Stream Characterization Checklist, OR-ISTP-CH-HET, Lot 1, August 1, 2011 

CCP Waste Stream Characterization Checklist, OR-ISTP-CH-HET, Lot 2, August 23, 2011 

CCP Waste Stream Characterization Checklist, OR-ISTP-CH-HET, Lot 3, August 23, 2011 

CCP-AK-ORNL-008 NDA Memorandum, Jeff Harrison, October 30, 2013 

CCP-AK-ORNL-008, Central Characterization Program Acceptable Knowledge Summary 

Report for Oak Ridge National Laboratory Isotopes Programs Contact-Handled Transuranic 

Waste, Waste Stream: OR-ISTP-CH-HET, Revision 1, January 9, 2014 

CCP-QP-005, Revision 23, CCP TRU Nonconforming Item Reporting and Control, Attachment 

1 – CCP Nonconformance Report (NCR), NCR-ORNL-0231-14, January 15, 2014 

CCP-QP-005, Revision 23, CCP TRU Nonconforming Item Reporting and Control, Attachment 

1 – CCP Nonconformance Report (NCR), WNCR-2014-001, February 4, 2014 

CCP-TP-002, Attachment 2, CCP Waste Stream Profile Form: OR-ISTP-CH-HET, Revision 0, 

July 25, 2011 

CCP-TP-005 Revision 19, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, OR-ISTP-CH-HET, July 8, 2010 

CCP-TP-005 Revision 19, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, OR-ISTP-CH-HET, July 8, 2010 

CCP-TP-005 Revision 26, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, OR-ISTP-CH-HET, December 6, 2013 
B-3 

CCP-TP-005, Revision 19, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, OR-ISTP-CH-HET, July 13, 2010 

CCP-TP-005, Revision 22, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, OR-ISTP-CH-HET, May 

17, 2011 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 14 – CCP 

Acceptable Knowledge Accuracy Report – Example Form, Lots 1–3, May 22, 2012 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, OR-ISTP-CH-HET, January 6, 2014 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, OR-ISTP-CH-HET, January 7, 2014 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, OR-ISTP-CH-HET, January 

16, 2014 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 7 – 

Radionuclides, OR-ISTP-CH-HET, October 30, 2013 

Characterization Information Summary for WSPF No. OR-ISTP-CH-HET, Lot 1, July 14, 2011 

Characterization Information Summary for WSPF No. OR-ISTP-CH-HET, Lot 2, August 22, 

2011 

Characterization Information Summary for WSPF No. OR-ISTP-CH-HET, Lot 3, August 29, 

2011 

DR024, Discrepancy Resolution – Waste Stream OR-ISTP-CH-HET EPA Hazardous Waste 

Number Assignment, Jeff Harrison, February 22, 2011

DR025, Discrepancy Resolution – Waste Stream OR-ISTP-CH-HET Generation Location 

Discrepancies, Jeff Harrison, February 22, 2011 

M126, RTR Video Tapes and DVDs from the WEAF Facility at Oak Ridge Waste, ORNL, 

1986-1992 

M171, ORNL EM Waste Database Query, November 9, 2009 

M187, EnergX Repack Forms for Waste Stream OR-ISTP-CH-HET, EnergX, various dates 

M189, EnergX RTR Data for Waste Stream OR-ISTP-CH-HET, EnergX, various dates 

M190, EnergX VE Data for Waste Stream OR-ISTP-CH-HET, EnergX, April 27, 2006 through 

April 25, 2007 

M191, UCN-2109 and UCN-2822 Forms and Associated Container Paperwork for Waste Stream 

OR-ISTP-CH-HET, ORNL, various dates 
B-4 

M192, Defense Determination for TRU Waste Generated in the Isotopes Facilities at Oak Ridge 

National Laboratory, Betty Humphrey, April 18, 2005

M197, Evaluation of Additional Drums for Waste Stream OR-ISTP-CH-HET, Jeff Harrison, 

Lisa Watson, Jason Montoya, Christopher Chancellor, various dates 

M217, eMWaste Database Query from ORNL Dated January 3, 2013, ORNL, January 3, 2013 

P022, Site Descriptions of Environmental Restoration Units at ORNL, Oak Ridge, Tennessee, 

A.J. Kuhaida Jr. and A.F. Parker, ORNL/ER-391, February 1997 

P047, The Management of Radioactive Waste at Oak Ridge National Laboratory: A Technical 

Review, Phillip E. Lamoreaux et al., DOE/DP/48010-T1, 1985 

P050, Oak Ridge National Laboratory Institutional Plan, FY-1980-FY1985, H. Postma et al., 

ORNL/PPA-79/8, November 1979 

P051, Oak Ridge National Laboratory Institutional Plan, FY-1981-FY1986, H. Postma et al., 

ORNL/PPA-80/12, December 1980 

P101, Isotopes White Paper: Volume II: Appendices, W.A. Goldsmith, W.B. Ellis, C.C. Ragan 

and W.R. Rhyne, January 1988 

P1085, Safety Analysis of the Source Development Laboratory and Isotopes Division Solid 

Waste Handling Procedure, J.A. Setaro and J.H. Gillette, ORNL-TM-2568, May 28, 1969 

P119, Oak Ridge Health Studies Phase I Report; Volume II –Part A Dose Reconstruction 

Feasibility Study, ChemRisk/ Tennessee Department of Health, September 1993 

P1269, Manual for Nuclear Materials Management and Safeguards System Reporting and Data 

Submission, U.S. DOE Office of Security, DOE M 474.1-2A, August 19, 2003 

P1351, Radioactive Operations Committee Reviews of Isotopes Facilities, Buildings 3028, 3029, 

3030, 3031, 3032, 3033A, 3038, 3047 and 9204-3, ORNL, multiple document numbers, 1962–

1988 

P175, Isotopes White Paper: Volume I: Assessments of Selected Isotopes Circle Facilities, 

Evaluation of Isotope Processing Alternatives and Funding Justification for LLW-CAT System 

for Isotopes Area, W.A. Goldsmith et al., December 1988 

P189, Curium Source Fabrication Facility, R.A. Robinson and R.W. Schalch, 1969 

P190, Final report on the Decontamination of the Curium Source Fabrication Facility, R.W. 

Schalch, ORNL/TM-8376, December 1983 

P225, Solid State Division Annual Progress Report Period Ending December 31, 1975, M.K. 

Wilkinson et al., May 1976 

P227, Solid State Division Annual Progress Report Period Ending April 30, 1977, M.K. 

Wilkinson et al., October 1977 
B-5 

P236, The Solid State Division, A Brief History (1952–1995), Mike Wilkinson (compiler), June, 

1996 

P336, Report re: Isotopes Development Center, Hazards Report for Building 3028-E (Curium 

Source Fabrication Facility), R.W. Schalch-Isotopes Division, ORNL-TM-768, March 1, 1964 

P346, Work Plan for the Isotopes Facilities Deactivation Project at ORNL, ORNL/ER-249, 

Revision 1, May 1, 1995 

P398, Safety Analysis of Isotopes Alpha Handling Facility Including Appendix C: Isotopes 

Division of Solid Waste Handling Procedure, H.G. Hunter, R.W. Schaich and J.A. Setaro, 

Revision 0, March 19, 1970 

P400, Safety Analysis of Building 302, R.W. Schalch, ORNL-TM-3192, Revision 0, December 

12, 1970 

P458, Final Safety Analysis of Building 303B, ORNL Operations Division, April 3, 1984 

P481, A Multipurpose Building for Processing Alpha Beta, Gamma and Neutron Emitters, R.W. 

Schalch, ORNL-TM-3225, Revision 0, December 8, 1970

P528, Safety Analysis Report- Building 3028, D.W. Ramey, April 27, 1984 

P569, Implementation Plan for US Department of Energy Order 435.1, U.S. Department of 

Energy – Oak Ridge Operations, Oak Ridge, Tennessee, DOE/OR/01-1879, June 2000 

P753, Problem Safety Summary: Bldg 3038 (Alpha Handling Facility Cells 4 & 5): Texas 

Nuclear Pu-239-Be Neutron Source Fabrication, Two Sources, J.R. Gibson, CD-130, April 18, 

1989 

Summation of Aspects based on CCP-AK-ORNL-008, Revision 0 

U038, ORNL TRU Waste Historical Survey, Volumes 1, 2 and 3 – Origins and Characteristics of 

Remote-Handled Transuranic Wastes (Trabalka Report) Plus Appendices, J.R. Trabalka, A.J. 

Mattis and S.N. Storch, BJC/OR-395-V/1,2,3, Draft, September 2001 

U647, Issue Paper: Does Oak Ridge Have High Level Waste (HLW)? John E Patterson, 

November 19, 1999 

WMP analysis memorandum, Jeff Harrison, April 29, 2011 

OR-NFS-CH-SOIL 

Acceptable Knowledge Accuracy Report: Oak Ridge National Laboratory Waste Stream Number 

OR-NFS-CH-SOIL, Soils, Lot 12, Cumulative for Lots 1 through 12, March 22, 2012 

C099, Letter to Harold Johnson, CBFO DOE re: KAPL-NFS Transuranic Waste Background 

Information, May 3, 2005 

C100, Interview with Richard Booth and faxed defense and Waste Information for NFS, 

February 24, 2005 
B-6 

C210, Interview re: NFS TRU Waste Shipped to Oak Ridge National Laboratory. Interviewees: 

Richard Booth, Richard Moore, Bob Hunt, Scott Toller, Marie Moore, J. Harrison and L. 

Watson, September 12, 2007 

C227, Interview with Scott Morie from NFS, September 23, 2010 

C321, Record of Communication. Subject: Soil and Groundwater Treatment Sludge to be 

Generated in 2011, January 11, 2011 

CCP Waste Stream Characterization Checklist, OR-NFS-CH-SOIL, Lot 12, September 6, 2011 

CCP-AK-ORNL-001 NDA Memorandum, Jeff Harrison, November 15, 2010 

CCP-AK-ORNL-001, Central Characterization Program Acceptable Knowledge Summary 

Report for Nuclear Fuel Services Contact-Handled Transuranic Waste Stored at Oak Ridge 

National Laboratory, Revision 8, December 12, 2013, and Revision 9, February 6, 2014 

CCP-QP-005, Revision 23, CCP TRU Nonconforming Item Reporting and Control, Attachment 

1 – CCP Nonconformance Report (NCR), NCR-ORNL-0841-13, Revision 0, origin December 4, 

2013, interim disposition December 11, 2013 

CCP-QP-005, Revision 23, CCP TRU Nonconforming Item Reporting and Control, Attachment 

1 – CCP Nonconformance Report (NCR), NCR-ORNL-0842-13 origin December 4, 2013, 

interim disposition December 11, 2013 

CCP-QP-005, Revision 23, CCP TRU Nonconforming Item Reporting and Control, Attachment 

1 – CCP Nonconformance Report (NCR), NCR-ORNL-0898-13, Revision 0, origin December 

23, 2013, closure December 23, 2013 

CCP-QP-005, Revision 23, CCP TRU Nonconforming Item Reporting and Control, Attachment 

1 – CCP Nonconformance Report (NCR), NCR-ORNL-0258-14, Revision 0, origin January 15, 

2014, closure January 15, 2014 

CCP-TP-002, Attachment 2, CCP Waste Stream Profile Form: OR-NFS-CH-SOIL, Revision 0, 

December 8, 2009 

CCP-TP-005, Revision 19, CCP Acceptable Knowledge Documentation, Attachment 10 – 

Acceptable Knowledge Re-evaluation Checklist, OR-NFS-CH-SOIL, July 7, 2010 

CCP-TP-005, Revision 22, CCP Acceptable Knowledge Documentation, Attachment 7 – 

Radionuclides, OR-NFS-CH-SOIL, May 31, 2011 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 14 – CCP 

Acceptable Knowledge Accuracy Report – Example Form, OR-NFS-CH-SOIL, Lot 12, March 

22, 2012 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, OR-NFS-CH-SOIL, January 7, 2014 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, OR-NFS-CH-SOIL, January 6, 2014 
B-7 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, OR-NFS-CH-SOIL, January 

16, 2014 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, OR-NFS-CH-SOIL, December 5, 2013 

Characterization Information Summary for WSFP No. OR-NFS-CH-SOIL, Lot 12, September 2, 

2011 

Characterization Information Summary for WSPF No. OR-NFS-CH-SOIL, Lot 1, December 8, 

2009 

Characterization Information Summary for WSPF No. OR-NFS-CH-SOIL, Lot 10, December 

16, 2009 

Characterization Information Summary for WSPF No. OR-NFS-CH-SOIL, Lot 11, December 

13, 2010 

DR010, Discrepancy Resolution re: Incorrect Waste Stream Assignment of Soil Waste 

Containers, Jeff Harrison, January 12, 2009 

DR022, Discrepancy Resolution re: OR-NFS-CH-SOIL and OR-NFS-CH-HET-A Waste Stream 

Designation, Jeff Harrison, March 6, 2010 

DR023, Discrepancy Resolution re: NFS0815 and X10C0506069, Jeff Harrison, March 22, 2010 

DR026, Discrepancy Resolution re: Reassignment of NFS0815 to OR-NFS-CH-SOIL, Jeff 

Harrison, July 7, 2010 

DWAS BDR No. OR-DWAS-0120, January 22, 2009, revised February 5, 2014 

I053, KAPL-TN Waste Profile for NFS Building 234 Soil, Joseph W. Pugh, September 11, 2003 

IQ3 BDR No. OR-IQ3-0228, January 2, 2014 

M003, ORNL UCN-2109 and UCN-2822 Forms for NFS TRU Waste and Related Paperwork for 

Waste Stored at ORNL, August 26, 1993 

M012, EM Query- Container Information; Waste Description; Isotopes, ORNL, August 9, 2007 

M075, TWPC Contact Handled Waste Repackaging Data Forms for NFS Waste (Container 

Paperwork), ORNL, various dates 

M128, Evaluation of Additional Containers for Waste Stream OR-NFS-CH-SOIL, J. Harrison, 

September 5, 2008 

M132, Evaluation Of Additional Containers for Waste Stream OR-NFS-CH-SOIL, September 

24, 2008 

M206, Wet Cell Excavation TRU Waster Shipping Schedule, NFS, January 11, 2011 
B-8 

M210, TRU Project Waste Processing Facility Job Recipe, Subject: Soil-Like Waste 

Remediation, Tim Hallman, January 29, 2011 

P1375, North Site Characterization Report for Nuclear Fuel Services, Erwin, Tennessee, 

Revision 1, July, 1999 

P1400, Operating Procedure for Soil Excavation, Processing and Packaging for the 234 

Excavation Facility, Revisions 0 and 1, May 17, 2010 - September 3, 2010 

P1401, Waste Packaging for WIPP Disposal, Revision 0 and 1 September 1, 2010 and October 

15, 2010 

P212, Lattice Experiments with Simulated Burned Up Fuel for D20 Power Reactors, N.P. 

Baumann et al., February 1968 

P218, Oak Ridge National Laboratory/ Nuclear Fuel Service, Inc. NFS Waste Parameter 

Verification Program, Martin Marietta Energy Systems, October 29, 1992 

P248, Structural Assessment of Building 234 Prepared for NFS, 1205 Banner Hill Rd, Erwin, TN 

37650, Siddharth Shah, November 1999 

P273, NFS, Inc Waste Certification Plan for Transuranic Waste, no date 

P306, Excavation of 110 Lab Tank, Revision 1, February 11, 1991 

P315, Wet Cell Soil Excavation and Mixing, Revision 0, July, 5, 1993 

P317, Packaging for Shipment of Processing, Storage or Burial, Revision 6, July 15, 1993 

P323, Status of Former Mixed Oxide Fuel Fabrication Facility, Eco Tec, Inc. January 10, 1994 

RTR BDR No. OR-RTR6-0305, May 4, 2010 

RTR BDR No. OR-RTR7-0002, December 3, 2013 

U038, ORNL TRU Waste Historical Survey; Volumes 1, 2 and 3- Origins and Characteristics of 

Remote-Handled Transuranic Wastes (Trabalka report) Plus Appendices, Draft, September 2001 

U055, Abstract, Calibration Schemed and Measurement Techniques, no date 

U058, Oak Ridge National Laboratory/NFS Waste Parameter Verification Program, no date 

Waste Material Parameter Analysis Memorandum, Jeff Harrison, January 16, 2014 

RH AK 

OR-REDC-RH-HET 

Acceptable Knowledge Accuracy Report: Oak Ridge National Laboratory Remote-Handled 

Transuranic (RH TRU) Waste Stream Number OR-REDC-RH-HET, Lots 1 through 28, Laura 

Nelson, January 11, 2012 
B-9 

Acceptable Knowledge Accuracy Report: Oak Ridge National Laboratory Remote-Handled 

Transuranic (RH TRU) Waste Stream Number OR-REDC-RH-HET, Lots 1 through 29, Laura 

Nelson, draft dated January 6, 2014 

AKE Qualification Card, Kevin Peters, June 16, 2011

AKE Qualification Card, Lisa Watson (Price), June 16, 2011 

AKE Qualification Card, Steve Shafer, June 16, 2011

Assigned Reading Report, CCP-QP-002, Revision 35, printed February 18, 2014 

Assigned Reading Report, CCP-QP-005, Revision 23, printed February 18, 2014 

Assigned Reading Report, CCP-TP-002, Revision 26, printed February 18, 2014 

Assigned Reading Report, CCP-TP-005, Revision 26, printed February 18, 2014 

Assigned Reading Report, DOE WIPP-02-3214, Revision 3, printed February 18, 2014 

C098, Interview with Wayne Evans: Waste Management Practices at REDC (Buildings 7920 and 

7930), Tom Krause, May 9, 2005 

C148, Interviews with REDC Personnel, J. Harrison and L. Watson, various dates 

C302, ORNL Comments on CCP-AK-ORNL-500, Revision 0, March 5, 2008 

C307, Interview of Walt Bond- Subject: Processes and Waste in Building 3508 at ORNL, Lisa 

Watson, February 21, 2008 

C308, Interview with Jason Taylor, ORNL-PCB Coordinator from 1997–2004 re: PCB 

Management at ORNL, Jeff Harrison, April 8, 2008 

C600, Interviews with Don Coffee and Wayne Evans re: REDC RH Waste Cask Packaging 

Clarification and Swipe Sample Collection, K. Peters and M. Doherty, June 4, 2008 

CCP-AK-ONRL-505B, Central Characterization Program Nondestructive Assay Sampling Plan 

for Oak Ridge National Laboratory Engineering Development Center RH TRU Waste (SETF), 

Revision 1, November 8, 2013 

CCP-AK-ORNL-500, Central Characterization Program Acceptable Knowledge Summary 

Report for Oak Ridge National Laboratory Radiochemical Engineering Development Center 

Remote Handled Transuranic Waste, Waste Stream: OR-REDC-RH-HET, Revision 3, January 8, 

2014, Revision 4, February 6, 2014 

CCP-AK-ORNL-501, Central Characterization Program Remote-Handled Transuranic 

Radiological Characterization Technical report for RH Transuranic Waste from Oak Ridge 

National Laboratory Radiochemical Engineering Development Center, Waste Stream: ORREDC-RH-HET , Revision 4, November 8, 2013 
B-10 

CCP-AK-ORNL-502, Central Characterization Program RH TRU Certification Plan for 40 CFR 

Part 194 Compliance for ORNL REDC RH Waste, Waste Stream: OR-REDC-RH-HET, 

Revision 4, January 31, 2014; Revision 5, February 6, 2014 

CCP-AK-ORNL-505A, Central Characterization Program Nondestructive Assay Sampling Plan 

for Oak Ridge National Laboratory Engineering Development Center RH TRU Waste (PreSETF), Revision 1, December 2, 2013 

CCP-QP-002, CCP Training and Qualification Plan, Revision 35, June 6, 2013 

CCP-QP-005, CCP TRU Nonconforming Item Reporting and Control, Revision 23, June 25, 

2013 

CCP-QP-005, Revision 20, CCP TRU Nonconforming Item Reporting and Control, Attachment 

1 – NCR-RH-ORNL-0291-11, May 19, 2011 

CCP-TP-002, CCP Reconciliation of DQOs and Reporting Characterization Data, Revision 26, 

June 19, 2013 

CCP-TP-005, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP Waste Stream 

Characterization Checklist – Example Form, OR-REDC-RH-HET, Lot 28, September 19, 2011 

CCP-TP-005, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP Waste Stream 

Characterization Checklist – Example Form, OR-REDC-RH-HET, Lot 29, Draft, undated, 

electronic file dated January 22, 2014 

CCP-TP-005, CCP Acceptable Knowledge Documentation, Attachment 4 – Acceptable 

Knowledge Source Document Information List, OR-REDC-RH-HET, January 7, 2014 

CCP-TP-005, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste Form, Waste 

Material Parameters, Prohibited Items, and Packaging, OR-REDC-RH-HET, January 22, 2014 

CCP-TP-005, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste Containers 

List, OR-REDC-RH-HET, April 14, 2009, with attached add-container memoranda dated May 

30, 2008, June 4, 2008, June 5, 2008, June 11, 2008, June 27, 2008 (2), May 19, 2009, June 16, 

2009 (2), June 19, 2009, July 14, 2009, September 1, 2009, September 29, 2009, January 26, 

2010 

CCP-TP-005, CCP Acceptable Knowledge Documentation, Revision 26, August 12, 2013 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, OR-REDC-RH-HET, December 30, 2013 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 15 – CCP 

TRU Waste Correlation and Surrogate Summary Form, OR-REDC-RH-HET, November 26, 

2013 

Characterization Information Summary, OR-REDC-RH-HET, Lot 1, February 18, 2009 

Characterization Information Summary, OR-REDC-RH-HET, Lot 28, September 19, 2011 
B-11 

Characterization Information Summary, OR-REDC-RH-HET, Lot 29, Draft, provided Januayr 

22, 2014 

Characterization Reconciliation Report, OR-REDC-RH-HET, Lot 28, September 19, 2011 

Characterization Reconciliation Report, OR-REDC-RH-HET, Lot 29, Draft, provided January 

22, 2014 

DR009, Discrepancy Resolution Re: Waste Incidental to Reprocessing Determination, Jeff 

Harrison, October 2, 2008 

DR601, Discrepancy Resolution, Re: Presence of Debris Items in Poly Blocks, Kevin J. Peters, 

July 1, 2008 

DR602, Discrepancy Resolution, Re: Follow-Up on DR005 for EPA Hazardous Waste Number 

Discrepancies, Kevin J. Peters, July 2, 2008 

DTC BDR No. ORRHDTC13001, assay on December 24, 2013 

I022, DOE Order 435.1, Radioactive Waste Management, U.S. DOE, DOE O 435.1, July 9, 1999 

I023, Radioactive Waste Management Manual, U.S. DOE, DOE M 435.1-1, June 19, 2001 

I044, Re-Evaluation of the Radiological Date for the Legacy CH TRU Waste from REDC 

Building 7920, Don Coffee, CAN-02MVSWSF-0014, Revision 0, April 14, 2005 

M023, Defense determination for REDC Heterogeneous Debris, B Humphrey, April 25, 2005 

M100, EM Waste Waste Database Query, various dates 

M120, ORNL RH Cask Evaluation and Supplemental Packaging Documentation, ORNL, 

various dates 

P058, Statistical Analysis of Radiochemical Measurements of TRU Radionuclides in REDC 

Waste, J. Beauchamp et al, ORNL/TM-13298, October 1996 

P125, Remote Handled Transuranic Solid Waste Characterization Study: ORNL, R.C. Stewart et 

al., ORNL/TM-11050, June 1989 

P161, Safety Analysis Report Radiochemical Engineering Development Center Building 7920, 

M.A. Green, SAR/7920-CTD/01, Revision 1, March 14, 2001 

P258, Production, Distribution and Applications of Califorium-252 Neutron Sources, Chemical 

Technology Division, ORNL/CP-102606, October 3, 1999 

P281, Califorium-251: A Remarkable Versatile Radioisotope, Irvin W. Osborne-Lee and C.W. 

Alexander, ORNL/TM-12706, October 10, 1995 

P569, Implementation Plan for U.S. Department of Energy Order 435.1, US Department of 

Energy - Oak Ridge Operations, Oak Ridge, Tennessee, DOE/OR/01-1879, June 2000 
B-12 

RH AK Tracking Spreadsheet dated January 28, 2014 

RH SPM Qualification Card, Dave Moody, June 8, 2011

RH SPM Qualification Card, Irene Joo (Quintana), September 17, 2009 

RH SPM Qualification Card, Laura Nelson, June 21, 2010 

Summation of Aspects based on CCP-AK-ORNL-500, Revision 0 

U011, Safety Analysis: Transuranium Processing Plant, Building 7920, L.J. King, J.E. Bigelow, 

E.D. Collins and W.T. McDuffee, ORNL/TM-7688, Draft, December 1984 

U038, ORNL TRU Waste Historical Survey; Volumes 1, 2 and 3–Origins and Characteristics of 

Remote-Handled Transuranic Wastes (Trabalka Report) Plus Appendices, J.R. Trabalka, A.J. 

Mattus and S.N. Storch, BJC/OR-395-V/1,2,3, Draft, September 2001 

U039, Oak Ridge Reservation Transuranic Waste Acceptable Knowledge Summary Report for 

the Radiochemical Engineering Development Center: Newly Generated Contact-Handled 

Transuranic Waste from Isotope Production, Eberline Services for DOE, ORNL-CH-AKTBD/RA, Draft, July 12, 2002 

U045, Waste Stream Profile Sheet for Building 7920, Hot Cells and Analytical Labs, Wayne 

Evans, 7920-HCAL-002, April 19, 1999 

U049, Waste Stream Profile Sheet for 7920-HCAL-005 and Supporting Documentation, ORNL, 

7920-HCAL-005, August 18, 1999 

U647, Issue Paper: Does Oak Ridge Have High Level Waste? John E. Patterson, November 19, 

1999 

VE BDR No. ORNLRHVE13004, December 13, 2013 

VE BDR No. ORNLRHVE13005, December 16, 2013 

Waste Material Parameter Analysis Memorandum, Steve Schafer, April 28, 2008 

Waste Stream Profile Form, Waste Stream OR-REDC-RH-HET, with Characterization 

Information Summary and Summation of Aspects, Revision 0, June 3, 2009 

NDA 

CCP-AK-ORNL-002 NDA Memorandum, Jeff Harrison, August 26, 2013 

CCP-TP-046, CCP IQ3 Calibration Procedure, Revision 5, November 6, 2013 

CCP-TP-047, CCP Mobile IQ3 Gamma Scanner Operation, Revision 12, November 6, 2013 

CCP-TP-048, CCP ORNL NDA System Data Reviewing, Validating and Reporting Procedure, 

Revision 16, November 1, 2013 
B-13 

CM-REF-WP-009, Mobile IQ3 System Data Reviewing Validating and Reporting, TRU Waste 

Processing Center, WAI Team, Revision 0, September 16, 2013 

CM-UET-WP-007, Mobile IQ3 Gamma Scanner Operation, TRU Waste Processing Center, 

WAI Team, Revision 0, September 16, 2013 

CM-UET-WP-008, Mobile IQ3 System Calibration, TRU Waste Processing Center, WAI Team, 

Revision 0, September 16, 2013 

IQ3 BDR No. OR-OQ3-0224 

IQ3 Operational Logbook, Control Number: CCP-ORNL-NDA-IQ3-001, Calendar Year 2013, 

pages 1-42, corresponding to restart of IQ3 operations until day of EPA inspection

LOQI for NDA IQ3 Operators, ITRs and Expert Analysts dated February 3, 2014 

MCS-IQ3-CAL-CONF-RPT-2013-01, Calibration Confirmation Verification and LLD Report 

for the MCS IQ3, Revision 0, November 20, 2013 

MCS-IQ3-CALIB-2009, Calibration Report for the Mobile Characterization Services IQ3, 

Revision 1, 2010 

MCS-IQ3-CALIB-2012, Calibration Report for the MCS IQ3, Revision 1, February 5, 2014 

MCS-IQ3-CALVER-2011-03, Calibration Verification Report for the IQ3, Revision 0, March 

22, 2011 

MCS-IQ3-QC-2010-02, Revision of MCS IQ3 QC Limits, Revision 0, September 27, 2010 

MCS-IQ3-TMU-2009, Total Measurement Uncertainty for the MCS IQ3, Revision 0, July 8, 

2009 

MCS-IQ3-WIMS-2011-2, Summary Report: Weekly Interfering Matrix Standards for the MCS 

IQ3, Period: April 21, 2011 to May 17, 2011, March 28, 2012 

NDA Drum System Registration Form IQ3, Qualities and Quantitative Gamma Scanner with 

Isotopics, January 11, 2011 

DTC 

CCP-TP-504, CCP DTC Survey Procedure for RH TRU Waste, Revision 15, September 17, 

2012 

DTC BDR No. ORRHDTC13001, December 39, 2013 

DTC Operational Logbook, May 8, 2013, corresponding to day of EPA inspection and sampling 

of entries

LOQI for DTC operators and ITRs dated January 21, 2014 

NIST Report of Calibration for detector XY022481, October 25, 2002 
B-14 

RH-DM-ORNL-002, Operator Aid, Posted in Control Room of DTC, CCP, Revision 17, April 8, 

2013 

RH-DM-ORNL-003, Operator Aid Posted in Control Room of DTC, CCP, Revision 2, 

November 29, 2012 

Source Calibration Certificates and Source Capsule Descriptions of DTC Sources, March 29, 

2007 

NDE 

American Society for Nondestructive Testing, Recommended Practices, No. SNT-TC-1A, June 

1980 Edition

CCP-PO-001, CCP Transuranic Waste Characterization Quality Assurance Project Plan, 

Revision 21, May 31, 2013

CCP-PO-002, CCP Transuranic Waste Certification Plan, Revision 27, May 31, 2013

CCP-QP-002, CCP Training and Qualification Plan, Revision 35, June 6, 2013

CCP-QP-005, CCP TRU Nonconforming Item Reporting and Control, Revision 23, June 25, 

2013 

CCP-TP-001, CCP Project Level Data Validation and Verification, Revision 21, June 6, 2013 

CCP-TP-028, CCP Radiographic Test Drum and Training Container Construction, Revision 8, 

June 17, 2013

CCP-TP-053, CCP CH Standard Real-Time Radiography Inspection Procedure, Revision 9, 

September 30, 2010 

CCP-TP-053, CCP CH Standard Real-Time Radiography Inspection Procedure, Revision 10, 

March 4, 2011 

CCP-TP-053, CCP CH Standard Real-Time Radiography Inspection Procedure, Revision 11, 

July 20, 2011 

CCP-TP-053, CCP CH Standard Real-Time Radiography Inspection Procedure, Revision 14, 

September 25, 2013 

CCP-TP-500, CCP Remote-Handled Waste Visual Examination, Revision 13, April 21, 2013 

CH RTR BDR No. OR-RTR6-0440, December 17, 2013, and associated audio/visual recording 

CH RTR BDR No. OR-RTR7-0002, December 12, 2013, and associated audio/visual recording 

CH RTR BDR No. OR-RTR7-0007, December 27, 2013, and associated audio/visual recording 

CH RTR BDR No. OR-RTR7-0008, December 27, 2013, and associated audio/visual recording 
B-15 

Inventory sheets for RTR container Nos. NDE-TEST-11, NDE-TEST-20, NDE-TEST-22, NDETRAINING-19, NDE-TRAINING-26, NDE-TRAINING-30 and NDE-TRAINING-32

January 20, 2011, letter from Jonathan Edwards (EPA) to Ed Ziemianski (CBFO) regarding 

calculation of liquid volumes

LOQI for VE and RTR operators dated January 21, 2014 

Qualification Cards for selected VE and RTR personnel 

Radiography Data Sheet for demonstration container No. X10CSATN02022J

Revisions 1 and 2 of Prohibited Items training for RTR operators

RH VE BDR No. ORNLRHVE13001, December 30, 2013 

RH VE BDR No. ORNLRHVE13002, December 30, 2013 

RH VE BDR No. ORNLRHVE13003, December 30, 2013 

RH VE BDR No. ORNLRHVE13004, December 30, 2013 

RH VE BDR No. ORNLRHVE13005, December 30, 2013 

RH VE BDR No. ORNLRHVE13006, January 15, 2014

RH VEE appointment email, dated October 11, 2013 

Training Container Evaluation Data Sheets for various RTR operators

Training roster for CCP-AK-ORNL-001, Revisions 7 and 8 

Visual Examination Data Form for demonstration container No. ORRH00697
C-1 

ATTACHMENT C: INSPECTION PERSONNEL 

Personnel Affiliation Area of Expertise/Function Entrance Meeting Interviewed Exit Meeting 

Rajani Joglekar U.S. EPA ORIA Inspector–Team Leader  Ed Feltcorn U.S. EPA ORIA Inspector  Dorothy Gill SC&A, Inc. RTR/VE Inspector  Connie Walker SC&A, Inc. AK Inspector  Kira Darlow SC&A, Inc. AK Inspector  Patrick Kelly SC&A, Inc. NDA/DTC Inspector  Andrew Stallings ORNL-CCP VPM  Anthony Harley ORNL-CCP VE Operator/ITR, VEE, SME/OJT Expert   Berry Pace CBFO/CTAC QA Observer  Beverly Schrock CCP CH SPM   Chuck Wallace ORNL-CCP VE Operator/ITR Daniel Crosby MCS/CCP DTC Operator David Queen DOE EMOR Project Manager David W. Moody NWP/CCP RH SPM   Derek Matheny ORNL-CCP VE Operator/ITR Derek Ott NWP/CCP RH Radiological Engineer   Fred Oney CCP/VJT RTR/LO   Irene Joo NWP/CCP RH Manager   J.R. Stroble DOE/CBFO Observer Jeff Harrison ORNL-CCP AKE   Jeremy Robinson NFT/CCP FGA Jose R. Franco DOE/CBFO Observer Kenneth Lickliter CBFO/CTAC Observer  Kevin J. Peters ORNL-CCP AKE  LaTravia Harmon CCP QA QA (NWP)  Lisa Watson ORNL-CCP AKE   Marcus A. Pinzel DOE/CBFO RH Program Manager Maria Steade MCS/CCP NDA IQ3 Operator Mark Doherty CBFO/CTAC Observer  
C-2 

Michael Sensibaugh CCP Operations Manager   

Neil Dickes NWP/CCP NDA Support  R.C. McKay WAI General Manager Ronald Whitson MCS/CCP NDA/DTC   Ronnie Lee NWP/CCP Waste Characterization Manager  Scott Kranker WAI STR  Sean Stanfield MCS NDA IQ3 Steve Redmond ORNL-CCP RTR Tammy Reynolds NWP/CCP CCP Program Manager/Observer Tom Morgan CBFO/NTP CCP Manager   
D-1 

ATTACHMENT D.1: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: WASTE STREAM 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HET Inspection 

Technical Elements Objective Evidence Comm

General AK-1: Confirm that AK, training and nonconformance procedures adequately reflect the requirements of 40 CFR 194. 

CCP-QP-002, Revision 35, training and qualification plan CCP-QP-005, Revision 23, nonconforming item report CCP-TP-002, Revision 26, WSPF package development CCP-TP-005, Revision 26, AK documentation 

40 CFR Part 194.24 (c) requir

of controls to characterize wascomponents. The procedures lcharacterization method, wastdevelopment, nonconformancrequirements that help fulfill tPart 194.24(c). This report and its attachmentadequate implementation of ea

AK-2: Confirm that AKE and SPM training records and qualification cards are complete and that each individual’s training was conducted prior to them performing work on this waste stream. 

Charles Allen Dickerson, AKE, 9/7/2010; 6/16/2011 Trey Greenwood, AKE, 6/16/2011 Jeff Harrison, AKE, 12/3/2002; 6/22/2011 Jason Montoya, AKE, 9/30/2008; 6/16/2011 Kevin Peters, AKE, 6/16/2011 Steve Schafer, AKE, 6/16/2011 Travis Smith, AKE, 6/16/2011 Rich Kantrowitz, SPM, 5/2/2006; Addendum J – Oak Ridge National Laboratory Qualification Card, 1/2/2008 Jake Knox, SPM, 10/23/2013 Laura Nelson, SPM, 6/21/2010 Beverly Schrock, SPM, 6/23/2010; revised 2/5/2014 

Daniel Wade, SPM, 10/23/2013 Roger Whiteaker, SPM, 5/3/2012 CCP-QP-002, Revision 35, Assigned Reading Report, printed 2/18/2014 CCP-QP-005, Revision 23, Assigned Reading Report, printed 2/18/2014 CCP-TP-002, Revision 26, Assigned Reading Report, printed 2/18/2014 CCP-TP-005, Revision 26, Assigned Reading Report, printed 2/18/2014 

The qualification cards indicatthe procedure in effect at the t

sign-off. EPA verified Kevin P

and Jeff Harrison’s skills by ininspection. Verified current trapersonnel by review of the AsCBFO revised Beverly Schroc

to indicate that site-specific ad

required. 
D-2 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HET Inspection 

Technical Elements Objective Evidence Comm

AK-3: Confirm that nonconformances are documented appropriately. 

NCR-ORNL-0231-14, Drum X10CSATN03195A, Impenetrable object identification with respect to completion of Section 5 of CCP-TP-053, 1/15/2014 WNCR-2014-001, Drum X10C9312607, Items > 200 mrem/hr, 2/4/ 2014 

The AKE indicated that NCRs when an item in the drum mea

visual examination. When this between the items and detecto

measurement is <200mrem/hr

and the NCR is closed. If the mmr/hr at the drum lid, the wast

in an RH waste stream or for pinclusion in the CH waste stre

drum was not in the ISTP was

as an example of how this typAKE indicated this waste streameasure >200 mrem/hr. 

CCP-TP-005 Implementation AK-4: Confirm that Attachment 1, Acceptable Knowledge Documentation Checklist, is complete. 

CCP-TP-005, Revision 26, Attachment 1, Signed by Jeff Harrison, 1/6/2014 CCP-TP-005, Revision 19, Attachment 1, Signed by Jeff Harrison, 7/13/2010 

The reference list in the AKSR 

Sample source documents exaprogram and waste stream ele

AK-5: Confirm that Attachment 2, Record of Communication, is completed as necessary. 

Source Documents C087, C089, C096 and C097 Record of Communication is n

a consistent format to docume

AK-6: Confirm that an Attachment 3, Acceptable Knowledge Source Document Summary, is complete for every source document. 

See reference list in Attachment B to this report All provided source document

summary. 

AK-7: Confirm that Attachment 4, Acceptable Knowledge Information List, is complete and up to date. 

CCP-TP-005, Revision 26, Attachment 4, Signed by Travis Smith, 1/7/2014 

All references in AKSR are lis

AK-8: Confirm that Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, and Packaging, is complete and up to date. 

CCP-TP-005, Revision 26, Attachment 6, Signed by Jeff Harrison, 1/16/2014 CCP-TP-005, Revision 22, Attachment 6, Signed by Allen Dickerson, 5/17/2011 WMP analysis memorandum, Signed by Jeff Harrison, 4/29/2011 Historical well records for drums X10C9311225, X10C9311139, X10C0501650 and X10C0501534 

Values in memorandum correAKSR. Historical well records verifie

combustible assignments in Aassignments.
D-3 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HET Inspection 

Technical Elements Objective Evidence Comm

AK-9: Confirm that Attachment 7, Radionuclides, is complete and up to date and that AK-NDA communication is appropriately documented. 

CCP-TP-005, Revision 26, Attachment 7, Signed by Jeff Harrison, 10/30/2013 NDA memorandum, Signed by Jeff Harrison (AKE), Robert Ceo (NDA SME), Joe Wachter (MCS Technical Director) and Neil Dickes (CCP Project Office), 10/30/2013 

Based on the NDA memo, genbe critical to understanding whcontainer and how to approachcalculation of 242Pu. The NDA 

containers that may require spevaluation by NDA based on e252Cf and 242Cm contents, and 

which these containers must bindicated that direct instrumendefault isotopics will be used iEA is expected to use the infomemorandum when any assay results and to consult the AK tdetermine which distribution iEPA could not verify NDA EA memorandum because ORNLassays since the resumption.

AK-10: Confirm that Attachment 8, Waste Containers List, is complete and up to date. 

CCP-TP-005 Revision 26, Attachment 8, Signed by Jeff Harrison, 12/6/2013 CCP-TP-005 Revision 19, Attachment 8, Signed by Jason Montoya, 7/8/2010 Source Document M197 

Att. 8 indicates there are 610 5

stream. The superseded Att. 8 there were 543 “containers” in drums. Reference M197 added stream, which brought the tota

AK-11: Confirm that Attachment 10, Acceptable Knowledge Re-evaluation Checklist, is completed as necessary. 

N/A AKE confirmed that as of the 

been no Acceptable Knowledgrequired, in part due to the facwhen to perform AK re-evaluadecision. 

AK-12: Confirm that Attachment 11, Acceptable Knowledge Source Document Discrepancy Resolution, is completed as necessary. 

DR024, CCP-TP-005, Revision 21, Attachment 11, Signed by Jeff Harrison, 2/22/2011 (hazardous waste number assignment discrepancy) DR025, CCP-TP-005, Revision 21, Attachment 11, Signed by Jeff Harrison, 2/22/2011 (generation location discrepancies) 

Discrepancy resolutions adequ

identified. AKE confirmed thawritten since re-start. 
D-4 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HET Inspection 

Technical Elements Objective Evidence Comm

AK-13: Confirm that Attachment 13, CCP Waste Stream Characterization Checklist, is completed foreach characterization lot. 

Lot 1, Signed by Richard Kantrowitz (SPM) and Jeff Harrison (AKE), 8/1/2011 Lot 2, Signed by Candice Weston (SPM) and Jeff Harrison (AKE), 8/23/2011 Lot 3, Signed by Candice Weston (SPM) and Jeff Harrison (AKE), 8/23/2011 

ORNL-CCP did not use the Cexample form, but all required 

Characterization checklists indprevalent radionuclides by mafavorably” with the AKSR. Th

most prevalent radionuclides b

and the two most prevalent TRare 237Np and 239Pu. The chara

that the measured predominan

and 239Pu, but that not enough 

assayed to determine that an Anecessary. 

AK-14: Confirm that Attachment 14, CCP Acceptable Knowledge Accuracy Report, is completed annually and verify that the AK accuracy report memorandum is technically adequate. 

Acceptable Knowledge Accuracy Report: Oak Ridge National Laboratory Waste Stream Number OR-ISTP-CH-HET, Heterogeneous Debris, Lots 1 through 3, 3/22/2012, including CCP-TP-005, Revision 24, Attachment 14, Lots 1-3, Signed by Beverly Schrock, 3/22/2012 

The AK accuracy report states 

However, the characterization radionuclide distribution in asthan that in the AKSR. The AK 

not reflect this apparent discre

is based on whether AK re-evAs stated in checklist item AKdetermined AK re-evaluation time. The AK accuracy report was pactive at the site. The AKE anaccuracy reports were preparerequirements and confirmed thAK accuracy since resumption

AK-15: Confirm that Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form, is completed as necessary. 

N/A N/A 
D-5 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HET Inspection 

Technical Elements Objective Evidence Comm

AK-16: Confirm that the AKSR is complete and accurately describes the subject waste. 

CCP-AK-ORNL-008, Revision 1 The AKSR identifies the prev

Ci. While not critical to this ap

revisit the prevalent isotope aswhether it would be better to brather than mass%. Further, seNDA memorandum are not in 

are not critical to EPA approv

update the AKSR in the future limitations and information. AKSR, Revision 1, includes a

AKCH-17–AKCH-19 and AK

Waste Stream Definition and Waste Identification AK-17: Verify that all waste within the waste stream was generated from a single process/activity and that the generating process/activity is adequately described. 

CCP-AK-ORNL-008, Revision 1, Sections 4.4, 5.1 and 5.3. Source Documents: C096, M171, M191, M217, P022, P101, P175, P189, P190, P236, P336, P346, P398, P400, P481, P458, P528, P753, P1085, P1351 and U038 

The ORNL Isotopes Program 

the following activities: 

• Radioisotope services. • Isotope enrichment. • IRML activities. • Isotope Distribution (Sales

AK-18: Verify that all waste within the waste stream is similar in material and physical form and that the expected physical parameters are adequately described. 

CCP-AK-ORNL-008, Revision 1, Sections 2.0, 4.5 and 5.4 CCP-TP-005, Attachment 6 and memorandum Source Documents: M126, M187, M189, M190, M191 and M197 

The physical parameters for thextremely diverse; the waste i

form and may be composed of Revision 1, describes the hundcomponents and the AK recorcomposition information abou

waste content is adequately de

only in that each drum will be 

AK-19: Verify that the expected radiological characteristics are adequately described. 

CCP-AK-ORNL-008, Revision 1, Sections 2.0, 4.5 and 5.4 CCP-TP-005, Attachment 7 and memorandum Source Documents: M171, M191, P1269 and U038 

Many drums in the waste strea

radiological composition inforiterations of NDA by different radiological composition of eaAK record. Radiological propbatch basis, and the expected rthe waste stream is adequately specific AK data are availablethat the two most prevalent rad

232Th and 238U. The two most 

by mass are 237Np and 239Pu. 
D-6 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HET Inspection 

Technical Elements Objective Evidence Comm

AK-20: Verify that waste containers are traceable from retrieval through CCP’s EPA-approved characterization process. 

For each container: Source Documents M187, M188, M191; AK tracking spreadsheets; CCP-TP005, Attachment 7 and memorandum X10C0501534: Parent Drum X10C9311139. Drum 

was emplaced in WIPP prior to ORNL-CCP shutdown. X10C0501650: Parent Drum X10C9312391. Drum was emplaced in WIPP prior to ORNL-CCP shutdown. X10C9312235A: Isotope batch FP-26R; has not been characterized X10C9312555: Isotope batch FP-27; excluded (determined to be LLW) X10C9400218: Isotope batch FP-35; excluded (determined to be LLW) X10C9311225: 144Cm population in NDA memorandum; inactive excluded (prohibited item) X10C9309168: Energx and ORNL assay, Np/Pu/235U; has not been characterized. 

The listed references indicated traceable from the point of genplacement/removal on the AK ORNL-CCP BDR generation has three AK tracking spreadsthe waste stream,(2) excluded 

excluded drums that are segre

presence of prohibited items. Eappropriate AK tracking spreadrums include several selected memorandum list, many of wh

Land Withdrawal Act Requirements AK-21: Verify that all of the waste in the waste stream is defense in origin. 

CCP-AK-ORNL-008, Revision 1 Source Documents C034, C087, C089, C097, M192, P047, P050, P051, P089, P119, P175, P225, P227 and U038 

Wastes were extensively comm

isotope-related activities were 

overall defense determination 

Defense Determination Approwaste was commingled (defenunder the defense source “defedefense nuclear waste and by-

AK-22: Verify that none of the waste in the waste stream is high-level waste. 

CCP-AK-ORNL-008, Revision 1 Source Documents P569, U038 and U647 

HLW was not generated becaunot process SNF. 

AK-23: Verify that none of the waste in the waste stream is spent nuclear fuel. 

CCP-AK-ORNL-008, Revision 1 Source Documents U038 and U647 

While the waste stream may in

materials are unirradiated and 
D-7 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HET Inspection 

Technical Elements Objective Evidence Comm

Waste Stream Certification AK-24: Verify that the WSPF is complete and accurate. 

Waste Stream Profile Form, Revision 0, 7/25/2011. ORNL-CCP has increased the 

approximately 10% since appr10). This constitutes an increaAKE stated this was not sufficWSPF. 

AK-25: Confirm that a characterization information summary and summation of aspects are included in the WSPF package and are complete and accurate. 

CIS for Lot 1 Summation of Aspects based on CCP-AK-ORNL008, Revision 0 

The Summation of Aspects is 

revision in place at the time th

AK-26: Confirm that a characterization information summary is adequately completed for each characterization lot. 

Lot 1, 714/2011; Lot 2, 8/22/2011; Lot 3, 8/29/2011 The CIS addressed headspace 

information was evaluated per 

Tier 2 Reporting AK-27: Verify that ORNL-CCP has reported to EPA completion or revision of AK accuracy reports for this waste stream annually, at a minimum. 

Acceptable Knowledge Accuracy Report: Oak Ridge National Laboratory Waste Stream Number OR-ISTP-CH-HET, Heterogeneous Debris, Lots 1 through 3, 3/22/2012 

ORNL-CCP resumed operatio

and has not yet completed an Awaste stream. 

AK-28: Verify that ORNL-CCP has reported to EPA completion or revision of AK-AK and AKNDA/NDE DR reports associated with this waste stream. 

CCP-TP-005, Attachment 4, 1/7/2014 ORNL-CCP resumed operatio

and has not yet completed any 

AK-29: Verify that ORNL-CCP has reported to EPA completion or revision of CCP-TP-005, Attachment 4, for this waste stream. 

CCP-TP-005, Attachment 4, 1/7/2014 ORNL-CCP revised Att. 4 dur

(1/7/2014), which was still the EPA inspection. 

AK-30: Verify that ORNL-CCP has reported to EPA completion or revision of CCP-TP-005, Attachment 6, and the associated memorandum for this waste stream. 

CCP-TP-005, Attachment 6, 1/16/2014 ORNL-CCP revised Att. 6 dur

(1/16/2014), which was still thEPA inspection. 

AK-31: Verify that ORNL-CCP has reported to EPA completion or revision of the AK-NDA memorandum for this waste stream. 

CCP-TP-005, Attachment 7, 10/30/2013 NDA memorandum, 10/30/2013 FY14 1st quarter notification report 

ORNL-CCP revised the NDA 10/30/2013 and correctly repo

quarter notification report. 
D-8 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HET Inspection 

Technical Elements Objective Evidence Comm

AK-32: Verify that ORNL-CCP has reported to EPA completion or revision of this waste stream’s AKSR.

CCP-AK-ORNL-008, Revision 1, 1/9/2014 ORNL-CCP revised AKSR du

(1/9/2014), which was still the EPA inspection. 

AK-33: Verify that ORNL-CCP has reported to EPA completion or revision of the WSPF, including change notices, and the associated documentation for this waste stream. 

WSPF for Waste Stream OR-ISTP-CH-HET, 7/25/2011 

ORNL-CCP resumed operatio

and has not revised the ISTP w

AK-34: Verify that ORNL-CCP has reported to EPA completion or revision of add-container memoranda for this waste stream. 

CCP-TP-005, Attachment 8, 12/6/2013 FY14 1st quarter notification report 

ORNL-CCP has not generated memoranda since the resumpt

8 on 12/6/2013 and reported it 

notification report. 
D-9 

ATTACHMENT D.2: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: WASTE STREAM 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-NFS-CH-SOIL Inspection 

Technical Elements Objective Evidence Comm

General AK-1: Confirm that AK, training and nonconformance procedures adequately reflect the requirements of 40 CFR 194. 

CCP-QP-002, Revision 35, training and qualification plan CCP-QP-005, Revision 23, nonconforming item report CCP-TP-002, Revision 26, WSPF package development CCP-TP-005, Revision 26, AK documentation 

See Attachment D.1 

AK-2: Confirm that AKE and SPM training records and qualification cards are complete and that each individual’s training was conducted prior to them performing work on this waste stream. 

See list in Attachment D.2 Chris Chancellor, AKE, 6/16/2011 Candice Weston, SPM, 11/1/2006 

Chris Chancellor and Candice 

with the ORNL-CCP program included in any of the Assigne

signed documents that are still 

Waste Stream OR-NFS-CH-Squalification cards to confirm 

documents were signed. 

AK-3: Confirm that nonconformances are documented appropriately. 

NCR-ORNL-0841-13 NCR-ORNL-0842-13 NCR-ORNL-0898-13 NCR-ORNL-0258-14 

NCR 0841-13 is open, documdiscrepancy, will be reviewed require an AK re-evaluation aNCR 1842-13 is open, docum

will be reviewed by AKE, and AKSR revision but not impact NCRs 0898-13 and 0258-14 adrums falling out of waste stre

CCP-TP-005 Implementation AK-4: Confirm that Attachment 1, Acceptable Knowledge Documentation Checklist, is complete. 

CCP-TP-005, Revision 26, Attachment 1, Signed by Jeff Harrison, 1/7/2014 

Att. 1 includes every source dthought might apply to the SO

apply to specific AK requiremfound to not apply or not be uremoved from Att. 1. Everythibe listed in Att. 1, but not vice 

AK-5: Confirm that Attachment 2, Record of Communication, is completed as necessary. 

References C100, C210, C227 and C321 Record of Communication is n

a consistent format to docume
D-10 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-NFS-CH-SOIL Inspection 

Technical Elements Objective Evidence Comm

AK-6: Confirm that an Attachment 3, Acceptable Knowledge Source Document Summary, is complete for every source document. 

See reference list in Attachment B to this report All reviewed source documen

summary. 

AK-7: Confirm that Attachment 4, Acceptable Knowledge Information List, is complete and up to date. 

CCP-TP-005, Revision 26, Signed by Travis Smith, 1/6/2014 

Att. 4 includes every SD that a

apply to the SOIL waste stream

apply or not be useful, it is nofrom Att. 4. Every SD cited in 

but not vice versa. 

AK-8: Confirm that Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, and Packaging, is complete and up to date. 

CCP-TP-005, Revision 26, Signed by Jeff Harrison, 1/16/2014 WMP analysis memorandum, Signed by Jeff Harrison, 1/16/2014 

Up to date and revised to inclu

generated soil. Supports Table 

AK-9: Confirm that Attachment 7, Radionuclides, is complete and up to date and that AK-NDA communication is appropriately documented. 

CCP-TP-005, Revision 22, Signed by Allen Dickerson, 5/31/2011 NDA memorandum, Signed by Jeff Harrison (AKE), Robert Ceo (NDA SME), Joe Wachter (MCS Technical Director) and Joe Harvill (CCP Project Office), 11/15/2010 

Soil discussion in memoranduthird soil generation campaign 

are based on ratio of building-and the same building-wide rabuilding D&D. Supports Tabl

AK-10: Confirm that Attachment 8, Waste Containers List, is complete and up to date. 

CCP-TP-005, Revision 26, Dated 12/5/2013, Signed by Jeff Harrison References M128 and M132 

Att. 8 is a record of what was 

containers are only removed frdifferent ORNL-CCP waste stotherwise excluded, stay in Atcontainer numbers are not addcontainers added since resumpcontainers in storage at ORNL waste stream when moved to T

AK-11: Confirm that Attachment 10, Acceptable Knowledge Re-evaluation Checklist, is completed as necessary. 

CCP-TP-005, Revision 19, Signed by Jeff Harrison (AKE) and Candice Weston (SPM), 7/7/2010, corresponds to DR026 

This was the most recent Att. Att. 10s for SOIL waste stream 

AK-12: Confirm that Attachment 11, Acceptable Knowledge Source Document Discrepancy Resolution, is completed as necessary. 

DR026, CCP-TP-005, Revision 19, Signed by Jeff Harrison, 7/7/2010 

This was the most recent Att. 

new Att. 11s or DRs for SOIL resumption. 
D-11 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-NFS-CH-SOIL Inspection 

Technical Elements Objective Evidence Comm

AK-13: Confirm that Attachment 13, CCP Waste Stream Characterization Checklist, is completed foreach characterization lot. 

Lot 12, Signed by Candice Weston (SPM) and Jeff Harrison (AKE), 9/6/2011 

Lot 12 was the last lot compleconfirmed that there have been 

compiled since resumption. OCCP-TP-005, Attachment 13 erequired components are prese

AK-14: Confirm that Attachment 14, CCP Acceptable Knowledge Accuracy Report, is completed annually and verify that the AK accuracy report memorandum is technically adequate. 

Acceptable Knowledge Accuracy Report: Oak Ridge National Laboratory Waste Stream Number OR-NFS-CH-SOIL, Soils, Lot 12, Cumulative for Lots 1 through 12, 3/22/2012, including CCP-TP005, Revision 24, Attachment 14, Lot 12, Signed by Bevery Schrock, 3/22/2012 

AKEs and SPM confirmed tha

accuracy since resumption. 

AK-15: Confirm that Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form, is completed as necessary. 

N/A N/A 

AK-16: Confirm that the AKSR is complete and accurately describes the subject waste. 

CCP-AK-ORNL-001, Revision 8 CCP-AK-ORNL-001, Revision 9 

AKSR revised during EPA ins

includes all required compone19 and AKCH-21–AKCH-23. 

Waste Stream Definition and Waste Identification AK-17: Verify that all waste within the waste stream was generated from a single process/activity and that the generating process/activity is adequately described. 

CCP-AK-ORNL-001, Revision 9 References: C099, C100, C210, I053, M003, M132, M206, P212, P218, P248, P273, P306, P315, P323, P1375, P1400 and U055

NFS generated the waste from 234 and removal of Building 1tank. 

AK-18: Verify that all waste within the waste stream is similar in material and physical form and that the expected physical perameters are adequately described. 

CCP-AK-ORNL-001, Revision 9 CCP-TP-005, Attachment 6 and memorandum References: C321, M003, M075, M128, M132, M210, P248, P315, P317, P1400, P1401, U055 and U058 

Waste containers hold soil and 

AK-19: Verify that the expected radiological characteristics are adequately described. 

CCP-AK-ORNL-001, Revision 9 CCP-TP-005, Attachment 7 and memorandum References: C099, C100, C210, I053, M003, M012, P218, P273, P1401 

238U and 239Pu are predicted m

measurements may result in 23

prevalent due to expected issu
D-12 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-NFS-CH-SOIL Inspection 

Technical Elements Objective Evidence Comm

AK-20: Verify that waste containers are traceable from retrieval through CCP’s EPA-approved characterization process. 

X10C0506047: Att. 8; DR010; DR022; M003; 

M012; OR-RTR6-0305, 5/4/2010; OR-DWAS0120, initial assay 12/3/2008, reassay 2/1/2011 forNCR-ORNL-0535-10 (trigger from WDS calculation); CIS Lot 12, 9/2/2011; emplaced 12/1/2011 NFS0815: Att. 8; DR023; DR026; M003; M012; OR-RTR7-0003, 12/12/2013; NCR-ORNL-0842-13 for plastic liner bag not being present as identified in AK; container status is “hold” X10C0506151C: M003; M075, repackaged into A–K (only B, C and E are TRU); M128; OR-RTR7-0002, 12/3/2013; OR-IQ3-0228, assay 12/19/2013 

Containers not fully certified fCCP ceasing operations will bNDA prior to WIPP emplacemThe “C” in X10C0506151C incontainer of X10C0506151. 

Land Withdrawel Act Requirements AK-21: Verify that all of the waste in the waste stream is defense in origin. 

CCP-AK-ORNL-001, Revision 9 References: C099, C100 and M021 

Over 90% of the NFS fuel pro

related projects/clients. ORNL-CCP intended to use Mdetermination for all NFS was

document explicitly only appl

stream. ORNL-CCP revised A

explaining that it applies to all 

AK-22: Verify that none of the waste in the waste stream is high-level waste. 

CCP-AK-ORNL-001, Revision 9 References: P315, U038 and U055 

Soil filtered/sized repackagedAlso, NFS did not reprocess S

AK-23: Verify that none of the waste in the waste stream is spent nuclear fuel. 

CCP-AK-ORNL-001, Revision 8 References: P315, U038 and U055 

Soil filtered/sized repackagedAlso, NFS did not handle SNF

Waste Stream Certification AK-24: Verify that the WSPF is complete and accurate. 

Waste Stream Profile Form, Revision 0, 12/8/2009 AKSR, Revision 9, which was 

inspection, includes a change WMPs. Therefore, ORNL-CCWSPF. EPA will review the rereview or during the next continspection. 
D-13 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-NFS-CH-SOIL Inspection 

Technical Elements Objective Evidence Comm

AK-25: Confirm that a characterization information summary and summation of aspects are included in the WSPF package and are complete and accurate. 

CIS for Lot 1 Summation of Aspects based on CCP-AK-ORNL001, Revision 4 

The CIS for Lot 1 is complete WSPF. The Summation of Aspects wicurrent AKSR when the WSPF 

AKCH-24. 

AK-26: Confirm that a characterization information summary is adequately completed for each characterization lot. 

Lot 10, 12/16/2009; Lot 11, 12/13/2010; Lot 12, 9/2/2011 

SPM confirmed no characterizsince resumption. 

Tier 2 Reporting AK-27: Verify that ORNL-CCP has reported to EPA completion or revision of AK accuracy reports for this waste stream annually, at a minimum. 

Acceptable Knowledge Accuracy Report: Oak Ridge National Laboratory Waste Stream Number OR-NFS-CH-SOIL, Soils, Lot 12, Cumulative for Lots 1 through 12, March 22, 2012 

ORNL-CCP resumed operatio

and has not yet completed an ASOIL waste stream. 

AK-28: Verify that ORNL-CCP has reported to EPA completion or revision of AK-AK and AKNDA/NDE DR reports associated with this waste stream. 

CCP-TP-005, Attachment 4, 1/6/2014 ORNL-CCP resumed operatio

and has not yet completed any stream. 

AK-29: Verify that ORNL-CCP has reported to EPA completion or revision of CCP-TP-005, Attachment 4, for this waste stream. 

CCP-TP-005, Attachment 4, 1/6/2014 ORNL-CCP revised Att. 4 dur

(1/6/2014), which was still the EPA inspection. 

AK-30: Verify that ORNL-CCP has reported to EPA completion or revision of CCP-TP-005, Attachment 6, and the associated memorandum for this waste stream. 

CCP-TP-005, Attachment 6, 12/5/2013 FY14 1st quarter notification report 

ORNL-CCP revised Att. 6 on reported it in the FY14 1st qua

ORNL-CCP revised Att. 6 aga

(1/16/2014), which was still thEPA inspection. 

AK-31: Verify that ORNL-CCP has reported to EPA completion or revision of the AK-NDA memorandum for this waste stream. 

NDA memorandum, 11/15/2010 ORNL-CCP resumed operatio

and has not revised the NDA mwaste stream. 

AK-32: Verify that ORNL-CCP has reported to EPA completion or revision of this waste stream’s AKSR.

CCP-AK-ORNL-001, Revision 8, 12/12/2013 CCP-AK-ORNL-001, Revision 9, 2/6/2014 FY14 1st quarter notification report 

ORNL-CCP revised AKSR (Rand correctly reported it in the 

notification report. ORNL-CC9) during FY14 2nd quarter (2/

current quarter during the EPA 
D-14 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-NFS-CH-SOIL Inspection 

Technical Elements Objective Evidence Comm

AK-33: Verify that ORNL-CCP has reported to EPA completion or revision of the WSPF, including change notices, and the associated documentation for this waste stream. 

Waste Stream Profile Form, Revision 0, 12/8/2009 ORNL-CCP resumed operatio

and has not yet revised the SO

AK-34: Verify that ORNL-CCP has reported to EPA completion or revision of add-container memoranda for this waste stream. 

CCP-TP-005, Attachment 4, 1/6/2014 CCP-TP-005, Attachment 8, 12/8/2013 

ORNL-CCP has not generated memoranda since the resumpt

8 on 12/8/2013 and reported it 

notification report. 
D-15 

ATTACHMENT D.3: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: WASTE STREAM 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HET Inspection 

Technical Elements Objective Evidence Comm

GeneralAK-1: Confirm that AK, training and nonconformance procedures adequately reflect the requirements of 40 CFR 194. 

CCP-QP-002, Revision 35, training and qualification plan CCP-QP-005, Revision 23, nonconforming item report CCP-TP-002, Revision 26, WSPF package development CCP-TP-005, Revision 26, AK documentation 

40 CFR Part 194.24 (c) requir

of controls to characterize was

components. The procedures lcharacterization method, wastdevelopment, nonconformancrequirements that help fulfill tPart 194.24(c). This report and examples of adequate implemdocument. 

AK-2: Confirm that AKE and SPM training records and qualification cards are complete and that each individual’s training was conducted prior to them performing work on this waste stream. 

Steve Schafer, AKE, 6/8/2011 Kevin Peters, AKE, 6/8/2011 Lisa Watson (Price), AKE, 6/8/2011 Dave Moody, SPM, 6/8/2011 Laura Nelson, SPM, 6/21/2010 Irene Joo (Quintana), SPM, 9/17/2009 CCP-QP-002, Revision 35, Assigned Reading Report, printed 2/18/2014 CCP-QP-005, Revision 23, Assigned Reading Report, printed 2/18/2014 CCP-TP-002, Revision 26, Assigned Reading Report, printed 2/18/2014 CCP-TP-005, Revision 26, Assigned Reading Report, printed 2/18/2014 DOE WIPP-02-3214, Revision 3, Assigned Reading Report, printed 2/18/2014 

The qualification cards indicatthe procedure in effect at the t

sign-off. CCP trained Steve ScWatson, and Dave Moody to tAKRH-1, as well as the WAPQAPP. CCP trained Irene Joo TRAMPAC, as well as CCP-scharacterization and tracking r

EPA verified the skills and traby interview during the inspecprovided assigned reading list 

the AKEs and SPMs are familversion of the WCPIP and eacAKRH-1. 

AK-3: Confirm that nonformances are documented appropriately. 

NCR RH-ORNL-0291-11, Containers ORRH00642, ORRH00643 and ORRH00644, 5/19/2011, highest measured dose rate less than three times background 

AKEs confirmed that ORNL-CNCRs for Waste Stream OR-Rstart. 
D-16 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HET Inspection 

Technical Elements Objective Evidence Comm

CCP-TP-005 Implementation AK-4: Confirm that Attachment 1, Acceptable Knowledge Documentation Checklist, is complete. 

CCP TP 005, Revision 26, Attachment 1, Signed by Kevin Peters, 12/30/2013

Att. 1 shows how ORNL-CCP mandated AK element. The Wsystem of controls in place to with 40 CFR Part 194.24. Comdemonstrates that AK is colleccontrols. 

AK-5: Confirm that Attachment 2, Record of Communication, is completed as necessary. 

Source Documents C098, C148, C302, C307, C308 and C600 

Record of Communication is na consistent format to docume

communications.

AK-6: Confirm that an Attachment 3, Acceptable Knowledge Source Document Summary, is complete for every source document. 

See reference list in Attachment B to this report All provided source document

summary. 

AK-7: Confirm that Attachment 4, Acceptable Knowledge Information List, is complete and up to date. 

CCP-TP-005, Revision 26, Attachment 4, Signed by Kevin Peters, 12/23/2013 

Att. 4 shows all source documduring the course of the AK pr

of checking unused references to verify adequate compilation available AK data. EPA verifireferences cited in the AKSR, 

AK-8: Confirm that Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, and Packaging, is complete and up to date. 

CCP-TP-005, Revision 26, Attachment 6, Signed by Kevin Peters, 12/30/2013 WMP analysis memorandum, Signed by Steve Schafer, 4/28/2008 

The WMP values in the memoRevision 3, Table 5-1 are equiBetween re-start of waste char

the EPA inspection, ORNL-Cwaste stream from canisters thin 1996. The physical content with the overall waste stream the WMP calculations is not w
D-17 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HET Inspection 

Technical Elements Objective Evidence Comm

AK-9: Confirm that Attachment 8, Waste Containers List, is complete and up to date. 

Attachment 8 – Waste Containers List, signed by Christopher Chancellor, 4/14/2009, with attached add-container memoranda dated 5/30/2008, 6/4/2008, 6/5/2008, 6/11/2008, 6/27/2008 (2), 5/19/2009, 6/16/2009 (2), 6/19/2009, 7/14/2009, 9/1/2009, 9/29/2009, 1/26/2010 Additional add-container memoranda dated: 8/26/2010, 5/20/2011, 1/17/2011, 1/3/2014, 1/28/2014 RH AK Tracking Spreadsheet dated 1/28/2014 

Att. 8, 4/14/ 2009, showed the

in the waste stream at this timcontainer memos generated beAtt. 8 has not been updated sin

however, several more add-coassociated with Att. 8. The total number of drums in 

Attachment 8 and all add-contonly 327 are currently on the A

The AKE indicated and demowas due to subsequent movem

LLW waste streams following 

AK-10: Confirm that Attachment 10, Acceptable Knowledge Re-evaluation Checklist, is completed as necessary. 

N/A AKE confirmed that there hav

Knowledge Re-Evaluation Ch

waste stream since re-start. 

AK-11: Confirm that Attachment 11, Acceptable Knowledge Source Document Discrepancy Resolution, is completed as necessary. 

DR601, CCP-TP-005, Revision 18, Attachment 11, Signed by Kevin Peters, 6/20/2008 (physical description discrepancy) DR602, CCP-TP-005, Revision 18, Attachment 11, Signed by Kevin Peters, 7/2/2008 [Hazardous Waste Number (HWN) discrepancies]

Discrepancy resolutions adequ

identified. AKE confirmed thawritten since re-start. 

AK-12: Confirm that Attachment 13, CCP Waste Stream Characterization Checklist, is completed foreach characterization lot. 

CCP-TP-005, Revision 26, Attachment 13, Lot 29, Draft, unsigned, undated, electronic file dated 1/22/2014. Lot 28, Signed by Laura Nelson (SPM) and Kevin Peters (AKE), 9/19/2011 

Historical characterization chedemonstrate provision of comchecklist. 

AK-13: Confirm that Attachment 14, CCP Acceptable Knowledge Accuracy Report, is completed annually and verify that the AK accuracy report memorandum is technically adequate. 

Acceptable Knowledge Accuracy Report: Oak Ridge National Laboratory Remote-Handled Transuranic (RH TRU) Waste Stream Number ORREDC-RH-HET, Lots 1 Through 29, Laura Nelson, draft dated 1/6/2014 Acceptable Knowledge Accuracy Report: Oak Ridge National Laboratory Remote-Handled Transuranic (RH TRU) Waste Stream Number ORREDC-RH-HET, Lots 1 Through 28, Laura Nelson, 1/11/ 2012 

EPA verified that the draft AK 

integrates new information (Laccuracy results. The 2012 AK accuracy report was not active at the site. The that accuracy reports were preaudit requirements and confirmassessed AK accuracy since re
D-18 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HET Inspection 

Technical Elements Objective Evidence Comm

AK-14: Confirm that Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form, is completed as necessary. 

CCP-TP-005, Revision 26, Attachment 15, Signed by Kevin Peters, 11/26/2013. 

The CSSF verified the comparwaste stream and RH REDC w

isotopic distribution and physiradiological data are not curreagainst RH radiological data; used as default isotopics by thREDC waste stream. 

AK-15: Confirm that the AKSR is complete and accurately describes the subject waste. 

CCP-AK-ORNL-500, Revision 3, 1/8/2014 CCP-AK-ORNL-500, Revision 4, 2/6/2014 

AKSR revised during EPA ins

includes all required compone18 and AKRH-20–AKRH-22. 

Waste Stream Definition and Waste Identification AK-16: Verify that all waste within the waste stream was generated from a single process/activity and that the generating process/activity is adequately described. 

CCP-AK-ORNL-500, Revision 3 CCP-AK-ORNL-500, Revision 4 Source Documents: C302, C600, DR601, P125, P161, P279 and U011 

RH REDC waste stream inclu

generated in the REDC hot cerelated to target fabrication/ pr

chemistry lab analyses, and pr

REDC is still active, but the Astream is limited, at this time, 

1972 and 2007. 

AK-17: Verify that all waste within the waste stream is similar in material and physical form and that the expected physical parameters are adequately described. 

CCP-AK-ORNL-500, Revision 3 CCP-AK-ORNL-500, Revision 4 CCP-TP-005, Attachment 6 and memorandum Source Documents: M100, M105, M120, P125, P161, P058, U045 and U049 

RH REDC waste stream is com

(16.97%) and inorganic (83.03generally consists of CPR, gla
D-19 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HET Inspection 

Technical Elements Objective Evidence Comm

AK-18: Verify that all waste within the waste stream has similar radiological properties and that the expected radiological characteristics are adequately described. 

CCP-AK-ORNL-500, Revision 3 CCP-AK-ORNL-500, Revision 4 CCP-AK-ORNL-501, Revision 4 CCP-AK-ORNL-505A, Revision 1 CCP-AK-ONRL-505B, Revision 1 Source Documents: P161, I044, U011, U045 and U049 

The waste stream is composed 

distributions described as: 

• Pre-SETF (HFIR, 1972–19• SETF (HFIR & SETF, 197• Mark 42 (which includes a 

HIFR/HIFR subpopulation

The REDC is primarily involv

storage, and distribution of the 

249Bk, 252Cf, 253Es and 257Fm thirradiation of curium targets (g242Pu at SRS or ORNL) in the 

from these activities is referrespecific isotopic distribution. Uwas also performed in Buildin1979 and 1986 in addition to tcharacterizes the SETF isotopgrouping includes both Mark 4HFIR campaigns. The AKSR radionuclides in the waste stre

246Cm, and the predominant ra244Cm and 90Sr. 
D-20 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HET Inspection 

Technical Elements Objective Evidence Comm

AK-19: Verify that waste containers are traceable from retrieval through CCP’s EPA-approved characterization process? 

ORRH00681: Parent cask X10C9402622 in 

overpack cask X10C9600188; VE BDR No. ORNLRHVE13004, 12/13/2013; DTC BDR No. ORRHDTC13001, assay on 12/24/2013; AK tracking spreadsheet, 1/28/2014 ORRH00683: Parent cask X10C9402622 in overpack cask X10C9600188; VE BDR No. ORNLRHVE13005, 12/16/2013; DTC BDR No. ORRHDTC13001, assay on 12/24/2013; AK tracking spreadsheet, 1/28/2014 X10C9600188: M100; Add-Container Memorandum, 1/3/2014; AK tracking spreadsheet, 1/28/2014 

The listed references indicated traceable from the point of genplacement/removal on the AK 

ORNL-CCP BDR generation. The AKE described the contai

process: 

1) Cask is identified by ORN

the waste stream. 

2) AK evaluated the cask ag

data (including parent casdetermine whether it fits 

3) Add the cask to the AK tr

assign radiological characon date (only) of cask ma

4) As containers are VE’d, v

add-container memorandwaste stream. 

Note that the traceability drumasked to evaluate them for incIn those instances, the cask ev

add-container memorandum to cask. Also, radiological distribAKE on the AK tracking sprecharacterization team consults the appropriate radiological di

Land Withdrawal Act Requirements AK-20: Verify that all of the waste in the waste stream is defense in origin. 

CCP-AK-ORNL-500, Revision 3 CCP-AK-ORNL-500, Revision 4 Source Documents: M023, P258, P281 and U039 

REDC waste are “irretrievably 

generated, in part, by the folloactivities”: 

• Naval reactors developme• Defense nuclear materials • Defense nuclear waste and • Defense research and deve
D-21 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HET Inspection 

Technical Elements Objective Evidence Comm

AK-21: Verify that none of the waste in the waste stream is spent nuclear fuel. 

CCP-AK-ORNL-500, Revision 3 CCP-AK-ORNL-500, Revision 4 Source Documents: DR009, P569, U038, U647, I022 and I023 

The AKSR, Revision 3, did no

SNF determination based on rU647, which clearly indicated believed the waste to contain Sthe AKSR to describe an evalu

the waste generated from the pMark-42 targets processed in tbecause they were not generat

generation. 

AK-22: Verify that none of the waste in the waste stream is high-level waste. 

CCP-AK-ORNL-500, Revision 3 CCP-AK-ORNL-500, Revision 4 Source Documents: DR009, P569, U038, U647, I022 and I023 

The AKSR, Revision 3, did no

HLW determination based on 

U647, which clearly indicated believed the waste to contain Hthe REDC waste is not SNF (s21). For this reason, the proceresult in the generation of HLW primarily or solely materials rextraction system (or equivaleSNF. Additionally, the LWR aspecimens processed during ththe small-scale processing of tdevelopment of separation and not HLW from a reprocessing separation of fissile elements aelements contained in SNF for recovering desired materials. 

Waste Stream Certification AK-23: Confirm that the certification plan is complete and adequately describes the role of AK inthe waste characterization methodology. 

CCP-AK-ORNL-502 Revision 4, 1/31/ 2014 CCP-AK-ORNL-502, Revision 5, 2/6/2014 

Revision 4 of the certification 

HLW/SNF. ORNL-CCP revisto state that the waste stream d

and referenced back to the AKinformation. 

AK-24: Verify that the WSPF is complete and accurate. 

Waste Stream Profile Form, Revision 0, 6/3/2009 ORNL-CCP added 14 drums t

January 2014. This constitutes volume, but the AKE stated thwarrant a new WSPF. 
D-22 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HET Inspection 

Technical Elements Objective Evidence Comm

AK-25: Confirm that a characterization information summary, characterization reconciliation report andsummation of aspects are included in the WSPF package and are complete and accurate. 

Characterization Reconciliation Report, Lot 28, 9/19/2011 Characterization Information Summary, Lot 1, 2/18/2009 Summation of Aspects based on CCP-AK-ORNL500, Revision 0 

The Summation of Aspects winew SNF/HLW information, bSummation is not critical at th

changes do not modify the connot contain SNF or HLW. 

AK-26: Confirm that a characterization information summary is adequately completed for each characterization lot. 

Draft Characterization Information Summary, Lot 29, electronic file dated 1/22/2014 Characterization Information Summary Lot 28, 9/19/2011 

The Lot 28 CIS verified adequcharacterization lot and CIS pr

AK-27: Confirm that a characterization reconciliation report is adequately completed for each characterization lot. 

Draft Characterization Reconciliation Report, Lot 29, electronic file dated 1/22/2014 Characterization Reconciliation Report, Lot 28, 9/19/2011 

The Lot 28 CRR verified adeqand CRR preparation process. 

Data Quality Objectives AK-28: Identify how ORNL-CCP will meet the DQO for defense waste, HLW and SNF determination. 

CCP-AK-ORNL-502, Revision 4 CCP-AK-ORNL-502, Revision 5 

The certification plan, Revisio

and HLW. ORNL-CCP reviseinclude reference to DQOs/QAchecklist item AKRH-23. 

AK-29: Identify how ORNL-CCP will meet the DQOs for radioactive properties: TRU waste determination, RH waste determination and activity determination. 

CCP-AK-ORNL-502, Revision 4 CCP-AK-ORNL-502, Revision 5 

The certification plan, Revisio

address the activity determinarespect to the role of AK in th

process. ORNL-CCP revised t

address this item. 

AK-30: Identify how ORNL-CCP will meet the DQOs for physical properties: liquids and physical form. 

CCP-AK-ORNL-502, Revision 4 CCP-AK-ORNL-502, Revision 5 

The certification plan, Revisio

the physical form and prohibit

Tier 2 Reporting AK-31: Verify that ORNL-CCP has reported to EPA completion or revision of AK accuracy reports for this waste stream annually, at a minimum. 

Acceptable Knowledge Accuracy Report: Oak Ridge National Laboratory Remote-Handled Transuranic (RH TRU) Waste Stream Number ORREDC-RH-HET, Lots 1 Through 28, Laura Nelson, 1/11/ 2012 

ORNL-CCP resumed operatio

and has not completed an AK RH waste stream since re-start
D-23 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HET Inspection 

Technical Elements Objective Evidence Comm

AK-32: Verify that ORNL-CCP has reported to EPA completion or revision of DRs or data limitation information associated with this waste stream. 

CCP-TP-005, Attachment 4, 1/7/2014 ORNL-CCP resumed operatio

and has not completed any DRstream since re-start. 

AK-33: Verify that ORNL-CCP has reported to EPA completion or revision of a Correlation Surrogate Summary Form. 

CCP-TP-005, Attachment 15, 11/26/2013 ORNL-CCP revised the CSSF 

have reported it in the FY14 1

However, because ORNL-CCto CCP Records until 1/7/2014CCP is planning to report the rFY14 2nd quarter notification r

AK-34: Verify that ORNL-CCP has reported to EPA completion or revision of the Characterization Reconciliation Reports and Characterization Information Summaries. 

Draft Characterization Reconciliation Report, Lot 29, electronic file dated 1/22/2014 Characterization Reconciliation Report, Lot 28, 9/19/2011 Draft Characterization Information Summary, Lot 29, electronic file dated 1/22/2014 Characterization Information Summary Lot 28, 9/19/2011 

ORNL-CCP resumed operatio

and has not completed any CRwaste stream since re-start. 

AK-35: Verify that ORNL-CCP has reported to EPA completion or revision of this waste stream’s AKSR or certification plan. 

CCP-AK-ORNL-500, Revision 3, 1/8/2014 CCP-AK-ORNL-500, Revision 4, 2/6/2014 CCP-AK-ORNL-502, Revision 3, 11/11/2013 CCP-AK-ORNL-502, Revision 4, 1/31/2014 CCP-AK-ORNL-502, Revision 5, 2/6/2014 

ORNL-CCP revised the certifi11/11/2013 and correctly repo

quarter notification report. ORNL-CCP revised the AKSR twice during FY14 2nd quarter 

2/6/2014; certification plan: 1/of which were during the same inspection. 

AK-36: Verify that ORNL-CCP has reported to EPA completion or revision of the WSPF, including change notices, and the associated documentation for this waste stream. 

Waste Stream Profile Form, Revision 0, 6/3/2009 ORNL-CCP resumed operatio

and has not revised the REDC 

AK-37: Verify that ORNL-CCP has reported to EPA completion or revision of add-container memoranda for this waste stream. 

Add-container memorandum, 1/3/2014 Add-container memorandum, 1/28/2014 

ORNL-CCP generated two adduring FY14 2nd quarter (1/3/2

was still the current quarter du
D-24 

EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HET Inspection 

Technical Elements Objective Evidence Comm

AK-38: Verify that ORNL-CCP has reported to EPA completion or revision of CCP-AK-ORNL002. 

N/A ORNL-CCP resumed operatio

and has not revised CCP-AK-
E-1 

ATTACHMENT E: NDA CONTINUED COMPLIANCE INSPECTION CHECKLIST: 

Technical Elements Objective Evidence 

General IQ3-1: Confirm the NDA system is the same unit EPA inspected and approved previously. 

Located in Trailer No. NDA-IQ3-01, Building 7880 in the CH Storage Area at ORNL TWPC. 

EPA the app

IQ3-2: Describe the IQ3. The IQ3 is a segmented gamma scanning system that acquires data with three 

detectors simultaneously. An additional set of three detectors for isotopic analyses are mounted orthogonally to the first three. 

N/A 

IQ3-3: Identify the consensus standards that were used for the system calibration 

ASTM C-1030, C-1133, C-1215, E-181. As 

201with 

IQ3-4: Describe the IQ3’s operational history since the baseline approval. 

The IQ3 assay system was relocated to ORNL from SRS in 2009, following which EPA approved it for WIPP assays. From May 2011 to September 2013 the IQ3 has been performing Non-WIPP assay. The IQ3 was recalibrated in 2012 by WAI following the replacement of detectors and electronic upgrades, and ORNLCCP has accepted the 2012 calibration. 

As ND

IQ3-5: Identify the container types assayed on the IQ3 

The IQ3 can assay 55-gallon drums only. Vis

concan 

IQ3-6: Identify the number of BDRs and waste containers this system assayed since resuming activities. 

Since resuming activities, the IQ3 has assayed approximately 187 drums, which were compiled into 30 BDRs. 

Non

IQ3-7: Confirm that the IQ3 is able to report quantitative values for the WIPP-tracked radionuclides 

Direct Measurements: 239Pu, 241Am, 233U, 235U, 238U and 137Cs. 

Isotopic Fractions: 238Pu, 240Pu, 241Pu, relative to Pu, 242Pu by correlation. 

Radionuclides by Scaling: 90Sr and 234U. 

CCP-ORNL-IQ3-003, Revision 0. 

As Revinteduri

IQ3-8: Confirm the IQ3’s calibration of record. Documented in MCS-IQ3-CALIB-2012, Revision 1, provided during on-site 

inspection 

Conduri

IQ3-9: Identify the procedures that govern this function and where the results of these calculations are documented. 

CCP-TP-047, Operating Procedure (Revision 12, 11/6/2013). CCP-TP-046, Calibration Procedure (Revision 5, 11//6/2013). 

CCP-TP-048, Data Validation Procedure (Revision 16, 11/1/2013). 

Thecurrwerat th

IQ3-10: Confirm that the methods used to derive the isotopic contribution for unmeasured radionuclides are MGA and MGA-U. 

MGA and MGA-U are integral parts of the IQ3 operation as shown in CCP-TP047. Con

ORinsp
E-2 

Technical Elements Objective Evidence 

IQ3-11: Confirm the IQ3 operational range with respect to matrix (density) and activity. 

Range is defined as the system’s LLD and 175 g 239Pu, limited by system dead 

time. Density range is 0.015 to 1.64 g/cm3 in density, multi-curve assays without 

attenuators. Expressly excluded is the use of the attenuated mode. 

EPA pers

Calibration Verification and ConfirmationIQ3-12: Identify the date of the last calibration verification. Have any others been completed in the last year? 

None were performed since resuming activities. EPA 

pers

IQ3-13: Confirm the pedigree of all radionuclide standards that were used for calibration confirmation and/or verifications. 

Sources are summarized in MCS-IQ3-CAL-CONF-RPT-2013-01. EPA 

certindeacccali

IQ3-14: Requirements for accuracy and precision must be met, as specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for calibration verifications. 

The calibration verification results are contained in MCS-IQ3-CAL-CONF-RPT2013-01. % R was found to be between 70 and 130% and % RSD was found to be less than 14%. 

Accwerveri

LLD IQ3-15: Confirm that the LLD for the IQ3 has been determined. 

The LLD is documented in MCS-CAL-CONF-RPT, January 2013, which indicates that the instrument meets the WAC TRU/Non-TRU discrimination criterion of 100 nCi/g or less. 

EPA with duriIQ3 

IQ3-16: Confirm if the IQ3 is used to discriminate TRU/non-TRU wastes at the 100 nCi/g criterion and that it has the required sensitivity. 

The IQ3 can discriminate between non-TRU and TRU waste based on the LLDs reported in MCS-IQ3-CAL-CONF-RPT for all measured radionuclides. 

Thicaliand 

IQ3-17: Identify any/all instances where an LLD value for a non-measured radionuclide is not 

provided based on a lack of technical feasibility. 

 Because an LLD is a measurement-based parameter, it is not technically feasible 

to calculate for radionuclides that are not directly measured. Plutonium isotopes 

238Pu, 240Pu and 242Pu are not usually directly measured by gamma spectroscopy 

and are instead derived by ratios to measured 239Pu. The reporting threshold for 

90Sr is computed based on the reported 137Cs LLD using an activity ratio 

determined from AK-NDA memoranda. ORNL-CCP states that it is not technically feasible to provide an LLD equivalent for 234U and that it is derived by 

algorithm from measured values of 235U, 238U and 238Pu. 

Thicalidoc

Quality Control IQ3-18: All operators have current CCP training as verified on LOQI. 

LOQI provided on 2/3/2014 contains five operators, all with current training, see IQ3-22, below. 

EPA listeliste
E-3 

Technical Elements Objective Evidence 

IQ3-19: Confirm the IQ3’s status with respect to the CBFO NDA PDP and last cycle. 

The IQ3 successfully participated in drum cycle 20C of the CBFO NDA PDP by assaying four matrix drums: glass, combustibles, metals and sludge. 

EPA partCBF

IQ3-20: All IQ3 data must be reviewed and approved by qualified personnel. Identify the name and function of the individuals performing technical review and approval of IQ3 BDRs. 

Dan Crosby: Operator/ITR, 11/2016. Susan Anderson: Operator/ITR, 11/2015. Chad Gerlock, Operator/ITR, 11/2015. Ron Whitson: Operator/ITR, 11/2015 Maria Steade: Operator/ITR, 1/2016 Bruce Gillespie: EA. Kevin Meyer: EA. Bob Ceo, EA. Bart Morales, EA. Tim Southwort, EA. 

All techacc2/3/

IQ3-21: Identify any NCRs since resuming activities last year. 

There have been no NCRs on the IQ3 since resuming characterization activities last year. 

EPA with insp

TMU IQ3-22: Identify any changes to the method or details of the TMU calculation since baseline. 

No changes to the TMU were made since resuming activities last year. EPA 

with insp

IQ3-23: Evaluate the magnitude of the TMU values observed in the IQ3 BDRs that were examined during this inspection. 

The TMU for the IQ3 is documented in CCP-ORNL-IQ3-002, Total Measurement Uncertainty for the IQ3 System, dated April 20, 2005. This document does not have a revision number. The components of uncertainty included in the TMU determination consist of calibration source uncertainties, counting statistics, self-absorption effects, matrix nonhomogeneities, nonuniform source distributions and isotopic measurement uncertainties. The software for performing the TMU calculations is embedded in the NDA 2000 software. CCPORNL-IQ3-002 calls for administrative procedures that would define a minimum 

fill-height requirement to reduce the potential for increased uncertainties due to end effects. TMU values in BDRs are generally consistent with expectations. 

EPA with insp

Background and Performance Checks IQ3-24: Confirm that IQ3 background measurements have been taken daily. 

Confirm that IQ3 background measurements have been taken daily. EPA 

with entrand dou
E-4 

Technical Elements Objective Evidence 

IQ3-25: Assess how often background radiation was problematic to the extent that measurement personnel had to make adjustments. 

No instances of problematic backgrounds were observed since resuming activities last year. 

EPA with 

IQ3-26: Confirm that system performance checks have been performed at least once per operational day. Confirm that performance checks include gamma and neutron efficiency, matrix correction checks, and gamma peak position and resolution checks. 

Performance checks are done once per day as stated in CCP-TP-019, Revision 6. EPA 

with entrand doc

Data Management IQ3-27: IQ3 BDRs contain: • Testing facility name, testing batch number, 

container numbers, and signature of the SPM or designee 

• Table of contents 

• Background and performance check data or 

control charts for the relevant time period 

• Separate testing report sheets for each 

container 

EPA reviewed IQ3 BDR No. OR-IQ3-0224 and found it to contain appropriate 

information. 

N/A 

IQ3-28: IQ3 RDSs must include: • Title “Radioassay Data Sheet” 

• Method/procedure used 

• Date of radioassay 

• Activities and associated TMU for individual 

radionuclides 

• TRU alpha concentration and its associated 

TMU 

• Operator and reviewer signatures 

EPA reviewed IQ3 BDR No. OR-IQ3-0224 and found it to contain appropriate information. 

N/A 
F-1 

ATTACHMENT F.1: REPLICATE TESTING DATA FOR DRUM NO. X10CSATN022

Instrument: IQ3 Container: X10CSATN02241L 

Quantity of Interest

Original Measurement Replicate #1 

Reported Absolute Relative Reported Absolute Relative Reported 

Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) N/A N/A 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 1.26E-03 2.95E-03 2.34E+00 1.26E-03 2.97E-03 2.36E+00 1.26E-03 239Pu Activity (Ci) 1.18E-03 1.99E-03 1.69E+00 1.19E-03 2.00E-03 1.68E+00 1.18E-03 240Pu Activity (Ci) 2.01E-03 3.39E-03 1.69E+00 2.02E-03 3.41E-03 1.69E+00 2.01E-03 242Pu Activity (Ci) 1.93E-06 3.26E-06 1.69E+00 1.95E-06 3.28E-06 1.68E+00 1.94E-06 241Am Activity (Ci) 2.13E-03 3.33E-04 1.56E-01 2.12E-03 3.32E-04 1.57E-01 2.12E-03 90Sr Activity (Ci) 1.78E-02 2.71E-03 1.52E-01 1.80E-02 2.75E-03 1.53E-01 1.81E-02 137Cs Activity (Ci) 1.03E-03 1.57E-04 1.52E-01 1.04E-03 1.59E-04 1.53E-01 1.05E-03 TRU Alpha Conc. (nCi/g) 6.49E+02 4.35E+02 6.70E-01 6.51E+02 4.38E+02 6.73E-01 6.49E+02 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported Absolute Relative Reported Absolute Relative Reported 

Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) N/A N/A 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 1.27E-03 2.98E-03 2.35E+00 1.27E-03 3.00E-03 2.36E+00 1.26E-03 239Pu Activity (Ci) 1.19E-03 2.00E-03 1.68E+00 1.20E-03 2.01E-03 1.68E+00 1.18E-03 240Pu Activity (Ci) 2.02E-03 3.41E-03 1.69E+00 2.04E-03 3.44E-03 1.69E+00 2.02E-03 242Pu Activity (Ci) 1.95E-06 3.28E-06 1.68E+00 1.96E-06 3.31E-06 1.69E+00 1.94E-06 241Am Activity (Ci) 2.14E-03 3.35E-04 1.57E-01 2.18E-03 3.41E-04 1.56E-01 2.15E-03 90Sr Activity (Ci) 1.83E-02 2.79E-03 1.53E-01 1.84E-02 2.82E-03 1.53E-01 1.83E-02 137Cs Activity (Ci) 1.06E-03 1.62E-04 1.53E-01 1.07E-03 1.63E-04 1.52E-01 1.06E-03 TRU Alpha Conc. (nCi/g) 6.53E+02 4.39E+02 6.72E-01 6.60E+02 4.42E+02 6.70E-01 6.52E+02 
F-2 

Quantity of Interest 

Original Measurement 

χ2 Pr(x <|χ2|)

Reported Absolute Sample Standard Standard 

Value Uncertainty Mean Deviation Deviation 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A234U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A238U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A238Pu Activity (Ci) 1.26E-03 2.95E-03 1.26E-03 5.48E-06 4.33E-03 1.38E-05 1.00E+00239Pu Activity (Ci) 1.18E-03 1.99E-03 1.19E-03 8.37E-06 7.04E-03 7.07E-05 1.00E+00240Pu Activity (Ci) 2.01E-03 3.39E-03 2.02E-03 1.10E-05 5.42E-03 4.18E-05 1.00E+00242Pu Activity (Ci) 1.93E-06 3.26E-06 1.95E-06 8.37E-09 4.29E-03 2.64E-05 1.00E+00241Am Activity (Ci) 2.13E-03 3.33E-04 2.14E-03 2.49E-05 1.16E-02 2.24E-02 1.00E+0090Sr Activity (Ci) 1.78E-02 2.71E-03 1.82E-02 1.64E-04 9.02E-03 1.47E-02 1.00E+00137Cs Activity (Ci) 1.03E-03 1.57E-04 1.06E-03 1.14E-05 1.08E-02 2.12E-02 1.00E+00TRU Alpha Conc. (nCi/g) 6.49E+02 4.35E+02 6.53E+02 4.18E+00 6.41E-03 3.70E-04 1.00E+00

Quantity of Interest 

t Pr(x <|t|) χ2 Test t Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable234U Activity (Ci) N/A N/A Not Applicable Not Applicable238U Activity (Ci) N/A N/A Not Applicable Not Applicable238Pu Activity (Ci) -6.67E-01 5.41E-01 Not Significant Not Significant239Pu Activity (Ci) -8.73E-01 4.32E-01 Not Significant Not Significant240Pu Activity (Ci) -1.00E+00 3.74E-01 Not Significant Not Significant242Pu Activity (Ci) -1.96E+00 1.21E-01 Not Significant Not Significant241Am Activity (Ci) -4.40E-01 6.83E-01 Not Significant Not Significant90Sr Activity (Ci) -2.33E+00 8.00E-02 Not Significant Not Significant137Cs Activity (Ci) -2.08E+00 1.06E-01 Not Significant Not SignificantTRU Alpha Conc. (nCi/g) -8.73E-01 4.32E-01 Not Significant Not Significant
F-3 

ATTACHMENT F.2: REPLICATE TESTING DATA FOR DRUM NO. NFS0419D 

Instrument: IQ3 Container: NFS0419D 

Quantity of Interest

Original Measurement Replicate #1 

Reported Absolute Relative Reported Absolute Relative Reported 

Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) 1.16E-03 1.95E-04 1.68E-01 1.03E-03 1.75E-04 1.70E-01 1.11E-03 234U Activity (Ci) N/A N/A 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 3.64E-04 8.55E-04 2.35E+00 5.83E-04 3.00E-04 5.15E-01 7.45E-04 239Pu Activity (Ci) 2.86E-03 6.71E-03 2.35E+00 4.59E-03 2.28E-03 4.97E-01 5.86E-03 240Pu Activity (Ci) 1.03E-03 2.41E-03 2.34E+00 1.64E-03 8.49E-04 5.18E-01 2.10E-03 242Pu Activity (Ci) 2.45E-07 5.75E-07 2.35E+00 3.93E-07 2.03E-07 5.18E-01 5.01E-07 241Am Activity (Ci) 1.97E-03 4.63E-03 2.35E+00 3.16E-03 1.63E-03 5.16E-01 4.04E-03 90Sr Activity (Ci) 3.46E-06 5.63E-07 1.63E-01 3.48E-06 5.67E-07 1.63E-01 3.47E-06 137Cs Activity (Ci) 3.46E-06 5.63E-07 1.63E-01 3.48E-06 5.67E-07 1.63E-01 3.47E-06 TRU Alpha Conc. (nCi/g) 2.98E+02 4.05E+02 1.36E+00 4.76E+02 1.39E+02 2.92E-01 6.07E+02 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported Absolute Relative Reported Absolute Relative Reported 

Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) 1.15E-03 1.94E-04 1.69E-01 1.10E-03 1.88E-04 1.71E-01 1.01E-03 234U Activity (Ci) N/A N/A 238U Activity (Ci) N/A N/A 238Pu Activity (Ci) 4.71E-04 1.16E-04 2.46E-01 6.69E-04 1.62E-04 2.42E-01 5.32E-04 239Pu Activity (Ci) 3.71E-03 7.61E-04 2.05E-01 5.26E-03 1.06E-03 2.02E-01 4.18E-03 240Pu Activity (Ci) 1.33E-03 3.31E-04 2.49E-01 1.89E-03 4.63E-04 2.45E-01 1.50E-03 242Pu Activity (Ci) 3.17E-07 7.89E-08 2.49E-01 4.50E-07 1.10E-07 2.44E-01 3.58E-07 241Am Activity (Ci) 2.56E-03 6.35E-04 2.48E-01 3.63E-03 8.87E-04 2.44E-01 2.88E-03 90Sr Activity (Ci) 3.46E-06 5.63E-07 1.63E-01 3.42E-06 5.58E-07 1.63E-01 3.53E-06 137Cs Activity (Ci) 3.46E-06 5.63E-07 1.63E-01 3.42E-06 5.58E-07 1.63E-01 3.53E-06 TRU Alpha Conc. (nCi/g) 3.85E+02 4.98E+01 1.29E-01 5.45E+02 6.93E+01 1.27E-01 4.34E+02 
F-4 

Quantity of Interest 

Original Measurement 

χ2 Pr(x <|χ2|)

Reported Absolute Sample Standard Standard 

Value Uncertainty Mean Deviation Deviation 

233U Activity (Ci) 1.16E-03 1.95E-04 1.08E-03 5.83E-05 5.40E-02 3.58E-01 9.86E-01234U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A238U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A238Pu Activity (Ci) 3.64E-04 8.55E-04 6.00E-04 1.09E-04 1.81E-01 6.48E-02 9.99E-01239Pu Activity (Ci) 2.86E-03 6.71E-03 4.72E-03 8.54E-04 1.81E-01 6.49E-02 9.99E-01240Pu Activity (Ci) 1.03E-03 2.41E-03 1.69E-03 3.07E-04 1.81E-01 6.48E-02 9.99E-01242Pu Activity (Ci) 2.45E-07 5.75E-07 4.04E-07 7.30E-08 1.81E-01 6.45E-02 9.99E-01241Am Activity (Ci) 1.97E-03 4.63E-03 3.25E-03 5.89E-04 1.81E-01 6.48E-02 9.99E-0190Sr Activity (Ci) 3.46E-06 5.63E-07 3.47E-06 3.96E-08 1.14E-02 1.98E-02 1.00E+00137Cs Activity (Ci) 3.46E-06 5.63E-07 3.47E-06 3.96E-08 1.14E-02 1.98E-02 1.00E+00TRU Alpha Conc. (nCi/g) 2.98E+02 4.05E+02 4.89E+02 8.81E+01 1.80E-01 1.89E-01 9.96E-01

Quantity of Interest 

t Pr(x <|t|) χ2 Test t Test

233U Activity (Ci) 1.25E+00 2.79E-01 Not Significant Not Significant234U Activity (Ci) N/A N/A Not Applicable Not Applicable238U Activity (Ci) N/A N/A Not Applicable Not Applicable238Pu Activity (Ci) -1.98E+00 1.19E-01 Not Significant Not Significant239Pu Activity (Ci) -1.99E+00 1.18E-01 Not Significant Not Significant240Pu Activity (Ci) -1.97E+00 1.20E-01 Not Significant Not Significant242Pu Activity (Ci) -1.99E+00 1.18E-01 Not Significant Not Significant241Am Activity (Ci) -1.99E+00 1.18E-01 Not Significant Not Significant90Sr Activity (Ci) -2.76E-01 7.96E-01 Not Significant Not Significant137Cs Activity (Ci) -2.76E-01 7.96E-01 Not Significant Not SignificantTRU Alpha Conc. (nCi/g) -1.98E+00 1.18E-01 Not Significant Not Significant
F-5 

ATTACHMENT F.3: REPLICATE TESTING DATA FOR DRUM NO. NFS0478A 

Instrument: IQ3 Container: NFS0478A 

Quantity of Interest

Original Measurement Replicate #1 

Reported Absolute Relative Reported Absolute Relative Reported 

Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) N/A N/A 238U Activity (Ci) 3.68E-06 5.62E-07 1.53E-01 3.17E-06 4.88E-07 1.54E-01 3.16E-06 238Pu Activity (Ci) 1.34E-02 2.17E-03 1.62E-01 1.03E-02 1.77E-03 1.72E-01 1.32E-02 239Pu Activity (Ci) 1.75E-01 2.56E-02 1.46E-01 1.79E-01 2.62E-02 1.46E-01 1.81E-01 240Pu Activity (Ci) 3.86E-02 5.73E-03 1.48E-01 3.92E-02 5.84E-03 1.49E-01 3.87E-02 242Pu Activity (Ci) 3.99E-06 7.08E-07 1.77E-01 4.06E-06 7.21E-07 1.78E-01 4.01E-06 241Am Activity (Ci) 7.14E-02 1.05E-02 1.47E-01 7.30E-02 1.07E-02 1.47E-01 7.35E-02 90Sr Activity (Ci) 2.96E-07 4.34E-08 1.47E-01 4.80E-07 7.01E-08 1.46E-01 4.77E-07 137Cs Activity (Ci) 2.96E-07 4.34E-08 1.47E-01 4.80E-07 7.01E-08 1.46E-01 4.77E-07 TRU Alpha Conc. (nCi/g) 4.38E+04 4.17E+03 9.52E-02 4.43E+04 4.26E+03 9.62E-02 4.50E+04 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported Absolute Relative Reported Absolute Relative Reported 

Value Uncertainty Uncertainty Value Uncertainty Uncertainty Value 

233U Activity (Ci) N/A N/A 234U Activity (Ci) N/A N/A 238U Activity (Ci) 4.13E-06 6.26E-07 1.52E-01 3.50E-06 5.36E-07 1.53E-01 3.66E-06 238Pu Activity (Ci) 1.30E-02 2.14E-03 1.65E-01 1.23E-02 2.05E-03 1.67E-01 1.32E-02 239Pu Activity (Ci) 1.88E-01 2.75E-02 1.46E-01 1.81E-01 2.65E-02 1.46E-01 1.80E-01 240Pu Activity (Ci) 3.92E-02 5.83E-03 1.49E-01 4.09E-02 6.08E-03 1.49E-01 3.88E-02 242Pu Activity (Ci) 4.10E-06 7.28E-07 1.78E-01 4.24E-06 7.52E-07 1.77E-01 4.03E-06 241Am Activity (Ci) 7.65E-02 1.12E-02 1.46E-01 7.50E-02 1.10E-02 1.47E-01 7.35E-02 90Sr Activity (Ci) 4.74E-07 6.92E-08 1.46E-01 4.06E-07 5.95E-08 1.47E-01 3.80E-07 137Cs Activity (Ci) 4.74E-07 6.92E-08 1.46E-01 4.06E-07 5.95E-08 1.47E-01 3.80E-07 TRU Alpha Conc. (nCi/g) 4.65E+04 4.46E+03 9.59E-02 4.55E+04 4.33E+03 9.52E-02 4.49E+04 
F-6 

Quantity of Interest 

Original Measurement 

χ2 Pr(x <|χ2|)

Reported Absolute Sample Standard Standard 

Value Uncertainty Mean Deviation Deviation 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A234U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N/A238U Activity (Ci) 3.68E-06 5.62E-07 3.52E-06 4.01E-07 1.14E-01 2.04E+00 7.28E-01238Pu Activity (Ci) 1.34E-02 2.17E-03 1.24E-02 1.23E-03 9.93E-02 1.29E+00 8.63E-01239Pu Activity (Ci) 1.75E-01 2.56E-02 1.82E-01 3.56E-03 1.96E-02 7.75E-02 9.99E-01240Pu Activity (Ci) 3.86E-02 5.73E-03 3.94E-02 8.91E-04 2.26E-02 9.67E-02 9.99E-01242Pu Activity (Ci) 3.99E-06 7.08E-07 4.09E-06 9.15E-08 2.24E-02 6.68E-02 9.99E-01241Am Activity (Ci) 7.14E-02 1.05E-02 7.43E-02 1.44E-03 1.94E-02 7.52E-02 9.99E-0190Sr Activity (Ci) 2.96E-07 4.34E-08 4.43E-07 4.70E-08 1.06E-01 4.69E+00 3.21E-01137Cs Activity (Ci) 2.96E-07 4.34E-08 4.43E-07 4.70E-08 1.06E-01 4.69E+00 3.21E-01TRU Alpha Conc. (nCi/g) 4.38E+04 4.17E+03 4.52E+04 8.23E+02 1.82E-02 1.56E-01 9.97E-01

Quantity of Interest 

t Pr(x <|t|) χ2 Test t Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable234U Activity (Ci) N/A N/A Not Applicable Not Applicable238U Activity (Ci) 3.55E-01 7.41E-01 Not Significant Not Significant238Pu Activity (Ci) 7.42E-01 4.99E-01 Not Significant Not Significant239Pu Activity (Ci) -1.74E+00 1.56E-01 Not Significant Not Significant240Pu Activity (Ci) -7.79E-01 4.79E-01 Not Significant Not Significant242Pu Activity (Ci) -9.78E-01 3.84E-01 Not Significant Not Significant241Am Activity (Ci) -1.84E+00 1.40E-01 Not Significant Not Significant90Sr Activity (Ci) -2.86E+00 4.57E-02 Not Significant Significant137Cs Activity (Ci) -2.86E+00 4.57E-02 Not Significant SignificantTRU Alpha Conc. (nCi/g) -1.60E+00 1.86E-01 Not Significant Not Significant
G-1 

ATTACHMENT G: DOSE-TO-CURIE CONTINUED COMPLIANCE INSPECTION 

CHECKLIST 

EPA Inspectors Present: Patrick Kelly 

Location of DTC: DTC occurs in the DTC Alcove in Building 7880 Process Building at the 

TWPC

Location of Waste Storage: CH Storage Area on site

CCP-TP-504 Revision: Revision 14, July 9, 2013

Operators and NTPC Training Renewal Due: 

Ronald Whitson DTC Operator/ITR due 12/2015 

David Crosby DTC Operator/ITR due 12/2014 

Chad Gerlock DTC Operator/ITR due 5/2014 

EPA reviewed the logbook pages and found that all operators listed in the logbook have 

current training in LOQI dated January 21, 2014. 

Scale No: WIPP 166

Scale Calibration Due Date: December 13, 2014

Instrument No: Thermo Scientific Model FH 40 G Unit

Instrument Calibration Due Date: January 8, 2014

Probe No.: Thermo Geiger Mueller (GM) FHZ Probe XC0761 (S/N 1098)

Probe Calibration/Due Date: October 10, 2014

Probe Ranges: low range: 10 μR/hr–800 mR/h; high range: 800 mR/hr–1,000 R/hr

DSC Source No: Both high and low range 137Cs source INL-ID: CP-TCS001 (Manufacturer 

Serial # 181-64)

Source Activity: 744.9 Ci

Reference Date: May 1, 2010 

Operator Aide(s) Used: OA-ORNL-0131-13, December 23, 2013 

Operator aid was posted in the DTC Control Area, EPA received a copy. 

BDR No: Not yet assigned number. CCP will provide BDR to EPA when it is finalized.

Packaging Configuration: 55-gallon drum 

Container No: ORRH00685

Waste Stream: OR-REDC-RH-HET 

Container Gross Wt: 67.0 kg

Gamma BKG: 0.065 mR/h

Dose Rate @ 0o

: 8.53 mR/h

Dose Rate @ 90o: 8.33 mR/h
G-2 

Dose Rate @ 180o: 7.34 mR/h

Dose Rate @ 270o: 8 mR/h

Highest measured Gamma Dose Rate >3 x BKG: Yes

Gamma Dose Rate Average: 8 mR/h

Estimated Contact Dose Rate: >200 mR/h gamma plus neutron 
H-1 

ATTACHMENT H: NDE CONTINUED COMPLIANCE INSPECTION CHECKLIST: CH 

EPA Inspection No.: ORNL-CC-2014 Inspection Da

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objective 

RTR-1: Site procedures identify required training and qualifications for RTR personnel CCP-TP-028, Revision 8 CCP-QP-002, Revision 35 

RTR operators receive training on the waste matrix parameters and typical packaging configurations expected in each waste stream. To become qualified, the RTR operator must pass a comprehensive written test based on training objectives with a minimum score of 80% Unsatisfactory performance – failed to identify prohibited item during OJT of score of less than 80% on exam Demonstrate capability (At initial qualification, requalification, and semiannually, successfully examine a training container). 

At initial qualification, and subsequent re-qualification, successfully examine a test drum. 

RHVE operators re-qualified every 2 years based on continued satisfactory performance 

Inventory sheets for RTR cNDE-TEST-20, NDE-TESTNDE-TRAINING-26, NDETRAINING-32 Training Container EvaluatRTR operators Qualification Cards for seleTraining roster for CCP-AKand 8 LOQI RTR operators dated Revisions 1 and 2 of ProhiboperatorsAmerican Society for NondRecommended Practices, NEdition

RTR-2: Site procedure(s) provide complete instructions for operators to perform the RTR examination and completion of the associated documentation CCP-TP-053, Revision 14 

RTR operator adequately explained the process followed for examining a drum and entering data into data forms (whether hard copy or electronic data entry is used). 

CH RTR BDR Nos. OR-RTOR-RTR7-0007 and OR-RAudio/visual recordings for 

the above CH BDRs Radiography Data Sheet foX10CSATN02022J Training roster for CCP-AKand 8 CCP-TP-053, CCP CH StanRadiography Inspection Pro09/25/2013 
H-2 

EPA Inspection No.: ORNL-CC-2014 Inspection Da

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objective 

RTR-3: The RTR procedure(s) require an image quality check to be performed CCP-TP-053, Revision 14, section 4.3, Attachment 1 

Operator adequately explained how the acceptability of an image is determined Image quality check is performed once per day (RTR Measurement Control Report) Performance of the image quality check is documented and recorded

CH RTR BDR Nos. OR-RTOR-RTR7-0007 and OR-RAudio/visual recordings for the above CH BDRs CCP-TP-053, CCP CH StanRadiography Inspection Pro09/25/2013 

RTR-4: The procedure allows the operator to adjust the RTR to accommodate the physical properties of the waste and waste containers likely to be encountered at the site CCP-TP-053, Revision 14 

Operator could identify applicable policies and procedures governing the operation of RTR equipment The RTR system could be adjusted High-density material was examined with the Xray device set on the maximum voltage and low density material at a lower voltage Operator adequately explained what is done if an image is unacceptable (e.g., the waste is solidified or the container is lead-lined) 

CH RTR BDR Nos. OR-RTOR-RTR7-0007 and OR-RAudio/visual recordings for 

the above CH BDRs Radiography Data Sheet foX10CSATN02022J Qualification Cards and trademonstration RTR operatoTraining Container EvaluatRTR operators Training roster for CCP-AKand 8 CCP-TP-053, CCP CH StanRadiography Inspection Pro09/25/2013 

RTR-5: Data records are of sufficiently high quality for complete review CCP-TP-053, Revision 14 

RTR tape is high quality, the sound track is audible, and the required information is contained on the audible portion of the tape The RTR tape is consistent with the data package for the same drum 

CH RTR BDR Nos. OR-RTOR-RTR7-0007 and OR-RAudio/visual recordings for 

the above CH BDRs CCP-TP-053, CCP CH StanRadiography Inspection Pro09/25/2013 
H-3 

EPA Inspection No.: ORNL-CC-2014 Inspection Da

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objective 

RTR-6: There is a procedure for determining whether the waste matches the waste stream description and Waste Matrix Code, and for determining Waste Material Parameters and weights CCP-TP-053, Revision 14, Tables 2 & 3, Attachment 2 

The procedure is adequately implemented Operators verify that the waste matches the waste stream description Waste Matrix Code is verified. If not, corrective action is taken WMP weights are estimated by compiling an inventory of waste items and residual/packaging materials Does the RTR operator use a standard weight lookup table to provide an estimate of WMP weights? If so, has the table been updated to reflect additional information gained through previous RTR/VE exams or updated AK information? 

CH RTR BDR Nos. OR-RTOR-RTR7-0007 and OR-RAudio/visual recordings for 

the above CH BDRs CCP-TP-053, CCP CH StanRadiography Inspection Pro09/25/2013 

RTR-7: The RTR procedure provides instructions for identifying prohibited items and for processingdrums containing prohibited items CCP-TP-053, Revision 14, Table 1 

Operator could name prohibited items Operator adequately explained how the presence of prohibited liquids is determined Operator’s explanation of required actions if prohibited items were encountered was consistent with procedure 

CH RTR BDR Nos. OR-RTOR-RTR7-0007 and OR-RAudio/visual recordings for 

the above CH BDRs Prohibited Item training modated 8/23/2010 and 3/29/2

RTR-8: RTR procedures include the required QC examinations, evaluation accuracy and reproducibility of the RTR process CCP-TP-053, Revision 14, sections 4.5 & 4.6 

An independent replicate scan is performed on one waste container per day or on one container per testing batch (whichever is less frequent) An independent observation of one scan (not the replicate) is performed, by a qualified RTR operator (anyone but the initial RTR operator) 

CH RTR BDR Nos. OR-RTOR-RTR7-0007 and OR-RAudio/visual recordings for 

the above CH BDRs CCP-TP-053, CCP CH StanRadiography Inspection Pro09/25/201 CCP-TP-053, CCP CH StanRadiography Inspection Pro09/25/2013 
H-4 

EPA Inspection No.: ORNL-CC-2014 Inspection Da

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objective 

RTR-9: Procedure(s) contain standardized forms for recording RTR data CCP-TP-053, Revision 14, Attachment 2 

RTR operator adequately explained the process followed for examining a drum and entering data into data forms (whether hard copy or electronic data entry is used). Direct data entry into an electronic form is done by 

the RTR operator using a computer while the operator is still in the RTR booth. The electronic data file undergoes the same QC checks used for hand-written data entries 

CH RTR BDR Nos. OR-RTOR-RTR7-0007 and OR-RAudio/visual recordings for the above CH BDRs Radiography Data Sheet foX10CSATN02022J CCP-TP-053, CCP CH StanRadiography Inspection Pro09/25/2013 

RTR-10: Site procedures require review of BDRs at the data generation and project level CCP-TP-053, Revision 14, section 4.10 CCP-TP-001, Revision 21, Attachment 2 

Data generation level reviews are performed and documented (ITR) Project level reviews are performed and documented (SPM) 

CH RTR BDR Nos. OR-RTOR-RTR7-0007, and OR-R
I-1 

ATTACHMENT H: NDE CONTINUED COMPLIANCE INSPECTION CHECKLIST: R

EPA Inspection No.: ORNL-CC-2014 Inspection Dat

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objective 

RHVE-1: Site procedures identify required training and qualifications for RHVE personnel CCP-QP-002, Revision 35

Formal training elements include: project requirements, container identification and labeling, applicable state and federal regulations 

Site-specific training program: OJT, identification of summary category groups, WMPs, packaging configurations, residual liquids. 

Qualification cards for selectQualification Card for ORNL VEE appointment letter, dateCCP-AK-ORNL-001, Revisisheet CCP-PO-001, CCP TransuraQuality Assurance Project PlCCP-QP-002, CCP Training Revision 35, 6/06/2013 

RHVE-2: Operator qualification and re-qualificationrequirements are described CCP-QP-002, Revision 35, s. 4.3.6 

To become qualified, the RHVE operator must pass a comprehensive written test with an 80 percent or better grade that addresses VE operations, documentation, characterization, formal training elements, and procedural elements. VE Operators must demonstrate capability in the presence of the site VEE during OJT. However, the formal training and OJT is conducted by a qualified

SME. 

Qualification cards for selectQualification Card for ORNL VEE appointment letter, dateCCP-AK-ORNL-001, Revisisheet CCP-PO-001, CCP TransuraQuality Assurance Project PlCCP-QP-002, CCP Training Revision 35, 6/06/2013 

RHVE-3: Each site has a designated VEE CCP-QP-002, Revision 35, s. 4.4. CCP-PO-001, QAPP, Revision 21 

VEE designation is documented VEE has knowledge of the RH TRU waste being characterized Responsible for overall direction and implementation of VE at the facility Certification Plan specifies the selection, qualification, and training requirements of VEE 

Qualification Card for ORNL VEE appointment letter, dateCCP-AK-ORNL-001, Revisi

sheet CCP-PO-001, CCP TransuraQuality Assurance Project PlCCP-QP-002, CCP Training Revision 35, 06/06/2013 
I-2 

EPA Inspection No.: ORNL-CC-2014 Inspection Dat

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objective 

RHVE-4: Procedures and technical guidance documents provide complete instructions for performing RHVE CCP-TP-500, Revision 13, s. 4.1-4.2, Attachment 1

100% of containers will be subject to VE at the time of packaging Waste Stream Description and WMC verified Presence/absence of prohibited items confirmed Two operators used even if audio/visual recording of VE is generated 

Qualification cards for selectQualification Card for ORNL VEE appointment letter, dateCCP-AK-ORNL-001, Revisisheet RH VE BDR Nos. ORNLRHORNLRHVE13002, ORNLRORNLRHVE13004, ORNLRORNLRHVE13006 CCP-PO-001, CCP TransuraQuality Project Assurance PlCCP-QP-002, CCP Training Revision 35, 06/06/2013 CCP-TP-500, CCP Remote-HExamination, Revision 13, 0

RHVE-5: Corrective actions are taken when necessary CCP-TP-500, Revision 13, s. 2.4.2 

Operators were able to describe how they initiate acorrective action 

Qualification cards for selectQualification Card for ORNL CCP-QP-005, CCP TRU Noand Control, Revision 23, 06RH VE BDR Nos. ORNLRHORNLRHVE13002, ORNLRORNLRHVE13004, ORNLRORNLRHVE13006 CCP-TP-500, CCP Remote-HExamination, Revision 13, 0

RHVE-6: Site procedure(s) require data generation and project level reviews of BDRs CCP-TP-500, Revision 13 

ITR review Attachment 2 SPM review Attachment 3 

RH VE BDR Nos. ORNLRHORNLRHVE13002, ORNLRORNLRHVE13004, ORNLRORNLRHVE13006 
I-3 

EPA Inspection No.: ORNL-CC-2014 Inspection Dat

Establishment of Required Technical Elements in 

Procedures Execution of Procedures Objective 

RHVE-7: Records are available for review CCP-TP-500, Revision 13, s. 5.0 

Lifetime/QA records – Attachments 1-5, Copy of NCRs QA/nonpermanent records – VHS tape or DVD (primary and backup) 

Qualification cards for selectQualification Card for ORNL VEE appointment letter, dateCCP-AK-ORNL-001, Revisi

sheet RH VE BDR Nos. ORNLRHORNLRHVE13002, ORNLRORNLRHVE13004, ORNLRORNLRHVE13006 CCP-PO-001, CCP TransuraQuality Project Assurance 05/31/2013 CCP-QP-002, CCP Training Revision 35, 06/06/2013 CCP-AK-ORNL-001, Revisisheet CCP-PO-001, CCP TransuraQuality Assurance Project PlCCP-TP-500, CCP Remote-HExamination, Revision 13, 0
J-1 

ATTACHMENT J: EPA INSPECTION ISSUE TRACKING FORM, 

ISSUE NO. ORNL-CCP-CC-RTR-2014-01C, FINAL 

Inspection No.: ORNL-CC-2014 Issue Number: ORNL-CCP-CC-RTR-01C 

Date: February 6, 2014 

Inspector: D. Gill 

Attachments? YES NO 

Sample Size: 2 Test container inventories 

Population size (if known): Unknown 

Description of Issue: Procedure CCP-TP-028, CCP Radiographic Test Drum and Training Container 

Construction, Attachment 1, item No. 11, requires that a "Leaded glove or leaded apron" be added to the 

container. However, this attachment is meant to provide an exact inventory for the container and should be 

specific for the items added. CCP should consider changing how this information is recorded on the 

inventory so that no uncertainty is attached to its contents. 

B. Regulatory Reference: 40 CFR 194.24(c) 

C. Site requirement(s): Not applicable 

D. Discussed with: Tom Morgan, Marcus Pinzel, Mike Sensibaugh 

E. Additional Comments: None

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: Not applicable 
K-1 

ATTACHMENT K: EPA INSPECTION ISSUE TRACKING FORM, 

ISSUE NO. ORNL-CCP-CC-RTR-2014-02CR, FINAL

Inspection No.: ORNL-CC-2014 Issue Number: ORNL-CCP-CC-RTR-02CR 

Date: Revised Feb 11, 2014 Final 

Inspector: D. Gill 

Attachments? YES NO 

Sample Size: Training container evaluations for 2 operators 

Population size (if known): Unknown 

Description of Issue: EPA is concerned that the processes used to evaluate an RTR operator's continued 

job performance do not demonstrate the sucessful examination of unknown containers. This concern is 

based on the following: 

(1) Operators are not required to generate a written record when examining a Training Container as they 

would for a routine waste container or a Test container. This is an historical practice without any regulatory 

basis. 

(2) A Lead Operator observes the operator's performance during the Training Container evaluation but does 

not possess an inventory for the Training Container and cannot assess whether items are missed. 

(3) The operator is considered successful in the test if he/she identifies all Summary Category Groups and 

all prohibited items. There is no requirement for the operator to identify all waste items as they would for a 

routine waste container. 

(4) The NDE Cognizant Engineer (CE) also evaluates the performance but there are no records generated 

regarding if missed items are brought to the attention of the operator by CE to provide objective evidence of 

continued training in this circumstance. 

Starting in 2005, EPA has identified issues related to NDE training several times. EPA has listed the 

concern numbers correlated to each instance of an NDE-related concern below: 

SRS-CCP-RTR-05-003CR 

HAN-RTR-07-006CR (not a CCP issue) 

ORNL-CCP-CH-RTR-07-004C 

INL-CCP-CH-VE-T1-004CR 

INL-CCP-CH-VE-T1-005CR 

ORNL-CCP-CH-RTR-09-001CR 

INL-CCP-RH-T1-Lot 2-RTR-01C 

INL-CCP-CC-2013-01C 

INL-CCP-CC-2013-02CR 

ORNL-CCP-CC-RTR-01C (this inspection) 

EPA requests that CBFO review these concerns with a view to developing an integrated, complete, and 

long-term response that would assess the on-going adequacy of NDE training within the WIPP program. 

B. Regulatory Reference: 40 CFR 194.24(c) 

C. Site requirement(s): Not applicable 

D. Discussed with: Tom Morgan, Marcus Pinzel, Mike Sensibaugh 

E. Additional Comments: None

F. Site Response Information: 

 Site Response Required? YES NO 

 Site Response Due Date: 2-20-14