# 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 PROG RAM

WASTE CHARACTERIZATION PROGRAM

AT THE OAK RIDGE NATIONAL LABORATORY

AND MODIFICATION OF THE MOBILE CHARACTERIZATION SER VICES

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

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# TABLE OF CONTENTS

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

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

2.0 Resuming Transuranic Waste Characterization Activit ies 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 Servi ces 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 Rad iography ........... 28

8.4.2 Technical Evaluation: Remote-Handled Visual Examina tion .................. 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 Wa ste Characterization Processes Implemented by ORNL-CCP ...........................

................................................... ............................ 4 Table 2. Tiering of Remote-Handled Transuranic Was te Characterization Processes Implemented by ORNL-CCP ...........................

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

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# ATTACHMENTS

Attachment A.1 Approval Summary for ORNL-CCP Contac t-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 In spection

Attachment C Inspection Personnel

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

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

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

Attachment E NDA Continued Compliance Inspection Ch ecklist: 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 Ins pection Checklist

Attachment H NDE Continued Compliance Inspection Ch ecklist: CH RTR

Attachment I NDE Continued Compliance Inspection Ch ecklist: RH VE

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

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

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# 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

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# 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/cm 3 

# 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 Cent er

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

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# Sr strontium

SRS Savannah River Site

T1 Tier 1

T2 Tier 2

TMU total measurement uncertainty

TRAMPAC Trupact Authorized Methods for Payload Cont rol

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

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# 1.0 EXECUTIVE SUMMARY

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

determination that the Central Characterization Pro gram’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 adequ ate 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 supp orts EPA’s approval of a Tier 1 (T1) change

for modifications to the Mobile Characterization Se rvices (MCS) IQ3 nondestructive assay (NDA) system.

In 2008, ORNL-CCP began operating waste characteriz ation programs for contact-handled (CH) and remote-handled (RH) TRU wastes at ORNL in Oak R idge, Tennessee. DOE suspended

waste characterization activities at ORNL in June 2 011. In November 2013, the Carlsbad Field Office (CBFO) informed EPA that ORNL-CCP resumed wa ste 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 documente d resumption process EPA concluded that a new baseline inspection and approval would n ot be necessary. Instead, EPA would conduct a continued compliance inspection in accordance wit h 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 re quirements.

On January 7, 2014, CBFO also requested two T1 chan ges to the ORNL-CCP CH TRU waste characterization program. CBFO requested: (1) EPA a pproval of a T1 change to approve modifications made to the MCS IQ3 NDA system 2 

# 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 s cope of the MCS IQ3 T1 evaluation overlapped significantly with the scope of the cont inued 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).

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# Based on the results of this T1 evaluation and cont inued compliance inspection, EPA approves ORNL-CCP’s modifications to the MCS IQ3, and confir ms that the ORNL-CCP CH and RH TRU waste characterization programs in the configur ation observed during this inspection are

consistent with the limitations described in the ba seline 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 an d A.2 summarize all of EPA’s approvals

of the ORNL-CCP CH and RH TRU waste characterizatio n programs. Henceforth, EPA will use results of this joint T1 evaluation and continued c ompliance inspection to support the streamlined T1 evaluation and decision process disc ussed in section 3.0 of this report.

Based on this inspection and T1 evaluation, EPA mad e several changes to the CH and RH tiering designations, as shown in Tables 1 and 2. Any use o f VE to characterize CH waste is a new T1 change. During the 2008 baseline inspection, EPA ap proved 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 C H VE process during the continued compliance inspection, the CH VE process must be ap proved 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 an d RH waste characterization programs at ORNL. These changes to the T2 requirements are nece ssary to make the ORNL-CCP tiering designations consistent with the requirements at ot her 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 Expe rts (AKEs) and Site Project Mangers (SPMs) who performed work in these roles fo r the ORNL-CCP waste characterization program during the previous quarte r. 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 per sonnel who performed work during the previous quarter is a new NDA T2 change (see Ta ble 1). Specifically, the list must include all operators, Expert Analysts (EAs) and In dependent Technical Reviewers (ITRs).

3. DOE needs to submit to EPA of a list of all DTC per sonnel who performed work during the previous quarter is a new radiological characte rization 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 (RT R 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 includ e all VE and RTR operators, ITRs and Visual Examination Experts (VEEs).

5. DOE needs to notify EPA upon completion of or subst antive modification to CCP-TP005, Attachments 4, 6, 7 and 8 and/or associated me moranda, including “Add Container” memoranda is a modified CH AK T2 change that clarif ies and combines existing requirements (see Table 1).

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# 6. DOE needs to notify EPA upon completion of or revis ions to all discrepancy resolution (DR) reports. This is a modified RH AK T2 change (s ee Table 2).

EPA also revised the tiering tables to remove dupli cate entries and ensure completeness and consistency with recent EPA continued compliance an d T1 approval reports. Tables 1 and 2 show the substantive T1 and T2 changes for CH and R H in bold text. T1 and T2 changes that were initiated during the CH and RH baseline and su bsequent T1 approvals remain in effect. The language in Tables 1 and 2 regarding AK documentati on applies to all ORNL-CCP waste

streams.

EPA did not identify any findings during this conti nued compliance inspection. EPA identified two concerns related to RTR: Concern No. 1, which i dentified areas of weakness in the RTR test and traning container process, did not require a re sponse while Concern No. 2, which identified practices regarding the evaluation of the results o f 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 throu gh the EPA website and by sending emails to the WIPPNEWS list, in accordance with 40 CFR 194.8( b)(3).4Table 1. Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented by ORNL-CCP(Based on November 13–15, 2007, Baseline Inspectionand Subsequent Tier 1 Evaluations, Updated May 2014)Process ElementsORNL-CCP CH Waste Characterization Process – T1 ChangesORNL-CCP CH Waste Characterization Process – T2 Changes*Acceptable Knowledge,including LoadManagementAny new waste category other than retrievably stored debris andsoils/gravel (i.e., solids or any type of newly generated waste)Load managementSubmission of a list of active ORNL-CCP CH AKEs andSPMsNotification to EPA upon completion of or substantive modification** to:•AK accuracy reports (annually, at a minimum)•AK-AK and AK-NDA/NDE Discrepancy Resolution Reports•WSPFs and related attachments (e.g., CIS) for all new or modified wastestreams, including change notices•AKSRs (new and updated versions)•CCP-TP-005, Attachments 4, 6, 7 and 8 and/or associatedmemoranda, including“Add Container” memoranda•Site AK procedures requiring CBFO approvalNondestructive Assay New equipment or substantive physical modifications** to approvedequipmentExtension of or changes to approved calibration range for approvedequipmentSubmission of a list of ORNL-CCP NDA operators, EAsand ITRs thatperformed work during the previous quarterNotification to EPA upon substantive modification**to:•Software for approved equipment•Operating ranges upon CBFO approval•Site NDA procedures requiring CBFO approvalReal-Time Radiography NoneSubmission of a list of ORNL-CCP RTR operators andITRs thatperformed work during the previous quarterNotification to EPA upon:•New equipment or substantive physical modifications** to approvedequipment•Substantive modification** to site RTR procedures requiring CBFOapprovalVisual Examination andVisual ExaminationTechniqueAny use of visual examination Submission of a listof ORNL-CCP VE operators, VE Experts and ITRsthat performed work during the previous quarterWIPP Waste Data System Load managementNotification to EPA upon substantive modification**to site WDSprocedures requiring CBFO approvalNew T1s, T2s and significant modifications to existing T1s or T2s are inboldtext; T1s or T2s that were only revised for styleare not shown in bold.* ORNL-CCP will report all T2 changes to EPA everythree months.** “Substantive modification” refers to a change with the potential to affect ORNL-CCP’s CH waste characterization processes or documentation of them, excluding changesthat are solely related to the environment, safetyand health; nuclear safety; or the Resource Conservation and Recovery Act, or that are editorial in nature or are required toaddress administrative concerns. EPA may request copies of new references that DOE adds during a document revision.5Table 2. Tiering of Remote-Handled Transuranic Waste Characterization Processes Implemented by ORNL-CCP(Based on June 30–July 2, 2008, Baseline Inspectionand Subsequent Tier 1 Evaluations, Updated May 2014)Process ElementsORNL-CCP RH Waste Characterization Process – T1 ChangesORNL-CCP RH Waste Characterization Process – T2 Changes*Acceptable Knowledge Any new waste streams not approved under the baselineModification of the approved population of the OR-REDC-RH-HETwastes to include any containers not included in the CCP-AKORNL-501, Revision 3 analysisSubstantive modification** to the AKSR (e.g., CCP-AK-ORNL500), certification test plan (e.g., CCP-AK-ORNL-502), correlationand surrogate summary form, AK accuracy report andwaste streamprofile formImplementation of load managementSubmission of a list of active ORNL-CCP RH AKEs andSPMsNotification to EPA upon availability of or nonsubstantive modification** to:•AKSRs and certification test plans (e.g., CCP-AK-ORNL-500, CCP-AKORNL-502)•Correlation and surrogate summary form•AK accuracy reports (annually, at a minimum)•The waste stream data package for waste streams andany modifications tothe WSPF, including the CRR and CISNotification to EPA upon availability of or substantive modification** to:•CCP-AK-ORNL-002•Add container memoranda•Documentation of RH sample reclassified as CH and subject toconfirmatory analyses via NDA•DRs or data limitation information•Site AK procedures requiring CBFO approvalRadiologicalCharacterization, includingDose-to-CurieApplication of new scaling factors for isotopic determination otherthan those documented in CCP-AK-ORNL-501, Revision3Use of any alternate radiological characterizationprocedure otherthan DTC, with established scaling factors as documented in CCPTP-504Any new waste stream not approved under the baseline or additionof containers to Waste Stream OR-REDC-RH-HET that requireschanging the established radionuclide scaling factors in CCP-AKORNL-501, Revision 3Substantive modification** of EPA-approved procedures orradiological characterization technical reports (e.g., CCP-TP-504,CCP-AK-ORNL-501)Submission of a list of ORNL-CCP DTC operators, EAsand ITRs thatperformed work during the previous quarterNotification to EPA upon:•Nonsubstantive modification** to procedures or radiological technicalreports (e.g., CCP-TP-504, CCP-AK-ORNL-501) requiring CBFO approval•Results from any RH TRU containers that qualify asCH and are subject toNDAVisual Examination Implementation of VE by any system other than two operatorsperforming VE (i.e., viewing a previously recordedVE event)Submission of a list of ORNL-CCP VE operators, VE Experts and ITRsthat performed work during the previous quarterNotification to EPA upon:•Substantive modification** to site VE procedures requiring CBFO approval•Characterization of SCG S3000 or S4000 RH waste byan approved process6Process ElementsORNL-CCP RH Waste Characterization Process – T1 ChangesORNL-CCP RH Waste Characterization Process – T2 Changes*Real-time Radiography Any use of real-time radiographyWIPP Waste Data System NoneNotification to EPA upon substantive modification**to:•Site WDS procedures requiring CBFO approval•The Excel spreadsheet titled WWIS Data Entry Summary Characterizationand CertificationNew T1s, T2s and significant modifications to existing T1s or T2s are inboldtext; T1s or T2s that were only revised for styleare not shown in bold.* 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 documentation of them, excluding changes thatare solely related to the environment, safety and health; nuclear safety; or the Resource Conservationand Recovery Act; or that are editorial in natureor are required to addressadministrative concerns. EPA may request copies ofnew references that DOE adds during a document revision.

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# 2.0 RESUMING TRANSURANIC WASTE CHARACTERIZATION ACTIVIT IES 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 sta ff continued to perform annual audits of ORNL-CCP to evaluate and recertify that the TRU was te 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, h ealth and safety requirements.

ORNL-CCP resumed TRU waste characterization activit ies 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 inspectio n 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 resume d TRU waste characterization activities using previously EPA-approved processes. ORNL-CCP:

• Implemented the latest revisions of CCP’s waste cha racterization procedures. While the ORNL-CCP TRU program was suspended, CCP continued t o update and revise waste characterization procedures to support waste charac terization programs at other TRU

sites. EPA evaluated and concurred with the revised procedures as part of the continued compliance inspections conducted at other active TR U sites.

• Resumed active use of the same ORNL-based AK, radio logical and physical characterization systems that EPA evaluated and app roved 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 con duct 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 basel ine 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 wa ste 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 ex plain and support ORNL-CCP’s waste characterization program resumption:

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

• CCP-TWPC Return Narrative

• CCP-PO-027, CCP/TRU Waste Processing Center/Oak Rid ge 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 dispo sal 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 OR NL-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 th e 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 4 2571–42583, 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 a pplicable 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 auth ority to conduct continued compliance inspections to verify that the site (1) continues t o 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 an d approve changes, if necessary, to the site’s approved waste characterization program by conducti ng additional inspections under the authority of 40 CFR 194.24(h).

In November 2012, DOE, DOE contractor staff, EPA an d EPA contractor staff discussed DOE’s TRU site cleanup goals through 2016 and ways to imp rove EPA’s evaluation and decision process to support DOE sites’ state-mandated cleanu p needs. As a result of this discussion, EPA finalized a streamlined evaluation and decision pro cess 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 elemen ts of waste characterization processes that are not expected to vary significantly on a waste s tream or T1 change basis. Examples of the common characterization elements are personnel trai ning, procedures and equipment capabilities. Each site is also required to provide changes to waste characterization elements in conjunction with the quarterly T2 change reports fo r EPA review. The quarterly review of the common elements will be independent of EPA’s approv als of T1 change requests and will ensure

that the waste characterization elements of each ac tive 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 b e the basis for EPA’s evaluation of any ORNL-CCP T1 change requests submitted before the ne xt EPA continued compliance inspection. Thus, EPA will focus on only those wast e characterization components that are critical to the specific T1 change request, evaluat ion and approval (e.g., waste-stream-specific AK records). In addition, EPA may not revisit the e lements discussed in this report until the next continued compliance inspection, at the Agency’s di scretion.

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# 4.0 PURPOSE OF TIER 1 EVALUATIONS

Certain changes to the waste characterization activ ities 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 th e July 16, 2004, Federal Register notice (Vol. 69, No. 136, pages 42571–42583), EPA must per form a single baseline inspection of a TRU waste generator site’s waste characterization p rogram. The purpose of EPA’s baseline inspection is to approve the site’s waste character ization program, based on the demonstration that the program’s components, with applicable cond itions and limitations, can adequately characterize TRU wastes and comply with the regulat ory requirements imposed on TRU wastes destined for disposal at the WIPP.

Following EPA’s baseline approval, EPA is authorize d to evaluate and approve changes, if necessary, to the site’s approved waste characteriz ation 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 req uiring post-implementation notification (T2) are identified in the site-specific baseline inspec tion reports. When evaluating proposed T1 changes for approval, EPA may conduct a site inspec tion 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 characteriz e 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 implem ented 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 wa stes, 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 was te characterization systems evaluated during this continued compliance inspecti on and T1 evaluation.

• Identifies all areas where waste characterization s ystems have changed relative to what was approved during the baseline inspection and oth er subsequent EPA T1 evaluations and assesses the impact, if any, of those changes.

• Provides objective evidence to support the basis fo r EPA’s continued approval of all waste characterization systems.

• Provides objective evidence to support the basis fo r EPA’s decision to approve the modifications to the MCS IQ3 NDA system.

• Describes any tests or demonstrations completed dur ing the course of the inspection and T1 evaluation and their relevance to EPA’s approval decision.

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# The DOE documents that EPA reviewed for this inspec tion 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 i ncluded the evaluation of selected elements of the waste characterization systems in use at ORN L-CCP to characterize CH and RH TRU wastes that were approved during the baseline inspe ctions 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 sys tem 5 

# for CH waste characterization and the DTC system for RH waste ch aracterization; RTR operations for multiple CH SCGs; and VE operations for RH debris waste char acterization.

7.0 INSPECTION PERSONNEL

EPA and its support personnel conducted interviews with ORNL-CCP waste characterization personnel in several disciplines. The personnel con tacted 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 cha racterization 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 su bmissions, 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) w aste and SCG S4000 (soils). EPA selected one waste stream from each approved SCG (O R-ISTP-CH-HET and OR-NFS-CHSOIL) to review as representative samples of the OR NL-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 over laps significantly with the scope of the NDA continued compliance inspection. EPA decided to con duct the T1 evaluation and continued compliance ins pection concurrently and perform the inspection/T1 evaluati on as an expanded NDA continued compliance inspecti on.

# 11



# ORNL-CCP’s RH AK characterization program is EPA-ap proved 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 che cklist used for this inspection is

included as Attachment D.3.

8.1.1 Technical Evaluation: Contact-Handled Waste

(1) EPA examined select Central Characterization Progra m procedures and found them to be adequate.

EPA reviewed several CCP procedures for AK document ation, training of AKEs and disposition of nonconformances for technical sufficiency and sc ope. Specifically, EPA reviewed:

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

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

2013.

• CCP-TP-002, Revision 26, “Reconciliation of DQOs an d 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 2 6 of the AK procedure (CCP-TP-005) directly impact the comparison of NDA measurement r esults to AK-expected radionuclide values and indirectly impact the AK accuracy evalua tion process. Revision 26 no longer requires CCP personnel to compare drum-specific isotopic rat ios against the range of isotopic values expected in the AK. CCP personnel explained that th is change was done for two reasons: (1) the isotopic ratio comparison made sense for streams co mposed of very specific radiological compositions like those from Rocky Flats, but is no t useful for waste streams with a more varied composition like those originating from the ORNL Is otope 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 compl eteness, 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 document s require the comparison against expected ranges of values and that this change brings the ra dionuclide comparison process in line with the waste material parameter comparison process.

Revision 26 requires CCP personnel to perform a was te stream or waste stream lot comparison of the two most prevalent radionuclides and expecte d radionuclides identified by AK against NDA results, but the AK procedure no longer explici tly requires that any comparisons be made on a drum-by-drum basis. CCP personnel explained th at AK predicts the two most prevalent radionuclides on a waste stream basis; therefore, t he comparison should also be conducted at the waste stream or lot level. CCP personnel also expla ined that while the AK procedure does not require a drum-by-drum comparison to AK for the exp ected 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 compari son of radionuclides present with the list of AK-expected radionuclides will still take place.

Implementation of CCP-TP-005, Revision 26, AK-NDA c omparison requirements will be apparent in the certification checklists and any co rresponding AK re-evaluations. These changes will likely reduce the number and frequency of AK r e-evaluations, which may result in artificial AK accuracy determinations of 100%. ORNL-CCP has no t yet completed any certification

checklists for either Waste Stream OR-ISTP-CH-HET o r Waste Stream OR-NFS-CH-SOIL. EPA will review certification checklists during a f uture inspection to evaluate the implemented impact of the CCP-TP-005 revisions.

EPA found that all four procedures listed above ade quately reflect the requirements of 40 CFR 194. Procedure implementation is evidenced b y adequate preparation and maintenance of the required documentation, as reviewed below. N otification to EPA upon completion of or substantive modification to site AK procedures requ iring CBFO approval remains a T2 change (see Table 1).

(2) EPA verified that the acceptable knowledge characte rization process for containers, including acceptable knowledge assembly, compilatio n 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 al l applicable CCP-TP-005 attachments using the correct revision of each form. EPA establ ished the correct revision by comparing the procedure’s effective date to the date the AKE sign ed 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 ac cess to the current revision of all controlled

CCP documents.

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

ORNL-CCP has elected not to use the actual CCP-TP-0 05 form. The requirements in CCP-TP005, Attachment 13, have changed with recent revisi ons to CCP-TP-005, but ORNL-CCP has not completed any certification checklists since CC P 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 S tream 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 throug h ORNL-CCP characterization (as applicable).

# 13



# (4) EPA assessed the acceptable knowledge summary repor ts 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 so urce documents, to support the following

statements:

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

• All waste within the waste stream is similar in mat erial 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 nucl ear fuel (SNF). 3



# ORNL-CCP provided CCP-AK-ORNL-008, Revision 1, as t he AKSR for Waste Stream ORISTP-CH-HET, and CCP-AK-ORNL-001, Revision 8, as th e 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 incom plete and insufficient. To address this deficiency, ORNL-CCP revised CCP-AK-ORNL-001 and pr ovided 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 supp orting 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, checkl ist 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, checkl ist 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 aspe cts, for Waste Stream OR-ISTP-CH-HET

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

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

EPA reviewed complete qualification cards for all o f 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

6 

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

Act of 1982.”

# 14



# Harrison, Jason Montoya, Kevin Peters, Steve Schafe r and Travis Smith. EPA also reviewed complete SPM qualification cards for Rich Kantrowit z, Jake Knox, Laura Nelson, Beverly Schrock, Daniel Wade, Roger Whiteaker and Candice W eston. 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 ev aluation. EPA verified current training for the other listed personnel 7 

# by reviewing the Assigned Reading Reports.

EPA found the training records for the personnel li sted above to be complete and adequate. EPA will review training records for any additional per sonnel 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 pe rformed work in these roles for the ORNL-CCP CH waste characterization program in the p revious 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 infor m the scope of AK components evaluated during future T1 change evaluations.

(7) EPA assessed nonconformance and discrepancy resolut ion documentation and found it to be adequate.

EPA reviewed sample nonconformance reports (NCRs) a ssociated 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 substanti ve 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 si tes and to reflect current T2 reporting practices (see Table 1).

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

EPA reviewed the latest annual AK accuracy report f or 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 whil e the CCP characterization activities at ORNL were suspended during 2012, CCP prepared the r eport for a CBFO QA recertification audit. CCP must prepare AK accuracy reports annuall y 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 acc uracy 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 indic ates 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 card s to ensure that they were qualified during the time tha t they signed the documentation, but EPA did not re view any documentation concerning their knowledge of the cur rent procedure revisions.

# 15



# identified by AK do not agree with those obtained t hrough assay. The SPM indicated that forthcoming reports will likely take into account t he disagreement between NDA and AK with respect to the two most prevalent radionuclides; ho wever, the changes to CCP-TP-005 [discussed above in Item (1)] may result in the disagreement n ot 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 substanti ve modification to AK accuracy reports (annually, at a minimum) remains a T2 change (see T able 1).

(9) EPA assessed communication between acceptable knowl edge 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 mem oranda 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 releva nt information presented in the NDA memorandum. This inconsistency does not affect comp liance; the AKE stated that he will revisit

the NDA memorandum and include relevant AK informat ion 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 substanti ve 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 ma nagement such that a payload container may include drums that measure less than 100 nanocu ries per gram (nCi/g) so long as the payload in total is greater than 100 nCi/g. The AKS R for each waste stream selected for payload management must include an estimate of the total wa ste volume and percentage of the waste volume that is above and below100 nCi/g. Each conta iner selected for payload management must also contain at least one TRU isotope whose activit y exceeds the lower limit of detection (LLD) of the radioassay system used to characterize the w aste, and each container may only be overpacked into a payload container with other cont ainers 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 man agement for waste streams other than

those discussed in AKSR CCP-AK-ORNL-009 remains a T 2 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 substa ntive 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 c ompliance inspection with the fiscal year

# 16



# (FY) 2014 first quarter T2 notification report prov ided to EPA by CBFO in order to verify ORNL-CCP’s T2 reporting process since resuming oper ations.

EPA found that ORNL-CCP appropriately reported T2 c hanges 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 thi s document.

Summary of Acceptable Knowledge for Contact-Handled Waste

EPA did not identify any findings or concerns relat ed to AK for CH waste as a result of this continued compliance inspection.

Submission to EPA of a list of all AKEs and SPMs wh o 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 memoran da, including “Add Container” memoranda is a modified AK T2 change that clarifies and combi nes existing requirements (see Table 1).

8.1.2 Technical Evaluation: Remote-Handled Waste

(1) EPA examined select Central Characterization Progra m procedures and found them to be adequate.

EPA reviewed several CCP procedures for AK document ation, training of AKEs and disposition of nonconformances for technical sufficiency and sc ope. Specifically, EPA reviewed:

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

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

2013.

• CCP-TP-002, Revision 26, “Reconciliation of DQOs an d Reporting Characterization Data,” June 19, 2013.

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

2013.

These procedures adequately reflect applicable requ irements of 40 CFR 194.24. ORNL-CCP provided an assigned reading list acknowledging tra ining 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 documentati on associated with these procedures, as reviewed below. In addition, AKEs and SPMs were tra ined to the most recent version of the Remote-Handled TRU Waste Characterization Program I mplementation Plan (WCPIP), which documents DOE’s approach to characterize RH waste i n compliance with 40 CFR 194.24. WIPP Waste Acceptance Criteria and WIPP Waste Analysis P lan proficiency, which contribute to DOE’s demonstrated system of controls, was demonstr ated by RH AKEs and SPMs.

Notification to EPA upon completion of or substanti ve modification to site AK procedures requiring CBFO approval remains a T2 change (see Ta ble 2).

# 17



# (2) EPA verified that ORNL-CCP adequately implemented t he 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 pr ocess) for Waste Stream OR-REDCRH-HET. Several add-container memoranda were append ed to CCP-TP-005, Attachment 8. The containers listed on CCP-TP-005, Attachment 8, toge ther with those on the add-container memoranda represent all containers added to the was te stream, but Attachment 8 did not include

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

discussed this observation with the ORNL-CCP AKE wh o will rectify and monitor revision of Attachment 8. EPA will continue to verify Attachmen t completeness and adequacy because these demonstrate adequate process implementation.

Notification to EPA upon completion of or substanti ve modification to add-container memoranda remains a T2 change (see Table 2). Notifi cation 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 Str eam 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 the ir building of generation through ORNL-CCP

characterization.

(4) EPA assessed the acceptable knowledge summary repor t 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 docume nts, to support the following statements:

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

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

• All waste within the waste stream has similar radio logical 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 conclusi ons. The ORNL-CCP AKE modified the AKSR (CCP-AK-ORNL-500, Revision 4) to better explai n 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.

8 

# As defined by U.S. Code, Title 42, “The Public Heal th 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-H ET, including the CISs and summations of aspects. EPA found these documents to be adequate.

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

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

EPA reviewed qualification cards and assigned readi ng reports, which showed that ORNL-CCP AKEs and SPMs are trained to previous and current v ersions of the procedures listed in Item (1) of this section, including the WCPIP. Personnel rec ords examined included those for the AKEs Steve Schafer, Kevin Peters and Lisa Watson and SPM s Dave Moody, Irene Joo and Laura Nelson. Training records for the personnel listed a bove are complete and adequate. EPA will review training records for any additional personne l 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 pe rformed work in these roles for the ORNL-CCP RH waste characterization program in the p revious 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 infor m the scope of AK components evaluated during future T1 change evaluations.

(7) EPA assessed nonconformance and discrepancy resolut ion documentation and found it to be adequate.

EPA reviewed sample NCRs associated with waste stre am OR-REDC-RH-HET and found that ORNL-CCP adequately prepared the documents. EPA als o reviewed DR reports associated with the waste stream and found them to be adequately pr epared. ORNL-CCP generated these NCRs and DR reports prior to the 2011 suspension of wast e characterization activities.

Notification to EPA upon completion of or substanti ve modification to DR reports is a new T2 change. EPA added this T2 requirement to make the O RNL-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 foun d 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 info rmation 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 th e site; the AKE and SPM indicated that they prepared the accuracy report to address interi m audit requirements.

# 19



# Notification to EPA upon completion of or substanti ve modification to AK accuracy reports (annually, at a minimum) remains a T2 change (see T able 2).

(9) EPA evaluated the certification plan and identifica tion 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 p rovided the revised report to EPA during the continued compliance inspection. Other than thi s change, EPA found the certification plan to be complete and adequate.

Notification to EPA upon availability of nonsubstan tive modifications to certification plans remains a T2 change (see Table 2).

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

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

Notification to EPA upon implementation of load man agement 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 substa ntive 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 c ompliance inspection with the FY 2014 first quarter T2 notification report provided to EPA by C BFO in order to verify ORNL-CCP’s T2 reporting process since resuming operations.

EPA found that ORNL-CCP did not provide T2 notifica tion for the correlation and summary surrogate form (CSSF) for Waste Stream OR-REDC-RH-H ET (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 dis cussed 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 n otification 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 subs equent 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 relat ed 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 wh o performed work during the previous quarter is a new AK T2 change and notification of a vailability 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 Concer ns

EPA did not identify any findings or concerns relat ed to AK as a result of this continued compliance inspection.

Acceptable Knowledge Approval

Submission to EPA of a list of AKEs and SPMs who pe rformed 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 pictu re of ORNL-CCP waste characterization activities, which will inform the scope of AK compo nents 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 dat a examined, EPA determines that ORNL-CCP demonstrated continued AK characterization complian ce.

8.2 Nondestructive Assay (NDA) – Contact-Handled Waste

The purpose of this inspection was to confirm the c ontinued 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 evalu ation in February 2010 (see EPA Docket No. A-98-49; II-A4-125, dated March 24, 2010). Prio r to resuming TRU waste characterization operations in 2013, ORNL-CCP replaced gamma detecto rs and recalibrated the IQ3, actions which constituted a T1 change. EPA decided to evalu ate 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 inspe ction are provided in the NDA checklist in

Attachment E.

This inspection focused on the following:

• Confirmation that the ORNL-CCP IQ3 system was the s ame as what EPA approved initially and that its design and technical capabil ities had not changed significantly since EPA’s last inspection.

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

• Operational and maintenance history of the IQ3 syst em since resuming TRU waste characterization operations at ORNL-CCP.

• Knowledge, understanding and training status of ORN L-CCP NDA personnel.

# 21



# • Applicability of the IQ3 system’s current configura tion to assay the waste types that ORNL-CCP was processing in terms of physical form a nd radionuclides.

• Replicate testing of the IQ3 to verify that the sys tem can provide reproducible results for the determination of the quantity of 10 WIPP-tracke d radionuclides [americium-241 ( 241 

# Am), cesium-137 ( 137 

# Cs), plutonium-238 ( 238 

# Pu), 239 

# Pu, 240 

# Pu, 242 

# Pu, strontium-90 ( 90 

# Sr), uranium-233 ( 233 

# U), 234 

# U and 238 

# U] and the TRU alpha concentration. The replicate spreadsheets are in Attachments F.1 throu gh F.3.

8.2.1 Technical Evaluation: Mobile Characterization Servi ces IQ3 System

The following aspects of the IQ3 were evaluated dur ing this inspection.

(1) The IQ3 nondestructive assay system is the same sys tem 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 sy stem 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 conf irmed that this is the IQ3 system that was approved initially. Other than the detector replace ments 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 inspec tion. EPA did not identify any concerns regarding the ORNL-CCP IQ3 system.

(2) EPA assessed the design and operational range of th e IQ3 and found them to be adequate for the wastes currently being assayed.

The date of the last IQ3 batch data report (BDR) th at ORNL-CCP produced prior to suspending WIPP operations is May 18, 2011. The date of the fi rst 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 S tream OR-REDC-CH-HET, as

documented in CCP-AK-ORNL-002 NDA Memorandum. The d ensity range of the current IQ3 calibration is 1.639 grams per cubic centimeter (g/ cm 3 

# ), 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 ev aluated background, daily performance, resolution (full width at half maximum or FWHM), an d 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; howev er, ORNL-CCP has performed successful assays of 187 drums. ORNL-CCP deems all 187 assays adequate t o 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 w ere using the current revisions of the operating procedure, CCP-TP-047, Revision 12. All a spects of the IQ3 operation were acceptable.

(3) ORNL-CCP performed and documented system calibratio n 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 Advan tage Incorporated (WAI) performed these calibrations under contract to ORNL using WAI proce dures. ORNL-CCP evaluated and accepted these calibrations after determining they were comp liant 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 verific ation measurements, which are documented in MCS-IQ3-CAL-CONF-RPT 2013-01. Upon co mpletion 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 re viewed did not present a clear description

of the technical details of the calibration. ORNL-C CP revised these documents following discussions with EPA technical personnel and the re vised documents addressed all aspects of the

calibration and calibration verification. EPA did n ot identify any concerns regarding the

calibration and calibration verification of the ORN L-CCP IQ3 system.

(4) Determination and documentation for the total measu rement uncertainty for the IQ3 system are adequate.

The technical determination of total measurement un certainty (TMU) of assays performed on the IQ3 had been documented in detail in a 2009 ORNL-CC P TMU report. The EPA inspection team verified that they did not make any substantiv e changes to this report and that the TMU values in the IQ3 BDRs were consistent with expecta tions 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 ass ay 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 unambigu ously assigned as TRU. EPA did not identify any concerns regarding the technical adequacy and d ocumentation of LLD values for the IQ3

system.

# 23



# (6) The IQ3 system participated in drum cycle 20C of th e CBFO-sponsored performance demonstration program, as required.

The IQ3 system assayed four Performance Demonstrati on Program (PDP) drums for PDP Cycle 20C: metals, combustibles, sludge and glass. CBFO p rovided results for this cycle to EPA on February 24, 2014, indicating that the IQ3 passed a ll 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 area s, 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 p art of this inspection is to provide EPA with an independent means to verify that the IQ3 can pro vide reproducible results for the determination of the quantity of 10 WIPP-tracked ra dionuclides ( 241 

# Am, 137 

# Cs, 238 

# Pu, 239 

# Pu,

240 

# Pu, 242 

# Pu, 90 

# Sr, 233 

# U, 234 

# U and 238 

# U) 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 ta ken 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 a ssayed on the IQ3. ORNL-CCP reassayed Drum Nos. X10CSATN02241L, NFS0419D and NFS0478A fiv e 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 anal yses are included in Attachments F.1 through

F.3. The χ

2 

# test, which is also known as the goodness-of-fit t est or the chi-squared test for independence, is used to show how observed data com pare 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 me asurement. The t test is a statistical tool that

is used to tell if two sets of data are statistical ly different from one another. EPA applied it to th e replicate data to see if there are statistically si gnificant differences between the original assay values and the average of the five replicate measur ements.

10 

# Revision 2 of the Environmental Protection Agency Replicate Testing Protocol provides the details of the replicate testing assay protocol and data evaluatio n.

# 24



# For Drum Nos. X10CSATN02241L, NFS0419D and NFS0478A , the χ 2 

# test showed that the observed variances in the replicate measurements ar e 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 significa nt differences between the original assay values and the average of the five replicate measur ements.

The t test for Drum No. NFS0478A showed a statistically significant difference between the original assay value and the average of the five re plicate measurements for 137 

# Cs and 90 

# Sr. The

137 

# Cs and 90 

# Sr values are correlated in that 90 

# Sr is quantified by scaling it to the drum’s measur ed

137 

# Cs content. The Significant flag indicates that the variances in the replicate measurements for this container were greater than the reported uncer tainties relative to the limits of the test and tha t there was a statistically significant difference be tween the original assay (2.96x10 -07 

# Ci) and the average of the replicate measurements (4.43x10 -07 

# Ci) of 137 

# Cs. 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 137 

# Cs and 90 

# Sr replicate values versus original values. ORNL-CCP indicated t hat the background was most probably enhanced due to other containers with higher 137 

# Cs content on the five replicate assays. The

actual amount of 137 

# Cs detected is small, on the order of 296 nCi for t he initial assay versus 443 nCi for the mean of the five replicates. Although t he 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 testi ng for the IQ3.

8.2.2 Nondestructive Assay Findings and Approval

Summary of Nondestructive Assay Findings and Concer ns

EPA did not identify any findings or concerns for N DA 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 ch ange (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 ev aluations.

Based on the results of this evaluation and the dat a examined, EPA determines that ORNL-CCP demonstrated continued compliance with the EPA-appr oved 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 t his 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) F HZ 612 Probe (Instrument No.) attached to Probe No. XC0761 (S/N 1098). Using 137 

# Cs 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 beg in 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 weig ht on the measurement control report (CCP-TP-504, Revision 14, Attachment 2) and summari zed this activity in the operational logbook, Operational Logbook for Remote Handled Operations, Control No. CCP-RH-ORNLDTC-002, Calendar Year 2014, ORNL Building 7800, Pr ocess Building.

The DTC operational logbook listed tolerances for t he test drum weights, scale error, operational ranges for the GM probes and acceptance criteria fo r source checks. ORNL-CCP DTC operators took a background dose reading of 0.065 milliroentg en per hour (mR/hr) 11 

# while all containers were in a shielded position, followed by source che cks for the high and low ranges, and all

measurements were recorded on the measurement contr ol report and summarized in the operational logbook.

DTC personnel controlled all drum operations remote ly using a series of cameras and manipulators, and all ORNL-CCP personnel that EPA o bserved were working to the current revisions of ORNL-CCP procedures. A Thermo Model E SM FH 40G Ratemeter with a Model FHZ 512 probe measured the gamma dose rate for RH C ontainer No. ORRH-00685 in the DTC Alcove and the ORNL-CCP DTC operator (D. Crosby) re corded 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 commo nly called dose or when it is expressed per unit time, a dose rate . The criterion for RH determination is expressed i n terms of a dose rate in rem, which, while technically incorrect, is commonly use d. Additionally, gamma measurements which technical ly 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 componen t 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-0 0685 onto the DTC assembly, where DTC personnel weighed the container and recorded th e gross weight. Gamma (and neutron)

measurements were made and after the first measurem ent, the container was rotated 90o and this was repeated until a total of four measurements wer e made, noted as R1 through R4, as specified in CCP-TP-504, Revision 14. The four measurement va lues were expressed in mR/hr, as follows: R1 – 8.53; R2 – 8.33; R3 – 7.34; R4 – 8 (all measur ements are gamma only). The DTC Operator

recorded all measurements on the container data she et (CCP-TP-504, Revision 14, Attachment 2), a copy of which was provided to EPA. The dose r ate measurements (gamma plus neutron) of

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

all cases.

EPA did not identify any concerns regarding the tec hnical adequacy and documentation of DTC operations at ORNL-CCP.

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

ORNL-CCP provided DTC BDR No. ORRHRTC13001 that con tained assay results for seven containers. The BDR contained all applicable elemen ts, including documentation of the

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

BDR.

(3) EPA assessed the training for dose-to-curie personn el 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 pe rsonnel.

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 D TC 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, whic h will inform the scope of DTC components evaluated during future T1 change evalua tions.

# 27



# Based on the results of this evaluation and the dat a examined, EPA determines that ORNL-CCP demonstrated continued compliance with the EPA-appr oved 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 d ebris) and SCG S4000 (soils) and VE for SCG S5000 waste. ORNL-CCP did not provide EPA w ith any information about VE for CH waste; therefore, EPA only reviewed RTR for CH wast e during this continued compliance inspection. The RTR checklist used for this inspect ion is included as Attachment H.

ORNL-CCP’s RH NDE characterization program is EPA-a pproved for VE on SCG S5000 waste. The AK checklist used for this inspection is included as Attachment I.

Real-Time Radiography and Visual Examination Proced ures

EPA reviewed the following procedures as part of th is inspection:

• CCP-PO-001, CCP Transuranic Waste Characterization Quality Assurance Project Plan, Revision 21, May 31, 2013

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

• CCP-QP-002, CCP Training and Qualification Plan, Re vision 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 Examina tion, Revision 13, April 21,

2013

• CCP-TP-053, CCP CH Standard Real-Time Radiography I nspection Procedure, Revision 9, September 30, 2010

• CCP-TP-053, CCP CH Standard Real-Time Radiography I nspection Procedure, Revision 10, March 4, 2011

• CCP-TP-053, CCP CH Standard Real-Time Radiography I nspection Procedure, Revision 11, July 20, 2011

• CCP-TP-053, CCP CH Standard Real-Time Radiography I nspection Procedure, Revision 14, September 25, 2013

• CCP-QP-005, CCP TRU Nonconforming Item Reporting an d Control, Revision 23, June 25, 2013

• CCP-TP-001, CCP Project Level Data Validation and V erification, 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 Rad iography

1) EPA observed ORNL-CCP perform a real-time radiograp hy 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 Str eam OR-REDC-CH-HET. ORNL-CCP performed the demonstration using unit RTR 6, housed in Building 7880-J. The operator had already performed the necessary equipm ent 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 th e 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 f or 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 gener ated 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 char acterization 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 was te 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 a nd 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 rec ords 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 oper ators, including Qualification Cards and Test and Training container examination records. EP A wrote Concern No. ORNL-CCP-ORNLRTR-01C not requiring a response, regarding the wri tten inventories made for test and training containers, which is reproduced in full in Attachme nt J. The issue as presented in the concern is

as follows:

# 29



# Procedure CCP-TP-028, CCP Radiographic Test Drum an d Training Container Construction, Attachment 1, item No. 11, requires t hat a "Leaded glove or leaded apron" be added to the container. However, this att achment is meant to provide an exact inventory for the container and should be spe cific for the items added. CCP should consider changing how this information is re corded on the inventory so that no uncertainty is attached to its contents.

EPA also identified Concern No. ORNL-CCP-ORNL-RTR-0 2CR that required a response, regarding operator training/test container record r equirements, 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 evaluat e an RTR operator's continued job performance do not demonstrate the sucessful ex amination of unknown containers. This concern is based on the following:

(1) Operators are not required to generate a written re cord when examining a Training Container as they would for a routine wast e container or a Test container. This is an historical practice without a ny regulatory basis.

(2) A Lead Operator observes the operator's performance during the Training Container evaluation but does not possess an invent ory for the Training

Container and cannot assess whether items are misse d.

(3) The operator is considered successful in the test i f he/she identifies all Summary Category Groups and all prohibited items. T here 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 objectiv e 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 i nstance 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 compon ents 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 procedu ral revisions and found that CBFO and CCP have adequately addressed the issues. CBFO prov ided 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 demo nstrate that these omissions were brought to the attention of each applicable operator. EPA cons iders 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 tr ained in accordance with CCP procedures and that training records were readily available fo r 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 Fi ndings and Concerns

EPA did not identify any findings for CH RTR at ORN L-CCP.

EPA generated a concern not requiring a response, C oncern No. ORNL-CCP-CC-RTR-01C, and a concern requiring a response, Concern No. ORNL-CC P-CC-RTR-02CR, for RTR training. ORNL-CCP responded adequately to the concern requir ing 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 R TR 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 requ irement to ensure that EPA has a complete picture of ORNL-CCP waste characterization activiti es, which will inform the scope of CH RTR components evaluated during future T1 change evalua tions.

Based on the results of this inspection and the dat a examined, EPA determined that ORNL-CCP demonstrated continued compliance with the EPA-appr oved waste characterization program for

CH RTR.

# 31



# 8.4.2 Technical Evaluation: Remote-Handled Visual Examina tion (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 exami nation 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 e xamination. The VE operators directed the ORNL-site personnel and examined, identified and re corded each waste item placed in the 55- gallon receiving drum. Waste Material Parameters (W MPs) 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 id entification were verified and operators signed and dated the data sheets as requi red by the procedure. The operators verified that no prohibited items were loaded into the recei ving container. The operators used procedure CCP-TP-500, Revision 13, to guide the VE process. E PA reviewed the container data sheets generated during the demonstration and determined t hat they had been completed correctly and signed by the VE operators.

2) EPA examined visual examination characterization re cords and found them to be adequate.

EPA reviewed RH VE BDR Nos. ORNLRHVE13001, ORNLRHVE13002, ORNLRH VE13003, 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 proce dures. The VE operators recorded the WMP of each waste item, verified the WMC and confir med 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 record s and found them to be adequate.

The EPA inspectors reviewed training records for se lected operators. The qualification cards and other training records were complete and available for review.

EPA determined that RH VE operators and VEEs contin ued to be trained in accordance with CCP procedures and that training records are availa ble for review.

Summary of Remote-Handled Visual Examination Findin gs and Concerns

EPA did not identify any findings or concerns for R H 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 V E personnel who performed work during the previous quarter is a new RH VE T2 change (see Tabl e 2). Specifically, the list must include all

# 32



# operators, VEEs and ITRs. EPA added this requiremen t to ensure that EPA has a complete picture of ORNL-CCP waste characterization activiti es, which will inform the scope of RH VE components evaluated during future T1 change evalua tions.

Based on the results of this inspection and the dat a examined, EPA determined that ORNL-CCP demonstrated continued compliance with the EPA-appr oved 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-C CP. EPA generated a concern not requiring a response, Concern No. ORNL-CCP-CC-RTR-0 1C, 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 res ponse and EPA considers both issues to be

closed.

Nondestructive Examination Approval

Based on the results of this inspection and the dat a examined, EPA determines that ORNL-CCP demonstrated continued compliance with the EPA-appr oved waste characterization program for the CH RTR and RH VE systems. EPA did not review an y 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 faci lity. ORNL-CCP must notify EPA prior to using VE to characterize CH waste and seek EPA appr oval as a T1 change.

Based on this inspection, there is one change to th e 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 oper ators, ITRs and VEEs.

9.0 FINDINGS AND CONCERNS

EPA identified two concerns during this continued c ompliance inspection and T1 evaluation, both in the area of NDE. One concern required a res ponse, which ORNL-CCP provided to EPA and the other concern did not require a response. E PA considers both concerns to be closed.

EPA did not identify any findings during the ORNL-C CP continued compliance inspection or T1 evaluation. EPA generated a concern not requiring aresponse, Concern No. ORNL-CCP-CCRTR-01C, and a concern requiring a response, Concer n No. ORNL-CCP-CC-RTR-02CR, for CH RTR training. ORNL-CCP responded adequately to t he 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 wast e is a new T1 change. During the 2008 baseline inspection, EPA did approve ORNL-CCP to us e VE to characterize CH waste; however, this process was not included in the continued comp liance 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 C H VE process during the continued compliance inspection, EPA must approve this proces s 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 wh o performed work in these roles for the ORNL-CCP waste characterization program dur ing 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 wh o 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 IT Rs.

3. Submission to EPA of a list of all DTC personnel wh o performed work during the previous quarter is a new RH radiological character ization 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 substanti ve modification to CCP-TP-005, Attachments 4, 6, 7 and 8 and/or associated memoran da, including “Add Container” memoranda is a modified CH AK T2 change that clarif ies 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 t he ORNL-CCP tiering designations consistent with the requirements at other CH TRU si tes and to support the streamlined process for conducting T1 evaluations (see section 3.0). EP A also revised the tiering tables to ensure completeness and consistency with recent EPA T1 app roval 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 subsequ ent T1 approvals remain in effect. The language in Tables 1 and 2 regarding AK documentati on applies to all ORNL-CCP waste

streams.

# 34



# Approval

EPA determined that the ORNL-CCP waste characteriza tion 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 l imitations 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 i nspection to support the streamlined T1 evaluation and decision process discussed in sectio n 3.0 of this report. The results of this continued compliance inspection and the review of q uarterly 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 in spection. As a result, EPA will only focus on the significant waste characterization component s 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 co ntinued compliance inspection, at the Agency’s

discretion.

# A-1



# ATTACHMENT A.1: APPROVAL SUMMARY FOR ORNL-CCP CONTA CTHANDLED 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 Densit y 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 Novembe r 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 REMOT E-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 Novembe r 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 I NSPECTION

CH AK

Common to both CH waste streams:

AKE Qualification Card, Charles Allen Dickerson, Se ptember 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, 201 1

AKE Qualification Card, Travis Smith, June 16, 2011

AKE Qualification Card, Trey Greenwood, June 16, 20 11

Assigned Reading Report, CCP-QP-002, Revision 35, p rinted February 18, 2014

Assigned Reading Report, CCP-QP-005, Revision 23, p rinted February 18, 2014

Assigned Reading Report, CCP-TP-002, Revision 26, p rinted February 18, 2014

Assigned Reading Report, CCP-TP-005, Revision 26, p rinted February 18, 2014

CCP-QP-002, CCP Training and Qualification Plan, Re vision 35, June 6, 2013

CCP-QP-005, CCP TRU Nonconforming Item Reporting an d Control, Revision 23, June 25,

2013

CCP-TP-002, CCP Reconciliation of DQOs and Reportin g 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, 2 013

CH SPM Qualification Card, Laura Nelson, June 21, 2 010

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 Nat ional 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-Rel ated Activities Conducted in the Isotopic Research Materials Laboratory (IRML) at ORNL, J.R. Trabalka, July 16, 1999

C087, Interview with Jack Collins: Historical Opera tions and Waste Management at Building 9204-3 at Y-12, Tom Krause, May 18, 2005

C089, Interview with Joe Devore: Historical Operati ons and Waste Management at Building 3028, Tom Krause, May 10, 2005

C096, Interview with Tom Miner: Historical Operatio ns and Waste Management at Building 3028, Tom Krause, May 18, 2005

C097, Interview with Tom Miner: Historical Operatio ns and Waste Management at Building 3038, Tom Krause, May 18, 2005

CCP Waste Stream Characterization Checklist, OR-IST P-CH-HET, Lot 1, August 1, 2011

CCP Waste Stream Characterization Checklist, OR-IST P-CH-HET, Lot 2, August 23, 2011

CCP Waste Stream Characterization Checklist, OR-IST P-CH-HET, Lot 3, August 23, 2011

CCP-AK-ORNL-008 NDA Memorandum, Jeff Harrison, Octo ber 30, 2013

CCP-AK-ORNL-008, Central Characterization Program A cceptable Knowledge Summary Report for Oak Ridge National Laboratory Isotopes P rograms Contact-Handled Transuranic Waste, Waste Stream: OR-ISTP-CH-HET, Revision 1, Ja nuary 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 Do cumentation, Attachment 8 – Waste Containers List, OR-ISTP-CH-HET, July 8, 2010

CCP-TP-005 Revision 19, CCP Acceptable Knowledge Do cumentation, Attachment 8 – Waste Containers List, OR-ISTP-CH-HET, July 8, 2010

CCP-TP-005 Revision 26, CCP Acceptable Knowledge Do cumentation, Attachment 8 – Waste Containers List, OR-ISTP-CH-HET, December 6, 2013

# B-3



# CCP-TP-005, Revision 19, CCP Acceptable Knowledge D ocumentation, Attachment 1 – Acceptable Knowledge Documentation Checklist, OR-IS TP-CH-HET, July 13, 2010

CCP-TP-005, Revision 22, CCP Acceptable Knowledge D ocumentation, 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 D ocumentation, Attachment 14 – CCP Acceptable Knowledge Accuracy Report – Example Form , Lots 1–3, May 22, 2012

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 1 – Acceptable Knowledge Documentation Checklist, OR-IS TP-CH-HET, January 6, 2014

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 4 – Acceptable Knowledge Source Document Information Li st, OR-ISTP-CH-HET, January 7, 2014

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, 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 D ocumentation, Attachment 7 – Radionuclides, OR-ISTP-CH-HET, October 30, 2013

Characterization Information Summary for WSPF No. O R-ISTP-CH-HET, Lot 1, July 14, 2011

Characterization Information Summary for WSPF No. O R-ISTP-CH-HET, Lot 2, August 22,

2011

Characterization Information Summary for WSPF No. O R-ISTP-CH-HET, Lot 3, August 29,

2011

DR024, Discrepancy Resolution – Waste Stream OR-IST P-CH-HET EPA Hazardous Waste Number Assignment, Jeff Harrison, February 22, 2011

DR025, Discrepancy Resolution – Waste Stream OR-IST P-CH-HET Generation Location Discrepancies, Jeff Harrison, February 22, 2011

M126, RTR Video Tapes and DVDs from the WEAF Facili ty at Oak Ridge Waste, ORNL,

1986-1992

M171, ORNL EM Waste Database Query, November 9, 200 9

M187, EnergX Repack Forms for Waste Stream OR-ISTP- CH-HET, EnergX, various dates

M189, EnergX RTR Data for Waste Stream OR-ISTP-CH-H ET, EnergX, various dates

M190, EnergX VE Data for Waste Stream OR-ISTP-CH-HE T, EnergX, April 27, 2006 through April 25, 2007

M191, UCN-2109 and UCN-2822 Forms and Associated Co ntainer 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 Stre am OR-ISTP-CH-HET, Jeff Harrison, Lisa Watson, Jason Montoya, Christopher Chancellor, various dates

M217, eMWaste Database Query from ORNL Dated Januar y 3, 2013, ORNL, January 3, 2013

P022, Site Descriptions of Environmental Restoratio n Units at ORNL, Oak Ridge, Tennessee, A.J. Kuhaida Jr. and A.F. Parker, ORNL/ER-391, Febr uary 1997

P047, The Management of Radioactive Waste at Oak Ri dge National Laboratory: A Technical Review, Phillip E. Lamoreaux et al., DOE/DP/48010-T 1, 1985

P050, Oak Ridge National Laboratory Institutional P lan, FY-1980-FY1985, H. Postma et al., ORNL/PPA-79/8, November 1979

P051, Oak Ridge National Laboratory Institutional P lan, 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 La boratory and Isotopes Division Solid Waste Handling Procedure, J.A. Setaro and J.H. Gill ette, ORNL-TM-2568, May 28, 1969

P119, Oak Ridge Health Studies Phase I Report; Volu me II –Part A Dose Reconstruction Feasibility Study, ChemRisk/ Tennessee Department o f 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, ORN L, multiple document numbers, 1962–

1988

P175, Isotopes White Paper: Volume I: Assessments o f Selected Isotopes Circle Facilities, Evaluation of Isotope Processing Alternatives and F unding Justification for LLW-CAT System for Isotopes Area, W.A. Goldsmith et al., December 1988

P189, Curium Source Fabrication Facility, R.A. Robi nson and R.W. Schalch, 1969

P190, Final report on the Decontamination of the Cu rium Source Fabrication Facility, R.W. Schalch, ORNL/TM-8376, December 1983

P225, Solid State Division Annual Progress Report P eriod Ending December 31, 1975, M.K. Wilkinson et al., May 1976

P227, Solid State Division Annual Progress Report P eriod Ending April 30, 1977, M.K. Wilkinson et al., October 1977

# B-5



# P236, The Solid State Division, A Brief History (19 52–1995), Mike Wilkinson (compiler), June,

1996

P336, Report re: Isotopes Development Center, Hazar ds 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 Deactiv ation Project at ORNL, ORNL/ER-249, Revision 1, May 1, 1995

P398, Safety Analysis of Isotopes Alpha Handling Fa cility Including Appendix C: Isotopes Division of Solid Waste Handling Procedure, H.G. Hu nter, 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. R amey, April 27, 1984

P569, Implementation Plan for US Department of Ener gy 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 Hand ling Facility Cells 4 & 5): Texas Nuclear Pu-239-Be Neutron Source Fabrication, Two S ources, J.R. Gibson, CD-130, April 18,

1989

Summation of Aspects based on CCP-AK-ORNL-008, Revi sion 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 W aste (HLW)? John E Patterson, November 19, 1999

WMP analysis memorandum, Jeff Harrison, April 29, 2 011

OR-NFS-CH-SOIL

Acceptable Knowledge Accuracy Report: Oak Ridge Nat ional 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-N FS Transuranic Waste Background Information, May 3, 2005

C100, Interview with Richard Booth and faxed defens e and Waste Information for NFS, February 24, 2005

# B-6



# C210, Interview re: NFS TRU Waste Shipped to Oak Ri dge National Laboratory. Interviewees: Richard Booth, Richard Moore, Bob Hunt, Scott Tolle r, Marie Moore, J. Harrison and L. Watson, September 12, 2007

C227, Interview with Scott Morie from NFS, Septembe r 23, 2010

C321, Record of Communication. Subject: Soil and Gr oundwater 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, Nove mber 15, 2010

CCP-AK-ORNL-001, Central Characterization Program A cceptable Knowledge Summary Report for Nuclear Fuel Services Contact-Handled Tr ansuranic 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 D ocumentation, Attachment 10 – Acceptable Knowledge Re-evaluation Checklist, OR-NF S-CH-SOIL, July 7, 2010

CCP-TP-005, Revision 22, CCP Acceptable Knowledge D ocumentation, Attachment 7 – Radionuclides, OR-NFS-CH-SOIL, May 31, 2011

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, 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 D ocumentation, Attachment 1 – Acceptable Knowledge Documentation Checklist, OR-NF S-CH-SOIL, January 7, 2014

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 4 – Acceptable Knowledge Source Document Information Li st, OR-NFS-CH-SOIL, January 6, 2014

# B-7



# CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, 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 D ocumentation, Attachment 8 – Waste Containers List, OR-NFS-CH-SOIL, December 5, 2013

Characterization Information Summary for WSFP No. O R-NFS-CH-SOIL, Lot 12, September 2,

2011

Characterization Information Summary for WSPF No. O R-NFS-CH-SOIL, Lot 1, December 8,

2009

Characterization Information Summary for WSPF No. O R-NFS-CH-SOIL, Lot 10, December 16, 2009

Characterization Information Summary for WSPF No. O R-NFS-CH-SOIL, Lot 11, December
13, 2010

DR010, Discrepancy Resolution re: Incorrect Waste S tream Assignment of Soil Waste Containers, Jeff Harrison, January 12, 2009

DR022, Discrepancy Resolution re: OR-NFS-CH-SOIL an d OR-NFS-CH-HET-A Waste Stream Designation, Jeff Harrison, March 6, 2010

DR023, Discrepancy Resolution re: NFS0815 and X10C0 506069, Jeff Harrison, March 22, 2010

DR026, Discrepancy Resolution re: Reassignment of N FS0815 to OR-NFS-CH-SOIL, Jeff Harrison, July 7, 2010

DWAS BDR No. OR-DWAS-0120, January 22, 2009, revise d February 5, 2014

I053, KAPL-TN Waste Profile for NFS Building 234 So il, 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 Descri ption; Isotopes, ORNL, August 9, 2007

M075, TWPC Contact Handled Waste Repackaging Data F orms 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 Sched ule, NFS, January 11, 2011

# B-8



# M210, TRU Project Waste Processing Facility Job Rec ipe, Subject: Soil-Like Waste Remediation, Tim Hallman, January 29, 2011

P1375, North Site Characterization Report for Nucle ar Fuel Services, Erwin, Tennessee, Revision 1, July, 1999

P1400, Operating Procedure for Soil Excavation, Pro cessing and Packaging for the 234 Excavation Facility, Revisions 0 and 1, May 17, 201 0 - 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 S ervice, Inc. NFS Waste Parameter Verification Program, Martin Marietta Energy System s, October 29, 1992

P248, Structural Assessment of Building 234 Prepare d for NFS, 1205 Banner Hill Rd, Erwin, TN 37650, Siddharth Shah, November 1999

P273, NFS, Inc Waste Certification Plan for Transur anic Waste, no date

P306, Excavation of 110 Lab Tank, Revision 1, Febru ary 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 Param eter 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 Nat ional 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 Nat ional 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 1 6, 2011

AKE Qualification Card, Steve Shafer, June 16, 2011

Assigned Reading Report, CCP-QP-002, Revision 35, p rinted February 18, 2014

Assigned Reading Report, CCP-QP-005, Revision 23, p rinted February 18, 2014

Assigned Reading Report, CCP-TP-002, Revision 26, p rinted February 18, 2014

Assigned Reading Report, CCP-TP-005, Revision 26, p rinted 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 a nd L. Watson, various dates

C302, ORNL Comments on CCP-AK-ORNL-500, Revision 0, March 5, 2008

C307, Interview of Walt Bond- Subject: Processes an d Waste in Building 3508 at ORNL, Lisa Watson, February 21, 2008

C308, Interview with Jason Taylor, ORNL-PCB Coordin ator 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. Peter s and M. Doherty, June 4, 2008

CCP-AK-ONRL-505B, Central Characterization Program Nondestructive Assay Sampling Plan for Oak Ridge National Laboratory Engineering Devel opment Center RH TRU Waste (SETF), Revision 1, November 8, 2013

CCP-AK-ORNL-500, Central Characterization Program A cceptable Knowledge Summary Report for Oak Ridge National Laboratory Radiochemi cal 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 R emote-Handled Transuranic Radiological Characterization Technical report for RH Transuranic Waste from Oak Ridge National Laboratory Radiochemical Engineering Devel opment Center, Waste Stream: ORREDC-RH-HET , Revision 4, November 8, 2013

# B-10



# CCP-AK-ORNL-502, Central Characterization Program R H TRU Certification Plan for 40 CFR Part 194 Compliance for ORNL REDC RH Waste, Waste S tream: 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 Devel opment Center RH TRU Waste (PreSETF), Revision 1, December 2, 2013

CCP-QP-002, CCP Training and Qualification Plan, Re vision 35, June 6, 2013

CCP-QP-005, CCP TRU Nonconforming Item Reporting an d 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 Reportin g 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 Packagin g, 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 D ocumentation, Attachment 1 – Acceptable Knowledge Documentation Checklist, OR-RE DC-RH-HET, December 30, 2013

CCP-TP-005, Revision 26, CCP Acceptable Knowledge D ocumentation, Attachment 15 – CCP TRU Waste Correlation and Surrogate Summary Form, O R-REDC-RH-HET, November 26,

2013

Characterization Information Summary, OR-REDC-RH-HE T, Lot 1, February 18, 2009

Characterization Information Summary, OR-REDC-RH-HE T, Lot 28, September 19, 2011

# B-11



# Characterization Information Summary, OR-REDC-RH-HE T, 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 Debr is Items in Poly Blocks, Kevin J. Peters, July 1, 2008

DR602, Discrepancy Resolution, Re: Follow-Up on DR0 05 for EPA Hazardous Waste Number Discrepancies, Kevin J. Peters, July 2, 2008

DTC BDR No. ORRHDTC13001, assay on December 24, 201 3

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 th e Legacy CH TRU Waste from REDC Building 7920, Don Coffee, CAN-02MVSWSF-0014, Revis ion 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 Pack aging Documentation, ORNL,

various dates

P058, Statistical Analysis of Radiochemical Measure ments of TRU Radionuclides in REDC Waste, J. Beauchamp et al, ORNL/TM-13298, October 1 996

P125, Remote Handled Transuranic Solid Waste Charac terization Study: ORNL, R.C. Stewart et al., ORNL/TM-11050, June 1989

P161, Safety Analysis Report Radiochemical Engineer ing 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, 199 9

P281, Califorium-251: A Remarkable Versatile Radioi sotope, Irvin W. Osborne-Lee and C.W. Alexander, ORNL/TM-12706, October 10, 1995

P569, Implementation Plan for U.S. Department of En ergy 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), Se ptember 17, 2009

RH SPM Qualification Card, Laura Nelson, June 21, 2 010

Summation of Aspects based on CCP-AK-ORNL-500, Revi sion 0

U011, Safety Analysis: Transuranium Processing Plan t, 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 Accep table Knowledge Summary Report for the Radiochemical Engineering Development Center: N ewly 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 W aste? 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, Revis ion 0, June 3, 2009

NDA

CCP-AK-ORNL-002 NDA Memorandum, Jeff Harrison, Augu st 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, Val idating and Reporting Procedure, Revision 16, November 1, 2013

# B-13



# CM-REF-WP-009, Mobile IQ3 System Data Reviewing Val idating 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 W aste Processing Center, WAI Team, Revision 0, September 16, 2013

IQ3 BDR No. OR-OQ3-0224

IQ3 Operational Logbook, Control Number: CCP-ORNL-N DA-IQ3-001, Calendar Year 2013, pages 1-42, corresponding to restart of IQ3 operati ons until day of EPA inspection

LOQI for NDA IQ3 Operators, ITRs and Expert Analyst s dated February 3, 2014

MCS-IQ3-CAL-CONF-RPT-2013-01, Calibration Confirmat ion Verification and LLD Report for the MCS IQ3, Revision 0, November 20, 2013

MCS-IQ3-CALIB-2009, Calibration Report for the Mobi le 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 Re port 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 Interfe ring Matrix Standards for the MCS IQ3, Period: April 21, 2011 to May 17, 2011, March 28, 2012

NDA Drum System Registration Form IQ3, Qualities an d Quantitative Gamma Scanner with Isotopics, January 11, 2011

DTC

CCP-TP-504, CCP DTC Survey Procedure for RH TRU Was te, 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, 2 014

NIST Report of Calibration for detector XY022481, O ctober 25, 2002

# B-14



# RH-DM-ORNL-002, Operator Aid, Posted in Control Roo m 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, Recomm ended 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 Pla n, Revision 27, May 31, 2013

CCP-QP-002, CCP Training and Qualification Plan, Re vision 35, June 6, 2013

CCP-QP-005, CCP TRU Nonconforming Item Reporting an d Control, Revision 23, June 25,

2013

CCP-TP-001, CCP Project Level Data Validation and V erification, 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 I nspection Procedure, Revision 9, September 30, 2010

CCP-TP-053, CCP CH Standard Real-Time Radiography I nspection Procedure, Revision 10, March 4, 2011

CCP-TP-053, CCP CH Standard Real-Time Radiography I nspection Procedure, Revision 11, July 20, 2011

CCP-TP-053, CCP CH Standard Real-Time Radiography I nspection Procedure, Revision 14, September 25, 2013

CCP-TP-500, CCP Remote-Handled Waste Visual Examina tion, 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 N DE-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, 201 4

Qualification Cards for selected VE and RTR personn el

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 vario us RTR operators

Training roster for CCP-AK-ORNL-001, Revisions 7 an d 8

Visual Examination Data Form for demonstration cont ainer No. ORRH00697C-1ATTACHMENT C: INSPECTION PERSONNELPersonnelAffiliationArea of Expertise/FunctionEntranceMeetingInterviewedExitMeetingRajani Joglekar U.S. EPA ORIAInspector–Team LeaderEd Feltcorn U.S. EPA ORIA InspectorDorothy Gill SC&A, Inc. RTR/VE InspectorConnie Walker SC&A, Inc. AK InspectorKira Darlow SC&A, Inc. AK InspectorPatrick Kelly SC&A, Inc. NDA/DTC InspectorAndrew Stallings ORNL-CCP VPMAnthony Harley ORNL-CCPVE Operator/ITR, VEE,SME/OJT ExpertBerry Pace CBFO/CTAC QA ObserverBeverly Schrock CCP CH SPMChuck Wallace ORNL-CCP VE Operator/ITRDaniel Crosby MCS/CCP DTC OperatorDavid Queen DOE EMOR Project ManagerDavid W. Moody NWP/CCP RH SPMDerek Matheny ORNL-CCP VE Operator/ITRDerek Ott NWP/CCP RH Radiological EngineerFred Oney CCP/VJT RTR/LOIrene Joo NWP/CCP RH ManagerJ.R. Stroble DOE/CBFO ObserverJeff Harrison ORNL-CCP AKEJeremy Robinson NFT/CCP FGAJose R. Franco DOE/CBFO ObserverKenneth Lickliter CBFO/CTAC ObserverKevin J. Peters ORNL-CCP AKELaTravia Harmon CCP QA QA (NWP)Lisa Watson ORNL-CCP AKEMarcus A. Pinzel DOE/CBFO RH Program ManagerMaria Steade MCS/CCP NDA IQ3 OperatorMark Doherty CBFO/CTAC ObserverC-2Michael Sensibaugh CCP Operations ManagerNeil Dickes NWP/CCP NDA SupportR.C. McKay WAI General ManagerRonald Whitson MCS/CCP NDA/DTCRonnie Lee NWP/CCPWaste CharacterizationManagerScott Kranker WAI STRSean Stanfield MCS NDA IQ3Steve Redmond ORNL-CCPRTRTammy Reynolds NWP/CCPCCP ProgramManager/ObserverTom Morgan CBFO/NTP CCP ManagerD-1ATTACHMENT D.1: AK CONTINUED COMPLIANCE INSPECTIONCHECKLIST: WASTE STREAM OR-ISTP-CH-HETEPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsGeneralAK-1:Confirm that AK, training andnonconformance procedures adequately reflect therequirements of 40 CFR 194.CCP-QP-002, Revision 35, training andqualification planCCP-QP-005, Revision 23, nonconforming itemreportCCP-TP-002, Revision 26, WSPF packagedevelopmentCCP-TP-005, Revision 26, AK documentation40 CFR Part 194.24 (c) requires establishment of asystemof controls to characterize waste critical and limiting wastecomponents. The procedures listed provide the AK wastecharacterization method, waste stream profiledevelopment, nonconformance reporting, and trainingrequirements that help fulfill the requirements of40 CFRPart 194.24(c).This report and its attachments provide examples ofadequate implementation of each listed document.AK-2:Confirm that AKE and SPM training recordsand qualification cards are complete and that eachindividual’s training was conducted prior to themperforming work on this waste stream.Charles Allen Dickerson, AKE, 9/7/2010;6/16/2011Trey Greenwood, AKE, 6/16/2011Jeff Harrison, AKE, 12/3/2002; 6/22/2011Jason Montoya, AKE, 9/30/2008; 6/16/2011Kevin Peters, AKE, 6/16/2011Steve Schafer, AKE, 6/16/2011Travis Smith, AKE, 6/16/2011Rich Kantrowitz, SPM, 5/2/2006; Addendum J –Oak Ridge National Laboratory Qualification Card,1/2/2008Jake Knox, SPM, 10/23/2013Laura Nelson, SPM, 6/21/2010Beverly Schrock, SPM, 6/23/2010; revised 2/5/2014Daniel Wade, SPM, 10/23/2013Roger Whiteaker, SPM, 5/3/2012CCP-QP-002, Revision 35, Assigned ReadingReport, printed 2/18/2014CCP-QP-005, Revision 23, Assigned ReadingReport, printed 2/18/2014CCP-TP-002, Revision 26, Assigned ReadingReport, printed 2/18/2014CCP-TP-005, Revision 26, Assigned ReadingReport, printed 2/18/2014The qualification cards indicated training to the version ofthe procedure in effect at the time of Qualification Cardsign-off. EPA verified Kevin Peters’, Beverly Schrock’s,and Jeff Harrison’s skills by interview during theinspection. Verified current training of remainingpersonnel by review of the Assigned Reading Reports.CBFO revised Beverly Schrock’s SPM qualification cardto indicate that site-specific addenda are no longerrequired.D-2EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-3:Confirm that nonconformances aredocumented appropriately.NCR-ORNL-0231-14, Drum X10CSATN03195A,Impenetrable object identification with respect tocompletion of Section 5 of CCP-TP-053, 1/15/2014WNCR-2014-001, Drum X10C9312607, Items >200 mrem/hr, 2/4/ 2014The AKE indicated that NCRs are sometimes preparedwhen an item in the drum measures >200mrem/hr duringvisual examination. When this occurs, a drum lid isplacedbetween the items and detector, and if the resultingmeasurement is <200mrem/hr, the waste is consideredCHand the NCR is closed. If the measured item is still >200mr/hr at the drum lid, the waste is segregated forinclusionin an RH waste stream or for pipe overpacking andinclusion in the CH waste stream. The WNCR-2014-001drum was not in the ISTP waste stream, but was providedas an example of how this type of NCR is managed, as theAKE indicated this waste stream may contain items thatmeasure >200 mrem/hr.CCP-TP-005 ImplementationAK-4:Confirm that Attachment 1, AcceptableKnowledge Documentation Checklist, is complete.CCP-TP-005, Revision 26, Attachment 1, Signed byJeff Harrison, 1/6/2014CCP-TP-005, Revision 19, Attachment 1, Signed byJeff Harrison, 7/13/2010The reference list in the AKSR used to generate Att. 1.Sample source documents examined support Att. 1program and waste stream elements.AK-5:Confirm that Attachment 2, Record ofCommunication, is completed as necessary.Source Documents C087, C089, C096 and C097 Record of Communication is not mandatory, but providesa consistent format to document interviews.AK-6:Confirm that an Attachment 3, AcceptableKnowledge Source Document Summary, is completefor every source document.See reference list in Attachment B to this report All provided source documents have an associated Att. 3summary.AK-7:Confirm that Attachment 4, AcceptableKnowledge Information List, is complete and up todate.CCP-TP-005, Revision 26, Attachment 4, Signed byTravis Smith, 1/7/2014All references in AKSR are listed in Att. 4.AK-8:Confirm that Attachment 6, Waste Form,Waste Material Parameters, Prohibited Items, andPackaging, is complete and up to date.CCP-TP-005, Revision 26, Attachment 6, Signed byJeff Harrison, 1/16/2014CCP-TP-005, Revision 22, Attachment 6, Signed byAllen Dickerson, 5/17/2011WMP analysis memorandum, Signed by JeffHarrison, 4/29/2011Historical well records for drums X10C9311225,X10C9311139, X10C0501650 and X10C0501534Values in memorandum correspond with Table 5-1 inAKSR.Historical well records verified the general percentcombustible assignments in Att. 6 and the overall WMPassignments.D-3EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-9:Confirm that Attachment 7, Radionuclides, iscomplete and up to date and that AK-NDAcommunication is appropriately documented.CCP-TP-005, Revision 26, Attachment 7, Signed byJeff Harrison, 10/30/2013NDA memorandum, Signed by Jeff Harrison(AKE), Robert Ceo (NDA SME), Joe Wachter(MCS Technical Director) and Neil Dickes (CCPProject Office), 10/30/2013Based on the NDA memo, generator paperwork (AK) willbe critical to understanding what to expect in eachcontainer and how to approach, for example, thecalculation of242Pu. The NDA memo states the number ofcontainers that may require special consideration andevaluation by NDA based on elevated242Pu,234U,90Sr,252Cf and242Cm contents, and presents the methods bywhich these containers must be evaluated. The AKEindicated that direct instrument measurements rather thandefault isotopics will be used in most cases, but the NDAEA is expected to use the information in the NDAmemorandum when any assay brings to question analysisresults and to consult the AK tracking spreadsheettodetermine which distribution is applicable.EPA could not verify NDA EA use of the NDAmemorandum because ORNL-CCP has not performed anyassays since the resumption.AK-10:Confirm that Attachment 8, WasteContainers List, is complete and up to date.CCP-TP-005 Revision 26, Attachment 8, Signed byJeff Harrison, 12/6/2013CCP-TP-005 Revision 19, Attachment 8, Signed byJason Montoya, 7/8/2010Source Document M197Att. 8 indicates there are 610 55-gallon drums in the wastestream. The superseded Att. 8 dated 7/8/2010 indicatedthere were 543 “containers” in the stream, all of which aredrums. Reference M197 added 67 containers to the wastestream, which brought the total to 610 drums.AK-11:Confirm that Attachment 10, AcceptableKnowledge Re-evaluation Checklist, is completed asnecessary.N/AAKE confirmed that as of the inspection date therehavebeen no Acceptable Knowledge Re-Evaluation Checklistsrequired, in part due to the fact that the determination ofwhen to perform AK re-evaluation is a subjectivedecision.AK-12:Confirm that Attachment 11, AcceptableKnowledge Source Document DiscrepancyResolution, is completed as necessary.DR024, CCP-TP-005, Revision 21, Attachment 11,Signed by Jeff Harrison, 2/22/2011 (hazardouswaste number assignment discrepancy)DR025, CCP-TP-005, Revision 21, Attachment 11,Signed by Jeff Harrison, 2/22/2011 (generationlocation discrepancies)Discrepancy resolutions adequately addressed the issuesidentified. AKE confirmed that there have been no DRswritten since re-start.D-4EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-13:Confirm that Attachment 13, CCP WasteStream Characterization Checklist, is completed foreach characterization lot.Lot 1, Signed by Richard Kantrowitz (SPM) andJeff Harrison (AKE), 8/1/2011Lot 2, Signed by Candice Weston (SPM) and JeffHarrison (AKE), 8/23/2011Lot 3, Signed by Candice Weston (SPM) and JeffHarrison (AKE), 8/23/2011ORNL-CCP did not use the CCP-TP-005, Attachment 13example form, but all required components are present.Characterization checklists indicated that the mostprevalent radionuclides by mass do not “comparefavorably” with the AKSR. The AKSR states that thetwomost prevalent radionuclides by mass are232Th and238Uand the two most prevalent TRU radionuclides by massare237Np and239Pu. The characterization checklists statethat the measured predominant isotopes by mass are238Uand239Pu, but that not enough containers have beenassayed to determine that an AK re-evaluation isnecessary.AK-14:Confirm that Attachment 14, CCPAcceptable Knowledge Accuracy Report, iscompleted annually and verify that the AK accuracyreport memorandum is technically adequate.Acceptable Knowledge Accuracy Report: OakRidge National Laboratory Waste Stream NumberOR-ISTP-CH-HET, Heterogeneous Debris, Lots 1through 3, 3/22/2012, including CCP-TP-005,Revision 24, Attachment 14, Lots 1-3, Signed byBeverly Schrock, 3/22/2012The AK accuracy report states that accuracy is high.However, the characterization checklists show thattheradionuclide distribution in assayed containers isdifferentthan that in the AKSR. The AK accuracy calculationsdonot reflect this apparent discrepancy because AK accuracyis based on whether AK re-evaluations were performed.As stated in checklist item AKCH-13, the SPMdetermined AK re-evaluation to not be necessary atthistime.The AK accuracy report was prepared when CCP was notactive at the site. The AKE and SPM indicated thataccuracy reports were prepared to address interim auditrequirements and confirmed that they have not assessedAK accuracy since resumption.AK-15:Confirm that Attachment 15, CCP TRUWaste Correlation and Surrogate Summary Form, iscompleted as necessary.N/AN/AD-5EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-16:Confirm that the AKSR is complete andaccurately describes the subject waste.CCP-AK-ORNL-008, Revision 1 The AKSR identifies theprevalent isotopes by mass, notCi. While not critical to this approval, the AKE agreed torevisit the prevalent isotope assignment to determinewhether it would be better to base the assessment on Ci%rather than mass%. Further, several AK limitationsin theNDA memorandum are not in the AKSR. These omissionsare not critical to EPA approval, but the AKE agreed toupdate the AKSR in the future to include all the relevantlimitations and information.AKSR, Revision 1, includes all required components.SeeAKCH-17–AKCH-19 and AKCH-21–AKCH-23.Waste Stream Definition and Waste IdentificationAK-17:Verify that all waste within the waste streamwas generated from a single process/activity and thatthe generating process/activity is adequatelydescribed.CCP-AK-ORNL-008, Revision 1, Sections 4.4, 5.1and 5.3.Source Documents: C096, M171, M191, M217,P022, P101, P175, P189, P190, P236, P336, P346,P398, P400, P481, P458, P528, P753, P1085, P1351and U038The ORNL Isotopes Program generated the waste duringthe following activities:•Radioisotope services.•Isotope enrichment.•IRML activities.•Isotope Distribution (Sales) Office activities.AK-18:Verify that all waste within the waste streamis similar in material and physical form and that theexpected physical parameters are adequatelydescribed.CCP-AK-ORNL-008, Revision 1, Sections 2.0, 4.5and 5.4CCP-TP-005, Attachment 6 and memorandumSource Documents: M126, M187, M189, M190,M191 and M197The physical parameters for this waste stream areextremely diverse; the waste is not segregated by physicalform and may be composed of any debris material. AKSR,Revision 1, describes the hundreds of potential debriscomponents and the AK record includes physicalcomposition information about each drum, so the potentialwaste content is adequately described. The waste issimilaronly in that each drum will be composed of debris.AK-19:Verify that the expected radiologicalcharacteristics are adequately described.CCP-AK-ORNL-008, Revision 1, Sections 2.0, 4.5and 5.4CCP-TP-005, Attachment 7 and memorandumSource Documents: M171, M191, P1269 and U038Many drums in the waste stream have generator calculatedradiological composition information as well as upto twoiterations of NDA by different site contractors, sotheradiological composition of each drum is availablein theAK record. Radiological properties can be verifiedon abatch basis, and the expected radiological composition ofthe waste stream is adequately described because drumspecific AK data are available. AKSR, Revision 1, statesthat the two most prevalent radionuclides by mass are232Th and238U. The two most prevalent TRU radionuclidesby mass are237Np and239Pu.D-6EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-20:Verify that waste containers are traceablefrom retrieval through CCP’s EPA-approvedcharacterization process.For each container: Source Documents M187,M188, M191; AK tracking spreadsheets; CCP-TP005, Attachment 7 and memorandumX10C0501534: Parent Drum X10C9311139. Drumwas emplaced in WIPP prior to ORNL-CCP shutdown.X10C0501650: Parent Drum X10C9312391. Drumwas emplaced in WIPP prior to ORNL-CCP shutdown.X10C9312235A: Isotope batch FP-26R; has notbeen characterizedX10C9312555: Isotope batch FP-27; excluded(determined to be LLW)X10C9400218: Isotope batch FP-35; excluded(determined to be LLW)X10C9311225:144Cm population in NDAmemorandum; inactive excluded (prohibited item)X10C9309168: Energx and ORNL assay,Np/Pu/235U; has not been characterized.The listed references indicated that the containersaretraceable from the point of generation throughplacement/removal on the AK tracking spreadsheet, toORNL-CCP BDR generation (as applicable). ORNL-CCPhas three AK tracking spreadsheets: (1) CH TRU drums inthe waste stream,(2) excluded drums that are LLW and (3)excluded drums that are segregated for other reasons likepresence of prohibited items. EPA traced each drumto theappropriate AK tracking spreadsheet. Also, traceabilitydrums include several selected from the AK-NDAmemorandum list, many of which were later excluded.Land Withdrawal Act RequirementsAK-21:Verify that all of the waste in the wastestream is defense in origin.CCP-AK-ORNL-008, Revision 1Source Documents C034, C087, C089, C097,M192, P047, P050, P051, P089, P119, P175, P225,P227 and U038Wastes were extensively commingled and enough of theisotope-related activities were defense-related toimpart anoverall defense determination to the waste stream.ADefense Determination Approval Form states that thewaste was commingled (defense–non-defense) and fellunder the defense source “defense nuclear materials,defense nuclear waste and by-products, defense R&D.”AK-22:Verify that none of the waste in the wastestream is high-level waste.CCP-AK-ORNL-008, Revision 1Source Documents P569,U038 and U647HLW was not generated because the Isotopes Programdidnot process SNF.AK-23:Verify that none of the waste in the wastestream is spent nuclear fuel.CCP-AK-ORNL-008, Revision 1Source Documents U038 and U647While the waste stream may include fuel materials,thematerials are unirradiated and cannot be SNF.D-7EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsWaste Stream CertificationAK-24:Verify that the WSPF is complete andaccurate.Waste Stream Profile Form, Revision 0, 7/25/2011.ORNL-CCP has increased the waste stream volume byapproximately 10% since approval of the WSPF (AKCH10). This constitutes an increase in waste volume,but theAKE stated this was not sufficient to warrant a newWSPF.AK-25:Confirm that a characterization informationsummary and summation of aspects are included inthe WSPF package and are complete and accurate.CIS for Lot 1Summation of Aspects based on CCP-AK-ORNL008, Revision 0The Summation of Aspects is consistent with the AKSRrevision in place at the time the WSPF was generated.AK-26:Confirm that a characterization informationsummary is adequately completed for eachcharacterization lot.Lot 1, 714/2011; Lot 2, 8/22/2011; Lot 3, 8/29/2011The CIS addressed headspace gas data and indicatedRTRinformation was evaluated per CCP-TP-002.Tier 2 ReportingAK-27:Verify that ORNL-CCP has reported to EPAcompletion or revision of AK accuracy reports forthis waste stream annually, at a minimum.Acceptable Knowledge Accuracy Report: OakRidge National Laboratory Waste Stream NumberOR-ISTP-CH-HET, Heterogeneous Debris, Lots 1through 3, 3/22/2012ORNL-CCP resumed operations during FY14 1stquarterand has not yet completed an AK accuracy report forISTPwaste stream.AK-28:Verify that ORNL-CCP has reported to EPAcompletion or revision of AK-AK and AKNDA/NDE DR reports associated with this wastestream.CCP-TP-005, Attachment 4, 1/7/2014 ORNL-CCP resumedoperations during FY14 1stquarterand has not yet completed any DRs for ISTP waste stream.AK-29:Verify that ORNL-CCP has reported to EPAcompletion or revision of CCP-TP-005, Attachment4, for this waste stream.CCP-TP-005, Attachment 4, 1/7/2014 ORNL-CCP revisedAtt. 4 during FY14 2ndquarter(1/7/2014), which was still the current quarter during theEPA inspection.AK-30:Verify that ORNL-CCP has reported to EPAcompletion or revision of CCP-TP-005, Attachment6, and the associated memorandum for this wastestream.CCP-TP-005, Attachment 6, 1/16/2014 ORNL-CCP revised Att. 6 during FY14 2ndquarter(1/16/2014), which was still the current quarter during theEPA inspection.AK-31:Verify that ORNL-CCP has reported to EPAcompletion or revision of the AK-NDAmemorandum for this waste stream.CCP-TP-005, Attachment 7, 10/30/2013NDA memorandum, 10/30/2013FY14 1stquarter notification reportORNL-CCP revised the NDA memorandum and Att. 7 on10/30/2013 and correctly reported it in the FY14 1stquarter notification report.D-8EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-ISTP-CH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-32:Verify that ORNL-CCP has reported to EPAcompletion or revision of this waste stream’s AKSR.CCP-AK-ORNL-008, Revision 1, 1/9/2014 ORNL-CCP revised AKSR during FY14 2ndquarter(1/9/2014), which was still the current quarter during theEPA inspection.AK-33:Verify that ORNL-CCP has reported to EPAcompletion or revision of the WSPF, includingchange notices, and the associated documentation forthis waste stream.WSPF for Waste Stream OR-ISTP-CH-HET,7/25/2011ORNL-CCP resumed operations during FY14 1stquarterand has not revised the ISTP waste stream WSPF.AK-34:Verify that ORNL-CCP has reported to EPAcompletion or revision of add-container memorandafor this waste stream.CCP-TP-005, Attachment 8, 12/6/2013FY14 1stquarter notification reportORNL-CCP has not generated any add-containermemoranda since the resumption. ORNL-CCP revised Att.8 on 12/6/2013 and reported it in the FY14 1stquarternotification report.D-9ATTACHMENT D.2: AK CONTINUED COMPLIANCE INSPECTIONCHECKLIST: WASTE STREAM OR-NFS-CH-SOILEPA Inspection No.: ORNL-CC-2014 Waste Stream:OR-NFS-CH-SOILInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsGeneralAK-1:Confirm that AK, training andnonconformance procedures adequately reflect therequirements of 40 CFR 194.CCP-QP-002, Revision 35, training andqualification planCCP-QP-005, Revision 23, nonconforming itemreportCCP-TP-002, Revision 26, WSPF packagedevelopmentCCP-TP-005, Revision 26, AK documentationSee Attachment D.1AK-2:Confirm that AKE and SPM training recordsand qualification cards are complete and that eachindividual’s training was conducted prior to themperforming work on this waste stream.See list in Attachment D.2Chris Chancellor, AKE, 6/16/2011Candice Weston, SPM, 11/1/2006Chris Chancellor and Candice Weston are no longer activewith the ORNL-CCP program and therefore are notincluded in any of the Assigned Reading Reports. Bothsigned documents that are still part of the activerecord forWaste Stream OR-NFS-CH-SOIL. EPA reviewed theirqualification cards to confirm their training at the time thedocuments were signed.AK-3:Confirm that nonconformances aredocumented appropriately.NCR-ORNL-0841-13NCR-ORNL-0842-13NCR-ORNL-0898-13NCR-ORNL-0258-14NCR 0841-13 is open, documents apparent WMCdiscrepancy, will be reviewed by AKE, and will probablyrequire an AK re-evaluation and impact AK accuracy.NCR 1842-13 is open, documents packaging discrepancy,will be reviewed by AKE, and will probably requireAKSR revision but not impact AK accuracy.NCRs 0898-13 and 0258-14 are closed and documentdrums falling out of waste stream for not being TRU.CCP-TP-005 ImplementationAK-4:Confirm that Attachment 1, AcceptableKnowledge Documentation Checklist, is complete.CCP-TP-005, Revision 26, Attachment 1, Signed byJeff Harrison, 1/7/2014Att. 1 includes every source document that any AKEeverthoughtmightapply to the SOIL waste stream andmightapply to specific AK requirements. If a source document isfound to not apply or not be useful, it is not automaticallyremoved from Att. 1. Everything cited in the AKSR mustbe listed in Att. 1, but not vice versa.AK-5:Confirm that Attachment 2, Record ofCommunication, is completed as necessary.References C100, C210, C227 and C321 Record of Communication is not mandatory, but providesa consistent format to document interviews.D-10EPA Inspection No.: ORNL-CC-2014 Waste Stream:OR-NFS-CH-SOILInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-6:Confirm that an Attachment 3, AcceptableKnowledge Source Document Summary, is completefor every source document.See reference list in Attachment B to this report All reviewed source documents have an associated Att. 3summary.AK-7:Confirm that Attachment 4, AcceptableKnowledge Information List, is complete and up todate.CCP-TP-005, Revision 26, Signed by Travis Smith,1/6/2014Att. 4 includes every SD that any AKE ever thoughtmightapply to the SOIL waste stream. If a SD is found tonotapply or not be useful, it is not automatically removedfrom Att. 4. Every SD cited in AKSR must be in Att.4,but not vice versa.AK-8:Confirm that Attachment 6, Waste Form,Waste Material Parameters, Prohibited Items, andPackaging, is complete and up to date.CCP-TP-005, Revision 26, Signed by Jeff Harrison,1/16/2014WMP analysis memorandum, Signed by JeffHarrison, 1/16/2014Up to date and revised to include RTR records and newlygenerated soil. Supports Table 6-1 in AKSR, Revision 9.AK-9:Confirm that Attachment 7, Radionuclides, iscomplete and up to date and that AK-NDAcommunication is appropriately documented.CCP-TP-005, Revision 22, Signed by AllenDickerson, 5/31/2011NDA memorandum, Signed by Jeff Harrison(AKE), Robert Ceo (NDA SME), Joe Wachter(MCS Technical Director) and Joe Harvill (CCPProject Office), 11/15/2010Soil discussion in memorandum does not need revision forthird soil generation campaign because default isotopicsare based on ratio of building-wide Pu work from 1960sand the same building-wide ratio applies to all aspects ofbuilding D&D. Supports Table 6-4 in AKSR, Revision9.AK-10:Confirm that Attachment 8, WasteContainers List, is complete and up to date.CCP-TP-005, Revision 26, Dated 12/5/2013, Signedby Jeff HarrisonReferences M128 and M132Att. 8 is a record of what was added to the waste stream;containers are only removed from Att. 8 if added toadifferent ORNL-CCP waste stream. If fall out for LLW orotherwise excluded, stay in Att. 8; daughter or repackagedcontainer numbers are not added to Att. 8. No newcontainers added since resumption. There are ~1,000containers in storage at ORNL that will be added toSOILwaste stream when moved to TWPC.AK-11:Confirm that Attachment 10, AcceptableKnowledge Re-evaluation Checklist, is completed asnecessary.CCP-TP-005, Revision 19, Signed by Jeff Harrison(AKE) and Candice Weston (SPM), 7/7/2010,corresponds to DR026This was the most recent Att. 10. AKEs confirmed nonewAtt. 10s for SOIL waste stream since resumption.AK-12:Confirm that Attachment 11, AcceptableKnowledge Source Document DiscrepancyResolution, is completed as necessary.DR026, CCP-TP-005, Revision 19, Signed by JeffHarrison, 7/7/2010This was the most recent Att. 11/DR. AKEs confirmednonew Att. 11s or DRs for SOIL waste stream sinceresumption.D-11EPA Inspection No.: ORNL-CC-2014 Waste Stream:OR-NFS-CH-SOILInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-13:Confirm that Attachment 13, CCP WasteStream Characterization Checklist, is completed foreach characterization lot.Lot 12, Signed by Candice Weston (SPM) and JeffHarrison (AKE), 9/6/2011Lot 12 was the last lot completed. AKEs and SPMconfirmed that there have been no fully characterized lotscompiled since resumption. ORNL-CCP did not use theCCP-TP-005, Attachment 13 example form, but allrequired components are present.AK-14:Confirm that Attachment 14, CCPAcceptable Knowledge Accuracy Report, iscompleted annually and verify that the AK accuracyreport memorandum is technically adequate.Acceptable Knowledge Accuracy Report: OakRidge National Laboratory Waste Stream NumberOR-NFS-CH-SOIL, Soils, Lot 12, Cumulative forLots 1 through 12, 3/22/2012, including CCP-TP005, Revision 24, Attachment 14, Lot 12, Signed byBevery Schrock, 3/22/2012AKEs and SPM confirmed that they have not assessedAKaccuracy since resumption.AK-15:Confirm that Attachment 15, CCP TRUWaste Correlation and Surrogate Summary Form, iscompleted as necessary.N/AN/AAK-16:Confirm that the AKSR is complete andaccurately describes the subject waste.CCP-AK-ORNL-001, Revision 8CCP-AK-ORNL-001, Revision 9AKSR revised during EPA inspection. AKSR, Revision9,includes all required components. See AKCH-17–AKCH19 and AKCH-21–AKCH-23.Waste Stream Definition and Waste IdentificationAK-17:Verify that all waste within the waste streamwas generated from a single process/activity and thatthe generating process/activity is adequatelydescribed.CCP-AK-ORNL-001, Revision 9References: C099, C100, C210, I053, M003, M132,M206, P212, P218, P248, P273, P306, P315, P323,P1375, P1400 and U055NFS generated the waste from decommissioning Building234 and removal of Building 110 laboratory undergroundtank.AK-18:Verify that all waste within the waste streamis similar in material and physical form and that theexpected physical perameters are adequatelydescribed.CCP-AK-ORNL-001, Revision 9CCP-TP-005, Attachment 6 and memorandumReferences: C321, M003, M075, M128, M132,M210, P248, P315, P317, P1400, P1401, U055 andU058Waste containers hold soil and absorbent.AK-19:Verify that the expected radiologicalcharacteristics are adequately described.CCP-AK-ORNL-001, Revision 9CCP-TP-005, Attachment 7 and memorandumReferences: C099, C100, C210, I053, M003, M012,P218, P273, P1401238U and239Pu are predicted most prevalent by mass butmeasurements may result in239Pu and240Pu being mostprevalent due to expected issues measuring238U.D-12EPA Inspection No.: ORNL-CC-2014 Waste Stream:OR-NFS-CH-SOILInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-20:Verify that waste containers are traceablefrom retrieval through CCP’s EPA-approvedcharacterization 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 WDScalculation); CIS Lot 12, 9/2/2011; emplaced12/1/2011NFS0815: Att. 8; DR023; DR026; M003; M012;OR-RTR7-0003, 12/12/2013; NCR-ORNL-0842-13for plastic liner bag not being present as identifiedin 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 12/19/2013Containers not fully certified for shipment prior to ORNLCCP ceasing operations will be re-certified by NDEandNDA prior to WIPP emplacement.The “C” in X10C0506151C indicates that it is a daughtercontainer of X10C0506151.Land Withdrawel Act RequirementsAK-21:Verify that all of the waste in the wastestream is defense in origin.CCP-AK-ORNL-001, Revision 9References: C099, C100 and M021Over 90% of the NFS fuel production was for defense-related projects/clients.ORNL-CCP intended to use M021 to support the defensedetermination for all NFS waste streams; however, thedocument explicitly only applied to the debris wastestream. ORNL-CCP revised Att. 3 to add a limitationexplaining that it applies to all NFS waste streams.AK-22:Verify that none of the waste in the wastestream is high-level waste.CCP-AK-ORNL-001, Revision 9References: P315, U038 and U055Soil filtered/sized repackaged; soil cannot containHLW.Also, NFS did not reprocess SNF or handle HLW.AK-23:Verify that none of the waste in the wastestream is spent nuclear fuel.CCP-AK-ORNL-001, Revision 8References: P315, U038 and U055Soil filtered/sized repackaged; soil cannot containSNF.Also, NFS did not handle SNF.Waste Stream CertificationAK-24:Verify that the WSPF is complete andaccurate.Waste Stream Profile Form, Revision 0, 12/8/2009 AKSR, Revision 9, which was published during the EPAinspection, includes a change to the SOIL waste streamWMPs. Therefore, ORNL-CCP will be revising theWSPF. EPA will review the revised WSPF during a T2review or during the next continued complianceinspection.D-13EPA Inspection No.: ORNL-CC-2014 Waste Stream:OR-NFS-CH-SOILInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-25:Confirm that a characterization informationsummary and summation of aspects are included inthe WSPF package and are complete and accurate.CIS for Lot 1Summation of Aspects based on CCP-AK-ORNL001, Revision 4The CIS for Lot 1 is complete and included with theWSPF.The Summation of Aspects will be revised to reflectthecurrent AKSR when the WSPF is revised as discussedinAKCH-24.AK-26:Confirm that a characterization informationsummary is adequately completed for eachcharacterization lot.Lot 10, 12/16/2009; Lot 11, 12/13/2010; Lot 12,9/2/2011SPM confirmed no characterization lots have been formedsince resumption.Tier 2 ReportingAK-27:Verify that ORNL-CCP has reported to EPAcompletion or revision of AK accuracy reports forthis waste stream annually, at a minimum.Acceptable Knowledge Accuracy Report: OakRidge National Laboratory Waste Stream NumberOR-NFS-CH-SOIL, Soils, Lot 12, Cumulative forLots 1 through 12, March 22, 2012ORNL-CCP resumed operations during FY14 1stquarterand has not yet completed an AK accuracy report forSOIL waste stream.AK-28:Verify that ORNL-CCP has reported to EPAcompletion or revision of AK-AK and AKNDA/NDE DR reports associated with this wastestream.CCP-TP-005, Attachment 4, 1/6/2014 ORNL-CCP resumedoperations during FY14 1stquarterand has not yet completed any DRs for SOIL wastestream.AK-29:Verify that ORNL-CCP has reported to EPAcompletion or revision of CCP-TP-005, Attachment4, for this waste stream.CCP-TP-005, Attachment 4, 1/6/2014 ORNL-CCP revisedAtt. 4 during FY14 2ndquarter(1/6/2014), which was still the current quarter during theEPA inspection.AK-30:Verify that ORNL-CCP has reported to EPAcompletion or revision of CCP-TP-005, Attachment6, and the associated memorandum for this wastestream.CCP-TP-005, Attachment 6, 12/5/2013FY14 1stquarter notification reportORNL-CCP revised Att. 6 on 12/5/2013 and correctlyreported it in the FY14 1stquarter notification report.ORNL-CCP revised Att. 6 again during FY14 2ndquarter(1/16/2014), which was still the current quarter during theEPA inspection.AK-31:Verify that ORNL-CCP has reported to EPAcompletion or revision of the AK-NDAmemorandum for this waste stream.NDA memorandum, 11/15/2010 ORNL-CCP resumed operations during FY14 1stquarterand has not revised the NDA memorandum for the SOILwaste stream.AK-32:Verify that ORNL-CCP has reported to EPAcompletion or revision of this waste stream’s AKSR.CCP-AK-ORNL-001, Revision 8, 12/12/2013CCP-AK-ORNL-001, Revision 9, 2/6/2014FY14 1stquarter notification reportORNL-CCP revised AKSR (Revision 8) on 12/12/2013and correctly reported it in the FY14 1stquarternotification report. ORNL-CCP revised AKSR (Revision9) during FY14 2ndquarter (2/6/2014), which was still thecurrent quarter during the EPA inspection.D-14EPA Inspection No.: ORNL-CC-2014 Waste Stream:OR-NFS-CH-SOILInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-33:Verify that ORNL-CCP has reported to EPAcompletion or revision of the WSPF, includingchange notices, and the associated documentation forthis waste stream.Waste Stream Profile Form, Revision 0, 12/8/2009 ORNL-CCP resumed operations during FY14 1stquarterand has not yet revised the SOIL waste stream WSPF.AK-34:Verify that ORNL-CCP has reported to EPAcompletion or revision of add-container memorandafor this waste stream.CCP-TP-005, Attachment 4, 1/6/2014CCP-TP-005, Attachment 8, 12/8/2013ORNL-CCP has not generated any add-containermemoranda since the resumption. ORNL-CCP revised Att.8 on 12/8/2013 and reported it in the FY14 1stquarternotification report.D-15ATTACHMENT D.3: AK CONTINUED COMPLIANCE INSPECTIONCHECKLIST: WASTE STREAM OR-RH-REDC-HETEPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsGeneralAK-1:Confirm that AK, training andnonconformance procedures adequately reflect therequirements of 40 CFR 194.CCP-QP-002, Revision 35, training andqualification plan CCP-QP-005, Revision 23,nonconforming item reportCCP-TP-002, Revision 26, WSPF packagedevelopmentCCP-TP-005, Revision 26, AK documentation40 CFR Part 194.24 (c) requires establishment of asystemof controls to characterize waste critical and limiting wastecomponents. The procedures listed provide the AK wastecharacterization method, waste stream profiledevelopment, nonconformance reporting, and trainingrequirements that help fulfill the requirements of40 CFRPart 194.24(c). This report and its attachments provideexamples of adequate implementation of each listeddocument.AK-2:Confirm that AKE and SPM training recordsand qualification cards are complete and that eachindividual’s training was conducted prior to themperforming work on this waste stream.Steve Schafer, AKE, 6/8/2011Kevin Peters, AKE, 6/8/2011Lisa Watson (Price), AKE, 6/8/2011Dave Moody, SPM, 6/8/2011Laura Nelson, SPM, 6/21/2010Irene Joo (Quintana), SPM, 9/17/2009CCP-QP-002, Revision 35, Assigned ReadingReport, printed 2/18/2014CCP-QP-005, Revision 23, Assigned ReadingReport, printed 2/18/2014CCP-TP-002, Revision 26, Assigned ReadingReport, printed 2/18/2014CCP-TP-005, Revision 26, Assigned ReadingReport, printed 2/18/2014DOE WIPP-02-3214, Revision 3, Assigned ReadingReport, printed 2/18/2014The qualification cards indicated training to the version ofthe procedure in effect at the time of Qualification Cardsign-off. CCP trained Steve Schafer, Kevin Peters,LisaWatson, and Dave Moody to the elements presented inAKRH-1, as well as the WAP, WAC, WCPIP and siteQAPP. CCP trained Irene Joo to the WCPIP andTRAMPAC, as well as CCP-specific wastecharacterization and tracking requirements for RH waste.EPA verified the skills and training of the personnel listedby interview during the inspection, and ORNL-CCPprovided assigned reading list reports demonstrating thatthe AKEs and SPMs are familiar with the most recentversion of the WCPIP and each procedure listed inAKRH-1.AK-3:Confirm that nonformances are documentedappropriately.NCR RH-ORNL-0291-11, ContainersORRH00642, ORRH00643 and ORRH00644,5/19/2011, highest measured dose rate less thanthree times backgroundAKEs confirmed that ORNL-CCP has not issued anyNCRs for Waste Stream OR-REDC-RH-HET since the restart.D-16EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsCCP-TP-005 ImplementationAK-4:Confirm that Attachment 1, AcceptableKnowledge Documentation Checklist, is complete.CCP TP 005, Revision 26, Attachment 1, Signed byKevin Peters, 12/30/2013Att. 1 shows how ORNL-CCP addressed each WAPmandated AK element. The WAP is a portion of thesystem of controls in place to demonstrate compliancewith 40 CFR Part 194.24. Completion of Att. 1demonstrates that AK is collected under a system ofcontrols.AK-5:Confirm that Attachment 2, Record ofCommunication, is completed as necessary.Source Documents C098, C148, C302, C307, C308and C600Record of Communication is not mandatory, but providesa consistent format to document interviews or emailcommunications.AK-6:Confirm that an Attachment 3, AcceptableKnowledge Source Document Summary, is completefor every source document.See reference list in Attachment B to this report All provided source documents have an associated Att. 3summary.AK-7:Confirm that Attachment 4, AcceptableKnowledge Information List, is complete and up todate.CCP-TP-005, Revision 26, Attachment 4, Signed byKevin Peters, 12/23/2013Att. 4 shows all source documents ORNL-CCP examinedduring the course of the AK process. It provides amethodof checking unused references against the list in the AKSRto verify adequate compilation and consideration ofavailable AK data. EPA verified that Att. 4 contains allreferences cited in the AKSR, Revision 3.AK-8:Confirm that Attachment 6, Waste Form,Waste Material Parameters, Prohibited Items, andPackaging, is complete and up to date.CCP-TP-005, Revision 26, Attachment 6, Signed byKevin Peters, 12/30/2013WMP analysis memorandum, Signed by SteveSchafer, 4/28/2008The WMP values in the memorandum and AKSR,Revision 3, Table 5-1 are equivalent.Between re-start of waste characterization activities andthe EPA inspection, ORNL-CCP added 14 drums to thewaste stream from canisters that were originally generatedin 1996. The physical content of these drums is consistentwith the overall waste stream description, so revision ofthe WMP calculations is not warranted at this time.D-17EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-9:Confirm that Attachment 8, Waste ContainersList, is complete and up to date.Attachment 8 – Waste Containers List, signed byChristopher Chancellor, 4/14/2009, with attachedadd-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, 1/26/2010Additional add-container memoranda dated:8/26/2010, 5/20/2011, 1/17/2011, 1/3/2014,1/28/2014RH AK Tracking Spreadsheet dated 1/28/2014Att. 8, 4/14/ 2009, showed there were 21 55-gallondrumsin the waste stream at this time (supported by addcontainer memos generated between 5/2008 and 4/2009).Att. 8 has not been updated since initial approval;however, several more add-container memoranda areassociated with Att. 8.The total number of drums in the waste stream basedonAttachment 8 and all add-container memoranda is 649, butonly 327 are currently on the AK tracking spreadsheet.The AKE indicated and demonstrated that the discrepancywas due to subsequent movement of containers to CHorLLW waste streams following assay.AK-10:Confirm that Attachment 10, AcceptableKnowledge Re-evaluation Checklist, is completed asnecessary.N/AAKE confirmed that there have been no AcceptableKnowledge Re-Evaluation Checklists prepared for thiswaste stream since re-start.AK-11:Confirm that Attachment 11, AcceptableKnowledge Source Document DiscrepancyResolution, is completed as necessary.DR601, CCP-TP-005, Revision 18, Attachment 11,Signed by Kevin Peters, 6/20/2008 (physicaldescription discrepancy)DR602, CCP-TP-005, Revision 18, Attachment 11,Signed by Kevin Peters, 7/2/2008 [HazardousWaste Number (HWN) discrepancies]Discrepancy resolutions adequately addressed the issuesidentified. AKE confirmed that there have been no DRswritten since re-start.AK-12:Confirm that Attachment 13, CCP WasteStream Characterization Checklist, is completed foreach characterization lot.CCP-TP-005, Revision 26, Attachment 13, Lot 29,Draft, unsigned, undated, electronic file dated1/22/2014.Lot 28, Signed by Laura Nelson (SPM) and KevinPeters (AKE), 9/19/2011Historical characterization checklist provided todemonstrate provision of completed and approvedchecklist.AK-13:Confirm that Attachment 14, CCPAcceptable Knowledge Accuracy Report, iscompleted annually and verify that the AK accuracyreport memorandum is technically adequate.Acceptable Knowledge Accuracy Report: OakRidge National Laboratory Remote-HandledTransuranic (RH TRU) Waste Stream Number ORREDC-RH-HET, Lots 1 Through 29, Laura Nelson,draft dated 1/6/2014Acceptable Knowledge Accuracy Report: OakRidge National Laboratory Remote-HandledTransuranic (RH TRU) Waste Stream Number ORREDC-RH-HET, Lots 1 Through 28, Laura Nelson,1/11/ 2012EPA verified that the draft AK accuracy report adequatelyintegrates new information (Lot 29) and the previous AKaccuracy results.The 2012 AK accuracy report was prepared when CCPwas not active at the site. The AKE and SPM indicatedthat accuracy reports were prepared to address interimaudit requirements and confirmed that they have notassessed AK accuracy since resumption.D-18EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-14:Confirm that Attachment 15, CCP TRUWaste Correlation and Surrogate Summary Form, iscompleted as necessary.CCP-TP-005, Revision 26, Attachment 15, Signedby Kevin Peters, 11/26/2013.The CSSF verified the comparability of the CH REDCwaste stream and RH REDC waste stream with respecttoisotopic distribution and physical form/composition. CHradiological data are not currently used or comparedagainst RH radiological data; the RH scaling factors areused as default isotopics by the CH program for theCHREDC waste stream.AK-15:Confirm that the AKSR is complete andaccurately describes the subject waste.CCP-AK-ORNL-500, Revision 3, 1/8/2014CCP-AK-ORNL-500, Revision 4, 2/6/2014AKSR revised during EPA inspection. AKSR, Revision4,includes all required components. See AKRH-16–AKRH18 and AKRH-20–AKRH-22.Waste Stream Definition and Waste IdentificationAK-16:Verify that all waste within the waste streamwas generated from a single process/activity and thatthe generating process/activity is adequatelydescribed.CCP-AK-ORNL-500, Revision 3CCP-AK-ORNL-500, Revision 4Source Documents: C302, C600, DR601, P125,P161, P279 and U011RH REDC waste stream includes debris waste that wasgenerated in the REDC hot cell facility as part ofactivitiesrelated to target fabrication/ processing, analyticalchemistry lab analyses, and process development. TheREDC is still active, but the AKSR states that thewastestream is limited, at this time, to waste generatedbetween1972 and 2007.AK-17:Verify that all waste within the waste streamis similar in material and physical form and that theexpected physical parameters are adequatelydescribed.CCP-AK-ORNL-500, Revision 3CCP-AK-ORNL-500, Revision 4CCP-TP-005, Attachment 6 and memorandumSource Documents: M100, M105, M120, P125,P161, P058, U045 and U049RH REDC waste stream is comprised primarily of organic(16.97%) and inorganic (83.03%) debris waste itemsandgenerally consists of CPR, glass and metal.D-19EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-18:Verify that all waste within the waste streamhas similar radiological properties and that theexpected radiological characteristics are adequatelydescribed.CCP-AK-ORNL-500, Revision 3CCP-AK-ORNL-500, Revision 4CCP-AK-ORNL-501, Revision 4CCP-AK-ORNL-505A, Revision 1CCP-AK-ONRL-505B, Revision 1Source Documents: P161, I044, U011, U045 andU049The waste stream is composed of three major isotopicdistributions described as:•Pre-SETF (HFIR, 1972–1978)•SETF (HFIR & SETF, 1978–1991)•Mark 42 (which includes a Mark42 population andHIFR/HIFR subpopulation, 1991–2007)The REDC is primarily involved with the production,storage, and distribution of the transcurium products of249Bk,252Cf,253Es and257Fm that are produced byirradiation of curium targets (generated by irradiation of242Pu at SRS or ORNL) in the HFIR. Waste generatedfrom these activities is referred to as “HFIR” waste with aspecific isotopic distribution. Uranium fuel-cycleworkwas also performed in Building 7920 hot cells between1979 and 1986 in addition to the HFIR activities, whichcharacterizes the SETF isotopic distribution. The Mark-42grouping includes both Mark 42 campaigns and ongoingHFIR campaigns. The AKSR states that the predominantradionuclides in the waste stream by mass are242Pu and246Cm, and the predominant radionulcides by Ci% are244Cm and90Sr.D-20EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-19:Verify that waste containers are traceablefrom retrieval through CCP’s EPA-approvedcharacterization process?ORRH00681: Parent cask X10C9402622 inoverpack cask X10C9600188; VE BDR No.ORNLRHVE13004, 12/13/2013; DTC BDR No.ORRHDTC13001, assay on 12/24/2013; AKtracking spreadsheet, 1/28/2014ORRH00683: Parent cask X10C9402622 inoverpack cask X10C9600188; VE BDR No.ORNLRHVE13005, 12/16/2013; DTC BDR No.ORRHDTC13001, assay on 12/24/2013; AKtracking spreadsheet, 1/28/2014X10C9600188: M100; Add-ContainerMemorandum, 1/3/2014; AK tracking spreadsheet,1/28/2014The listed references indicated that the containersaretraceable from the point of generation throughplacement/removal on the AK tracking spreadsheet, toORNL-CCP BDR generation.The AKE described the container addition and evaluationprocess:1)Cask is identified by ORNL for AK consideration inthe waste stream.2)AK evaluated the cask against the AKSR and otherdata (including parent cask documentation) todetermine whether it fits the waste stream.3)Add the cask to the AK tracking spreadsheet andassign radiological characterization distribution basedon date (only) of cask material.4)As containers are VE’d, verify contents and prepareadd-container memoranda to add 55-gallon drums towaste stream.Note that the traceability drums were VE’d before AK wasasked to evaluate them for inclusion in the waste stream.In those instances, the cask evaluation is includedin theadd-container memorandum to document addition of thecask. Also, radiological distributions are assignedby theAKE on the AK tracking spreadsheet, and the radiologicalcharacterization team consults the spreadsheet to verifythe appropriate radiological distribution.Land Withdrawal Act RequirementsAK-20:Verify that all of the waste in the wastestream is defense in origin.CCP-AK-ORNL-500, Revision 3CCP-AK-ORNL-500, Revision 4Source Documents: M023, P258, P281 and U039REDC waste are “irretrievably commingled with materialsgenerated, in part, by the following atomic energydefenseactivities”:•Naval reactors development.•Defense nuclear materials production.•Defense nuclear waste and by-products management.•Defense research and development activities.D-21EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-21:Verify that none of the waste in the wastestream is spent nuclear fuel.CCP-AK-ORNL-500, Revision 3CCP-AK-ORNL-500, Revision 4Source Documents: DR009, P569, U038, U647,I022 and I023The AKSR, Revision 3, did not adequately address theSNF determination based on references DR009, P569 andU647, which clearly indicated that the site originallybelieved the waste to contain SNF. ORNL-CCP revisedthe AKSR to describe an evaluation that determinedthatthe waste generated from the processing of HFIR andMark-42 targets processed in the REDC are not SNFbecause they were not generated for the purpose ofpowergeneration.AK-22:Verify that none of the waste in the wastestream is high-level waste.CCP-AK-ORNL-500, Revision 3CCP-AK-ORNL-500, Revision 4Source Documents: DR009, P569, U038, U647,I022 and I023The AKSR, Revision 3, did not adequately address theHLW determination based onreferences DR009, P569 andU647, which clearly indicated that the site originallybelieved the waste to contain HLW. DOE determined thatthe REDC waste is not SNF (see checklist item AKRH21). For this reason, the processing of these targets cannotresult in the generation of HLW because the wastesarenotprimarily or solely materials resulting from a first-cycleextraction system (or equivalent) used in reprocessing ofSNF. Additionally, the LWR and fast reactor testspecimens processed during the SETF program involvedthe small-scale processing of these materials fordevelopment of separation and recovery technologies, andnot HLW from a reprocessing facility responsible for theseparation of fissile elements and/or transuraniumelements contained in SNF for the sole purpose ofrecovering desired materials.Waste Stream CertificationAK-23:Confirm that the certification plan iscomplete and adequately describes the role of AK inthe waste characterization methodology.CCP-AK-ORNL-502 Revision 4, 1/31/ 2014CCP-AK-ORNL-502, Revision 5, 2/6/2014Revision 4 of the certification plan did not addressHLW/SNF. ORNL-CCP revised section 4.1 of that reportto state that the waste stream did not include SNFor HLWand referenced back to the AKSR for additionalinformation.AK-24:Verify that the WSPF is complete andaccurate.Waste Stream Profile Form, Revision 0, 6/3/2009 ORNL-CCP added 14 drums to the waste stream inJanuary 2014. This constitutes an increase in wastevolume, but the AKE stated this was not sufficienttowarrant a new WSPF.D-22EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-25:Confirm that a characterization informationsummary, characterization reconciliation report andsummation of aspects are included in the WSPFpackage and are complete and accurate.Characterization Reconciliation Report, Lot 28,9/19/2011Characterization Information Summary, Lot 1,2/18/2009Summation of Aspects based on CCP-AK-ORNL500, Revision 0The Summation of Aspects will be updated to includethenew SNF/HLW information, but revision of theSummation is not critical at this time because theAKSRchanges do not modify the conclusion that the wastedoesnot contain SNF or HLW.AK-26:Confirm that a characterization informationsummary is adequately completed for eachcharacterization lot.Draft Characterization Information Summary, Lot29, electronic file dated 1/22/2014Characterization Information Summary Lot 28,9/19/2011The Lot 28 CIS verified adequate completion of thecharacterization lot and CIS preparation process.AK-27:Confirm that a characterizationreconciliation report is adequately completed foreach characterization lot.Draft Characterization Reconciliation Report, Lot29, electronic file dated 1/22/2014Characterization Reconciliation Report, Lot 28,9/19/2011The Lot 28 CRR verified adequate completion of theCRRand CRR preparation process.Data Quality ObjectivesAK-28:Identify how ORNL-CCP will meet theDQO for defense waste, HLW and SNFdetermination.CCP-AK-ORNL-502, Revision 4CCP-AK-ORNL-502, Revision 5The certification plan, Revision 4, did not addressSNFand HLW. ORNL-CCP revised the certification plan toinclude reference to DQOs/QAOs for SNF/HLW. Seechecklist item AKRH-23.AK-29:Identify how ORNL-CCP will meet theDQOs for radioactive properties: TRU wastedetermination, RH waste determination and activitydetermination.CCP-AK-ORNL-502, Revision 4CCP-AK-ORNL-502, Revision 5The certification plan, Revision 4, did not adequatelyaddress the activity determination DQO/QAOs withrespect to the role of AK in the activity determinationprocess. ORNL-CCP revised the certification plan toaddress this item.AK-30:Identify how ORNL-CCP will meet theDQOs for physical properties: liquids and physicalform.CCP-AK-ORNL-502, Revision 4CCP-AK-ORNL-502, Revision 5The certification plan, Revision 4, adequately addressedthe physical form and prohibited item DQOs.Tier 2 ReportingAK-31:Verify that ORNL-CCP has reported to EPAcompletion or revision of AK accuracy reports forthis waste stream annually, at a minimum.Acceptable Knowledge Accuracy Report: OakRidge National Laboratory Remote-HandledTransuranic (RH TRU) Waste Stream Number ORREDC-RH-HET, Lots 1 Through 28, Laura Nelson,1/11/ 2012ORNL-CCP resumed operations during FY14 1stquarterand has not completed an AK accuracy report for REDCRH waste stream since re-start.D-23EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-32:Verify that ORNL-CCP has reported to EPAcompletion or revision of DRs or data limitationinformation associated with this waste stream.CCP-TP-005, Attachment 4, 1/7/2014 ORNL-CCP resumedoperations during FY14 1stquarterand has not completed any DRs for REDC RH wastestream since re-start.AK-33:Verify that ORNL-CCP has reported toEPA completion or revision of a CorrelationSurrogate Summary Form.CCP-TP-005, Attachment 15, 11/26/2013 ORNL-CCP revised the CSSF on 11/26/2013 and shouldhave reported it in the FY14 1stquarter notification report.However, because ORNL-CCP did not submit the CSSFto CCP Records until 1/7/2014, EPA assumes that ORNLCCP is planning to report the revised document in theFY14 2ndquarter notification report.AK-34:Verify that ORNL-CCP has reported to EPAcompletion or revision of the CharacterizationReconciliation Reports and CharacterizationInformation Summaries.Draft Characterization Reconciliation Report, Lot29, electronic file dated 1/22/2014Characterization Reconciliation Report, Lot 28,9/19/2011Draft Characterization Information Summary, Lot29, electronic file dated 1/22/2014Characterization Information Summary Lot 28,9/19/2011ORNL-CCP resumed operations during FY14 1stquarterand has not completed any CRRs or CISs for REDC RHwaste stream since re-start.AK-35:Verify that ORNL-CCP has reported to EPAcompletion or revision of this waste stream’s AKSRor certification plan.CCP-AK-ORNL-500, Revision 3, 1/8/2014CCP-AK-ORNL-500, Revision 4, 2/6/2014CCP-AK-ORNL-502, Revision 3, 11/11/2013CCP-AK-ORNL-502, Revision 4, 1/31/2014CCP-AK-ORNL-502, Revision 5, 2/6/2014ORNL-CCP revised the certification plan (Revision 3) on11/11/2013 and correctly reported it in the FY14 1stquarter notification report.ORNL-CCP revised the AKSR and certification plantwice during FY14 2ndquarter (AKSR: 1/8/2014 and2/6/2014; certification plan: 1/31/2014 and 2/6/2014), bothof which were during the same quarter as the EPAinspection.AK-36:Verify that ORNL-CCP has reported to EPAcompletion or revision of the WSPF, includingchange notices, and the associated documentation forthis waste stream.Waste Stream Profile Form, Revision 0, 6/3/2009 ORNL-CCP resumed operations during FY14 1stquarterand has not revised the REDC RH WSPF since re-start.AK-37:Verify that ORNL-CCP has reported to EPAcompletion or revision of add-container memorandafor this waste stream.Add-container memorandum, 1/3/2014Add-container memorandum, 1/28/2014ORNL-CCP generated two add-container memorandaduring FY14 2ndquarter (1/3/2014 and 1/28/2014), whichwas still the current quarter during the EPA inspection.D-24EPA Inspection No.: ORNL-CC-2014 Waste Stream: OR-REDC-RH-HETInspection Date: February 4–6, 2014Technical ElementsObjective EvidenceCommentsAK-38:Verify that ORNL-CCP has reported toEPA completion or revision of CCP-AK-ORNL002.N/AORNL-CCP resumed operations during FY14 1stquarterand has not revised CCP-AK-ORNL-002 since re-start.E-1ATTACHMENT E: NDA CONTINUED COMPLIANCE INSPECTION CHECKLIST: IQ3TechnicalElementsObjective EvidenceAdditional CommentsGeneralIQ3-1: Confirm the NDA system is the same unitEPA inspected and approved previously.Located in Trailer No. NDA-IQ3-01, Building 7880 inthe CH Storage Area atORNL TWPC.EPA inspectors found the IQ3 inthe same location as EPA’s initialapproval.IQ3-2: Describe the IQ3.The IQ3 is a segmented gamma scanning system that acquires data with threedetectors simultaneously. An additional set of three detectors for isotopic analysesare mounted orthogonally to the first three.N/AIQ3-3: Identify the consensus standards thatwere used for the system calibrationASTM C-1030, C-1133, C-1215, E-181.As stated in MCS-IQ3-CALIB2012, and confirmed by interviewwith NDA personnel.IQ3-4: Describe the IQ3’s operational historysince the baseline approval.The IQ3 assay system was relocated to ORNL from SRSin 2009, followingwhich EPA approved it for WIPP assays. From May 2011 to September 2013 theIQ3 has been performing Non-WIPP assay. The IQ3 wasrecalibrated in 2012 byWAI following the replacement of detectors and electronic upgrades, and ORNLCCP has accepted the 2012 calibration.As confirmed by interviews withNDA personnel.IQ3-5: Identify the container types assayed onthe IQ3The IQ3 can assay 55-gallon drums only.Visual inspection confirms nocontainers larger than 55-gallonscan be assayed.IQ3-6: Identify the number of BDRs and wastecontainers this system assayed since resumingactivities.Since resuming activities, the IQ3 has assayed approximately 187 drums, whichwere compiled into 30 BDRs.None.IQ3-7: Confirm that the IQ3 is able to reportquantitative values for the WIPP-trackedradionuclidesDirect Measurements:239Pu,241Am,233U,235U,238U and137Cs.Isotopic Fractions:238Pu,240Pu,241Pu, relative to Pu,242Pu by correlation.Radionuclides by Scaling:90Sr and234U.CCP-ORNL-IQ3-003, Revision 0.As stated in CCP-ORNL-IQ3-003,Revision 0, and confirmed byinterviews with NDA personnelduring inspection.IQ3-8: Confirm the IQ3’s calibration of record.Documented in MCS-IQ3-CALIB-2012, Revision 1, provided during on-siteinspectionConfirmed with NDA personnelduring inspection.IQ3-9: Identify the procedures that govern thisfunction and where the results of thesecalculations 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).These procedures are the mostcurrent revisions. Copies of eachwere found and easily accessibleat the IQ3 operator station.IQ3-10: Confirm that the methods used to derivethe isotopic contribution for unmeasuredradionuclides are MGA and MGA-U.MGA and MGA-U are integral parts of the IQ3 operation as shown in CCP-TP047.Confirmed by interviews withORNL-CCP IQ3 personnel duringinspection.E-2TechnicalElementsObjective EvidenceAdditional CommentsIQ3-11: Confirm the IQ3 operational range withrespect to matrix (density) and activity.Range is defined as the system’s LLD and 175 g239Pu, limited by system deadtime. Density range is 0.015 to 1.64 g/cm3in density, multi-curve assays withoutattenuators. Expressly excluded is the use of the attenuated mode.EPA confirmed this with NDApersonnel during the inspection.Calibration Verification and ConfirmationIQ3-12: Identify the date of the last calibrationverification. Have any others been completed inthe last year?None were performed since resuming activities. EPAconfirmed this with NDApersonnel during the inspection.IQ3-13: Confirm the pedigree of all radionuclidestandards that were used for calibrationconfirmation and/or verifications.Sources are summarized in MCS-IQ3-CAL-CONF-RPT-2013-01. EPA reviewed all sourcecertificates, all standards areindependently certified andacceptable to use for the IQ3calibration.IQ3-14: Requirements for accuracy andprecision must be met, as specified inDOE/WIPP-02-3122, Appendix A, Table A-3.2for calibration verifications.The calibration verification results are containedin MCS-IQ3-CAL-CONF-RPT2013-01. % R was found to be between 70 and 130% and % RSD was found to beless than 14%.Accuracy and precision criteriawere met for all calibrationverifications.LLDIQ3-15: Confirm that the LLD for the IQ3 hasbeen determined.The LLD is documented in MCS-CAL-CONF-RPT, January2013, whichindicates that the instrument meets the WAC TRU/Non-TRU discriminationcriterion of 100 nCi/g or less.EPA confirmed this by interviewswith ORNL-CCP IQ3 personnelduring inspection and reviewingIQ3 BDR No. OR-IQ3-0224.IQ3-16: Confirm if the IQ3 is used todiscriminate TRU/non-TRU wastes at the 100nCi/g criterion and that it has the requiredsensitivity.The IQ3 can discriminate between non-TRU and TRU waste based on the LLDsreported in MCS-IQ3-CAL-CONF-RPT for all measured radionuclides.This is documented in the 2013calibration confirmation documentand IQ3 BDR No. OR-IQ3-0224.IQ3-17: Identify any/all instances where an LLDvalue for anon-measuredradionuclide is notprovided based on a lack of technical feasibility.Because an LLD is a measurement-based parameter, it is not technically feasibleto calculate for radionuclides that are not directly measured. Plutonium isotopes238Pu,240Pu and242Pu are not usually directly measured by gamma spectroscopyand are instead derived by ratios to measured239Pu. The reporting threshold for90Sr is computed based on the reported137Cs LLD using an activity ratiodetermined from AK-NDA memoranda. ORNL-CCP states that it is nottechnically feasible to provide an LLD equivalent for234U and that it is derived byalgorithm from measured values of235U,238U and238Pu.This is documented in the 2013calibration confirmationdocument.Quality ControlIQ3-18: All operators have current CCP trainingas verified on LOQI.LOQI provided on 2/3/2014 contains five operators,all with current training, seeIQ3-22, below.EPA verified that the operatorslisted in the LOQI match thoselisted in the IQ3 logbook.E-3TechnicalElementsObjective EvidenceAdditional CommentsIQ3-19: Confirm the IQ3’s status with respect tothe CBFO NDA PDP and last cycle.The IQ3 successfully participated in drum cycle 20Cof the CBFO NDA PDP byassaying four matrix drums: glass, combustibles, metals and sludge.EPA verified successful PDPparticipation, documented inCBFO approval letter.IQ3-20: All IQ3 data must be reviewed andapproved by qualified personnel. Identify thename and function of the individuals performingtechnical 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, 11/2015Maria Steade: Operator/ITR, 1/2016Bruce Gillespie: EA.Kevin Meyer: EA.Bob Ceo, EA.Bart Morales, EA.Tim Southwort, EA.All individuals performing thetechnical review are qualifiedaccording to the LOQI dated2/3/2014.IQ3-21: Identify any NCRs since resumingactivities last year.There have been no NCRs on the IQ3 since resuming characterization activitieslast year.EPA confirmed this by interviewswith ORNL-CCP personnel duringinspection.TMUIQ3-22: Identify any changes to the method ordetails of the TMU calculation since baseline.No changes to the TMU were made since resuming activities last year.EPA confirmed this by interviewswith ORNL-CCP personnel duringinspectionIQ3-23: Evaluate the magnitude of the TMUvalues observed in the IQ3 BDRs that wereexamined during this inspection.The TMU for the IQ3 is documented in CCP-ORNL-IQ3-002, TotalMeasurement Uncertainty for the IQ3 System, dated April 20, 2005. Thisdocument does not have a revision number. The components of uncertaintyincluded in the TMU determination consist of calibration source uncertainties,counting statistics, self-absorption effects, matrix nonhomogeneities, nonuniformsource distributions and isotopic measurement uncertainties. The software forperforming the TMU calculations is embedded in theNDA 2000 software. CCPORNL-IQ3-002 calls for administrative procedures that would define a minimumfill-height requirement to reduce the potential forincreased uncertainties due toend effects. TMU values in BDRs are generally consistent with expectations.EPA confirmed this by interviewswith ORNL-CCP personnel duringinspection.Background and Performance ChecksIQ3-24: Confirm that IQ3 backgroundmeasurements have been taken daily.Confirm that IQ3 background measurements have beentaken daily. EPA confirmed this by interviewswith NDA personnel. The logbookentries selected at random by EPAand IQ3 BDR No. OR-IQ3-0224doument this.E-4TechnicalElementsObjective EvidenceAdditional CommentsIQ3-25: Assess how often background radiationwas problematic to the extent that measurementpersonnel had to make adjustments.No instances of problematic backgrounds were observed since resuming activitieslast year.EPA confirmed this by interviewswith NDA personnel.IQ3-26: Confirm that system performancechecks have been performed at least once peroperational day. Confirm that performancechecks include gamma and neutron efficiency,matrix correction checks, and gamma peakposition and resolution checks.Performance checks are done once per day as statedin CCP-TP-019, Revision 6. EPA confirmed this by interviewswith NDA personnel. The logbookentries selected at random by EPAand IQ3 BDR No. OR-IQ3-0224document these checks.Data ManagementIQ3-27: IQ3 BDRs contain:•Testing facility name, testing batch number,container numbers, and signature of the SPMor designee•Table of contents•Background and performance check data orcontrol charts for the relevant time period•Separate testing report sheets for eachcontainerEPA reviewed IQ3 BDR No. OR-IQ3-0224 and found it to contain appropriateinformation.N/AIQ3-28: IQ3 RDSs must include:•Title “Radioassay Data Sheet”•Method/procedure used•Date of radioassay•Activities and associated TMU for individualradionuclides•TRU alpha concentration and its associatedTMU•Operator and reviewer signaturesEPA reviewed IQ3 BDR No. OR-IQ3-0224 and found it to contain appropriateinformation.N/AF-1ATTACHMENT F.1: REPLICATE TESTING DATA FOR DRUM NO.X10CSATN02241LInstrument: IQ3Container: X10CSATN02241LQuantity of InterestOriginal Measurement Replicate #1 Replicate #2Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeValue Uncertainty UncertaintyValue Uncertainty UncertaintyValue Uncertainty Uncertainty233U Activity (Ci) N/A N/A N/A234U Activity (Ci) N/A N/A N/A238U Activity (Ci) N/A N/A N/A238Pu Activity (Ci) 1.26E-03 2.95E-03 2.34E+00 1.26E-03 2.97E-03 2.36E+00 1.26E-03 2.96E-03 2.35E+00239Pu Activity (Ci) 1.18E-03 1.99E-03 1.69E+00 1.19E-03 2.00E-03 1.68E+00 1.18E-03 1.99E-03 1.69E+00240Pu Activity (Ci) 2.01E-03 3.39E-03 1.69E+00 2.02E-03 3.41E-03 1.69E+00 2.01E-03 3.39E-03 1.69E+00242Pu Activity (Ci) 1.93E-06 3.26E-06 1.69E+00 1.95E-06 3.28E-06 1.68E+00 1.94E-06 3.26E-06 1.68E+00241Am Activity (Ci) 2.13E-03 3.33E-04 1.56E-01 2.12E-03 3.32E-04 1.57E-01 2.12E-03 3.32E-04 1.57E-0190Sr Activity (Ci) 1.78E-02 2.71E-03 1.52E-01 1.80E-02 2.75E-03 1.53E-01 1.81E-02 2.76E-03 1.53E-01137Cs Activity (Ci) 1.03E-03 1.57E-04 1.52E-01 1.04E-03 1.59E-04 1.53E-01 1.05E-03 1.60E-04 1.52E-01TRU Alpha Conc. (nCi/g) 6.49E+02 4.35E+02 6.70E-016.51E+02 4.38E+02 6.73E-01 6.49E+02 4.36E+02 6.72E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeValue Uncertainty UncertaintyValue Uncertainty UncertaintyValue Uncertainty Uncertainty233U Activity (Ci) N/A N/A N/A234U Activity (Ci) N/A N/A N/A238U Activity (Ci) N/A N/A N/A238Pu Activity (Ci) 1.27E-03 2.98E-03 2.35E+00 1.27E-03 3.00E-03 2.36E+00 1.26E-03 2.96E-03 2.35E+00239Pu Activity (Ci) 1.19E-03 2.00E-03 1.68E+00 1.20E-03 2.01E-03 1.68E+00 1.18E-03 1.99E-03 1.69E+00240Pu Activity (Ci) 2.02E-03 3.41E-03 1.69E+00 2.04E-03 3.44E-03 1.69E+00 2.02E-03 3.40E-03 1.68E+00242Pu Activity (Ci) 1.95E-06 3.28E-06 1.68E+00 1.96E-06 3.31E-06 1.69E+00 1.94E-06 3.27E-06 1.69E+00241Am Activity (Ci) 2.14E-03 3.35E-04 1.57E-01 2.18E-03 3.41E-04 1.56E-01 2.15E-03 3.37E-04 1.57E-0190Sr Activity (Ci) 1.83E-02 2.79E-03 1.53E-01 1.84E-02 2.82E-03 1.53E-01 1.83E-02 2.79E-03 1.53E-01137Cs Activity (Ci) 1.06E-03 1.62E-04 1.53E-01 1.07E-03 1.63E-04 1.52E-01 1.06E-03 1.62E-04 1.53E-01TRU Alpha Conc. (nCi/g) 6.53E+02 4.39E+02 6.72E-016.60E+02 4.42E+02 6.70E-01 6.52E+02 4.37E+02 6.70E-01F-2Quantity of InterestOriginal Measurementχ2Pr(x<|χ2|)Reported Absolute Sample Standard StandardValue Uncertainty Mean Deviation Deviation233U Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/A234U Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/A238U Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/A238Pu Activity (Ci) 1.26E-03 2.95E-031.26E-03 5.48E-06 4.33E-031.38E-05 1.00E+00239Pu Activity (Ci) 1.18E-03 1.99E-031.19E-03 8.37E-06 7.04E-037.07E-05 1.00E+00240Pu Activity (Ci) 2.01E-03 3.39E-032.02E-03 1.10E-05 5.42E-034.18E-05 1.00E+00242Pu Activity (Ci) 1.93E-06 3.26E-061.95E-06 8.37E-09 4.29E-032.64E-05 1.00E+00241Am Activity (Ci) 2.13E-03 3.33E-042.14E-03 2.49E-05 1.16E-022.24E-02 1.00E+0090Sr Activity (Ci) 1.78E-02 2.71E-031.82E-02 1.64E-04 9.02E-031.47E-02 1.00E+00137Cs Activity (Ci) 1.03E-03 1.57E-041.06E-03 1.14E-05 1.08E-022.12E-02 1.00E+00TRU Alpha Conc. (nCi/g) 6.49E+02 4.35E+026.53E+02 4.18E+00 6.41E-033.70E-04 1.00E+00Quantity of Interestt Pr(x<|t|)χ2Test t Test233U Activity (Ci) N/A N/ANot Applicable Not Applicable234U Activity (Ci) N/A N/ANot Applicable Not Applicable238U Activity (Ci) N/A N/ANot Applicable Not Applicable238Pu Activity (Ci) -6.67E-01 5.41E-01Not Significant Not Significant239Pu Activity (Ci) -8.73E-01 4.32E-01Not Significant Not Significant240Pu Activity (Ci) -1.00E+00 3.74E-01Not Significant Not Significant242Pu Activity (Ci) -1.96E+00 1.21E-01Not Significant Not Significant241Am Activity (Ci) -4.40E-01 6.83E-01Not Significant Not Significant90Sr Activity (Ci) -2.33E+00 8.00E-02Not Significant Not Significant137Cs Activity (Ci) -2.08E+00 1.06E-01Not Significant Not SignificantTRU Alpha Conc. (nCi/g) -8.73E-01 4.32E-01Not Significant Not SignificantF-3ATTACHMENT F.2: REPLICATE TESTING DATA FOR DRUM NO.NFS0419DInstrument: IQ3Container: NFS0419DQuantity of InterestOriginal Measurement Replicate #1 Replicate #2Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeValue Uncertainty UncertaintyValue Uncertainty UncertaintyValue Uncertainty Uncertainty233U Activity (Ci) 1.16E-03 1.95E-04 1.68E-01 1.03E-031.75E-04 1.70E-01 1.11E-03 1.87E-04 1.69E-01234U Activity (Ci)N/AN/AN/A238U Activity (Ci)N/AN/AN/A238Pu Activity (Ci) 3.64E-04 8.55E-04 2.35E+00 5.83E-04 3.00E-04 5.15E-01 7.45E-04 1.78E-04 2.39E-01239Pu Activity (Ci) 2.86E-03 6.71E-03 2.35E+00 4.59E-03 2.28E-03 4.97E-01 5.86E-03 1.15E-03 1.96E-01240Pu Activity (Ci) 1.03E-03 2.41E-03 2.34E+00 1.64E-03 8.49E-04 5.18E-01 2.10E-03 5.08E-04 2.42E-01242Pu Activity (Ci) 2.45E-07 5.75E-07 2.35E+00 3.93E-07 2.03E-07 5.18E-01 5.01E-07 1.21E-07 2.42E-01241Am Activity (Ci) 1.97E-03 4.63E-03 2.35E+00 3.16E-03 1.63E-03 5.16E-01 4.04E-03 9.74E-04 2.41E-0190Sr Activity (Ci) 3.46E-06 5.63E-07 1.63E-01 3.48E-06 5.67E-07 1.63E-01 3.47E-06 5.66E-07 1.63E-01137Cs Activity (Ci) 3.46E-06 5.63E-07 1.63E-01 3.48E-06 5.67E-07 1.63E-01 3.47E-06 5.66E-07 1.63E-01TRU Alpha Conc. (nCi/g) 2.98E+02 4.05E+02 1.36E+004.76E+02 1.39E+02 2.92E-01 6.07E+02 7.59E+01 1.25E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeValue Uncertainty UncertaintyValue Uncertainty UncertaintyValue Uncertainty Uncertainty233U Activity (Ci) 1.15E-03 1.94E-04 1.69E-01 1.10E-031.88E-04 1.71E-01 1.01E-03 1.72E-04 1.70E-01234U Activity (Ci)N/AN/AN/A238U Activity (Ci)N/AN/AN/A238Pu Activity (Ci) 4.71E-04 1.16E-04 2.46E-01 6.69E-04 1.62E-04 2.42E-01 5.32E-04 1.28E-04 2.41E-01239Pu Activity (Ci) 3.71E-03 7.61E-04 2.05E-01 5.26E-03 1.06E-03 2.02E-01 4.18E-03 8.30E-04 1.99E-01240Pu Activity (Ci) 1.33E-03 3.31E-04 2.49E-01 1.89E-03 4.63E-04 2.45E-01 1.50E-03 3.65E-04 2.43E-01242Pu Activity (Ci) 3.17E-07 7.89E-08 2.49E-01 4.50E-07 1.10E-07 2.44E-01 3.58E-07 8.70E-08 2.43E-01241Am Activity (Ci) 2.56E-03 6.35E-04 2.48E-01 3.63E-03 8.87E-04 2.44E-01 2.88E-03 7.00E-04 2.43E-0190Sr Activity (Ci) 3.46E-06 5.63E-07 1.63E-01 3.42E-06 5.58E-07 1.63E-01 3.53E-06 5.75E-07 1.63E-01137Cs Activity (Ci) 3.46E-06 5.63E-07 1.63E-01 3.42E-06 5.58E-07 1.63E-01 3.53E-06 5.75E-07 1.63E-01TRU Alpha Conc. (nCi/g) 3.85E+02 4.98E+01 1.29E-015.45E+02 6.93E+01 1.27E-01 4.34E+02 5.46E+01 1.26E-01F-4Quantity of InterestOriginal Measurementχ2Pr(x<|χ2|)Reported Absolute Sample Standard StandardValue Uncertainty Mean Deviation Deviation233U Activity (Ci) 1.16E-03 1.95E-041.08E-03 5.83E-05 5.40E-023.58E-01 9.86E-01234U Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/A238U Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/A238Pu Activity (Ci) 3.64E-04 8.55E-046.00E-04 1.09E-04 1.81E-016.48E-02 9.99E-01239Pu Activity (Ci) 2.86E-03 6.71E-034.72E-03 8.54E-04 1.81E-016.49E-02 9.99E-01240Pu Activity (Ci) 1.03E-03 2.41E-031.69E-03 3.07E-04 1.81E-016.48E-02 9.99E-01242Pu Activity (Ci) 2.45E-07 5.75E-074.04E-07 7.30E-08 1.81E-016.45E-02 9.99E-01241Am Activity (Ci) 1.97E-03 4.63E-033.25E-03 5.89E-04 1.81E-016.48E-02 9.99E-0190Sr Activity (Ci) 3.46E-06 5.63E-073.47E-06 3.96E-08 1.14E-021.98E-02 1.00E+00137Cs Activity (Ci) 3.46E-06 5.63E-073.47E-06 3.96E-08 1.14E-021.98E-02 1.00E+00TRU Alpha Conc. (nCi/g) 2.98E+02 4.05E+024.89E+02 8.81E+01 1.80E-011.89E-01 9.96E-01Quantity of Interestt Pr(x<|t|)χ2Test t Test233U Activity (Ci) 1.25E+00 2.79E-01Not Significant Not Significant234U Activity (Ci) N/A N/ANot Applicable Not Applicable238U Activity (Ci) N/A N/ANot Applicable Not Applicable238Pu Activity (Ci) -1.98E+00 1.19E-01Not Significant Not Significant239Pu Activity (Ci) -1.99E+00 1.18E-01Not Significant Not Significant240Pu Activity (Ci) -1.97E+00 1.20E-01Not Significant Not Significant242Pu Activity (Ci) -1.99E+00 1.18E-01Not Significant Not Significant241Am Activity (Ci) -1.99E+00 1.18E-01Not Significant Not Significant90Sr Activity (Ci) -2.76E-01 7.96E-01Not Significant Not Significant137Cs Activity (Ci) -2.76E-01 7.96E-01Not Significant Not SignificantTRU Alpha Conc. (nCi/g) -1.98E+00 1.18E-01Not Significant Not SignificantF-5ATTACHMENT F.3: REPLICATE TESTING DATA FOR DRUM NO.NFS0478AInstrument: IQ3Container: NFS0478AQuantity of InterestOriginal Measurement Replicate #1 Replicate #2Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeValue Uncertainty UncertaintyValue Uncertainty UncertaintyValue Uncertainty Uncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci)N/AN/AN/A238U Activity (Ci) 3.68E-06 5.62E-07 1.53E-01 3.17E-064.88E-07 1.54E-01 3.16E-06 4.88E-07 1.54E-01238Pu Activity (Ci) 1.34E-02 2.17E-03 1.62E-01 1.03E-02 1.77E-03 1.72E-01 1.32E-02 2.16E-02 1.64E+00239Pu Activity (Ci) 1.75E-01 2.56E-02 1.46E-01 1.79E-01 2.62E-02 1.46E-01 1.81E-01 2.65E-02 1.46E-01240Pu Activity (Ci) 3.86E-02 5.73E-03 1.48E-01 3.92E-02 5.84E-03 1.49E-01 3.87E-02 5.75E-03 1.49E-01242Pu Activity (Ci) 3.99E-06 7.08E-07 1.77E-01 4.06E-06 7.21E-07 1.78E-01 4.01E-06 7.12E-07 1.78E-01241Am Activity (Ci) 7.14E-02 1.05E-02 1.47E-01 7.30E-02 1.07E-02 1.47E-01 7.35E-02 1.08E-02 1.47E-0190Sr Activity (Ci) 2.96E-07 4.34E-08 1.47E-01 4.80E-07 7.01E-08 1.46E-01 4.77E-07 6.97E-08 1.46E-01137Cs Activity (Ci) 2.96E-07 4.34E-08 1.47E-01 4.80E-07 7.01E-08 1.46E-01 4.77E-07 6.97E-08 1.46E-01TRU Alpha Conc. (nCi/g) 4.38E+04 4.17E+03 9.52E-024.43E+04 4.26E+03 9.62E-02 4.50E+04 4.30E+03 9.56E-02Quantity of InterestReplicate #3 Replicate #4 Replicate #5Reported Absolute Relative Reported Absolute Relative Reported Absolute RelativeValue Uncertainty UncertaintyValue Uncertainty UncertaintyValue Uncertainty Uncertainty233U Activity (Ci)N/AN/AN/A234U Activity (Ci)N/AN/AN/A238U Activity (Ci) 4.13E-06 6.26E-07 1.52E-01 3.50E-065.36E-07 1.53E-01 3.66E-06 5.59E-07 1.53E-01238Pu Activity (Ci) 1.30E-02 2.14E-03 1.65E-01 1.23E-02 2.05E-03 1.67E-01 1.32E-02 2.17E-03 1.64E-01239Pu Activity (Ci) 1.88E-01 2.75E-02 1.46E-01 1.81E-01 2.65E-02 1.46E-01 1.80E-01 2.64E-02 1.47E-01240Pu Activity (Ci) 3.92E-02 5.83E-03 1.49E-01 4.09E-02 6.08E-03 1.49E-01 3.88E-02 5.77E-03 1.49E-01242Pu Activity (Ci) 4.10E-06 7.28E-07 1.78E-01 4.24E-06 7.52E-07 1.77E-01 4.03E-06 7.15E-07 1.77E-01241Am Activity (Ci) 7.65E-02 1.12E-02 1.46E-01 7.50E-02 1.10E-02 1.47E-01 7.35E-02 1.08E-02 1.47E-0190Sr Activity (Ci) 4.74E-07 6.92E-08 1.46E-01 4.06E-07 5.95E-08 1.47E-01 3.80E-07 5.56E-08 1.46E-01137Cs Activity (Ci) 4.74E-07 6.92E-08 1.46E-01 4.06E-07 5.95E-08 1.47E-01 3.80E-07 5.56E-08 1.46E-01TRU Alpha Conc. (nCi/g) 4.65E+04 4.46E+03 9.59E-024.55E+04 4.33E+03 9.52E-02 4.49E+04 4.29E+03 9.55E-02F-6Quantity of InterestOriginal Measurementχ2Pr(x<|χ2|)Reported Absolute Sample Standard StandardValue Uncertainty Mean Deviation Deviation233U Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/A234U Activity (Ci) 0.00E+00 N/AN/A N/A N/AN/A N/A238U Activity (Ci) 3.68E-06 5.62E-073.52E-06 4.01E-07 1.14E-012.04E+00 7.28E-01238Pu Activity (Ci) 1.34E-02 2.17E-031.24E-02 1.23E-03 9.93E-021.29E+00 8.63E-01239Pu Activity (Ci) 1.75E-01 2.56E-021.82E-01 3.56E-03 1.96E-027.75E-02 9.99E-01240Pu Activity (Ci) 3.86E-02 5.73E-033.94E-02 8.91E-04 2.26E-029.67E-02 9.99E-01242Pu Activity (Ci) 3.99E-06 7.08E-074.09E-06 9.15E-08 2.24E-026.68E-02 9.99E-01241Am Activity (Ci) 7.14E-02 1.05E-027.43E-02 1.44E-03 1.94E-027.52E-02 9.99E-0190Sr Activity (Ci) 2.96E-07 4.34E-084.43E-07 4.70E-08 1.06E-014.69E+00 3.21E-01137Cs Activity (Ci) 2.96E-07 4.34E-084.43E-07 4.70E-08 1.06E-014.69E+00 3.21E-01TRU Alpha Conc. (nCi/g) 4.38E+04 4.17E+034.52E+04 8.23E+02 1.82E-021.56E-01 9.97E-01Quantity of Interestt Pr(x<|t|)χ2Test t Test233U Activity (Ci) N/A N/ANot Applicable Not Applicable234U Activity (Ci) N/A N/ANot Applicable Not Applicable238U Activity (Ci) 3.55E-01 7.41E-01Not Significant Not Significant238Pu Activity (Ci) 7.42E-01 4.99E-01Not Significant Not Significant239Pu Activity (Ci) -1.74E+00 1.56E-01Not Significant Not Significant240Pu Activity (Ci) -7.79E-01 4.79E-01Not Significant Not Significant242Pu Activity (Ci) -9.78E-01 3.84E-01Not Significant Not Significant241Am Activity (Ci) -1.84E+00 1.40E-01Not Significant Not Significant90Sr Activity (Ci) -2.86E+00 4.57E-02Not SignificantSignificant137Cs Activity (Ci) -2.86E+00 4.57E-02Not SignificantSignificantTRU Alpha Conc. (nCi/g) -1.60E+00 1.86E-01Not Significant Not Significant

# G-1



# ATTACHMENT G: DOSE-TO-CURIE CONTINUED COMPLIANCE IN SPECTION

CHECKLIST

EPA Inspectors Present: Patrick Kelly

Location of DTC: DTC occurs in the DTC Alcove in Building 7880 Proce ss 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 o perators 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 137 

# Cs 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, EP A received a copy.

BDR No: Not yet assigned number. CCP will provide BDR to EP A 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 @ 0 o 

# : 8.53 mR/h

Dose Rate @ 90 o 

# : 8.33 mR/h

# G-2



# Dose Rate @ 180 o 

# : 7.34 mR/h

Dose Rate @ 270 o 

# : 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 neutronH-1ATTACHMENT H: NDE CONTINUED COMPLIANCE INSPECTION CHECKLIST: CH RTREPA Inspection No.: ORNL-CC-2014Inspection Date: February 4–6, 2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective EvidenceRTR-1: Site procedures identify required trainingand qualifications for RTR personnelCCP-TP-028, Revision 8CCP-QP-002, Revision 35RTR operators receive training on the waste matrixparameters and typical packaging configurationsexpected in each waste stream.To become qualified, the RTR operator must pass acomprehensive written test based on trainingobjectives with a minimum score of 80%Unsatisfactory performance – failed to identifyprohibited item during OJT of score of less than80% on examDemonstrate capability (At initial qualification,requalification, and semiannually, successfullyexamine atrainingcontainer).At initial qualification, and subsequentre-qualification, successfully examine atestdrum.RHVE operators re-qualified every 2 years basedon continued satisfactory performanceInventory sheets for RTR containers NDE-TEST-11,NDE-TEST-20, NDE-TEST-22, NDE-TRAINING-19,NDE-TRAINING-26, NDE-TRAINING-30, NDETRAINING-32Training Container Evaluation Data Sheets for variousRTR operatorsQualification Cards for selected RTR personnelTraining roster for CCP-AK-ORNL-001, Revisions 7and 8LOQI RTR operators dated 1/21/14Revisions 1 and 2 of Prohibited Items training forRTRoperatorsAmerican Society for Nondestructive Testing,Recommended Practices, No. SNT-TC-1A, June 1980EditionRTR-2: Site procedure(s) provide completeinstructions for operators to perform the RTRexamination and completion of the associateddocumentationCCP-TP-053, Revision 14RTR operator adequately explained the processfollowed for examining a drum and entering datainto data forms (whether hard copy or electronicdata entry is used).CH RTR BDR Nos. OR-RTR6-0440, OR-RTR7-0002,OR-RTR7-0007 and OR-RTR7-0008Audio/visual recordings for selected containers fromthe above CH BDRsRadiography Data Sheet for demonstration containerX10CSATN02022JTraining roster for CCP-AK-ORNL-001 Revisions 7and 8CCP-TP-053, CCP CH Standard Real-TimeRadiography Inspection Procedure, Revision 14,09/25/2013H-2EPA Inspection No.: ORNL-CC-2014Inspection Date: February 4–6, 2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective EvidenceRTR-3: The RTR procedure(s) require an imagequality check to be performedCCP-TP-053, Revision 14, section 4.3, Attachment1Operator adequately explained how theacceptability of an image is determinedImage quality check is performed once per day(RTR Measurement Control Report)Performance of the image quality check isdocumented and recordedCH RTR BDR Nos. OR-RTR6-0440, OR-RTR7-0002,OR-RTR7-0007 and OR-RTR7-0008Audio/visual recordings for selected containers fromthe above CH BDRsCCP-TP-053, CCP CH Standard Real-TimeRadiography Inspection Procedure, Revision 14,09/25/2013RTR-4: The procedure allows the operator to adjustthe RTR to accommodate the physical properties ofthe waste and waste containers likely to beencountered at the siteCCP-TP-053, Revision 14Operator could identify applicable policies andprocedures governing the operation of RTRequipmentThe RTR system could be adjustedHigh-density material was examined with the Xray device set on the maximum voltage and lowdensity material at a lower voltageOperator adequately explained what is done if animage is unacceptable (e.g., the waste is solidifiedor the container is lead-lined)CH RTR BDR Nos. OR-RTR6-0440, OR-RTR7-0002,OR-RTR7-0007 and OR-RTR7-0008Audio/visual recordings for selected containers fromthe above CH BDRsRadiography Data Sheet for demonstration containerX10CSATN02022JQualification Cards and training records for thedemonstration RTR operatorTraining Container Evaluation Data Sheets for variousRTR operatorsTraining roster for CCP-AK-ORNL-001 Revisions 7and 8CCP-TP-053, CCP CH Standard Real-TimeRadiography Inspection Procedure, Revision 14,09/25/2013RTR-5: Data records are of sufficiently high qualityfor complete reviewCCP-TP-053, Revision 14RTR tape is high quality, the sound track isaudible, and the required information is containedon the audible portion of the tapeThe RTR tape is consistent with the data packagefor the same drumCH RTR BDR Nos. OR-RTR6-0440, OR-RTR7-0002,OR-RTR7-0007 and OR-RTR7-0008Audio/visual recordings for selected containers fromthe above CH BDRsCCP-TP-053, CCP CH Standard Real-TimeRadiography Inspection Procedure, Revision 14,09/25/2013H-3EPA Inspection No.: ORNL-CC-2014Inspection Date: February 4–6, 2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective EvidenceRTR-6: There is a procedure for determiningwhether the waste matches the waste streamdescription and Waste Matrix Code, and fordetermining Waste Material Parameters and weightsCCP-TP-053, Revision 14, Tables 2 & 3,Attachment 2The procedure is adequately implementedOperators verify that the waste matches the wastestream descriptionWaste Matrix Code is verified. If not, correctiveaction is takenWMP weights are estimated by compiling aninventory of waste items and residual/packagingmaterialsDoes the RTR operator use a standard weightlookup table to provide an estimate of WMPweights? If so, has the table been updated toreflect additional information gained throughprevious RTR/VE exams or updated AKinformation?CH RTR BDR Nos. OR-RTR6-0440, OR-RTR7-0002,OR-RTR7-0007 and OR-RTR7-0008Audio/visual recordings for selected containers fromthe above CH BDRsCCP-TP-053, CCP CH Standard Real-TimeRadiography Inspection Procedure, Revision 14,09/25/2013RTR-7: The RTR procedure provides instructionsfor identifying prohibited items and for processingdrums containing prohibited itemsCCP-TP-053, Revision 14, Table 1Operator could name prohibited itemsOperator adequately explained how the presence ofprohibited liquids is determinedOperator’s explanation of required actions ifprohibited items were encountered was consistentwith procedureCH RTR BDR Nos. OR-RTR6-0440, OR-RTR7-0002,OR-RTR7-0007 and OR-RTR7-0008Audio/visual recordings for selected containers fromthe above CH BDRsProhibited Item training module, Revisions 7 and 8,dated 8/23/2010 and 3/29/2011 respectively.RTR-8: RTR procedures include the required QCexaminations, evaluation accuracy andreproducibility of the RTR processCCP-TP-053, Revision 14, sections 4.5 & 4.6An independent replicate scan is performed on onewaste container per day or on one container pertesting batch (whichever is less frequent)An independent observation of one scan (not thereplicate) is performed, by a qualified RTRoperator (anyone but the initial RTR operator)CH RTR BDR Nos. OR-RTR6-0440, OR-RTR7-0002,OR-RTR7-0007 and OR-RTR7-0008Audio/visual recordings for selected containers fromthe above CH BDRsCCP-TP-053, CCP CH Standard Real-TimeRadiography Inspection Procedure, Revision 14,09/25/201CCP-TP-053, CCP CH Standard Real-TimeRadiography Inspection Procedure, Revision 14,09/25/2013H-4EPA Inspection No.: ORNL-CC-2014Inspection Date: February 4–6, 2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective EvidenceRTR-9: Procedure(s) contain standardized forms forrecording RTR dataCCP-TP-053, Revision 14, Attachment 2RTR operator adequately explained the processfollowed for examining a drum and entering datainto data forms (whether hard copy or electronicdata entry is used).Direct data entry into an electronic form is done bythe RTR operator using a computer while theoperator is still in the RTR booth.The electronic data file undergoes the same QCchecks used for hand-written data entriesCH RTR BDR Nos. OR-RTR6-0440, OR-RTR7-0002,OR-RTR7-0007 and OR-RTR7-0008Audio/visual recordings for selected containers fromthe above CH BDRsRadiography Data Sheet for demonstration containerX10CSATN02022JCCP-TP-053, CCP CH Standard Real-TimeRadiography Inspection Procedure, Revision 14,09/25/2013RTR-10: Site procedures require review of BDRs atthe data generation and project levelCCP-TP-053, Revision 14, section 4.10CCP-TP-001, Revision 21, Attachment 2Data generation level reviews are performed anddocumented (ITR)Project level reviews are performed anddocumented (SPM)CH RTR BDR Nos. OR-RTR6-0440, OR-RTR7-0002,OR-RTR7-0007, and OR-RTR7-0008I-1ATTACHMENT H: NDE CONTINUED COMPLIANCE INSPECTION CHECKLIST: RH VEEPA Inspection No.: ORNL-CC-2014Inspection Date: February 4–6, 2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective EvidenceRHVE-1: Site procedures identify required trainingand qualifications for RHVE personnelCCP-QP-002, Revision 35Formal training elements include: projectrequirements, container identification and labeling,applicable state andfederalregulationsSite-specific training program:OJT,identification of summary category groups, WMPs,packaging configurations, residual liquids.Qualification cards for selected VE operatorsQualification Card for ORNL RH VEEVEE appointment letter, dated October, 2013CCP-AK-ORNL-001, Revisions 7 and 8, training sign-insheetCCP-PO-001, CCP Transuranic Waste CharacterizationQuality Assurance Project Plan, Revision 21, 05/31/2013CCP-QP-002, CCP Training and Qualification Plan,Revision 35, 6/06/2013RHVE-2: Operator qualification and re-qualificationrequirements are describedCCP-QP-002, Revision 35, s. 4.3.6To become qualified, the RHVE operator must passa comprehensive written test with an 80 percent orbetter grade that addresses VE operations,documentation, characterization, formal trainingelements, and procedural elements.VE Operators must demonstrate capability in thepresence of the site VEE during OJT. However, theformal training and OJT is conducted by a qualifiedSME.Qualification cards for selected VE operatorsQualification Card for ORNL RH VEEVEE appointment letter, dated October, 2013CCP-AK-ORNL-001, Revisions 7 and 8, training sign-insheetCCP-PO-001, CCP Transuranic Waste CharacterizationQuality Assurance Project Plan, Revision 21, 05/31/2013CCP-QP-002, CCP Training and Qualification Plan,Revision 35, 6/06/2013RHVE-3: Each site has a designated VEECCP-QP-002, Revision 35, s. 4.4.CCP-PO-001, QAPP, Revision 21VEE designation is documentedVEE has knowledge of the RH TRU waste beingcharacterizedResponsible for overall direction andimplementation of VE at the facilityCertification Planspecifies the selection,qualification, and training requirements of VEEQualification Card for ORNL RH VEEVEE appointment letter, dated October, 2013CCP-AK-ORNL-001, Revisions 7 and 8, training sign-insheetCCP-PO-001, CCP Transuranic Waste CharacterizationQuality Assurance Project Plan, Revision 21, 05/31/2013CCP-QP-002, CCP Training and Qualification Plan,Revision 35, 06/06/2013I-2EPA Inspection No.: ORNL-CC-2014Inspection Date: February 4–6, 2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective EvidenceRHVE-4: Procedures and technical guidancedocuments provide complete instructions forperforming RHVECCP-TP-500, Revision 13, s. 4.1-4.2, Attachment 1100% of containers will be subject to VE at the timeof packagingWaste Stream Description and WMC verifiedPresence/absence of prohibited items confirmedTwo operators used even if audio/visual recordingof VE is generatedQualification cards for selected VE operatorsQualification Card for ORNL RH VEEVEE appointment letter, dated October, 2013CCP-AK-ORNL-001, Revisions 7 and 8, training sign-insheetRH VE BDR Nos. ORNLRHVE13001,ORNLRHVE13002, ORNLRHVE13003,ORNLRHVE13004, ORNLRHVE13005 andORNLRHVE13006CCP-PO-001, CCP Transuranic Waste CharacterizationQuality Project Assurance Plan, Revision 21, 05/31/2013CCP-QP-002, CCP Training and Qualification Plan,Revision 35, 06/06/2013CCP-TP-500, CCP Remote-Handled Waste VisualExamination, Revision 13, 04/21/2013RHVE-5: Corrective actions are taken whennecessaryCCP-TP-500, Revision 13, s. 2.4.2Operators were able to describe how they initiate acorrective actionQualification cards for selected VE operatorsQualification Card for ORNL RH VEECCP-QP-005, CCP TRU Nonconforming Item Reportingand Control, Revision 23, 06/25/2013RH VE BDR Nos. ORNLRHVE13001,ORNLRHVE13002, ORNLRHVE13003,ORNLRHVE13004, ORNLRHVE13005 andORNLRHVE13006CCP-TP-500, CCP Remote-Handled Waste VisualExamination, Revision 13, 04/21/2013RHVE-6: Site procedure(s) require data generationand project level reviews of BDRsCCP-TP-500, Revision 13ITR review Attachment 2SPM review Attachment 3RH VE BDR Nos. ORNLRHVE13001,ORNLRHVE13002, ORNLRHVE13003,ORNLRHVE13004, ORNLRHVE13005 andORNLRHVE13006I-3EPA Inspection No.: ORNL-CC-2014Inspection Date: February 4–6, 2014Establishment of Required Technical Elements inProceduresExecution of ProceduresObjective EvidenceRHVE-7: Records are available for reviewCCP-TP-500, Revision 13, s. 5.0Lifetime/QA records – Attachments 1-5, Copy ofNCRsQA/nonpermanent records – VHS tape or DVD(primary and backup)Qualification cards for selected VE operatorsQualification Card for ORNL RH VEEVEE appointment letter, dated October, 2013CCP-AK-ORNL-001, Revisions 7 and 8, training sign-insheetRH VE BDR Nos. ORNLRHVE13001,ORNLRHVE13002, ORNLRHVE13003,ORNLRHVE13004, ORNLRHVE13005 andORNLRHVE13006CCP-PO-001, CCP Transuranic Waste CharacterizationQuality Project Assurance Plan, Revision 21,05/31/2013CCP-QP-002, CCP Training and Qualification Plan,Revision 35, 06/06/2013CCP-AK-ORNL-001, Revisions 7 and 8, training sign-insheetCCP-PO-001, CCP Transuranic Waste CharacterizationQuality Assurance Project Plan, Revision 21, 05/31/2013CCP-TP-500, CCP Remote-Handled Waste VisualExamination, Revision 13, 04/21/2013

# 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 t hat a "Leaded glove or leaded apron" be added to th e container. However, this attachment is meant to pro vide an exact inventory for the container and shoul d be specific for the items added. CCP should consider c hanging how this information is recorded on the inventory so that no uncertainty is attached to its contents.

B. Regula tory 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 N o. : 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 eval uate an RTR operator's continued job performance do not demonstrate the sucessful ex amination of unknown containers. This concern is based on the following: (1) Operators are not required to generate a writte n record when examining a Training Container as the y would for a routine waste container or a Test conta iner. This is an historical practice without any re gulatory

basis. (2) A Lead Operator observes the operator's perform ance during the Training Container evaluation but d oes not possess an inventory for the Training Container and cannot assess whether items are missed. (3) The operator is considered successful in the te st if he/she identifies all Summary Category Groups and all prohibited items. There is no requirement for t he operator to identify all waste items as they wou ld 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 attent ion of the operator by CE to provide objective evid ence 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 N DE-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 a dequacy 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