EPA DOCKET NO. A-98-49, II-A4-179 

WASTE CHARACTERIZATION INSPECTION 

CONTINUED COMPLIANCE REPORT 

EPA INSPECTION OF THE CENTRAL CHARACTERIZATION PROJECT 

WASTE CHARACTERIZATION PROGRAM 

AT THE LOS ALAMOS NATIONAL LABORATORY 

 

November 19–21, 2013 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

February 2014 
i 

TABLE OF CONTENTS 

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

2.0 Purpose of Continued Compliance Inspections .................................................................. 5

3.0 Purpose of This Report ....................................................................................................... 5

4.0 Scope of This Continued Compliance Inspection ............................................................... 6

5.0 Inspection Personnel ........................................................................................................... 6

6.0 Technical Evaluation .......................................................................................................... 6

6.1 Acceptable Knowledge ........................................................................................... 6

6.1.1 Technical Evaluation: Acceptable Knowledge ........................................... 7

6.1.2 Acceptable Knowledge Findings and Approval ....................................... 11

6.2 Nondestructive Assay ........................................................................................... 12

6.2.1 Technical Evaluation: High Efficiency Neutron Counter No. 1 ............... 13

6.2.2 Technical Evaluation: High Efficiency Neutron Counter No. 2 ............... 16

6.2.3 Technical Evaluation: Super High Efficiency Neutron Counter .............. 19

6.2.4 Technical Evaluation: Mobile In Situ Object Counting System Large 

Container Counter ................................................................................................. 23

6.2.5 Nondestructive Assay Findings and Approval ......................................... 24

6.3 Nondestructive Examination ................................................................................. 25

6.3.1 Technical Evaluation: Real-Time Radiography ........................................ 25

6.3.2 Technical Evaluation: Visual Examination .............................................. 27

6.3.3 Nondestructive Examination Findings and Approval ............................... 28

7.0 Findings and Concerns ...................................................................................................... 29

8.0 Conclusions ....................................................................................................................... 29

LIST OF TABLES 

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

by LANL-CCP ................................................................................................................................ 3

Table 2. RTR Container Records Examined in This Inspection ................................................... 26
ii 

ATTACHMENTS 

Attachment A Approval Summary for LANL-CCP Contact-Handled Waste Characterization 

Program 

Attachment B List of Documents Reviewed for This Inspection 

Attachment C Inspection Personnel 

Attachment D.1 AK Continued Compliance Inspection Checklist: Waste Stream LAMHD01.001 

Attachment D.2 AK Continued Compliance Inspection Checklist: Waste Stream LAMSG04.001 

Attachment D.3 AK Continued Compliance Inspection Checklist: Waste Stream LACIN01.001 

Attachment D.4 AK Continued Compliance Inspection Checklist: Waste Stream LA-OS-00-

01.001 

Attachment E.1 NDA Continued Compliance Inspection Checklist: HENC1 

Attachment E.2 NDA Continued Compliance Inspection Checklist: HENC2 

Attachment E.3 NDA Continued Compliance Inspection Checklist: SuperHENC 

Attachment E.4 NDA Continued Compliance Inspection Checklist: MILCC 

Attachment F.1 Replicate Testing Data for Drum No. 68428 – HENC2 

Attachment F.2 Replicate Testing Data for Drum No. 60434 – HENC2 

Attachment F.3 Replicate Testing Data for Drum No. 68571 – HENC2 

Attachment F.4 Replicate Testing Data for Drum No. 68107 – SuperHENC 

Attachment F.5 Replicate Testing Data for Drum No. 68214 – SuperHENC 

Attachment F.6 Replicate Testing Data for Drum No. 68211 – SuperHENC 
iii 

ACRONYMS AND ABBREVIATIONS 

AaS Add-a-Source 

AEC Atomic Energy Commission 

AK acceptable knowledge 

AKE Acceptable Knowledge Expert 

AKSR acceptable knowledge summary report 

AKTSS acceptable knowledge tracking spreadsheet 

Am americium 

ASTM American Society for Testing and Materials 

BDR batch data report 

BEGe broad-energy germanium 

χ

2

 chi-squared 

CBFO Carlsbad Field Office 

CCP Central Characterization Program 

Cf californium 

CFR Code of Federal Regulations 

CH contact-handled 

Ci curie 

CIS characterization information summary 

CMB corrugated metal box 

CN waste stream profile form change notice 

cps counts per second 

Cs cesium 

CTAC Carlsbad Technical Assistance Contractor 

D&D decontamination and decommissioning 

DOE U.S. Department of Energy 

DP Delta Prime 

DQO data quality objective 

DR discrepancy resolution 

EA Expert Analyst 

EPA U.S. Environmental Protection Agency 
iv 

Eu europium 

FRAM Fixed Energy Response as Multiple Energies 

FWHM full width at half maximum 

FY fiscal year 

g gram 

g/cc grams per cubic centimeter 

He helium 

HENC High Efficiency Neutron Counter 

HENC1 High Efficiency Neutron Counter No. 1 

HENC2 High Efficiency Neutron Counter No. 2 

HLW high-level waste 

HPGe high-purity germanium 

ISOCS In Situ Object Counting System 

ITR Independent Technical Reviewer 

keV kiloelectron volt 

kg kilogram 

LANL Los Alamos National Laboratory 

LLD lower limit of detection 

LN2 liquid nitrogen 

LOQI list of qualified individuals 

LWRHU Lightweight Radioisotope Heater Unit 

MCS Mobile Characterization Services 

MDA material disposal area 

MDC minimum detectable concentration 

MeV megaelectron volt 

MGA multigroup analysis 

MGA-U multigroup analysis-uranium 

MILCC Mobile In Situ Object Counting System Large Container Counter 

MT material type 

nCi/g nanocuries per gram 

NCR nonconformance report 

NDA nondestructive assay 

NDE nondestructive examination 
v 

Np neptunium 

NTP National TRU Programs 

NTPC National TRU Program Certification 

NWP Nuclear Waste Partnership, LLC 

ORIA Office of Radiation and Indoor Air 

OSRP Offsite Source Recovery Project 

PDP Performance Demonstration Program 

PM Project Manager 

Pu plutonium 

240PuEff plutonium-240 effective 

QA quality assurance 

QAPD quality assurance program document 

QC quality control 

R roentgen 

R&D research and development 

RCRA Resource Conservation and Recovery Act 

RDS radioassay data sheet 

RSD relative standard deviation 

RTR real-time radiography 

RSWD radioactive solid waste disposal 

 sigma 

SCG summary category group 

SHENC Super High Efficiency Neutron Counter 

SME Subject-Matter Expert 

SNF spent nuclear fuel 

SPM Site Project Manager 

Sr strontium 

SRS Savannah River Site 

SuperHENC Super High Efficiency Neutron Counter 

SWB standard waste box 

T1 Tier 1 

T2 Tier 2 
vi 

TA technical area 

TMU total measurement uncertainty 

TRU transuranic 

TWCP TRU Waste Characterization/Certification Program 

TWSR TRU Waste Storage Record 

U uranium 

VE visual examination 

VEE Visual Examination Expert 

VJT VJ Technologies 

WG weapons grade 

WIPP Waste Isolation Pilot Plant 

WMC waste matrix code 

WMP waste material parameter 

WSPF waste stream profile form 
1 

1.0 EXECUTIVE SUMMARY 

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

waste characterization program at the U.S. Department of Energy (DOE) Los Alamos National 

Laboratory (LANL) continues to be in compliance with federal regulations. In accordance with 

Title 40 of the Code of Federal Regulations (40 CFR) 194.24(h), EPA conducts continued 

compliance inspections of the EPA-approved transuranic (TRU) waste characterization systems 

used at the TRU waste sites operated by DOE. Since 2007, the Central Characterization Program 

(CCP),1 a mobile waste characterization systems provider, has operated a waste characterization 

program for contact-handled (CH) TRU wastes at LANL in Los Alamos, New Mexico. 

On November 19–21, 2013, EPA conducted a continued compliance inspection of the site’s 

program to characterize CH TRU wastes proposed for disposal at the Waste Isolation Pilot Plant 

(WIPP). During this inspection, EPA evaluated samples of the following waste characterization 

activities: 

 Acceptable knowledge (AK); evaluation took place on site at LANL. 

 Four nondestructive assay (NDA) systems: Two High Efficiency Neutron Counters 

(HENCs), the Super High Efficiency Neutron Counter (SuperHENC or SHENC) and the 

Mobile In Situ Object Counting System (ISOCS) Large Container Counter (MILCC); 

evaluation took place on site at LANL. 

 Real-time radiography (RTR); evaluation performed as a desktop evaluation. 

 Visual Examination (VE); evaluation performed as a desktop evaluation. 

Based on the results of this continued compliance inspection, EPA confirms that the LANL-CCP 

CH TRU waste characterization program in the configuration observed during this inspection is 

consistent with the limitations described in the baseline inspection report (see EPA Docket No. 

A-98-49; II-A4-88, dated June 21, 2007) and subsequent EPA Tier 1 (T1) approvals. Attachment 

A summarizes all of EPA’s approvals of the LANL-CCP CH TRU waste characterization 

program. EPA will use results of this continued compliance inspection to support the streamlined 

T1 evaluation and decision process discussed in section 2.0 below. 

Based on this inspection, there is one clarifying change to the VE T1 designations: any use of VE 

for summary category group (SCG) S4000 (soils) waste is a new T1 change. EPA previously 

approved the VE processes for characterization of SCG S5000 (heterogeneous debris) and SCG 

S3000 (homogeneous solids) wastes but had not explicitly stated that use of VE for SCG S4000 

waste required a T1 evaluation. This change is reflected in EPA’s tiering table, Table 1, below. 

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

NDE: 

1. Notification to EPA upon completion of or revisions to discrepancy resolution (DR) 

reports is a new AK T2 change. 

 1

 The Central Characterization Program was formerly known as the Central Characterization Project. 
2 

2. Submission to EPA of a list of all AK Experts (AKEs) and Site Project Mangers (SPMs) 

who performed work in these roles for the LANL-CCP waste characterization program 

during the previous quarter is a new AK T2 change. 

3. Submission to EPA of a list of all NDA personnel who performed work during the 

previous quarter is a new NDA T2 change. Specifically, the list must include all 

operators, Expert Analysts (EAs) and Independent Technical Reviewers (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 NDE T2 change. Specifically, the list must include 

all VE and RTR operators, ITRs and Visual Examination Experts (VEEs). 

The T2 changes listed above are necessary to make the LANL-CCP tiering designations 

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

for conducting T1 evaluations (see section 2.0). EPA also revised the tiering table to ensure 

completeness and consistency with recent EPA T1 approval reports. Table 1 identifies the 

substantive T1 and T2 changes in bold text. T1 and T2 changes that were initiated during the 

baseline and subsequent T1 approvals remain in effect. The language in Table 1 regarding AK 

documentation applies to all LANL-CCP waste streams. 

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

However, EPA observed several errors with LANL-CCP’s document and record management 

during the AK portion of the inspection as discussed in section 6.1 and Attachments D.1 through 

D.4 of this report. During the inspection, EPA informed CBFO and LANL-CCP that this issue 

must be corrected. LANL-CCP agreed and committed to take necessary steps to prevent 

recurrence. EPA also informed CCP and CBFO that a varying degree of similar errors has been 

observed in the past at other TRU Sites. CBFO and CCP need to address this systemic problem. 

EPA will continue to review CCP’s document and record management during future continued 

compliance inspections and T1 evaluations of all CCP TRU waste characterization programs. 

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

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

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

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

(Based on May 23–25, 2006, Baseline Inspection and Subsequent Evaluations, Updated Februa

Process Elements LANL-CCP Waste Characterization Process – T1 Changes LANL-CCP Waste Characterization 

Acceptable Knowledge, including Load Management 

Any new waste category, as well as any new OSRP waste streams addressed in AKSRs separate from CCP-AK-LANL-008 or new OSRP waste streams beyond LA-OS-00-01.001, LA-OS00-03, and LA-OS-00-04 added to CCP-AK-LANL-008 Load management for waste streams other than as documented in CCP-AK-LANL-009 

Submission of a list of active LANL-CCP CH A

Notification to EPA upon completion of or substa

 AK-NDA memoranda  AK accuracy reports (annually, at a minimum AK reassessment memoranda and combinatio

distinct at the time of the baseline inspection 

 Any new or updated WSPFs, including all ass

summation of aspects) and any change notices WSPFs, including additions to waste streams w

 AKSRs (new and updated versions), including  CCP-TP-005, Attachment 6, and associated m Site procedures requiring CBFO approval  Discrepancy Resolution Reports (new or up

Nondestructive Assay New equipment or substantive physical modifications** to 

approved equipment Extension of or changes to approved calibration ranges for approved equipment 

Submission of a list of LANL-CCP NDA operaperformed work during the previous quarter

Notification to EPA upon: 

 Substantive modification** to software for ap

 Substantive modification** to operating range

 Substantive modification** to site procedures 

 Any change to the MILCC that does not direc

calibration, including relocation of the system 

Real-Time Radiography None Submission of a list of LANL-CCP RTR opera

work during the previous quarterNotification to EPA upon: 

 New equipment or substantive physical modif

 Substantive modification** to site procedures 

Visual Examination and Visual Examination Technique 

Implementation of any visual examination process for SCG 

S4000 waste. 

Submission of a list of LANL-CCP VE operato

performed work during the previous quarterNotification to EPA upon substantive modificatioCBFO approval, including OSRP visual examinat
4 

WIPP Waste Data System 

None Notification to EPA upon substantive modificatio

 Site procedures requiring CBFO approval  Excel spreadsheet, Waste Data System data en

and certification requiring CBFO approval

New T1s, T2s and significant modifications to existing T1s or T2s are in bold text; T1s or T2s that were only revised for style are not shown in * LANL-CCP will report all T2 changes to EPA every three months. ** “Substantive modification” refers to a change with the potential to affect LANL-CCP’s CH waste characterization processes or documenta

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

† LANL-CCP will report relocation of any NDA system to EPA immediately.
5 

2.0 PURPOSE OF CONTINUED COMPLIANCE INSPECTIONS 

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

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

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

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

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

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

TRU wastes destined for disposal at the WIPP. 

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

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

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

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

approved waste characterization program by conducting additional inspections under the 

authority of 40 CFR 194.24(h). 

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

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

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

April 2013, EPA finalized a streamlined evaluation and decision process that includes an annual 

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

continued compliance inspections will cover the common elements of waste characterization 

processes that are not expected to vary significantly on a waste stream or T1 change basis. 

Examples of the common characterization elements are personnel training, procedures and 

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

elements in conjunction with the quarterly T2 change reports for EPA review (see T2 changes in 

bold in Table 1 of this report). The quarterly review of the common elements will be independent 

of EPA’s approvals of T1 change requests and will ensure that these waste characterization 

elements of each active site’s TRU program continue to remain in compliance with EPA WIPP 

requirements at 40 CFR 194.8 and 24.. 

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

submitted since the November 2013 inspection will be the basis for EPA’s evaluation of any 

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

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

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

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

continued compliance inspection, at the Agency’s discretion. 

3.0 PURPOSE OF THIS REPORT 

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

waste characterization program for CH TRU wastes. Specifically, this report: 

 Describes the sample of the LANL-CCP waste characterization systems evaluated during 

this inspection. 
6 

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

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

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

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

waste characterization systems. 

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

their relevance to EPA’s approval decision. 

The DOE documents that EPA reviewed for this 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 

4.0 SCOPE OF THIS CONTINUED COMPLIANCE INSPECTION 

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

of the waste characterization systems in use at LANL-CCP to characterize CH TRU wastes that 

were approved during the baseline inspection and subsequent T1 evaluations. Waste 

characterization activities evaluated included AK for Waste Streams LA-MHD01.001, LAMSG04.001, LA-CIN01.001 and LA-OS-00-01.001; all operating NDA systems (HENC1, 

HENC2, MILCC and SuperHENC) for waste characterization; and a desktop evaluation of RTR 

and VE operations for multiple SCGs. 

5.0 INSPECTION PERSONNEL 

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

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

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

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

6.0 TECHNICAL EVALUATION 

Sections 6.1 through 6.3 of this report detail the three technical areas assessed during this 

inspection: AK, NDA, and nondestructive examination (NDE), consisting of RTR and VE. EPA 

completed inspection checklists for AK and NDA based on responses of LANL-CCP waste 

characterization personnel to EPA queries and other documentation (see Attachments D.1 

through E.4). When evaluating future T1 change requests and concurring with quarterly T2 

change submissions, EPA may use these checklists to supplement its review. 

6.1 Acceptable Knowledge 

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

TRU waste characterization. LANL-CCP’s AK characterization program is EPA-approved for 

SCG S5000 (heterogeneous debris) waste, SCG S4000 (soils) and SCG S3000 (homogeneous 
7 

solids). EPA selected one waste stream from each approved SCG plus one of the Off-site Source 

Recovery Project (OSRP) debris waste streams (LA-MHD01.001, LA-MSG04.001, LACIN01.001 and LA-OS-00-01.001) to review as representative samples of the LANL-CCP CH 

AK waste characterization program. 

EPA has previously reviewed Waste Stream LA-MSG04.001 once (EPA Docket No. A-98-49; 

II-A4-168) and Waste Stream LA-OS-00-01.001 twice (EPA Docket Nos. A-98-49; II-A4-88 

and A-98-49; II-A4-141) and therefore focused this continued compliance inspection on changes 

to the waste streams and associated documentation since the last reviews in September 2012 and 

May 2010. EPA had not previously reviewed Waste Stream LA-MHD01.001 and Waste Stream 

LA-CIN01.001 and therefore reviewed their documentation in greater detail. The AK checklists 

used for this inspection are included in Attachments D.1 through D.4. 

6.1.1 Technical Evaluation: Acceptable Knowledge 

(1) EPA examined Central Characterization Program procedures for acceptable knowledge 

documentation, training of Acceptable Knowledge Experts and disposition of 

nonconformances and found them to be adequate. 

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

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

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

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

2013. 

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

Data,” June 19, 2013. 

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

2013. 

These procedures adequately reflect the requirements of 40 CFR 194. Procedure implementation 

is evidenced by adequate preparation and maintenance of the required documentation, as 

reviewed below. 

Part of the revision to CCP-TP-005 included changing the AK-NDA comparison requirements. 

CCP-TP-005, Revision 25, required comparing the NDA results for each drum to the AKexpected ratios of the prevalent radionuclides. In CCP-TP-005, Revision 26, CCP replaced this 

with (1) a requirement to compare the NDA-measured two most prevalent radionuclides for the 

whole waste stream and waste lot with the AK-expected two most prevalent radionuclides and 

(2) a requirement to compare the NDA results with the list of radionuclides expected by AK to 

be present in any quantity. This procedure change took effect in August 2013; at the time of the 

continued compliance inspection, LANL-CCP had not yet implemented this change for any of 

the sample waste streams. EPA will revisit this change during a future continued compliance 

inspection of a CCP CH waste characterization program or sooner in response to an AK CH T1 

change request. 
8 

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

requiring Carlsbad Field Office (CBFO) approval remains a T2 change (see Table 1). 

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

including acceptable knowledge assembly, compilation and verification, was adequately 

implemented. 

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

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

streams. 

EPA identified a few instances in which a CCP-TP-005 attachment was completed using an older 

revision of CCP-TP-005. LANL-CCP revised these attachments during the inspection. EPA will 

continue monitoring use of appropriate attachment revisions to ensure that this situation remains 

a rare and isolated occurrence. EPA expects that all LANL-CCP waste characterization 

personnel are aware of and have access to the current revision of all controlled CCP documents. 

EPA also identified an example of source documents and a CCP-TP-005, Attachment 8, that 

were not filed correctly with CCP Records. LANL-CCP and CCP Records corrected all 

identified errors during the inspection. EPA will continue to check that records and documents 

are properly managed. 

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

EPA randomly selected one to three containers each from each waste stream. These containers 

are traceable from their building of generation or source manufacture through LANL-CCP 

characterization. 

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

EPA evaluated the acceptable knowledge summary report (AKSR) for each sample waste stream 

for inclusion of sufficient information, supported by appropriate source documents, to support 

the following statements: 

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

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

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

 All of the waste in the waste stream is defense in origin.2

 None of the waste in the waste stream is high-level waste.3

 None of the waste in the waste stream is spent nuclear fuel.3

EPA found each AKSR to be adequate. Explanations and source documents supporting each of 

the above statements are included in the checklists in Attachments D.1 through D.4 to this report: 

 2

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

Act of 1982.” 
9 

 Waste Stream LA-MHD01.001: Attachment D.1, checklist item AK-4, summarizes the 

information provided in the AKSR CCP-AK-LANL-006, Revision 12. 

 Waste Stream LA-MSG04.001: Attachment D.2, checklist item AK-4, summarizes the 

information provided in the AKSR CCP-AK-LANL-010, Revision 6. 

 Waste Stream LA-CIN01.001: The AK for this waste stream is the same as that for Waste 

Stream LA-MHD01.001. Therefore, the summary of AKSR CCP-AK-LANL-006, 

Revision 12, in Attachment D.1, checklist item AK-4, is applicable to Waste Stream LACIN01.001. 

 Waste Stream LA-OS-00-01.001: Attachment D.4, checklist item AK-4, summarizes the 

information provided in the AKSR CCP-AK-LANL-008, Revision 9. 

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

Table 1). 

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

to be adequate. 

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

information summaries (CISs) and summations of aspects, and related change notices for Waste 

Streams LA-MHD01.001, LA-MSG04.001, LA-CIN01.001 and LA-OS-00-01.001 and found 

them to be complete and adequate. 

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

EPA reviewed qualification cards showing the familiarity of the AKEs with the current revisions 

of AK procedures for all AKEs identified on reviewed AK documents: Randy Fitzgerald, Amy 

Johns, Michael Papp, Jim Schoen, Chris Chancellor, Lisa Price-Watson and Sherry Aukland. 

EPA also reviewed complete SPM qualification cards for Terri-Anne Groover, Craig Simmons, 

Carolina Soaterna and Veronica Waldram. Training records for the personnel listed above are 

complete and adequate. EPA will review training records for any additional personnel supporting 

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

submission or during the next continued compliance inspection. 

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

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

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

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

during future T1 change evaluations. 

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

be adequate. 

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

found that they were adequately prepared. EPA also reviewed randomly selected DR reports 

associated with each sample waste stream and found them to be adequately prepared. 
10 

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

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

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

Table 1).

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

EPA reviewed the last three annual AK accuracy reports for Waste Streams LA-MHD01.001, 

LA-CIN01.001 and LA-OS-00-01.001 and found them to be adequate. Waste Stream LAMSG04.001 was certified within the last year and LANL-CCP has not yet prepared any AK 

accuracy reports for this waste stream. 

EPA identified that all three of the reviewed AK accuracy reports from 2011 were written using 

CCP-TP-005, Attachment 14, Revision 19, when they should have been written using Revision 

21. Similarly, all three of the reviewed 2013 AK accuracy reports were written using CCP-TP005, Attachment 14, Revision 24, when they should have been written using Revision 25. 

LANL-CCP investigated and found that all of one SPM’s 2013 Attachment 14s were written 

using the wrong revision (Revision 24). LANL-CCP wrote NCR-LANL-0734-13 for all incorrect 

2013 Attachment 14s and the three EPA-reviewed 2011 Attachment 14s. EPA reviewed the 

revised Attachment 14s and found them to be adequate. EPA will continue to review AK 

accuracy reports for adequacy and completeness. EPA expects that all LANL-CCP waste 

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

CCP documents. 

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

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

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

personnel and found it to be adequate. 

Radiological characterization of Waste Stream LA-OS-00-01.001 is based on AK; therefore, 

AK-NDA communication is not applicable. EPA reviewed the current AK-NDA memorandum 

for each of the other three sample waste streams, evaluated the memoranda for completeness and 

compared the memoranda with the AKSRs. The AK-NDA memorandum for Waste Stream LAMSG04.001 has not been updated since the last review. The AK-NDA memorandum for Waste 

Stream LA-MHD01.001 was revised in 2010, and the memorandum for Waste Stream LACIN01.001 was revised in 2012. EPA found that the level of detail and precision in the AK-NDA 

memoranda to be adequate. 

LANL-CCP initially provided EPA with the wrong revision of the AK-NDA memorandum for 

Waste Stream LA-MHD01.001 because the current revision had not been correctly appended to 

the associated CCP-TP-005, Attachment 7. LANL-CCP revised the CCP-TP-005, Attachment 7, 

to include the correct version of the memorandum during the EPA evaluation. 

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

remains a T2 change (see Table 1). 
11 

(10) EPA found load management to be acceptable. 

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

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

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

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

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

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

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

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

LANL-CCP does not perform load management for any of the sample waste streams reviewed 

during this inspection. 

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

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

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

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

dates of documents provided during this continued compliance inspection with the T2 

notification reports provided to EPA by CBFO. EPA began tracking T2 quarterly reports in the 

fourth quarter of fiscal year 2009 and, therefore, is unable to verify whether document revisions 

made prior to July 2009 were appropriately included in the T2 notification to EPA. 

EPA found that LANL-CCP did not provide T2 notification for the 2012 AK-NDA 

memorandum revision for Waste Stream LA-CIN01.001 or the 2013 AK accuracy report for 

Waste Stream LA-OS-00-01.001. LANL-CCP did provide notification for other AK-NDA 

memorandum revisions and for other 2013 AK accuracy reports. Therefore, EPA determined that 

these omissions were isolated events. EPA reminded LANL-CCP that all T2 requirements apply 

to all LANL-CCP waste streams, unless specifically stated otherwise. The tiering changes 

identified during the LANL-CCP CH baseline inspection and subsequent T1 evaluations remain 

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

6.1.2 Acceptable Knowledge Findings and Approval 

Summary of Acceptable Knowledge Findings and Concerns

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

continued compliance inspection. However, EPA observed several inconsistencies with specific 

AK documents as discussed in Items (2), (8) and (9) above. Specifically, two Attachment 6s and 

several Attachment 14s were written using the wrong revision of procedure CCP-TP-005, an 

Attachment 7 contained a superseded version of the AK-NDA memorandum, an Attachment 8 

from CCP Records did not match the version that the AKE submitted to records, and two source 
12 

documents were filed with the incorrect source document number and summary (Attachment 3).3 

LANL-CCP personnel corrected all of the identified errors during the inspection. EPA will 

continue to review CCP’s document and record management during future continued compliance 

inspections and T1 evaluations of all CCP TRU waste characterization programs.

Acceptable Knowledge Approval

Notification to EPA upon completion of or revisions to all DRs is a new T2 change. EPA added 

this requirement to make the LANL-CCP tiering designations consistent with the requirements at 

other sites and to reflect current T2 reporting practices (see Table 1). Submission to EPA of a list 

of AKEs and SPMs who performed work in these roles for the LANL-CCP waste 

characterization program during the previous quarter is a new T2 change (see Table 1). EPA 

added this requirement to ensure that EPA has a complete picture of LANL-CCP waste 

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

future T1 change evaluations. 

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

demonstrated continued AK characterization compliance. 

6.2 Nondestructive Assay 

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

LANL waste characterization program. LANL’s NDA program consisted of the following four 

separate assay units, all of which were previously approved by EPA: 

 High Efficiency Neutron Counter No. 1 (HENC1). 

 High Efficiency Neutron Counter No. 2 (HENC2). 

 SuperHENC. 

 MILCC. 

EPA approved the HENC1 and HENC2 initially during the CH baseline inspection in June 2007, 

and both had subsequent approvals to reflect changes to their operational ranges through the T1 

process. EPA approved the SuperHENC for addition to the LANL-CCP approval through a T1 

change in October 2011 and approved the MILCC in July 2013. LANL-CCP demonstrated the 

technical abilities of these four NDA systems initially during the baseline and subsequent T1 

evaluations. Attachment A lists the specific inspection reports that describe each system and 

present the results of EPA’s in-depth technical evaluation of each system; see these reports for 

specific technical details. This report presents the results of EPA’s onsite confirmation that the 

systems were essentially unchanged, i.e., that they continued to be consistent with EPA’s 

approval. Details of each NDA system that EPA evaluated at LANL during this inspection are 

provided in the NDA checklists in Attachments E.1 through E.4. 

This inspection focused on the following: 

 3

 The numbered Attachments (i.e., Attachments 3, 6, 7, 8 and 14) referenced in this sentence are 

attachments to the AK procedure, CCP-TP-005. 
13 

 Confirmation that the LANL-CCP NDA systems were the same as those that EPA 

approved initially and that their design and technical capabilities had not changed 

significantly since EPA’s last inspection. 

 Adequacy of the current revisions of the LANL-CCP NDA procedures and documents. 

 Operational and maintenance history of each NDA system since its last EPA inspection. 

 Knowledge, understanding and training status of LANL-CCP NDA personnel. 

 Applicability of each system’s current configuration to assay the waste types that LANLCCP was processing. 

Each of these four systems is evaluated in separate sections below. EPA also requested that 

LANL-CCP perform replicate analyses on two NDA systems, HENC2 and the SuperHENC. 

These are discussed in sections 6.2.2 and 6.2.3, respectively, and the replicate spreadsheets are in 

Attachments F.1 through F.6. 

6.2.1 Technical Evaluation: High Efficiency Neutron Counter No. 1 

EPA evaluated the continued compliance of the HENC1 with the EPA-approved waste 

characterization program for NDA at LANL-CCP. EPA used a modified NDA checklist, 

included in Attachment E.1, which addressed a subset of the items evaluated for this system 

during the initial approval. The following aspects of the HENC1 were evaluated during this 

inspection. 

(1) EPA verified that the High Efficiency Neutron Counter No. 1 was the same instrument 

that EPA approved previously and that its design and essential functions were unchanged 

since the last EPA inspection. 

The HENC1 is located in Trailer 54-506 on Pad 10 in Area G of technical area 54 (TA-54) at 

LANL, in the same location as when EPA initially inspected and approved it for WIPP assays. 

The system incorporates two measurement modalities, a passive neutron counter and an integral 

gamma-ray spectrometer. 

The passive neutron counter uses multiple helium-3 (3

He) proportional counters, in conjunction 

with a multiplicity shift register and an external californium-252 (252Cf) source for the Add-aSource (AaS) matrix correction function, to determine the spontaneously fissioning mass content 

of waste containers. Isotopic ratios are typically determined by multigroup analysis (MGA) of 

the gamma-ray spectrum based on data obtained with the system’s high-purity germanium 

(HPGe) detector. Gamma data can also provide direct quantification of a number of 

radionuclides, including plutonium-238 (238Pu), 239Pu, 241Pu, americium-241 (241Am), uranium233 (233U), 235U, 238U, cesium-137 (137Cs) and neptunium-237 (237Np). The HPGe detector uses a 

multicurve efficiency calibration based on the waste matrix density to correct for gamma 

attenuation and other losses. LANL-CCP has not made any major hardware or software changes 

to the HENC1 system for the neutron modality; however, the gamma system’s pulser was 

replaced on February 20, 2013. 
14 

New equipment or substantive physical modifications to approved equipment remains a T1 

change (see Table 1). Notification to EPA upon substantive modification to software for 

approved NDA equipment remains a T2 change (see Table 1). 

(2) EPA verified that the operational range of the HENC1 was unchanged from the last 

inspection and was adequate for the wastes LANL-CCP is currently assaying. 

Between November 13, 2012, and November 13, 2013, the HENC1 assayed 1,475 drums that 

were compiled in 199 batch data reports (BDRs). During this inspection, EPA observed the 

HENC1 assaying Drum No. WMC1014-08, a Performance Demonstration Program (PDP) drum, 

which was 100% full and had a net weight of 52.7 kilograms (kg). EPA observed that HENC1 

personnel were using the current revision of the HENC1 operating procedure (CCP-TP-063, 

Revision 15). For this assay, the LANL-CCP operator had performed and documented the daily 

background and performance check, and checks for the system’s full width at half maximum 

(FWHM) and energy calibration (gain). LANL-CCP had established control limits [2 and 3 

sigma () limits] for all parameters, as well as boundary limits for background [10–60 counts per 

second (cps), full spectrum], FWHM and gain. The HENC1 operator showed the EPA inspectors 

that all instrument parameters were acceptable and that LANL-CCP performed and documented 

the assay adequately. All operational aspects of the HENC1 operation were acceptable. 

Notification to EPA upon substantive modification to operating ranges or site NDA procedures 

requiring CBFO approval remains a T2 change (see Table 1). 

(3) EPA verified that the system’s calibration was unchanged since the last inspection and 

noted that there were no major system changes apart from routine maintenance. 

EPA confirmed that the HENC1’s calibration was unchanged from the last EPA inspection, as 

indicated in LANL-CCP records (MCS-HENC#1-NDA-1002). LANL-CCP has performed eight 

calibration verifications since August 2012 (the time of the last EPA inspection of the HENC1), 

all in response to routine operational measurement issues. EPA reviewed six of them; all aspects 

of the calibration verifications that EPA reviewed were technically acceptable and appropriately 

documented. Calibration verifications are a normal part of system operations and their presence 

is not indicative of a problem with the instrument. LANL-CCP personnel indicated that, on 

several occasions, ambient temperature fluctuations have affected the FWHM value to the point 

where the calibration had to be verified, as required by the LANL-CCP operating procedure. 

LANL-CCP performed subsequent quality assurance/quality control (QA/QC) checks, and all 

values were accepted relative to the acceptance criteria. Regarding maintenance and major 

system changes, LANL-CCP personnel stated that there were no major changes to the HENC1 

and that no minor components had been changed. 

All aspects of the HENC1’s calibration and the execution and documentation of calibration 

verifications were technically acceptable and appropriately documented. Extension of or changes 

to approved calibration ranges for approved equipment remains a T1 change (see Table 1). 
15 

(4) EPA confirmed that the determination and documentation of the total measurement 

uncertainty for the High Efficiency Neutron Counter No. 1 are adequate. 

EPA verified that the total measurement uncertainty (TMU) document (CI-HENC-TMU-101) 

was unchanged from EPA’s last inspection. LANL-CCP documented the TMU of assays 

performed on the HENC1, as evidenced by EPA’s review of HENC1 BDRs Nos. 1LANDA1850 

and 1LANDA1857. 

(5) EPA confirmed that LANL-CCP’s determination and documentation of the lower limit of 

detection, including the minimum detectable concentration of the High Efficiency 

Neutron Counter No. 1, had not changed, and that it was technically adequate. 

LANL-CCP had documented the technical basis for the system’s lower limit of detection (LLD), 

including reporting thresholds for specific nonmeasured radionuclides 242Pu and strontium-90 

(

90Sr). These are documented in MCS-HENC#1-NDA-1002, Revision 6, “Calibration Report for 

the HENC #1 Including Passive Neutron and Gamma Spectrometer Calibration and 

Confirmation,” issued October 2007, and MCS-HENC#1-NDA-1005-Lead-Lined, Revision 1, 

“Lead-Lined Calibration Report for the HENC #1 Including Passive Neutron and Gamma 

Spectrometer,” issued July 2012, both of which EPA previously determined were adequate. EPA 

verified that these documents were unchanged from EPA’s last inspection and continued to be 

adequate. 

(6) EPA established that the High Efficiency Neutron Counter No. 1 had successfully 

participated in drum cycle 20A of the Carlsbad Field Office-sponsored Performance 

Demonstration Program. 

The HENC1 successfully participated in the CBFO-sponsored NDA PDP cycle 20A in the spring 

of 2013. The HENC1 is scheduled to participate in the PDP annually. 

(7) EPA confirmed that training for all NDA personnel was adequate. 

The HENC1 has 12 operators/ITRs and five EAs. All NDA personnel associated with the 

calibration, operation and data review and approval of the HENC1 had current training in the 

applicable areas, as evidenced by the List of Qualified Individuals (LOQI) dated November 14, 

2013, 3:12 p.m., that was provided during the inspection. 

Submission to EPA of a list of all NDA personnel who performed work during the previous 

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

EAs and ITRs. EPA added this requirement to ensure that EPA has a complete picture of LANLCCP waste characterization activities, which will inform the scope of NDA components 

evaluated during future T1 change evaluations. 

Summary of High Efficiency Neutron Counter No. 1

EPA did not identify any findings or concerns regarding the operation of the HENC1 or 

documentation thereof. EPA determined that the HENC1 was adequate in every respect. 
16 

Submission to EPA of a list of all NDA personnel who performed work during the previous 

quarter is a new NDA T2 change (see Table 1). 

6.2.2 Technical Evaluation: High Efficiency Neutron Counter No. 2 

EPA evaluated LANL-CCP’s continued compliance with the EPA-approved waste 

characterization program for CH waste using the HENC2 NDA system. The EPA inspectors used 

a modified NDA checklist that addressed a subset of the items evaluated for this system during 

the initial approval, included in Attachment E.2. The following aspects of the HENC2 were 

evaluated during this inspection. 

(1) EPA verified that the High Efficiency Neutron Counter No. 2 was the same instrument 

that EPA approved previously and that its design and essential functions were unchanged 

since the last EPA inspection. 

The HENC2 is located in Trailer 54-506 on Pad 10 in Area G of TA-54 at LANL, in the same 

location as when EPA initially inspected and approved it for WIPP assays. The system 

incorporates two measurement modalities, a passive neutron counter and an integral gamma-ray 

spectrometer. The passive neutron counter uses multiple 3

He proportional counters, in 

conjunction with a multiplicity shift register and an external 252Cf source for the AaS matrix 

correction function, to determine the spontaneously fissioning mass content of waste containers. 

Isotopic ratios are typically determined by MGA of the gamma-ray spectrum based on data 

obtained with the system’s HPGe detector. Gamma data can also provide direct quantification of 

a number of radionuclides, including 238Pu, 239Pu, 241Pu, 241Am, 233U, 235U, 238U, 137Cs and 237Np. 

The HPGe detector uses a multicurve efficiency calibration based on the waste matrix density to 

correct for gamma attenuation and other losses. 

New equipment or substantive physical modifications to approved equipment remains a T1 

change (see Table 1). Notification to EPA upon substantive modification to software for 

approved NDA equipment remains a T2 change (see Table 1). 

(2) EPA verified that the operational range of the High Efficiency Neutron Counter No. 2 

was unchanged from the last inspection and was adequate for the wastes LANL-CCP is 

currently assaying. 

Between November 13, 2012, and November 13, 2013, the HENC2 assayed 1,154 drums that 

were compiled in 164 BDRs. During this inspection, EPA inspectors observed the HENC2 

assaying Drum No. 68434. This drum assay was the first of the five replicate assays that EPA 

requested, as discussed further in Item (8) of this section. This drum was 95% full and had a net 

weight of 2.9 kg. EPA observed that HENC2 personnel had available and were using the current 

revisions of the HENC operating procedure (CCP-TP-063, Revision 15). For this assay, the 

LANL-CCP operator had performed and documented the daily background and performance 

check, and checks for the system’s FWHM and energy calibration (gain). LANL-CCP had 

established control limits [2 and 3  limits] for all parameters as well as boundary limits for 

background (10–60 cps), full spectrum, FWHM and gain. The HENC2 operator showed the EPA 

inspectors that all instrument parameters were acceptable and that LANL-CCP performed and 
17 

documented the assay adequately. All operational aspects of the HENC2 operation were 

acceptable. 

Notification to EPA upon substantive modification to operating ranges or site NDA procedures 

requiring CBFO approval remains a T2 change (see Table 1). 

(3) EPA verified that the High Efficiency Neutron Counter No. 2’s calibration was 

unchanged since the last inspection and noted that there were no major system changes 

apart from routine maintenance. 

EPA confirmed that the HENC2’s calibration was unchanged from the last EPA inspection, as 

indicated in LANL-CCP records (HENC#2-NDA-1002). LANL-CCP has performed six 

calibration verifications since August 2012 (the time of the last EPA inspection of the HENC2), 

all in response to routine operational measurement issues. EPA reviewed five of them; all aspects 

of the calibration verifications that EPA reviewed were technically acceptable and appropriately 

documented. Calibration verifications are a normal part of system operations and their presence 

is not indicative of a problem with the instrument. LANL-CCP personnel indicated that, on 

several occasions, ambient temperature fluctuations affected the FWHM value to the point where 

the calibration had to be verified, as required by the LANL-CCP operating procedure. LANLCCP performed subsequent QA/QC checks, and all values were accepted relative to the 

acceptance criteria. Regarding routine maintenance, LANL-CCP personnel stated that they 

replaced the drum rotator on January 8, 2013. This replacement was appropriately documented in 

a calibration verification report dated January 8, 2013. Additionally, LANL-CCP personnel 

stated that the 252Cf source used for the AaS correction is nearing the end of its operational life. 

LANL-CCP NDA personnel are aware of this problem and are currently attempting to obtain a 

source. 

All aspects of the HENC2’s calibration and the execution and documentation of calibration 

verifications were technically acceptable and appropriately documented. Extension of or changes 

to approved calibration ranges for approved equipment remains a T1 change (see Table 1). 

(4) EPA verified that determination and documentation for the total measurement uncertainty 

for the HENC2 are adequate. 

EPA verified that the TMU document LANL-HENC2-TMU-101 was unchanged from EPA’s 

last inspection. LANL-CCP documented the TMU of assays performed on the HENC2, as 

evidenced by reviewing HENC2 BDR Nos. 2LANDA1229 and 2LANDA1234. 

(5) EPA confirmed that LANL-CCP’s determination and documentation of the lower limit of 

detection, including the minimum detectable concentration of the High Efficiency 

Neutron Counter No. 2, had not changed, and that it was technically adequate. 

LANL-CCP documented the technical basis for the system’s LLD, including reporting thresholds 

for specific nonmeasured radionuclides 242Pu and 90Sr. These aspects are documented in 

HENC#2-NDA-1002, Revision 3, “Calibration Report for HENC #2 Including Passive Neutron 

and Gamma Spectrometer Calibration and Confirmation,” dated September 14, 2007, and 

LANL-NDA-1003-Lead-Lined, Revision 3, “Lead-Lined Calibration Report for the HENC #2 

Including Passive Neutron and Gamma Spectrometer,” dated June 3, 2010, both of which EPA 
18 

previously determined were adequate. The EPA inspection team verified that these documents 

were unchanged from EPA’s last inspection and continued to be adequate. 

(6) EPA established that the High Efficiency Neutron Counter No. 2 successfully 

participated in drum cycle 20A of the Carlsbad Field Office-sponsored Performance 

Demonstration Program. 

The HENC2 successfully participated in the CBFO sponsored PDP cycle 20A in the spring of 

2013. The HENC2 is scheduled to participate in the PDP annually. 

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

The HENC2 has 12 operators/ITRs and five EAs. All NDA personnel associated with the 

calibration, operation and data review and approval of the HENC2 had current training in the 

applicable areas, as evidenced by the LOQI dated November 14, 2013, 3:12 p.m., that was 

provided during the inspection. 

Submission to EPA of a list of all NDA personnel who performed work during the previous 

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

EAs and ITRs. EPA added this requirement to ensure that EPA has a complete picture of LANLCCP waste characterization activities, which will inform the scope of NDA components 

evaluated during future T1 change evaluations. 

(8) LANL-CCP performed replicate testing of the High Efficiency Neutron Counter No. 2, 

and EPA found it complied with the criteria for the Environmental Protection Agency 

Replicate Testing Protocol. 

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

an independent means to verify that the HENC2 can provide reproducible results for the 

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

240Pu, 242Pu, 90Sr, 233U, 234U and 238U) and the TRU alpha concentration.4

 This is accomplished 

by the HENC2 reassaying drums it previously measured to demonstrate the system’s ability to do 

the following: 

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

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

reported TMU. 

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

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

As part of this inspection, EPA requested that LANL-CCP reassay three containers that EPA 

randomly selected from a list of containers previously assayed on the HENC2. Container Nos. 

68428, and 68434 and 68571 were reassayed five times, and the results were compared to the 

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

2

) test and a t-test, were performed on 

 4

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

replicate testing assay protocol and data evaluation. 
19 

all three replicate assayed containers. Data and results of the statistical analysis are included in 

Attachments F.1 through F.3. 

The χ

2

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

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

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

measurements differed from the expected original measurement. The χ

2

 test for all containers 

assayed on the HENC2 showed that the observed variances in the replicate measurements are 

less than or equal to the reported uncertainties within the statistical limits of the test. 

The t-test is a statistical tool that is used to tell if two sets of data are statistically different from 

one another. EPA applied it to the replicate data to see if there are statistically significant 

differences between the original assay values and the average of the five replicate measurements. 

The t-test for both containers assayed on the HENC2 did not show any statistically significant 

differences between the original measurement assay values and the average of the five replicate 

measurements for the activities of any of the target radionuclides or the TRU alpha activity 

concentration. 

There are no technical issues associated with replicate testing of the HENC2. 

Summary of High Efficiency Neutron Counter No. 2

EPA did not identify any findings or concerns regarding the operation of the HENC2 or 

documentation thereof. EPA determined that the HENC2 was adequate in every respect. 

Submission to EPA of a list of all NDA personnel who performed work during the previous 

quarter is a new NDA T2 change (see Table 1). 

6.2.3 Technical Evaluation: Super High Efficiency Neutron Counter 

EPA evaluated LANL-CCP’s continued compliance with the EPA-approved waste 

characterization program for CH waste using the SuperHENC system. The EPA inspectors used 

a modified NDA checklist that addressed a subset of the items evaluated for this system during 

the initial approval, included in Attachment E.3. The following aspects of the SuperHENC were 

evaluated during this inspection. 

(1) EPA verified that the Super High Efficiency Neutron Counter was the same instrument 

that EPA approved previously and that its design and essential functions were unchanged 

since the last EPA inspection. 

The SuperHENC system is located in a trailer on site at LANL in TA-54 on Pad 10 in Area G, 

Building No. 547. The SuperHENC is a self-contained NDA unit that is physically housed in a 

mobile manufactured enclosure made up of a “High-Cube” freight container measuring 

approximately 48 feet long by 81⁄2 feet wide by 131⁄2 feet high. LANL-CCP uses this system to 

assay mainly standard waste boxes (SWBs) containing SCG S5000 debris. During this 

inspection, EPA verified that there have been no substantive hardware changes other than the 

detector replacement and subsequent recalibration that EPA reviewed and approved as a T1 

change in February 2013. 
20 

New equipment or substantive physical modifications to approved equipment remains a T1 

change (see Table 1). Notification to EPA upon substantive modification to software for 

approved NDA equipment remains a T2 change (see Table 1). 

(2) EPA assessed the design and operational range of the Super High Efficiency Neutron 

Counter and found them to be unchanged from the last inspection and adequate for the 

wastes currently being assayed. 

Between November 13, 2012, and November 13, 2013, the SuperHENC assayed 306 containers 

that were compiled in 102 BDRs. SuperHENC operators stated that the SuperHENC has the 

capability to assay up to six containers a day; however, in practice the system typically assays 

four containers each day. EPA observed the SuperHENC reassay of SWB No. 68107, which had 

a net weight of 122.0 kg and was 75% full. This SWB assay was the first of the five replicate 

assays that EPA requested, as discussed further in Item (7) of this section. 

For this assay, the LANL-CCP operator had performed and documented the daily background 

and performance check, and checks for the system’s FWHM and energy calibration (gain). 

LANL-CCP had established control limits (2 and 3  limits) for all parameters, as well as 

boundary limits for background (10–60 cps, full spectrum), FWHM and gain. The SuperHENC 

operator showed the EPA inspectors that all instrument parameters were acceptable and that 

LANL-CCP performed and documented the assay adequately. All operational aspects of the 

SuperHENC operation were acceptable. 

Notification to EPA upon substantive modification to operating ranges or site NDA procedures 

requiring CBFO approval remains a T2 change (see Table 1). 

(3) EPA verified that system calibration and calibration confirmation of the Super High 

Efficiency Neutron Counter had been performed and documented as required. 

The EPA inspection team verified that the system’s calibration was unchanged since the 

recalibration that EPA approved in August 2012. LANL-CCP has performed eight calibration 

verifications for the SuperHENC since August 2012, when NDA personnel replaced a gamma 

detector. All aspects of the calibration verification were technically acceptable and appropriately 

documented. 

Extension of or changes to approved calibration ranges for approved equipment remains a T1 

change (see Table 1). 

(4) EPA verified that the lower limit of detection, including the minimum detectable 

concentration, had been determined and documented, as required. 

The technical basis for the SuperHENC’s LLD is documented in LANL-SHENC3-NDA-1004, 

Revision 4, “Calibration Report for the SuperHENC at Los Alamos National Laboratory 

Including Passive Neutron and Gamma Spectrometer Calibration and Confirmation,” dated June 

15, 2012, Section 6.0. This document includes the technical basis for the reporting thresholds for 

specific nonmeasured radionuclides 234U, 238Pu, 239Pu, 242Pu and 90Sr. EPA verified that this 

document was unchanged from EPA’s last T1 inspection. 
21 

(5) EPA established that the Super High Efficiency Neutron Counter successfully 

participated in solid waste box cycle B13A of the Carlsbad Field Office-sponsored 

Performance Demonstration Program. 

The SuperHENC participated successfully in cycle B13A of the CBFO-sponsored PDP for 

SWBs in May 2013. The SHENC is scheduled to participate in the PDP annually. 

(6) 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 SuperHENC had current training in the applicable areas, as evidenced by the LOQI dated 

November 14, 2013, 3:14 p.m., that was provided during the inspection. 

Submission to EPA of a list of all NDA personnel who performed work during the previous 

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

EAs and ITRs. EPA added this requirement to ensure that EPA has a complete picture of LANLCCP waste characterization activities, which will inform the scope of NDA components 

evaluated during future T1 change evaluations. 

(7) LANL-CCP performed replicate testing of the SuperHENC, and EPA determined that it 

complied with the criteria for the Environmental Protection Agency Replicate Testing 

Protocol. 

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

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

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

240Pu, 242Pu, 90Sr, 233U, 234U and 238U) and the TRU alpha concentration.5

 This is accomplished 

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

to do the following: 

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

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

reported TMU. 

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

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

As part of this inspection, EPA requested that LANL-CCP reassay three SWBs that EPA 

randomly selected from a list of SWBs previously assayed on the SHENC. Container Nos. 

68107, 68211, and 68214 were reassayed five times, and the results were compared to the 

original assay data. Two statistical tests, a χ

2

 test and a t-test, were performed. Data and results of 

the statistical analysis are included in Attachments F.4 through F.6. The χ

2

 test, which is also 

known as the goodness-of-fit test or the chi-squared test for independence, is used to show how 

observed data compare with data we would expect to obtain according to a specific hypothesis. 

EPA applied it in this instance to show whether the replicate measurements differed from the 

 5

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

replicate testing assay protocol and data evaluation. 
22 

expected original measurement. The t-test is a statistical tool that is used to tell if two sets of data 

are statistically different from one another. EPA applied it to the replicate data to see if there are 

statistically significant differences between the original assay values and the average of the five 

replicate measurements. 

For Container Nos. 68107, 68211, and 68214, the χ

2

 test showed that the observed variances in 

the replicate measurements are less than or equal to the reported uncertainties within the 

statistical limits of the test. The t-test for Drum Nos. 68107 and 68214 also showed no 

statistically significant differences between the original assay values and the average of the five 

replicate measurements. 

The t-test for Drum No. 68211 showed a statistically “Significant” difference between the 

original assay value and the average of the five replicate measurements for 237Np. This indicates 

that there was a statistically significant difference between the original assay and the average of 

the replicate measurements of 237Np. All other radionuclides detected were within the expected 

ranges. It is important to keep in mind when evaluating replicate data that “Significant” results 

are not always representative of true measurement issues. 

There are several possible reasons for the “Significant” differences in 237Np replicate values 

versus original values: (1) actual changes in the physical configuration of the drum’s contents 

due to movement or settling, (2) fluctuations in the measurement system’s background, (3) 

temporal factors such as radioactive growth or decay, or (4) actual changes in the measurement 

system, the aspect that these tests are designed to query. Although the software identified these 

variances as “Significant,” this does not necessarily indicate a measurement issue that warrants 

additional attention at this time. 

EPA reviewers evaluated the results and found that the replicate measurements of 237Np were all 

precise (i.e., very close together). This resulted in a very small standard deviation in the 

population of replicate measurements. Therefore, the t-test indicated that the original sample was 

different enough from the replicates to warrant a “Significant” result. The average of the 

replicates [9.56 x 10-5 curie (Ci)] and the original sample (9.73 x 10-5 Ci) differ by a small 

amount, and 237Np is not a WIPP-tracked radionuclide. Additionally, replicate measurements of 

Drum Nos. 68107 and 68214 showed the instrument to be functioning properly. This suggests 

that settling or movement of wastes in the container resulted in a slight difference in the 237Np 

detected in Drum No. 68211. Waste shifting is expected when a container is moved, and this is 

not indicative of a problem with the instrument. 

Summary of Super High Efficiency Neutron Counter

EPA did not identify any findings or concerns regarding the operation of the SuperHENC or 

documentation thereof. EPA determined that the SuperHENC was adequate in every respect. 

Submission to EPA of a list of all NDA personnel who performed work during the previous 

quarter is a new NDA T2 change (see Table 1). 
23 

6.2.4 Technical Evaluation: Mobile In Situ Object Counting System Large Container 

Counter 

EPA initially inspected and approved the MILCC in July 2013 (see EPA Docket No. A-98-49; 

II-A4-176). Although the MILCC is an approved measurement modality at LANL-CCP, it has 

only been used for a small number of WIPP assays since EPA’s initial approval. LANL-CCP 

NDA personnel indicated that they do not anticipate the frequency of use will increase in the 

near future. Despite its lack of use, LANL-CCP continues to run weekly checks on the 

instrument to keep the instrument functioning properly. The EPA inspectors used a modified 

NDA checklist that addressed a subset of the items evaluated for this system during the initial 

approval, included in Attachment E.4. EPA evaluated the following aspects of the MILCC 

during this inspection. 

(1) EPA verified that the Mobile In Situ Object Counting System Large Container Counter 

was the same instrument that EPA approved previously and that its design and essential 

functions were unchanged from EPA’s initial inspection and that they were adequate for 

the wastes currently being assayed. 

The MILCC is located at LANL in the east end of Dome 283 in Area G at TA-54. EPA verified 

that there have been no substantive hardware or software changes to this system since the last 

EPA inspection. EPA verified that the original operational ranges for all of the system’s 

previously approved assay configurations were unchanged since the last EPA inspection. 

New equipment or substantive physical modifications to approved equipment remains a T1 

change (see Table 1). Notification to EPA upon substantive modification to software for 

approved NDA equipment remains a T2 change (see Table 1). 

(2) EPA verified that system calibration and calibration confirmation of the Mobile In Situ 

Object Counting System Large Container Counter had been performed and documented 

as required. 

EPA verified that the system’s original calibrations for all previously approved assay 

configurations were unchanged. LANL-CCP has performed three calibration verifications on the 

MILCC since the initial approval. EPA evaluated one of them and found it to be adequate. 

Notification to EPA of any change to the MILCC that does not directly impact the EPAapproved calibration, including relocation of the system at LANL, remains a T2 change (see 

Table 1). 

(3) EPA verified that the total measurement uncertainty of assays performed on the Mobile 

In Situ Object Counting System Large Container Counter had been determined and 

documented, as required. 

EPA verified that the system’s original determinations of TMU for all previously approved assay 

configurations were unchanged since the last EPA inspection. 
24 

(4) EPA verified that the lower limit of detection, including the minimum detectable 

concentration of the Mobile In Situ Object Counting System Large Container Counter, 

had been determined and documented, as required. 

The EPA inspection team verified that the system’s original determinations of LLDs for all 

previously approved assay configurations were unchanged since the last EPA inspection. 

(5) EPA established that the Mobile In Situ Object Counting System Large Container 

Counter successfully participated in the Carlsbad Field Office-sponsored Performance 

Demonstration Program, as required. 

The MILCC successfully participated in PDP cycle 20A and supplemental cycle B12C (for 

boxes). The MILCC is scheduled to participate in the PDP annually. 

(6) 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 MILCC had current training in the applicable areas, as evidenced by the LOQI dated 

November 14, 2013, 3:12 p.m., that was provided during the inspection. 

Submission to EPA of a list of all NDA personnel who performed work during the previous 

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

EAs and ITRs. EPA added this requirement to ensure that EPA has a complete picture of LANLCCP waste characterization activities, which will inform the scope of NDA components 

evaluated during future T1 change evaluations. 

Summary of Mobile In Situ Object Counting System Large Container Counter

EPA did not identify any findings or concerns regarding the operation of the MILCC or 

documentation thereof. EPA determined that the MILCC was adequate in every respect. 

Submission to EPA of a list of all NDA personnel who performed work during the previous 

quarter is a new NDA T2 change (see Table 1). 

6.2.5 Nondestructive Assay Findings and Approval 

Summary of Nondestructive Assay Findings and Concerns

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

Nondestructive Assay Approval

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

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

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

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

of LANL-CCP waste characterization activities, which will inform the scope of NDA 

components evaluated during future T1 change evaluations. 
25 

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

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

all NDA systems. 

6.3 Nondestructive Examination 

EPA performed a records-based, desktop continuing compliance evaluation of LANL-CCP RTR 

and VE operations during November 2013. EPA had limited discussions with LANL-CCP NDE 

personnel during the onsite inspection. 

Real-Time Radiography and Visual Examination Procedures

The procedures used to generate the data reported in the BDRs discussed throughout section 6.3 

are well established and have been reviewed by EPA inspectors at previous onsite inspections. 

The procedures continue to comply with 40 CFR 194. 

The current revision of CCP-TP-0286

 states: 

4.3.6 Place items back into the container EXCEPT any waste stream specific 

items previously included on the inventory. 

4.3.7 Place new waste stream specific items in the container. 

It is unclear if the procedure and process for construction of the training/test containers requires 

mandatory items to be consistently placed at the bottom of the container and waste-streamspecific items to be placed on top. This arrangement may not present the most stringent 

challenge to operators during their demonstration of capability examinations. EPA will monitor 

test/training container construction at future inspections. 

Notification to EPA upon substantive modification to site NDE procedures requiring CBFO 

approval remains a T2 change (see Table 1). 

6.3.1 Technical Evaluation: Real-Time Radiography 

EPA evaluated LANL-CCP’s continued compliance with EPA-approved RTR procedures for CH 

waste characterization. LANL-CCP’s RTR characterization program is EPA-approved for SCG 

S5000 (heterogeneous debris) waste, SCG S4000 (soils) and SCG S3000 (homogeneous solids). 

EPA reviewed RTR records for SCG S5000 and S3000 waste containers during this evaluation. 

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

adequate. 

EPA reviewed the audio/visual and written records for selected containers from BDR Nos. LAHERTR-13-0022, LA-HERTR-13-0085, LA-HERTR-13-0096 and LA-HERTR-13-0104. EPA 

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

Operators had properly examined each container’s contents and entered characterization data 

 6

 LANL-CCP Procedure CCP-TP-028, “CCP Radiographic Test Drum and Training Container 

Construction,” Revision 8, June 17, 2013. 
26 

into an 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 identified in 

the containers from the reviewed BDRs. 

Table 2. RTR Container Records Examined in This Inspection 

LANL-CCP performed an image quality check prior to each RTR event and performed the 

required QC examinations, in the form of an independent observation and replicate scan, for the 

BDRs examined. 

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

on the appropriate forms from the applicable CCP procedures. 

No NCRs had been issued for the containers reported in these BDRs. However, EPA did 

investigate NCR-LANL-0902-07 because it included a large number of containers. LANL-CCP 

explained to EPA that the containers had been characterized but not shipped when a change to 

the WIPP permit7

 occurred. Due to the permit change, LANL-CCP had to write an NCR for the 

unshipped containers containing residual liquid. These containers were dispositioned 

accordingly. 

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

accordance with written procedures. 

(2) EPA examined real-time radiography training records and found them to be adequate. 

EPA reviewed the following written and audio/visual training records for selected RTR 

operator/ITR personnel: 

 NDE Training Container Inventory Sheets for container Nos. NDE-Training-09, NDETraining-19, NDE-Test-20, NDE-Training-29 and NDE-Training-30. 

 Training container evaluation data sheets for selected operators. 

 Audio/visual recordings of training/test examinations for selected personnel. 

 Qualification cards for selected personnel. 

 7

 New Mexico Environment Department, “WIPP Hazardous Waste Facility Permit,” November 1, 2012. 

BDR No. Container No./WMC 

Acceptable 

Image Check 

reviewed? 

Y or N 

Required QC 

performed? 

Y or N 

LA-HERTR-13-0022 (55-gal. 

drum) 66946 / S5400; 93135 / S3150 Y Y 

LA-HERTR-13-0085 (55-gal. 

drum) 93834 / S3150; 93839 / S3150 Y Y 

LA-HERTR-13-0096 (SWB) SWB10145 / S5400 (original & 

replicate scans) Y Y 

LA-HERTR-13-0104 (55-gal. 

drum) 94225 / S3150; 94229 / S3150 Y Y 
27 

 LOQI for dates covering the time periods when the BDRs discussed in section 6.3.1 were 

generated. 

EPA determined that operators were trained in accordance with CCP procedures and that training 

records were readily available for review. EPA identified three errors in the training material 

reviewed. These errors are: 

 NDE-Training-29, section 2, records the container type as a drum; however, the container 

is an SWB. 

 CCP-TP-028, Attachment 1, No. 11 states “Leaded glove or leaded apron.” Because the 

inventory records the actual contents of the training container, this optional statement 

does not appear to be appropriate. 

 The original inventory for container NDE-Training-30 was incomplete. An extra bottle 

containing liquid was identified by an operator during the training examination. LANLCCP opened the training container and corrected the inventory for this container. 

These errors do not warrant the issuance of a concern. EPA will monitor the accuracy of records 

generated by LANL-CCP through future inspections. 

Submission to EPA of a list of all RTR personnel who performed work during the previous 

quarter is a new RTR T2 change (see Table 1). Specifically, the list must include all RTR 

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

LANL-CCP waste characterization activities, which will inform the scope of RTR components 

evaluated during future T1 change evaluations. 

Summary of Real-Time Radiography Findings and Concerns

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

compliance inspection. 

Real-Time Radiography Approval

Based on the results of this inspection and the data examined, EPA determines that LANL-CCP 

demonstrated continued RTR compliance. 

Submission to EPA of a list of all RTR personnel who performed work during the previous 

quarter is a new RTR T2 change (see Table 1). 

6.3.2 Technical Evaluation: Visual Examination 

EPA evaluated LANL-CCP’s continued compliance with EPA-approved VE procedures for CH 

waste characterization. LANL-CCP’s VE characterization program is EPA-approved for SCG 

S5000 (heterogeneous debris) waste and SCG S3000 (homogeneous solids). EPA reviewed VE 

records for SCG S5000 waste containers during this evaluation. 
28 

(1) EPA examined visual examination characterization records and found them to be 

adequate. 

EPA reviewed BDR Nos. LAVE550084 (55-gallon drum), LAVE550088 (55-gallon drum), 

LA13-OSR-VE-009 (sealed source) and LA13-OSR-VE-013 (sealed source). EPA determined 

that characterization records were complete and properly processed in accordance with 

applicable procedures. No NCRs had been generated for the containers in these BDRs. 

(2) EPA examined contact-handled visual examination training records and found them to be 

adequate. 

EPA reviewed training records for selected operators. EPA determined that VE operators 

continued to be trained in accordance with CCP procedures and that training records continued to 

be available for review. 

Submission to EPA of a list of all VE personnel who performed work during the previous quarter 

is a new VE T2 change (see Table 1). Specifically, the list must include all VE operators, ITRs 

and VEEs. EPA added this requirement to ensure that EPA has a complete picture of LANLCCP waste characterization activities, which will inform the scope of VE components evaluated 

during future T1 change evaluations. 

Summary of Visual Examination Findings and Concerns

EPA did not identify any findings or concerns for VE at LANL-CCP as a result of this continued 

compliance inspection. 

Visual Examination Approval

Based on the results of this inspection and the data examined, EPA determines that LANL-CCP 

demonstrated continued VE compliance. 

Submission to EPA of a list of all VE personnel who performed work during the previous quarter 

is a new VE T2 change (see Table 1). 

6.3.3 Nondestructive Examination Findings and Approval 

Summary of Nondestructive Examination Findings and Concerns

EPA did not identify any findings or concerns for NDE at LANL-CCP. 

Nondestructive Examination Approval

Based on the results of this inspection and the data examined, EPA determines that LANL-CCP 

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

all NDE systems. 

Based on this inspection, there is one clarifying change to the VE T1 designations and one new 

NDE T2 change. Any use of VE for SCG S4000 (soils) waste is now explicitly defined as a T1 
29 

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 Table 1). Specifically, 

the list must include all VE and RTR operators, ITRs and VEEs. 

7.0 FINDINGS AND CONCERNS 

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

However, EPA observed several errors with LANL-CCP’s document and record management 

during the AK portion of the inspection as discussed in section 6.1 and Attachments D.1 through 

D.4 of this report. During the inspection, EPA informed CBFO and LANL-CCP that this issue 

must be corrected. LANL-CCP agreed and committed to take necessary steps to prevent 

recurrence. EPA also informed CCP and CBFO that a varying degree of similar errors has been 

observed in the past at other TRU Sites. CBFO and CCP need to address this systemic problem. 

EPA will continue to review CCP’s document and record management during future continued 

compliance inspections and T1 evaluations of all CCP TRU waste characterization programs. 

EPA has also observed similar inconsistencies with AK documents during inspections of other 

CCP TRU waste characterization programs. EPA will continue to review CCP’s document and 

record management during future continued compliance inspections and T1 evaluations of all 

CCP TRU waste characterization programs. 

8.0 CONCLUSIONS 

Changes to Tiering

Based on this inspection, there is one clarifying change to the VE T1 designations. Any use of 

VE for SCG S4000 (soils) waste is a new T1 change. EPA previously approved the VE processes 

for characterization of SCG S5000 (heterogeneous debris) and SCG S3000 (homogeneous 

solids) wastes but had not explicitly stated that use of VE for SCG S4000 waste required a T1 

evaluation. This change to the tiering table clarifies the requirement. 

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

NDE: 

1. Notification to EPA upon completion of or revisions to DRs is a new AK T2 change. 

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

the LANL-CCP waste characterization program during the previous quarter is a new AK 

T2 change. 

3. Submission to EPA of a list of all NDA personnel who performed work during the 

previous quarter is a new NDA T2 change. 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 NDE T2 change. Specifically, the list must include 

all VE and RTR operators, ITRs and VEEs. 
30 

The T2 changes listed above are necessary to make the LANL-CCP tiering designations 

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

for conducting T1 evaluations (see section 2.0 of this report). EPA also revised the tiering tables 

to ensure completeness and consistency with recent EPA T1 approval reports. Table 1 shows the 

substantive T1 and T2 changes in bold text. T1 and T2 changes that were initiated during the 

baseline and subsequent T1 approvals remain in effect. The language in Table 1 regarding AK 

documentation applies to all LANL-CCP waste streams. 

Approval

The EPA inspection team determined that the LANL-CCP waste characterization program 

activities continue to be technically adequate. EPA is not proposing any changes to the LANLCCP waste characterization program at this time. The scope of the compliance decision is based 

on EPA’s inspection completed November 19–21, 2013.

As mentioned above, EPA expects LANL-CCP to notify EPA at the end of the current quarter 

(2nd quarter, Fiscal Year 2014) regarding the changes that have been made to LANL-CCP’s 

procedures and practices to prevent recurrence of the document and record management issues. 

EPA will use results of this continued compliance inspection to support the streamlined T1 

evaluation and decision process discussed in section 2.0 of this report. The results of this 

continued compliance inspection and the review of quarterly T2 changes submitted since the 

November 2013 inspection will be the basis for EPA’s evaluations of any LANL-CCP T1 change 

requests until the next EPA continued compliance inspection. As a result, EPA will only focus 

on the significant waste characterization components of the T1 change request that are critical to 

a specific approval (e.g., waste-stream-specific AK records). In addition, EPA may not revisit the 

elements discussed in this report until the next continued compliance inspection, at the Agency’s 

discretion. 
A-1 

ATTACHMENT A: APPROVAL SUMMARY FOR LANL-CCP CONTACT-HANDLED 

WASTE CHARACTERIZATION PROGRAM 

Approved Activity EPA Inspection Number, 

Approval Dates EPA Docket Number 

LANL-CCP CH Baseline Approval LANL-CCP-05.06-8, June 21, 

2007 A-98-49, II-A4-88 

T1 Change – Extension of Range for the High 

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

T1 Change – Extension of Range for the High 

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

T1 Change – Assay of Lead-Lined Drums on the High 

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

Continued Compliance Inspection February 9, 2011 A-98-49, II-A4-141 

T1 Change – Addition of the SuperHENC October 28, 2011 A-98-49, II-A4-153 

T1 Change – Calibration Extension of High Efficiency 

Neutron Counter No.1 and SuperHENC August 14, 2012 A-98-49; II-A4-164 

T1 Change – Addition of SCG S3000 December 31, 2012 A-98-49; II-A4-168 

T1 Change – Addition of the MILCC July 22, 2013 A-98-49; II-A4-176 
B-1 

ATTACHMENT B: LIST OF DOCUMENTS REVIEWED FOR THIS INSPECTION 

AK

Common to all four waste streams: 

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

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

2013 

CCP-QP-005, Revision 21, Attachment 1 – CCP Nonconformance Report (NCR), NCR-LANL0734-13, Revision 0, Originated November 20, 2013 

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

June 19, 2013 

CCP-TP-005, CCP Acceptable Knowledge Documentation, Revision 26, August 12, 2013 

Lists of fully characterized containers for Waste Streams LA-MHD01.001, LA-MSG04.001, LACIN01.001 and LA-OS-00-01.001, provided October 29, 2013 

AKE Qualification card for Randy Fitzgerald, June 16, 2011 

AKE Qualification card for Amy Johns, June 16, 2011 

AKE Qualification card for Michael Papp, June 16, 2011 

AKE Qualification card for Jim Shoen, June 16, 2011 

AKE Qualification card for Chris Chancellor, June 16, 2011 

AKE Qualification card for Lisa Price-Watson, June 16, 2011 

AKE Qualification card for Sherry Auckland, September 28, 2011 

SPM Qualification card for Terri-Anne Groover, June 24, 2009 

SPM Qualification card for Craig Simmons, February 7, 2005 

SPM Qualification card for Carolina Soaterna, May 31, 2011 

SPM Qualification card for Veronica Waldram, August 4, 2009 

AK Tracking Spreadsheet (LANL), provided November 20, 2013 

Repackaged AK Tracking Spreadsheet (LANL), provided November 20, 2013 

Waste Streams LA-MHD01.001 and LA-CIN01.001 

Add Container Memorandum, April 6, 2012 
B-2 

Attachment 8 – Waste Containers List, Waste Stream LA-CIN01.001, November 13, 2012 

Attachment 8 – Waste Containers List, Waste Stream LA-MHD01.001, November 13, 2012 

C040, Interview with J. Foxx re: P/S Codes PB, PuBe, CC, MB, MS, FF, BF, and other issues, 

TWCP-4162, October 12, 2000 

C057, Commingling of Defense and Nondefense TRU Waste, Charles L. Foxx, TWCP-887, 

August 21, 1997 

C082, Interview with J. Foxx and Supporting Documentation re: Defense Relationship of TA-55 

Waste, J. Musgrave, TWCP-4167, October 18, 2000 

C124, Interview with Jim Foxx Regarding Material Type 83 Used at TA-55, Steve Schafer, 

September 16, 2004 

C125, Decay Corrected Values for LANL Heat Source Plutonium, Steve Schafer, April 25, 2006 

C144, Record of Communication, S. Schafer, November 28, 2006 

C145, Memo: Evaluation of LANL Pu-238 Waste Management Practices, K. Peters, January 2, 

2007 

C186, Letter on Material Type Isotopic Composition, Benchmark, AL-7193, May 2, 1997 

C192, Memorandum to Pamela Rogers; Acceptable Knowledge for Pu-238 Waste Generated at 

the Los Alamos Plutonium Facility, TA-55, C.L. Foxx and A.J. Montoya, NMT7-WM/EC-97-

201, December 19, 1997 

C194, Comments from Jim Foxx on the Draft Pu-238 AK Summary Report (dated November 

1999), C.L. Foxx, November 1999 

C197, Interview with Jim Foxx and Gary Rinehart Relating to the RCRA Characterization and 

Management of Pu-238 Liquids and P/S Code Operations, TWCP, December 22, 1999 

C204, Interview with Jim Foxx; Segregation of Non-Defense Wastes from Defense Wastes, 

TWCP, October 12, 2000 

C209, Interview with J. Foxx re: Sources of Cs-137, Pa-231 and Cm-244 in TA-55 TRU Waste, 

TWCP, April 11, 2001 

C212, Memorandum to Ed Wilmont, Pu-238 Waste at TA-55, CBFO, 

CBFO:Oom:RPD:JGW:04-0435:UFC:5822, May 20, 2004 

C219, Interview with Jim Foxx: Material Type 83 Used at TA-55, Steve Schafer, September 16, 

2004 

C220, Jim Foxx's Review and Comments on Draft Process Flow Diagrams, Jim Foxx, February 

21, 2006 

C222, Decay Corrected Values for LANL Heat Source Plutonium, Steve Schafer, April 25, 2006 
B-3 

C225, Evaluation of Additional Containers for Waste Stream LA-MHD01.001, Jim Schoen, 

various dates 

C234, Evaluation of Additional Containers for Waste Stream LA-CIN01.001, James M. Schoen, 

various dates 

CCP-AK-LANL-006, Central Characterization Program Acceptable Knowledge Summary 

Report for Los Alamos National Laboratory TA-55 Mixed Transuranic Waste, Waste Streams: 

LA-MHD01.001, LA-CIN01.001, LA-MIN02-V.001 and LA-MIN04-S.001, Revision 12, 

December 12, 2012 

CCP-QP-005, Revision 21, Attachment 1 – CCP Nonconformance Report (NCR), NCR-LANL0618-12, Revision 1, Originated March 27, 2012, Closed September 13, 2012 

CCP-QP-005, Revision 21, Attachment 1 – CCP Nonconformance Report (NCR), NCR-LANL1492-12, Revision 0, Originated August 8, 2012, Closed December 5, 2012 

CCP-QP-005, Revision 21, Attachment 1 – CCP Nonconformance Report (NCR), NCR-LANL0615-12, Revision 0, Originated March 16, 2012, Closed May 1, 2012 

CCP-QP-005, Revision 21, Attachment 1 – CCP Nonconformance Report (NCR), NCR-LANL1023-12, Revision 0, Originated September 19, 2012, Closed September 20, 2012 

CCP-QP-005, Revision 21, Attachment 1 – CCP Nonconformance Report (NCR), NCR-LANL1635-12, Revision 0, Originated August 30, 2012, Closed November 14, 2012 

CCP-QP-005, Revision 21, Attachment 1 – CCP Nonconformance Report (NCR), NCR-LANL0713-12, Revision 0, Originated May 8, 2012, Closed January 24, 2013 

CCP-QP-005, Revision 22, Attachment 1 – CCP Nonconformance Report (NCR), NCR-LANL2050-12, Revision 0, Originated November 26, 2012, Closed April 8, 2013 

CCP-QP-005, Revision 22, Attachment 1 – CCP Nonconformance Report (NCR), NCR-LANL0011-13, Revision 0, Originated February 1, 2013, Interim Disposition Approved February 5, 

2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, Waste Stream LA-CIN01.001, December 19, 

2012 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, Waste Stream LA-CIN01.001, 

December 14, 2012 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 10 – 

Acceptable Knowledge Re-evaluation Checklist, Waste Stream LA-CIN01.001, October 23, 

2012, October 30, 2012, and December 4, 2012 
B-4 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 11 – 

Acceptable Knowledge Source Document Discrepancy Resolution – Example Form, Waste 

Stream LA-CIN01.001, various dates 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, Waste Stream LA-MHD01.001, December 17, 

2012 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, Waste Stream LA-MHD01.001, 

December 14, 2012 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 10 – 

Acceptable Knowledge Re-evaluation Checklist, Waste Stream LA-MHD01.001, various dates 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 11 – 

Acceptable Knowledge Source Document Discrepancy Resolution – Example Form, Waste 

Stream LA-MHD01.001, various dates 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 7 – 

Radionuclides, Waste Stream LA-CIN01.001, November 6, 2013, including LA-CIN01.001 

AK/NDA Memo, Revision 1, James M. Schoen, December 12, 2012 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, Waste Stream LACIN01.001, November 20, 2013, including Waste Material Parameter Analysis Memorandum for 

Waste Stream LA-CIN01.001, LANL TA-55 Cemented TRU Waste, Steve Schafer, May 2, 2007 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 7 – 

Radionuclides, Waste Stream LA-MHD01.001, November 20, 2013, including LA-MHD01.001 

AK/NDA Memo, Revision 8, James M. Schoen, March 3, 2010 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, Waste Stream LAMHD01.001, November 19, 2013, including Waste Material Parameter Analysis Memorandum 

for Waste Stream LA-MHD01.001, LANL TA-55 Mixed Heterogeneous Debris Waste, Steve 

Schafer, December 13, 2011 

CCP-TP-005, various revisions, CCP Acceptable Knowledge Documentation, Attachment 13 – 

CCP Waste Stream Characterization Checklist – Example Form, Waste Stream LA-CIN01.001, 

various dates 

CCP-TP-005, various revisions, CCP Acceptable Knowledge Documentation, Attachment 13 – 

CCP Waste Stream Characterization Checklist – Example Form, Waste Stream LA-MHD01.001, 

various dates 

CCP-TP-005, various revisions, CCP Acceptable Knowledge Documentation, Attachment 14 – 

CCP Acceptable Knowledge Accuracy Report – Example Form, Waste Stream LA-MHD01.001, 

various dates 
B-5 

Characterization Information Summary, WSPF No. LA-CIN01.001, Lot 19, August 22, 2012 

Characterization Information Summary, WSPF No. LA-CIN01.001, Lot 41, December 28, 2012 

Characterization Information Summary, WSPF No. LA-MHD01.001, Lot 323, September 20, 

2012 

Characterization Information Summary, WSPF No. LA-MHD01.001, Lot 380, May 21, 2013 

Characterization Information Summary, WSPF No. LA-MHD01.001, Lot 332, November 6, 

2012 

D023, TA-55 Plutonium Facility Acceptable Knowledge Report, TWCP-AK-2.1-008, Revision 

2, May 14, 2001 

D025, Acceptable Knowledge Report for Debris Waste Streams Containing Pu-239, TWCP-AK2.1-015, Revision 3, April 10, 2003 

D041, Acceptable Knowledge Information Summary for LANL Transuranic Waste Streams, 

AK-00-019, Revision 1, September 22, 2003 

D045, Final Safety Analysis Report for TA-55 NMT, Derek Gordon, TWCP-415, July 13, 1995 

D073, Lightweight Radioisotope Heater Unit (LWRHU) Production for the Galileo Mission, 

G.H. Rinehart, LA-11166-MS, April 1998 

D074, Lightweight Radioisotope Heater Unit (LWRHU) Production for the Cassinni Mission, 

G.H. Rinehart, LA-13143-MS, May 1996 

D076, Acceptable Knowledge Summary Report for Waste Streams TA-55-43, TA-55-44, TA55-45, TA-55-46, TA-55-47, J. Musgrave, TWCP-AK-2.1-011, September 20, 2001 

D080, Process Acceptable Knowledge Summary Report for Plutonium-238 Operations at TA-55, 

J. Musgrave, TWCP-AK-2.1-009, August 7, 2001 

D083, Acceptable Knowledge Information Summary for LANL Transuranic Waste Streams, 

C.H. Smith, AK-00-01-019, Revision 1, September 22, 2003 

D084, Acceptable Knowledge Report for Debris Waste Streams Containing Pu-239, B.J. 

Humphrey, TWCP-AK-2.1-015, Revision 3, April 10, 2003 

DR001, Discrepancy Resolution: Waste Stream Assignment, Steve Schafer, April 12, 2005 

DR005, Acceptable Knowledge Source Document Discrepancy Resolution – Homogeneous 

Solids in Containers S818280, S818308, S822622, S818309, S832485, S862359, S802994 and 

S811632, Randy Fitzgerald, May 2, 2006 

DR032, Discrepancy Resolution – Removal of Seventeen (17) Homogeneous Containers from 

Debris Waste Stream LA-MHD01.001, Randy Fitzgerald, February 7, 2012 
B-6 

DR033, Discrepancy Resolution – Removal of Eleven (11) Homogeneous Drums from Debris 

Waste Stream (LA-MHD01.001), Randy Fitzgerald, February 7, 2012 

DR035, Removal of Twenty-Three (23) Homogeneous Drums from Debris Waste Stream (LAMHD01.001), Amy Johns, June 8, 2012 

DR040, Removal of Five (5) Homogeneous Drums from Debris Waste Stream LA-MHD01.001, 

Randy Fitzgerald, June 8, 2012 

DR042, Removal of 18 Homogeneous Drums from Heterogeneous Debris Waste Stream LAMHD01.001, Amy Johns, December 4, 2012 

DR043, Miscellaneous Debris Items in LA-CIN01.001 (cemented) Container No. 53706, Randy 

Fitzgerald, July 9, 2012 

DR044, Removal of 114 Heterogeneous Drums from Cemented Waste Stream (LA-CIN01.001) 

Amy Johns, August 17, 2012 

DR045, Acceptable Knowledge Source Document Discrepancy Resolution – Removal of 18 

Heterogeneous Drums from Cemented Waste Stream LA-CIN01.001, Amy Johns, October 22, 

2012 

DR046, Removal of 35 Heterogeneous Drums from Cemented Waste Stream (LA-CIN01.001), 

Amy Johns, October 30, 2012 

DR048, Acceptable Knowledge Source Document Discrepancy Resolution – Waste Stream LAMHD01.001 Radiological Characterization, Michael J. Papp, September 20, 2012 

DR049, Removal of 23 Homogeneous Drums from Heterogeneous Debris Waste Stream (LAMHD01.001), Amy Johns, December 5, 2012 

M015, Managing Radioactive Waste, LIR404-00-05.2, January 5, 1999 

M019, Generator Documentation, LANL, various document numbers, various dates 

M156, Project 2010 Container Specific Database Information for LA-MHD01.001, C. Smith, 

May 25, 2004 

M157, Project 2010 Database Summary of Waste Codes from LA-MHD01.001, September 17, 

2004 

M158, Project 2010 Database Information Waste Item Descriptions Summary, September 17, 

2004 

M159, Project 2010 Container Specific Database Information – Area G Reported Radionuclides, 

C. Smith, May 25, 2004 

M216, LANL Hard Copy TWSRs for LA-MHD01 and LA-MHD02 from AK6 Remaining Set, 

LANL Waste Generators, various dates 
B-7 

M217, LANL Hard Copy TWSRs for LA-MHD01 and LA-MHD02 from AK7 Remaining Set, 

LANL Waste Generators, various dates 

M219, Electronic Image of TWSRs and RSWD Forms from Imagic Software, LANL Waste 

Generators, various dates 

M222, Concert Database (converted to Access format), Nathan Mcranie, TWCP-24370, 

February 2, 2005 

M224, LANL Hard Copy RSWDs and TWSRs for LA-MHD01 and LA-MHD02, LANL Waste 

Generators, various dates 

M226, LANL Hard Copy RSWDs and TWSRs for LA-MHD01 and LA-MHD02, LANL Waste 

Generators, various dates 

M238, NUGEN Drum TWSRs, various dates 

M273, LA-MHD01.001 TWSRs, various dates 

M274, TWSRs for Containers 80000 Series, various dates 

M275, TA55 NUGEN TWSRs, various dates 

M308, Pu-238 Defense Determination Resolution, Steve Schafer, April 11, 2005 

M309, Radiological Discrepancy Report, Steve Schafer, April 25, 2006 

Memorandum from M.F. Ramirez to NTPC Records Custodian: Transmittal of Los Alamos 

National Laboratory Site Waste Stream Profile Form LA-MHD01.001, Revision 1, for Waste 

Stream LA-MHD01.001, May 20, 2013, including: CCP-TP-002, Revision 25, CCP 

Reconciliation of DQOs and Reporting Characterization Data, Attachment 2 – CCP Waste 

Stream Profile Form (Example), Waste Stream LA-MHD01.001, Revision 1, May 22, 2013; 

Characterization Information Summary, WSPF No. LA-MHD01.001, Lot 368, May 9, 2013; 

Summation of Aspects of AK Summary Report: LA-MHD01.001 

Memorandum from S.M. Peterman to C.A. Stepzinski: Acceptable Knowledge Accuracy Report: 

Los Alamos National Laboratory Waste Stream Number LA-CIN01.001, Mixed Cemented 

Homogeneous Solid Waste from TA-55, Lots 1 through 2, March 30, 2011, including CCP-TP005, Revision 19, CCP Acceptable Knowledge Documentation, Attachment 14 – CCP 

Acceptable Knowledge Accuracy Report – Example Form, Waste Stream LA-CIN01.001, Lots 1 

through 2, March 30, 2011; CCP-TP-005, Revision 26, CCP Acceptable Knowledge 

Documentation, Attachment 14 – CCP Acceptable Knowledge Accuracy Report – Example 

Form, Waste Stream LA-CIN01.001, Lots 1 through 2, November 20, 2013 

Memorandum from S.M. Peterman to C.A. Stepzinski: Acceptable Knowledge Accuracy Report: 

Los Alamos National Laboratory Waste Stream Number LA-MHD01.001, Mixed Heterogeneous 

Debris from TA-55, Lots 180 through 226, March 30, 2011, including CCP-TP-005, Revision 

19, CCP Acceptable Knowledge Documentation, Attachment 14 – CCP Acceptable Knowledge 

Accuracy Report – Example Form, Waste Stream LA-MHD01.001, Lots 180 through 226, 

March 30, 2011; CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, 
B-8 

Attachment 14 – CCP Acceptable Knowledge Accuracy Report – Example Form, Waste Stream 

LA-MHD01.001, Lots 180 through 226, November 20, 2013 

Memorandum from S.M. Peterman to CCP Records Custodian: Transmittal of Approved Waste 

Stream Profile Form for Los Alamos National Laboratory Mixed Cemented Homogeneous Solid 

Waste from TA-55 (LA-CIN01.001), June 28, 2010, including: CCP-TP-002, Revision 21, CCP 

Reconciliation of DQOs and Reporting Characterization Data, Attachment 2 – CCP Waste 

Stream Profile Form (Example), Waste Stream LA-CIN01.001, Revision 0, June 9, 2010; 

Characterization Information Summary, WSPF No. LA-CIN01.001, Lot 1, June 4, 2010; 

Summation of Aspects of AK Summary Report: LA-CIN01.001 

Memorandum from T. Groover to C.E. Simmons: Acceptable Knowledge Accuracy Report: Los 

Alamos National Laboratory Waste Stream Number LA-CIN01.001, Mixed Cemented 

Homogeneous Solid Waste from TA-55, Lots 7 through 60, July 1, 2013, including CCP-TP005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 14 – CCP 

Acceptable Knowledge Accuracy Report – Example Form, Waste Stream LA-CIN01.001, Lots 7 

through 60, July 1, 2013; CCP-TP-005, Revision 26, CCP Acceptable Knowledge 

Documentation, Attachment 14 – CCP Acceptable Knowledge Accuracy Report – Example 

Form, Waste Stream LA-CIN01.001, Lots 7 through 60, November 20, 2013 

Memorandum from T. Groover to C.E. Simmons: Acceptable Knowledge Accuracy Report: Los 

Alamos National Laboratory Waste Stream Number LA-MHD01.001, Mixed Heterogeneous 

Debris from TA-55, Lots 300 through 367, July 1, 2013, including CCP-TP-005, Revision 24, 

CCP Acceptable Knowledge Documentation, Attachment 14 – CCP Acceptable Knowledge 

Accuracy Report – Example Form, Waste Stream LA-MHD01.001, Lots 300 through 367, July 

1, 2013; CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 14 

– CCP Acceptable Knowledge Accuracy Report – Example Form, Waste Stream LAMHD01.001, Lots 300 through 367, November 20, 2013 

Memorandum from T. Groover to R.D. Reeves: Acceptable Knowledge Accuracy Report: Los 

Alamos National Laboratory Waste Stream Number LA-CIN01.001, TA-55 Mixed Transuranic 

Waste (Cemented TRU Waste), Lots 3 through 6, July 11, 2012, including CCP-TP-005, 

Revision 24, CCP Acceptable Knowledge Documentation, Attachment 14 – CCP Acceptable 

Knowledge Accuracy Report – Example Form, Waste Stream LA-CIN01.001, Lots 3 through 6, 

July 11, 2012 

Memorandum from T. Groover to R.D. Reeves: Acceptable Knowledge Accuracy Report: Los 

Alamos National Laboratory Waste Stream Number LA-MHD01.001, TA-55 Mixed Transuranic 

Waste (Heterogeneous Debris), Lots 227 through 299, July 12, 2012, including CCP-TP-005, 

Revision 24, CCP Acceptable Knowledge Documentation, Attachment 14 – CCP Acceptable 

Knowledge Accuracy Report – Example Form, Waste Stream LA-MHD01.001, Lots 227 

through 299, July 12, 2012 

NDA BDR 1LANDA1621, August 16, 2012 

NDA BDR 1LANDA1757, April 24, 2013 

NDA BDR 2LANDA1021, July 23, 2012 

NDA BDR 2LANDA1059, September 26, 2012 
B-9 

NDA BDR 2LANDA1208, August 8, 2013 

NDA BDR 3LANDA0059, May 4, 2012 

P094, Documenting Acceptable Knowledge for Legacy Waste Items, NMT7-AP-020, Revision 

1, October 30, 2002 

P118, Acceptable Knowledge Documentation, TWCP-QP-1.1-021, Revision 0, April 22, 1997 

RTR BDR LA-HERTR-12-0034, April 12, 2012 

RTR BDR LA-HERTR-12-0065, July 21, 2012 

RTR BDR LA-HERTR-12-0082, August 15, 2012 

RTR BDR LA-HERTR-13-0030, March 23, 2013 

RTR BDR LA-HERTR-13-0058, May 17, 2013 

RTR BDR LA-RTR2-12-0113, September 24, 2012 

Waste Stream LA-MSG04.001 

C033, Evaluation of Volume, Period Generation, and Calculation of Individual and Total 

Radionuclide Masses and Activities for Waste Stream LA-MSG04.001, J. Schoen, September 

30, 2009 

C035, Record of Communication, Subject: Drum Washing of Drums Retrieved from BelowGrade, James R. Fitzgerald, February 25, 2009 

C037, Evaluation of Volume and Period of Generation for Waste Streams LA-MHD04.001 and 

LA-MSG04.001, and Calculation of Individual and Total Radionuclide Masses and Activities for 

Waste Stream LA-MHD04.001, James M. Schoen, P2010-3188, April 4, 2012 

C038, Evaluation of Additional Containers for Waste Stream LA-MSG04.001, James M. 

Schoen, P2010-3366, various dates 

CCP-AK-LANL-010, Central Characterization Program Acceptable Knowledge Summary 

Report for Los Alamos National Laboratory TA-21 DP West Facility, Waste Streams: LAMHD04.001 and LA-MSG04.001, Revision 6, February 14, 2013 

CCP-QP-005, Revision 20, Attachment 1 – CCP Nonconformance Report (NCR), NCR-LANL3637-11, Revision 0, Originated October 6, 2011, Closed May 21, 2012 

CCP-QP-005, Revision 23, Attachment 1 – CCP Nonconformance Report (NCR), NCR-LANL0681-13, Revision 0, Originated September 17, 2013, Interim Disposition Approved September 

19, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, April 12, 2012 
B-10 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, January 16, 2013, including 

Waste Material Parameter Analysis Memorandum for Waste Stream LA-MSG04.001, Mixed 

Contaminated Soil from TA-21 DP West Facility, Michael J. Papp, January 16, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, July 30, 2012, and February 12, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, February 11, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, June 5, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 10 – 

Acceptable Knowledge Re-evaluation Checklist, June 7, 2012 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 11 – 

Acceptable Knowledge Source Document Discrepancy Resolution –Example Form, June 7, 2012 

CCP-TP-005, Revision 25, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist – Example Form, June 27, 2013 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 7 – 

Radionuclides, November 19, 2013, including LA-MSG04.001 AK/NDA Memo, Revision 2, 

May 12, 2012 

Characterization Information Summary, WSPF No. LA-MSG04.001, Lot 2, June 27, 2013 

D006, Demolition of Building 12, an Old Plutonium Filter Facility, E.L. Christensen, R. Garde 

and A.M. Valentine, LA-5755, TWCP-18949, Jan 1975 

D035, Los Alamos DP West Plutonium Facility Decontamination Project 1978–1981 Raymond 

Garde, E.J. Cox, Allen M. Valentine, LA-9513-MS, TWCP-14396, September 1982 

D059, Acceptable Knowledge Operations Report for Plutonium Processing at the TA-21 DP 

West Facility (Draft Report), C. Smith, P2010-0608, TWCP 23596, AK-00-23, Revision 0, July 

8, 2004 

D069, A History of Waste Disposal at Technical Area 21 1943–1978, Ethan Merrill, March 1990 

M003, Waste Streams from Buildings TA-21, TA-55, TA-50 and TA-00 at LANL. Appendices 

B, C, D, E and F (Changes to Sampling Plan), TWCP-04138, TWCP Plan-0.2.7-001, Revision 2, 

June 4, 1999 

M004, TA-55 NMT Waste Management System (CONCERT Database), LANL NMT division, 

no date 

M008, Excerpt from CONCERT Database, August 17, 2006 
B-11 

M012, Radioactive Solid Waste Disposal (RSWD) Records from TA-50 Documenting TA-21 

Repackaged Waste, various dates 

M020, RSWD/TWSR Records for LA-MSG04.001, various dates 

Memorandum from M.F. Ramirez to NTPC Records Custodian: Transmittal of Los Alamos 

National Laboratory Site Waste Stream Profile Form LA-MSG04.001 for Waste Stream LAMSG04.001, June 26, 2013, including: CCP-TP-002, Revision 24, CCP Reconciliation of DQOs 

and Reporting Characterization Data, Attachment 2 – CCP Waste Stream Profile Form 

(Example), Waste Stream LA-MSG04.001, Revision 0, June 19, 2013; Characterization 

Information Summary, WSPF No. LA-MSG04.001, Lot 1, June 4, 2013; Summation of Aspects 

of AK Summary Report: LA-MSG04.001 

NDA BDR 2LANDA0878, September 27, 2011 

P036, Waste Management Plan for Material Disposal Area (MDA) B, Don Allen, TA21-MDABPLAN-00014, Revision 1, December 15, 2010 

RTR BDR LA-RTR2-11-0116, September 26, 2011 

Waste Stream LA-OS-00-01.001 

C002, Letter to J. Browne (LANL) re: Approval to Generate OSRP Waste with No Disposal 

Path, R. Glass, DOE, TWCP-03760, February 10 2000 

C004, Memos and Other Documentation Supporting Pu-239 Defense Relationship, TWCP17036, 

July 8, 2003 

C005, Memo to K. Hargis re: Transfer Planning Letter for Shipment of Special Nuclear Material 

(UCNI), J. Brooks, U.S. Navy, June 10, 1999 

C006, Memos to S. Leonard and other re: Release of Sources to DOE (UCNI), N. Wrzeski, U.S. 

Navy, TWCP-05615, March 1, 2000 

C011, Defense Documentation for Eight SRS-Owned Sealed Sources, T. Feske, TWCP-10113, 

September 12, 2002 

C066, Interview of Jim Matzkev and Jerry McAlpin by AKE Lisa Watson regarding Method for 

Handling Leaking Sealed Sources, Lisa Watson, C066, January 25, 2012 

C073, OSRP email requests for drums to be characterized between December 2012 to March 

2013 to be added to the LANL AK Tracking Spreadsheet, Christopher Chancellor and Sherry 

Auckland, various dates 

C074, OSRP email requests for drums to be characterized between March 2013 through May 

2013 to be added to the LANL AK Tracking Spreadsheet, Christopher Chancellor and Sherry 

Auckland, various dates 

C076, Email requests for drums to be added to the LANL AK Tracking Spreadsheet between 

July 2013 and September 2013, Sherry Auckland, various dates 
B-12 

CCP-AK-LANL-008, Central Characterization Program Acceptable Knowledge Summary 

Report for Los Alamos National Laboratory Off-Site Source Recovery Project Sealed Sources, 

Waste Streams: LA-OS-00-01.001, LA-OS-00-03 and LA-OS-00-04, Revision 9, May 3, 2012 

CCP-QP-005, Revision 20, Attachment 1 – CCP Nonconformance Report (NCR), NCR-LANL3637-11, Revision 0, Originated October 6, 2011, Closed May 21, 2012 

CCP-QP-005, Revision 23, Attachment 1 – CCP Nonconformance Report (NCR), NCR-LANL0587-13, Revision 1, Originated August 14, 2013, Closed September 17, 2013 

CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, July 18, 2012 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers List, October 29, 2013 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 7 – 

Radionuclides, November 20, 2013, including M133, Characterization of Am-241/Be/Cs-137 

Combination Sources, Alex Feldman, N2: 07-142(R1)/TA54-04090/P2010-2175, June 28, 2007; 

C027, Memorandum: Explanation of Table Revisions to CCP-AK-LANL-008 for Incorporation 

of Am-241/Be/Cs-137 Combination Sources, Alex Feldman, NS-07-001 OSRP Files, October 

31, 2007 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, October 30, 2013 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, October 29, 2013 

CCP-TP-005, various revisions, CCP Acceptable Knowledge Documentation, Attachment 11 – 

Acceptable Knowledge Source Document Discrepancy Resolution –Example Form, various 

dates 

CCP-TP-005, various revisions, CCP Acceptable Knowledge Documentation, Attachment 13 – 

CCP Waste Stream Characterization Checklist – Example Form, various dates 

Characterization BDR LA12-OSR-CH-054, January 2, 2013 

Characterization BDR LA13-OSR-CH-007, March 28, 2013 

Characterization Information Summary, WSPF No. LA-OS-00-01.001, Lot 82, August 23, 2013 

Characterization Information Summary, WSPF No. LA-OS-00-01.001, Lot 72, March 5, 2013 

D003, Hazardous Waste Determination for Actinide-Bearing Sealed Sources to Be Received at 

LANL, L. Leonard, TWCP-03409, February 25, 2005 

D004, The Off-Site Source Recovery Project at Los Alamos, L. Leonard, J. Tompkins, S. 

Leonard, M. Pearson, J. McAlpin and C. Grigsby, TWCP-03756, LA-UR-99-6218, January 1, 

1999 
B-13 

D005 Summary of Sealed Source Types, OSR Project, S. Loenard, TWCP-03759, April 11, 2000 

D011, Special Form Documentation for AmBe and PuBe Neutron Test Sources (UCNI), J. 

Foster, TWCP-05634, March 1, 1991 

D023, WIPP Eligibility Determination of U.S. Army Research Laboratory Pu-239 Fission Foils, 

S. Leonard, TWCP-25636, June 1, 1999 

D025, Transuranic Waste Defense Determination Approval Forms, Joel Grimm, NNSA, 

February 17, 2006 

D030, Transuranic Waste Defense Determination Approval Forms, Waste Stream LA-OS-NS04, Julia Whitworth, P210-2296, various dates 

D031, Waste Determination of Encapsulated Radioactive Sources Containing Small Quantities 

of Lithium, M.W. Pearson, Julia Whitworth, Timothy Burns and John U. Moon, LA-UR-08-

03351, April 1, 2008 

DR001, Discrepancy Resolution re: Difference between NMMSS and Shipping Data for Seven 

LLNL Sealed Sources, J. Whitworth, TWCP-24765, April 7, 2005 

DR002, Discrepancy Resolution re: Source MRC-PuBe-8-8, J. Whitworth, TWCP-25265, June 

15, 2005 

DR003, Discrepancy Resolution re: Manufacture Dates on Recanned Monsanto Sources, J. 

Whitworth, TWCP-24925, June 13, 2005 

DR004, Discrepancy Resolution re: Source Pu8Be47-A&B from SRS, J. Whitworth, TWCP25633, June 15, 2005 

DR005, Discrepancy Resolution re: Pu Value on Source M-1228, J. Whitworth, TWCP-24926, 

May 3, 2005 

DR006, Discrepancy Resolution re: Pu Value on Source M561, J. Whitworth, TWCP-25266, 

June 15, 2005 

DR007, Discrepancy Resolution re: Sources MRPUBE346-348, J. Whitworth, TWCP-25264, 

June 20, 2005 

DR008, Discrepancy Resolution re: Sources in Container 60384, J. Whitworth, TWCP-25634, 

July 21, 2005 

DR009, Discrepancy Resolution re: Sources MRPU228-252, J. Whitworth, TWCP-25635, July 

19, 2005 

DR010, Discrepancy Resolution re: Certain Dates in NMMSS Database, J. Whitworth, DR010, 

August 8, 2005 

DR011, Discrepancy Resolution of Manufacturing Orders for AmBe Neutron Sources Made by 

Monsanto Research Corp. for Schlumberger Well Services, Monsanto Research Corp (MRC), 

M189–M190, various dates 
B-14 

DR012, Discrepancy Resolution of Attempt to Add the Already Emplaced Container No. 58651 

to the Tracking Spreadsheet Based on a VE-BDR that Included It among Four Other Containers 

that Were to Be Added to the AK, Christopher Chancellor, DR012, April 24, 2012 

M001, Summary of Waste Stream Containers/Spreadsheet of OSR Defense Related Drums, J. 

McAlpin/J. Whitworth, P2010-0919, various dates 

M005, Query of “Registry of Radioactive Sealed Sources and Devices,” May 21, 1982, J. 

Whitworth/S. Leonard (LANL), TWCP-03758/P0210-0925, various dates 

M031, Container Packaging and VE Data Records, various dates 

M305, AK Documentation for VE BDR LA13-OSR-VE-016 and Characterization BDR LA13-

OSR-CH-016 Drums: LA00000065490 and LA00000066724, LA-UR-13-27553, various dates 

M306, AK Documentation for VE BDR LA13-OSR-VE-018 and Characterization BDR LA13-

OSR-CH-18 Drums: LAD0000066719 and LA00000067500, LA-UR-13-27552, various dates 

M307, AK Documentation for VE BDR LA13-OSR-VE-019 and Characterization BDR LA13-

OSR-CH-019 Drums: LA00000061472, LA00000065492 and LA00000065493, LA-UR-13-

27551, various dates 

M308, AK Documentation for VE BDR LA13-OSR-VE-020 and Characterization BDR LA13-

OSR-CH-020 Drum: LA00000062756, LA-UR-13-27855, various dates 

Memorandum from R.R. Chavez to CCP Records Custodian: Transmittal of Waste Stream 

Profile Forms for Waste Streams LA-MHD01.001, LA-MIN03-NC.001, LA-OS-00-01.001 and 

LA-MHD02.001, May 11, 2006, including: CCP-TP-002, Revision 14, CCP Reconciliation of 

DQOs and Reporting Characterization Data, CCP Waste Stream Profile Form, Waste Stream 

LA-OS-00-01.001, Revision 0, June 29, 2005; Characterization Information Summary, WSPF 

No. LA-OS-00-01.001, Lot 1, June 23, 2005; Summation of Aspects of AK Summary Report: 

LA-OS-00-01.001 

Memorandum from S.M. Peterman to C.A. Stepzinski: Acceptable Knowledge Accuracy Report: 

Los Alamos National Laboratory Waste Stream Number LA-OS-00-01.001, WIPP Eligible Offsite Recovery Sealed Sources, Lots 22 through 36, March 30, 2011, including CCP-TP-005, 

Revision 19, CCP Acceptable Knowledge Documentation, Attachment 14 – CCP Acceptable 

Knowledge Accuracy Report – Example Form, Waste Stream LA-OS-00-01.001, Lots 22 

through 36, March 30, 2011; CCP-TP-005, Revision 26, CCP Acceptable Knowledge 

Documentation, Attachment 14 – CCP Acceptable Knowledge Accuracy Report – Example 

Form, Waste Stream LA-OS-00-01.001, Lots 22 through 36, November 20, 2013 

Memorandum from T. Groover to C.E. Simmons: Acceptable Knowledge Accuracy Report: Los 

Alamos National Laboratory Waste Stream Number LA-OS-00-01.001, WIPP Eligible Off-site 

Resources Sealed Sources, Lots 47 through 78, June 27, 2013, including CCP-TP-005, Revision 

24, CCP Acceptable Knowledge Documentation, Attachment 14 – CCP Acceptable Knowledge 

Accuracy Report – Example Form, Waste Stream LA-OS-00-01.001, Lots 47 through 78, June 

27, 2013; CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 

14 – CCP Acceptable Knowledge Accuracy Report – Example Form, Waste Stream LA-OS-00-

01.001, Lots 47 through 78, November 20, 2013 
B-15 

Memorandum from T. Groover to R.D. Reeves: Acceptable Knowledge Accuracy Report: Los 

Alamos National Laboratory Waste Stream Number LA-OS-00-01.001, Off-site Source 

Recovery Project Sealed Sources (Defense Sealed Sources), Lots 37 through 46, July 11, 2012, 

including CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 

14 – CCP Acceptable Knowledge Accuracy Report – Example Form, Waste Stream LA-OS-00-

01.001, Lots 37 through 46, July 11, 2012 

P001, CCP-TP-069 CCP Sealed Source Visual Examination and Packaging, Central 

Characterization Program (CCP), CCP-TP-069, Revision 5, November 9, 2010 

P004, Recovery, Transport, and Storage of Off-Site Source Recovery Project Material, Jim 

Matzke, OSR-OP-100 (TWCP-24436) (P2010-0951), Revision 9, February 12, 2010 

VE BDR LA12-OSR-VE-054, November 29, 2012 

VE BDR LA13-OSR-VE-007, August 10, 2010 

WIPP Eligible OSR Sealed Sources (LA-OS-00-01.001) Change Notice #1 Update for WIPP 

Operating Record, Sue Peterman, Revision 0, December 5, 2006 

WIPP Eligible OSR Sealed Sources (LA-OS-00-01.001) Change Notice #2 Update for WIPP 

Operating Record, Sue Peterman, Revision 0, June 15, 2010 

NDA

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

NDA 2000, Revision 2, August 26, 2013 

CCP-TP-063, CCP Operating the High Efficiency Neutron Counter Using NDA 2000, Revision 

15, August 23, 2013 

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

Efficiency Neutron Counter Using NDA 2000, Revision 7, August 23, 2013 

CCP-TP-076, CCP Operating the Mobile ISOCS Large Container Counter Using NDA 2000, 

Revision 0, May 16, 2013 

CCP-TP-077, CCP Calibrating the Mobile ISOCS Large Container Counter Using NDA 2000, 

Revision 0, May 16, 2013 

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

at LANL Using NDA 2000, Revision 11, May 16, 2013 

CI-MILCC-NDA-1006, Calibration Report for the Mobile ISOCS Large Container Counter 

(MILCC) at Los Alamos National Laboratory Including Gamma Spectrometer Calibration and 

Confirmation, Revision 0, April 4, 2013 

CI-HENC-TMU-101, Revision 0, Total Measurement Uncertainty for the MCS HENC #1 with 

Integral Gamma Spectrometer, Revision 1, March 23, 2005 
B-16 

HENC #1 Calibration Verifications, January 15, 2013, February 14, 2013, February 22, 2013, 

April 2, 2013, July 16, 2013, and October 23, 2013 

HENC #2 Calibration Verifications, January 8, 2013, March 27, 2013, April 30, 2013, May 31, 

2013, and July 25, 2013 

HENC#2-NDA-1002, Calibration Report for HENC #2 Including Passive Neutron and Gamma 

Spectrometer Calibration and Confirmation, Revision 3, September 14, 2007 

HENC1 BDR Nos. 1LANLDA1850 and 1LANDA1857 

HENC1 Operational Logbook pages, April 22, 2013, and May 10, 2013 

HENC2 BDR Nos. 2LANDA1234 and 2LANDA1229 

HENC2 Operational Logbook pages, August 22, 2013, and October 2, 2013 

LANL-CCP List of Qualified Individuals, November 14, 2013, 3:12 p.m. 

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

Gamma Spectrometer, Revision 0, April 10, 2006 

LANL-NDA-1003-Lead-Lined, Lead-Lined Calibration Report for the HENC #2 Including 

Passive Neutron and Gamma Spectrometer, Revision 3, June 3, 2010 

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

Laboratory Including Passive Neutron and Gamma Spectrometer Calibration and Confirmation, 

Revision 4, June 15, 2012 

MCS-HENC#1-NDA-1002, Calibration Report for the HENC #1 Including Passive Neutron and 

Gamma Spectrometer Calibration and Confirmation, Revision 6, October 3, 2007 

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

Including Passive Neutron and Gamma Spectrometer, Revision 1, July 5, 2012 

MILCC BDR Nos. 4LANDA0012 and 4LANDA0016 

MILCC Calibration Verification, October 22, 2013 

MILCC Operational Logbook pages, July 15, 2013, July 24, 2013, and November 19, 2013 

SuperHENC BDR Nos. 3LANDA0215 and 3LANDA0219 

SuperHENC Calibration Verifications, October 15, 2012, October 29, 2012, January 23, 2013, 

May 3, 2013, July 1, 2013, July 3, 2013, July 29, 2013, and July 31, 2013 

SuperHENC Operational Logbook pages, May 18, 2013, and July 8, 2013 

Total Measurement Uncertainty for the MCS/LANL ISOCS ‘Box Counter,’ Revision 2, March 

27, 2013 
B-17 

NDE

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

CCP-TP-028, CCP Radiographic Test Drum and Training Container Construction, Revision 8, 

June 17, 2013 

CCP-TP-113, CCP Standard Contact-Handled Waste Visual Examination, Revision 18, 

September 25, 2013 

CCP-TP-053, CCP Standard Real-Time Radiography (RTR) Inspection Procedure, Revision 14, 

September 25, 2013 

CCP-TP-069, CCP Sealed Source Visual Examination and Packaging, Revision 6, June 6, 2013 

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

2013 

NDE Training Container Inventory Sheets for container Nos. NDE-Training-09, NDE-Training19, NDE-Test-20, NDE-Training-29 and NDE-Training-30 

RTR BDR LA-HERTR-13-0022, March 7, 2013 

RTR BDR LA-HERTR-13-0085, July 17, 2013 

RTR BDR LA-HERTR-13-0096, September 4, 2013 

RTR BDR LA-HERTR-13-0104, September 23, 2013 

Audio/visual recordings for selected containers from RTR BDR Nos. LA-HERTR-13-0022, LAHERTR-13-0085, LA-HERTR-13-0096 and LA-HERTR-13-0104 

VE BDR LAVE550084, December 17, 2012 

VE BDR LAVE550088, February 15, 2013 

VE BDR LA13-OSR-VE-009, April 22, 2013 

VE BDR LA13-OSR-VE-013, July 1, 2013 

List of Non-Conformance Reports 

NCR No. NCR-LANL-0902-07 

Lists of Qualified Individuals, dated between 2012 and 2013 

Qualification records for selected VE and RTR personnel 

RTR operator training DVDs and evaluation data sheets 

Training drum inventories, Container Nos. 09, 19, 29 and 30 
B-18 

Test drum inventories, Container No. 20 
C-1 

ATTACHMENT C: INSPECTION PERSONNEL 

Personnel Affiliation Area of Expertise/Function Entrance 

Meeting Interviewed 

Rajani Joglekar U.S. EPA ORIA Inspector–Team Leader  

Ed Feltcorn U.S. EPA ORIA Inspector 

Dorothy Gill SC&A, Inc. RTR/VE Inspector  

Kira Darlow SC&A, Inc. AK Inspector 

Patrick Kelly SC&A, Inc. NDA/DTC Inspector  

Rose Gogliotti SC&A, Inc. NDA/DTC Inspector 

Rick Day LANL NEN-3-OSRP AK  

Tom Morgan DOE CBFO Observer 

Mark Doherty CTAC/NTP Observer 

Kenneth Simpson VJT NDE 

Terri-Anne Groover NWP/CCP SPM  

Veronica Waldram NWP/CCP SPM  

Carolina Soaterna NWP/CCP SPM  

Michael Papp Tech Specs/CCP AKE  

Jim Shoen Tech Specs/CCP AKE  

David Hemsing NWP/CCP VE  

Jim Thompson NWP/CCP VE  

Aaron Elliott VJT NDE  

Curt Baumann MCS/Canberra NDA  

Gilbert Waldman NWP/CCP Observer–Safety  

Niel Dickes NWP/CCP NDA  

Sherry Aukland LANL AKE  

Tim Barton NDA-CCP NDA  

Ellen Gammon LANL VE/CH ITR 

Ioana Witkowski LANL CH SME/VE ITR 

Craig Simmons CCP/NWP PM 

Ed Gulbransen CCP/NWP NTPC Management 
D-1 

ATTACHMENT D.1: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: WASTE STREA

EPA Inspection No.: LANL-CC-2013 Waste Stream: LA-MHD01.001 Inspection D

Technical Elements Objective Evidence and Comments 

AK-1: Do AK, training and nonconformance 

procedures adequately reflect the requirements of 40 CFR 194? 

Yes. This report and its attachments provide examples of adequate implementation of elocation given after the dash: CCP-QP-002, Revision 35, training and qualification plan – report body 6.1.1, Item (6)CCP-QP-005, Revision 23, nonconforming item report: AK checklist item AK-6–NCRCCP-TP-002, Revision 26, WSPF package development: AK checklist item AK-5. CCP-TP-005, Revision 26, AK documentation: AK checklist items AK-2, 4, 6–DRs, 7, 

AK-2: Is the AK characterization process, 

including AK assembly, compilation and verification, adequate? 

Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, 

a. Attachment 1, Revision 24, Acceptable Knowledge Documentation Checklist: Comb. Attachment 2, Revision 23, Record of Communication: Completed when appropriatc. Attachment 3s, various revisions, Acceptable Knowledge Source Document Summa

source documents. 

d. Attachment 4, Revision 24, Acceptable Knowledge Information List: Complete. e. Attachment 5, Hazardous Constituents: Outside EPA’s purview; not reviewed. 

f. Attachment 6, Revision 26, Waste Form, Waste Material Parameters, Prohibited Ite

Initially provided as Revision 23 when should have been Revision 24; was revised dassociated WMP analysis memorandum support estimates in AKSR and discussed i

g. Attachment 7, Revision 26, Radionuclides: Complete. Revised during inspection to 

version of NDA memorandum. Supports estimates given in AKSR and discussed in also discussion in checklist item AK-8. 

h. Attachment 8, Revision N/A, Waste Containers List: Complete, dated 11/13/2012. L

format for Attachment 8; this format includes all required components. Revised perlist of containers; revised during inspection (ink correction) to correct number of waAdd-container memoranda (i.e., Reference C225) support evaluations of containers tracking spreadsheet and Attachment 8. 

i. Attachment 9 is no longer required and attachment number is reserved for future us

j. Attachment 10, Revision 24, Acceptable Knowledge Re-evaluation Checklist: Com

Attachment 10s written in 2012: one to change radionuclide range, four to remove cheterogeneous debris, one to return containers that had been erroneously removed dIn 2013, started appending to DRs and not storing separately. 

k. Attachment 11, Revision 24, Acceptable Knowledge Source Document Discrepancy 

appropriate; see AK checklist item AK-6. 

l. Attachment 12, Example Form and Content Guide for AK Summary Reports: Refer

completion; see review of completed AKSR in AK checklist item AK-4. 

m. Attachment 13, various revisions, CCP Waste Stream Characterization Checklist: C

n. Attachment 14, various revisions, CCP Acceptable Knowledge Accuracy Report: C

AK checklist item AK-7. 

o. Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: Not ap
D-2 

EPA Inspection No.: LANL-CC-2013 Waste Stream: LA-MHD01.001 Inspection D

AK-3: Are waste containers traceable from 

retrieval through CCP’s EPA-approved characterization process? 

Yes. Tracked Container Nos. 91027, S802581 and 66621. 91027: daughter drum from container S811897. Per the repackaging spreadsheet, S8118

gallon drums, including 91027, on 3/12/2012. S811897 was generated 12/08/1981 and cAKE stated that S811897 was added to AKTSS on 4/1/2008. 91027 was added to AKTMemorandum not provided). Physical characterization: LA-HERTR-12-022 resulted in 3/16/2012, for prohibited item; remediated 4/12/2012 and re-characterized in LA-HERTRadiological characterization: 3LANDA0059, assay on 5/4/2012 resulted in NCR-LAN

232U outside expected AK bounds. AK was revised, NDA determined acceptable, NCR 

91027 is included in LA-MHD01.001, Lot 323. Per AK tracking spreadsheet, container on 10/3/2012. (References AKSR, Rev. 12; AKTSS; CIS signed 9/20/2012, DR048 and S802581: generated 2/15/1980 and indicated to contain homogenous solids from PF-4. 

CIN01.001 but removed 8/30/2012 after RTR identified that the container was more thaMHD01.001 10/5/2012 (Add Container Memorandum not provided). Physical characte11/26/2012, rejected for impenetrable item(s); reran through HERTR 3/23/13 (ReferencRadiological characterization: 1LANDA1757, assay on 4/24/13. Drum No. S802581 is Lot 380. Per AK tracking spreadsheet, container not yet emplaced at WIPP facility. (Re5/21/2013, DR046, M238, NCR-LANL-1635-12 and NCR-LANL-2050-12) 66621: generated 3/19/2012 and contained debris from PF-4. Added to LA-MHD01.00

characterization: LA-RTR2-12-0113, 9/24/2012. Radiological characterization: 2LANDDrum No. 66621 is included in LA-MHD01.001, Lot 332. Per AK tracking spreadsheetWIPP facility on 12/8/2012. (References Add Container Memorandum dated 4/6/2012, M275) 

AK-4: Does the AK summary report include 

sufficient information, supported by appropriate source documents, to support the statements below? a. All waste within the waste stream was 

generated from a single process/activity. 

b. All waste within the waste stream is similar in 

material and physical form. 

c. All waste within the waste stream has similar 

radiological properties. 

d. All of the waste in the waste stream is defense 

in origin. 

e. None of the waste in the waste stream is highlevel waste. f. None of the waste in the waste stream is spent 

nuclear fuel. 

Yes. CCP-AK-LANL-006, Revision 12, contains all required items. 

a. LA-MHD01.001 was produced by all operations in PF-4 at TA-55 from 1979 throug

were distinctly different operations in PF-4, but the wastes were historically packagbe separated into separate waste streams. Operations were primarily in two categoriPu (primarily 239Pu and 240Pu) and 238Pu heat source programs (References C144, C

D025, D045, M019, M216, M217, M219 and M222). 

b. LA-MHD01.001 is a heterogeneous debris waste stream consisting of a variety of d

graphite, plastic, cellulosic materials, rubber and filters. Each container may also cocake/filter materials, salts and ash residues, but less than 50% by volume (ReferenceDR005, M019, M156, M157, M158, M216, M217, M219, M222, M224, M226, M2

c. All of the waste is from operations related to processing 239Pu, 240Pu and 238Pu. The 

expected in the waste stream are 239Pu and 238U, while over 95% of the total activity 

U is not usually part of the Pu MTs handled in PF-4, but 238U was introduced into th

(References C125, C186, C194, C209, C219, C222, D025, D073, D074, D076, D08M216, M217, M219, M222, M238, M273, M274, M275 and M309). 

d. The extraction and recovery of Pu operations were in direct support of LANL’s wea

program. 238Pu operations were both defense and non-defense related; however, all 

the defense production K Reactor at SRS. Additionally, all of the PF-4 wastes were defense or non-defense origin and cannot be separated (References C040, C057, C0
D-3 

EPA Inspection No.: LANL-CC-2013 Waste Stream: LA-MHD01.001 Inspection D

and M308). 

e. LA-MHD01.001 contains only wastes associated with R&D/fabrication and associa

equipment maintenance, D&D, waste repackaging, and below-grade retrieval opera

involve separation or reprocessing of constituent elements from reactor fuel, and, th(References D023, M015, P094 and P118). 

f. LA-MHD01.001 does not contain irradiated fuel elements withdrawn from a reactor

fuel elements. Therefore, the waste stream does not contain SNF (References D023

AK-5: Are the waste stream profile form and 

related attachments complete and adequate/accurate? Related attachments include: a. Characterization information summary b. Summation of aspects 

Yes. WSPF, Revision 1: dated 5/22/2013. WSPF is complete; package includes compleand complete summation of aspects based on the current-at-the-time AKSR (CCP-AK-LWSPF was revised to add content codes. 

AK-6: Are nonconformances and discrepancy 

resolutions documented appropriately? 

Yes. NCR-LANL-0011-13: containers RTR’d as homogenous; NCR open pending AK containers out of waste stream. NCR-LANL-0713-12: containers RTR’d as homogenous; NCR closed, containers rejecCIN01.001. DR032, DR033, DR035, DR040, DR042, DR048 and DR049 were written in 2012, six <50% heterogeneous debris. 

AK-7: Is the AK accuracy report technically 

adequate? Has it been updated annually? 

Yes. The 2011 report was written on Attachment 14, Revision 19. It should have been wreport was written on Attachment 24. It should have been written using Revision 25. LAfound that all of one SPM’s 2013 Attachment 14s were written using the wrong Revisio

written for all 2013 Attachment 14s and three 2011 Attachment 14s. EPA reviewed the 

AK-8: Is AK-NDA communication adequately 

documented? 

Yes. AK-NDA communication documented in CCP-TP-005, Revision 26, Attachment 7attached NDA memorandum signed 4/22/2010. Attachment 7 was modified to change texpected predominate radionuclides did not change; therefore, the NDA memorandum states that it supersedes the table in the NDA memorandum. No single isotopic distributwaste stream; therefore the EA will acquire container-specific information if AK is to b

characterization. Attachment 7 was modified during inspection to include the 2010 NDA 

AK-9: Has notification of applicable T2 changes 

been provided to EPA as required in the LANLCCP CH tiering table? 

Yes. EPA tracking began with 4th quarter FY 2009. Tier 2 change notification required 

a. AK accuracy reports (annually, at a minimum) – Received correct notification for 2

b. AK reassessment memoranda and combination of waste streams – N/A. No addition

combined with LA-MHD01.001. 

c. AK-VE memoranda – N/A. Not applicable to LA-MHD01.001. d. AK-NDA memoranda – revised March 2010 and signed 4/22/2010. EPA received c

quarter FY 2010 T2 report. 

e. AKSRs – EPA received T2 notifications for Revisions 10 (3rd quarter FY 2010), 11 

(1st quarter FY 2013). All other revisions were before EPA started tracking T2 notif

f. WSPFs, new, revised and CNs – EPA received T2 notification for Revision 1 (3rd qu
D-4 

ATTACHMENT D.2: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: WASTE STRE

EPA Inspection No.: LANL-CC-2013 Waste Stream: LA-MSG04.001 Inspection D

Technical Elements Objective Evidence and Comments 

AK-1: Do AK, training and nonconformance 

procedures adequately reflect the requirements of 40 CFR 194? 

Yes. See Attachment D.1, AK checklist item AK-1. 

AK-2: Is the AK characterization process, 

including AK assembly, compilation and verification adequate? 

Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, 

a. Attachment 1, Revision 24, Acceptable Knowledge Documentation Checklist: Com

b. Attachment 2, Revision 23, Record of Communication: Completed when appropriat

c. Attachment 3, various revisions, Acceptable Knowledge Source Document Summar

source documents. The Attachment 3s for C037 and C038 were generated since the stream. Both were appropriately completed using Revision 24 of the form. 

d. Attachment 4, Revision 24, Acceptable Knowledge Information List: Revised since 

C038. 

e. Attachment 5, Hazardous Constituents: Outside EPA’s purview; not reviewed. f. Attachment 6, Revision 24, Waste Form, Waste Material Parameters, Prohibited Ite

It and associated WMP analysis memorandum support estimates in AKSR and discu

g. Attachment 7, Revision 26, Radionuclides: Complete; was revised during the inspec

241Am range. Supports estimates given in AKSR and discussed in AK checklist item 

checklist item AK-8. 

h. Attachment 8, Revision 24, Waste Containers List: Has not been updated since the l

during the inspection LANL-CCP identified that the wrong version of Attachment 8 remediated during the inspection. C038 was added to the record as an add-container 

additional SWB of soil waste. 

i. Attachment 9 is no longer required and attachment number is reserved for future us

j. Attachment 10, Revision 24, Acceptable Knowledge Re-evaluation Checklist: Chec

additions have not been necessary since the initial evaluation. DR was completed as 

k. Attachment 11, Revision 24, Acceptable Knowledge Source Document Discrepancy 

been generated since the last evaluation (see AK checklist item AK-6). 

l. Attachment 12, Example Form and Content Guide for AK Summary Reports: Refer

completion; see review of completed AKSR in AK checklist item AK-4. 

m. Attachment 13, Revisions 24 and 25, CCP Waste Stream Characterization Checklis

n. Attachment 14, CCP Acceptable Knowledge Accuracy Report: Not yet completed; o. Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: Not ap

AK-3: Are waste containers traceable from 

retrieval through CCP’s EPA-approved characterization process? 

Yes. Tracked Container No. 89988, which is a daughter drum from Container no. S8132spreadsheet, S813240 was repackaged into 7 55-gallon drums, including 89988, on 9/131/29/1981 and contained soil from the tunnel under room 213. 89988 was added to wasAttachment 8. Physical characterization: LA-RTR-11-0116, examined on 9/26/2011. Ra

2LANDA0878, examined on 9/27/2011; NCR-LANL-3637-11 for mismatch between N
D-5 

EPA Inspection No.: LANL-CC-2013 Waste Stream: LA-MSG04.001 Inspection D

resolved by revising AK and closed on 5/21/2012. Drum No. 89988 is included in LA-Mtracking spreadsheet, container was emplaced at WIPP facility on 7/11/2013. (ReferencM020) 

AK-4: Does the AK summary report include 

sufficient information, supported by appropriate source documents, to support the statements below? a. All waste within the waste stream was 

generated from a single process/activity. 

b. All waste within the waste stream is similar in 

material and physical form. 

c. All waste within the waste stream has similar 

radiological properties. 

d. All of the waste in the waste stream is defense 

in origin. 

e. None of the waste in the waste stream is highlevel waste. f. None of the waste in the waste stream is spent 

nuclear fuel. 

Yes. CCP-AK-LANL-010, Revision 6, contains all required items and, except for WMP significantly revised since the last evaluation. 

a. LA-MSG04.001 was produced by D&D of TA-21 DP West facility. DP West opene

industrial Pu processing facility. Over the years, the facility shifted to R&D and fina

efforts since that time have generated containers of contaminated soils from spills olines, tunnels below buildings, MDAs, tank systems, and various locations in the im(References C033, D006, D035, D069, M003, M004 and P036). 

b. LA-MSG04.001 is composed primarily of soils/gravels. The WMP estimates were r

review. The new estimates are based on RTR data for Lot 1 containers with addition

AK record (References Attachment 6 & memo and BDR No. LA-RTR2-11-0116). 

c. Primary radionuclides expected in the waste stream are 238U and 239Pu (by mass), w

radiological activity expected to be contributed by 239Pu. All of DP West Facility’s 

contributed to the soil contamination and therefore LA-MSG04.001’s radiological p

and M008). 

d. DP West operations recovered Pu from residues and scraps from around the DOE c

defense nuclear materials production and defense nuclear waste and materials bypro

passed through the same gloveboxes, so all wastes are considered comingled; defeninseparable (References D059 and M012). 

e. LA-MSG04.001 wastes are from D&D of the DP West facility, which did not invol

the constituent elements of reactor fuel (Reference D059). 

f. LA-MSG04.001 wastes are from D&D of the DP West facility and do not contain ir

(References D059 and BDR No. LA-RTR2-11-0116). 

AK-5: Are the waste stream profile form and 

related attachments complete and adequate/accurate? Related attachments include: a. Characterization information summary b. Summation of aspects 

Yes. WSPF, Revision 0: dated 6/19/2013. WSPF is complete; package includes complecomplete summation of aspects based on the current-at-the-time AKSR (CCP-AK-LAN

AK-6: Are nonconformances and discrepancy 

resolutions documented appropriately? 

Yes. NCR-LANL-0681-13 is new since the last evaluation. It was appropriately initiate

disposition at time of inspection. LANL-CCP AKEs indicated that disposition will incluif the NDA results change the predominate radionuclides – no change to AK if no changradionuclides. LANL-CCP AKEs are also planning to revise the NDA memo to remove automatically write an NCR if the measured radionuclides are outside the expected rang

procedure CCP-TP-005. No DRs have been written for LA-MSG04.001 since the previous evaluation. 

AK-7: Is the AK accuracy report technically 

adequate? Has it been updated annually? 

N/A. LANL-CCP has not yet written an AK accuracy report for LA-MSG04.001. The wCBFO in June 2013. The first AK accuracy evaluation for this waste stream will be con
D-6 

EPA Inspection No.: LANL-CC-2013 Waste Stream: LA-MSG04.001 Inspection D

AK-8: Is AK-NDA communication adequately 

documented? 

Yes. AK-NDA communication documented in CCP-TP-005, Revision 26, Attachment 7attached NDA memorandum dated 5/12/2012. Attachment 7 was revised during this ins

expected range. The NDA memorandum has not been revised since the last evaluation; 7 did not affect the contents of the NDA memorandum. 

AK-9: Has notification of applicable T2 changes 

been provided to EPA as required in the LANLCCP CH tiering table? 

Yes. EPA tracking began with 4th quarter FY 2009. Tier 2 change notification required 

a. AK accuracy reports (annually, at a minimum) – N/A. There have been no accuracy 

b. AK reassessment memoranda and combination of waste streams – N/A. Not applicac. AK-VE memoranda – N/A. Not applicable to LA-MSG04.001. d. AK-NDA memoranda – EPA received notification of the revised NDA memorandu

T2 report. NDA memorandum was revised 5/12/2012, but not signed until August 2the 4th quarter was correct. 

e. AKSRs – The LANL-CCP requirement to submit T2 notification for all AKSR revi

12/12/2012 (EPA approval No. A-98-49; II-A4-168). T2 notification provided for R

2012) and Revision 6 (2nd quarter FY 2013). 

f. WSPFs, new and updated – The WSPF initial issuance was in June 2013 and T2 no

appropriately with the 3rd quarter report. 
D-7 

ATTACHMENT D.3: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: WASTE STRE

EPA Inspection No.: LANL-CC-2013 Waste Stream: LA-CIN01.001 Inspection D

Technical Elements Objective Evidence and Comments 

AK-1: Do AK, training and nonconformance 

procedures adequately reflect the requirements of 40 CFR 194? 

Yes. See Attachment D.1, AK checklist item AK-1. 

AK-2: Is the AK characterization process, 

including AK assembly, compilation and verification, adequate? 

Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, 

a. Attachment 1, Revision 24, Acceptable Knowledge Documentation Checklist: Comb. Attachment 2, Revision 23, Record of Communication: Completed when appropriatc. Attachment 3s, various revisions, Acceptable Knowledge Source Document Summa

source documents. 

d. Attachment 4, Revision 24, Acceptable Knowledge Information List: Complete. e. Attachment 5, Hazardous Constituents: Outside EPA’s purview; not reviewed. 

f. Attachment 6, Revision 26, Waste Form, Waste Material Parameters, Prohibited Ite

Initially provided as Revision 23 when should have been Revision 24; was revised dassociated WMP analysis memorandum support estimates in AKSR and discussed i

g. Attachment 7, Revision 26, Radionuclides: Complete. Supports estimates given in A

checklist item AK-4c. See also discussion in checklist item AK-8. 

h. Attachment 8, Revision N/A, Waste Containers List: Complete. LANL-CCP created 

Attachment 8; this format includes all required components. Revised periodically to containers. Add-container memoranda (i.e., Reference C234) support evaluations of the AK tracking spreadsheet and Attachment 8. 

i. Attachment 9 is no longer required and attachment number is reserved for future us

j. Attachment 10, Revision 24, Acceptable Knowledge Re-evaluation Checklist: Com

were written in 2012, all to remove containers that were >50% heterogeneous debri

k. Attachment 11, various revisions, Acceptable Knowledge Source Document Discrep

as appropriate; see AK checklist item AK-6. 

l. Attachment 12, Example Form and Content Guide for AK Summary Reports: Refer

completion; see review of completed AKSR in AK checklist item AK-4. 

m. Attachment 13, various revisions, CCP Waste Stream Characterization Checklist: C

n. Attachment 14, various revisions, CCP Acceptable Knowledge Accuracy Report: C

AK checklist item AK-7. 

o. Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: Not ap

AK-3: Are waste containers traceable from 

retrieval through CCP’s EPA-approved characterization process? 

Yes. Tracked Container Nos. 53769, 54268 and S833076. 53769: generated 9/2/1987 and contained homogenous solids from PF-4 (Los Alamos C

Record). It was overpacked into an 85-gal. drum, retaining the same drum number, on 8CIN01.001 in initial waste stream Attachment 8. Physical characterization: LA-HERTR

Radiological characterization: 2LANDA1021, assay on 7/23/2012. Drum No. 53769 is Lot 19. Per AK tracking spreadsheet, container was emplaced at WIPP facility on 9/16/
D-8 

EPA Inspection No.: LANL-CC-2013 Waste Stream: LA-CIN01.001 Inspection D

8/22/2012 and revised 12/10/2012 and M219) 54268: generated 4/14/1992 and contained homogenous solids from PF-4. Added to LA

stream Attachment 8. Physical characterization: LA-HERTR-13-0058, 5/17/2013. Radi

2LANDA1208, assay on 8/8/2013. Drum No. 54268 was not yet included in a lot at timtracking spreadsheet, container has not been emplaced at WIPP facility. (Reference M2S833076: generated 5/17/1983 and contained leached solids from PF-4. Added to LA-C

stream Attachment 8. Physical characterization: LA-HERTR-12-0082, 8/15/2012. Radi1LANDA1621, assay on 8/16/2012. Drum No. S833076 is included in LA-CIN01.001, spreadsheet, container was emplaced at WIPP facility on 3/14/2013. (References CIS si

1/29/2013 and M238) 

AK-4: Does the AK summary report include 

sufficient information, supported by appropriate source documents, to support the statements below? a. All waste within the waste stream was 

generated from a single process/activity. 

b. All waste within the waste stream is similar in 

material and physical form. 

c. All waste within the waste stream has similar 

radiological properties. 

d. All of the waste in the waste stream is defense 

in origin. 

e. None of the waste in the waste stream is highlevel waste. f. None of the waste in the waste stream is spent 

nuclear fuel. 

Yes. CCP-AK-LANL-006, Revision 12, contains all required items. See Attachment D.

AK-5: Are the waste stream profile form and 

related attachments complete and adequate/accurate? Related attachments include: a. Characterization information summary b. Summation of aspects 

Yes. WSPF, Revision 0: dated 6/9/2010. WSPF is complete; package includes complete complete summation of aspects based on the current-at-the-time AKSR (CCP-AK-LAN

AK-6: Are nonconformances and discrepancy 

resolutions documented appropriately? 

Yes. NCR-LANL-0618-12, Rev. 1: RTR identified leaded rubber gloves, which were nexpected. AK determined gloves accounted for. NCR closed, container use-as-is. 

NCR-LANL-1492-12: RTR identified waste packaging not in AK; standing order modi

packaging configurations after repackaging. NCR closed, container use-as-is. DR043–DR046 written in 2012 for removal of containers >50% heterogeneous debris. scanning questionable containers to verify WMC. A DR will always be written to move 

streams, but doing the initial WMC confirmation by fast scan avoids needing an NCR. 
D-9 

EPA Inspection No.: LANL-CC-2013 Waste Stream: LA-CIN01.001 Inspection D

AK-7: Is the AK accuracy report technically 

adequate? Has it been updated annually? 

Yes. The 2011 report was written on Attachment 14, Revision 19. It should have been wreport was written on Attachment 24. It should have been written using Revision 25. SeD.1, AK checklist item AK-7. 

AK-8: Is AK-NDA communication adequately 

documented? 

Yes. AK-NDA communication documented in CCP-TP-005, Revision 26, Attachment 7attached NDA memorandum dated 12/12/2012. Attachment 7 was modified to include tmemorandum, which updated the descriptions of AK usage and NDA capabilities and uradionuclides. 

AK-9: Has notification of applicable T2 changes 

been provided to EPA as required in the LANLCCP CH tiering table? 

Yes. EPA tracking began with 4th quarter FY 2009. Tier 2 change notification required 

a. AK accuracy reports (annually, at a minimum) – Received correct notification for 2

b. AK reassessment memoranda and combination of waste streams – N/A. Not applicac. AK-VE memoranda – N/A. Not applicable to LA-CIN01.001. d. AK-NDA memoranda – Was revised December 2012, EPA did not receive notificat

report. 

e. AKSRs – EPA received T2 notifications for Revisions 10 (3rd quarter FY 2010), 11 

(1st quarter FY 2013). All other revisions were before EPA started tracking T2 notif

f. WSPFs, new, revised and CNs – EPA received T2 notification for Revision 1 (3rd qu
D-10 

ATTACHMENT D.4: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: WASTE STREA

EPA Inspection No.: LANL-CC-2013 Waste Stream: LA-OS-00-01.01 Inspection D

Technical Elements Objective Evidence and Comments 

AK-1: Do AK, training and nonconformance 

procedures adequately reflect the requirements of 40 CFR 194? 

Yes. See Attachment D.1, AK checklist item AK-1. 

AK-2: Is the AK characterization process, 

including AK assembly, compilation and verification, adequate? 

Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, 

a. Attachment 1, Revision 26, Acceptable Knowledge Documentation Checklist: Com

b. Attachment 2, Revision 23, Record of Communication: Completed when appropriat

c. Attachment 3, various revisions, Acceptable Knowledge Source Document Summar

source documents. 

d. Attachment 4, Revision 26, Acceptable Knowledge Information List: Complete; rev

e. Attachment 5, Hazardous Constituents: Outside EPA’s purview; not reviewed. 

f. Attachment 6, Revision 24, Waste Form, Waste Material Parameters, Prohibited Ite

It and associated WMP analysis memorandum support estimates in AKSR and discuAK-4b. 

g. Attachment 7, Revision 26, Radionuclides: Complete. Includes a radiological chara

because NDA is not used. Revised during inspection to include radionuclide activity 

estimates given in AKSR and discussed in AK checklist item AK-4c. See also discu

h. Attachment 8, Revision 26, Waste Containers List: Complete. Revised periodically 

containers. Add-container memoranda (i.e., Reference C076) support evaluations of the AK tracking spreadsheet and Attachment 8. 

i. Attachment 9 is no longer required and attachment number is reserved for future us

j. Attachment 10, Acceptable Knowledge Re-evaluation Checklist: N/A. There are no 

with LA-OS-00-01.001. 

k. Attachment 11, various revisions, Acceptable Knowledge Source Document Discrep

as appropriate (see AK checklist item AK-6). 

l. Attachment 12, Example Form and Content Guide for AK Summary Reports: Refer

completion; see review of completed AKSR in AK checklist item AK-4. 

m. Attachment 13, various revisions, CCP Waste Stream Characterization Checklist: C

n. Attachment 14, various revisions, CCP Acceptable Knowledge Accuracy Report: C

item AK-7. 

o. Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: Not ap

AK-3: Are waste containers traceable from 

retrieval through CCP’s EPA-approved characterization process? 

Yes. Tracked Container Nos. 64589 and 66729. 64589: Container was generated and closed on 8/10/2010, and initially added to waste s

LANL-0587-13, Rev. 1, written 8/14/2013 because containers were added and characte

determination in place. Containers were removed from waste stream 6/11/2013; defense 8/2/2013; containers re-added to AK tracking spreadsheet 8/6/2013. Physical characteriduring packaging 8/10/2010. Radiological characterization: LA13-OSR-CH-007, 3/28/2
D-11 

EPA Inspection No.: LANL-CC-2013 Waste Stream: LA-OS-00-01.01 Inspection D

included in LA-OS-00-01.001, Lot 82. Per AK tracking spreadsheet, container was emp

10/2/2013. (References C074; C076; CIS signed 8/23/2013 and NCR-LANL-0587-13, R66729: Container was generated and closed on 11/27/2012, and added to waste stream o

characterization: LA12-OSR-VE-054 during packaging 11/29/2012. Radiological chara054, 1/2/2013. Container No. 66729 is included in LA-OS-00-01.001, Lot 72. Per AK twas emplaced at WIPP facility on 4/28/2013. (References C073 and CIS signed 3/5/201

AK-4: Does the AK summary report include 

sufficient information, supported by appropriate source documents, to support the statements below? a. All waste within the waste stream was 

generated from a single process/activity. 

b. All waste within the waste stream is similar in 

material and physical form. 

c. All waste within the waste stream has similar 

radiological properties. 

d. All of the waste in the waste stream is defense 

in origin. 

e. None of the waste in the waste stream is highlevel waste. f. None of the waste in the waste stream is spent 

nuclear fuel. 

Yes. CCP-AK-LANL-008, Revision 9, contains all required items. 

a. LA-OS-00-01.001 was produced by the recovery of sealed sources by OSRP. In the 

manufacturers produced various types of TRU sealed sources to enhance nuclear, mThe sealed sources are considered “nuclear material” until being declared “waste” a(References C002, C004, C005, C006, C066, D003, D004, M001, M031, M133, P0

b. LA-OS-00-01.001 is a debris waste stream consisting entirely of recovered sealed s

solid, inorganic, actinide metals or metal oxides in protective metal coverings (RefeM133). 

c. All of the sealed sources were manufactured and have detailed records of their comp

and radiological characterization is conducted by review of AK. LANL-CCP issued clarify that two primary radionuclides (by activity) in the waste stream are 238Pu and 

M001 and M133). 

d. OSRP recovers defense and non-defense sealed sources. Only the defense sources a

sources are defense in origin because they were derived from defense nuclear matermanagement and they are being recovered to support defense nuclear material secur

of NCR-LANL-0587-13, Rev. 1, AK tracking spreadsheet now identifies which defeach OSRP container (References C004, C011, D011, D023, D025 and D030). 

e. LA-OS-00-01.001 contains only sealed sources, which by definition are not HLW (

M307 and M308). 

f. LA-OS-00-01.001 contains only sealed sources, which by definition are not spent n

M306, M307 and M308). 

AK-5: Are the waste stream profile form and 

related attachments complete and adequate/accurate? Related attachments include: a. Characterization information summary b. Summation of aspects 

Yes. WSPF, Revision 0: dated 6/29/2005. WSPF is complete; package includes complecomplete summation of aspects based on the current-at-the-time AKSR (CCP-AK-LANCN #1, dated 12/5/2006: revised current volume generated, modified WMP estimates, eCN #2, dated 6/15/2010: revised current volume generated and added projected volumecategories listed, modified WMP and radionuclide information to match current waste s

AK-6: Are nonconformances and discrepancy 

resolutions documented appropriately? 

Yes. NCR-LANL-0587-13, Revision 1 is new since the last inspection. It was appropriaAK checklist items AK-3 and AK-4d. NCR-LANL-0734-13 was written during this ins

AK-7. Attachment 3s for DR001–DR010 were revised in 2012 to match the “AK documentati

DRs. DR011 and DR012 are new since the last inspection: DR011 for conflicting informDR012 for trying to add a container that had already been emplaced to the tracking spre
D-12 

EPA Inspection No.: LANL-CC-2013 Waste Stream: LA-OS-00-01.01 Inspection D

AK-7: Is the AK accuracy report technically 

adequate? Has it been updated annually? 

Yes. The 2011 report was written on Attachment 14, Revision 19. It should have been wreport was written on Attachment 24. It should have been written using Revision 25. SeD.1, AK checklist item AK-7. 

AK-8: Is AK-NDA communication adequately 

documented? 

N/A. Radiological characterization is done using AK. NDA is not used for LA-OS-00-0communication is not applicable. 

AK-9: Has notification of applicable T2 changes 

been provided to EPA as required in the LANLCCP CH tiering table? 

Yes. EPA tracking began with 4th quarter FY 2009. Tier 2 change notification required 

a. AK accuracy reports (annually, at a minimum) – Received correct notification for 2

not receive notification for the 2013 report. LANL-CCP submitted notification for a overlooked LA-OS-00-01.001. EPA will revisit during next inspection. 

b. AK reassessment memoranda and combination of waste streams – N/A. Not applicac. AK-VE memoranda – N/A. Not applicable to LA-OS-00-01.001. d. AK-NDA memoranda – N/A. Has not been revised since early 2009. e. AKSRs – EPA received T2 notifications for Revisions 8 (2nd quarter FY 2010) and 

other reviews were before EPA started tracking T2 notifications. 

f. WSPFs, new, revised and CNs – EPA received T2 notification for CN #2 (3rd quarte
E-1 

ATTACHMENT E.1: NDA CONTINUED COMPLIANCE INSPECTION CHECKLIST: H

Technical Elements Objective Evidence 

GeneralHENC1-1: Confirm the NDA system is the 

HENC1, its location and number and note any significant changes since the last EPA inspection.

LANL HENC1 is located in Trailer 53-506 on Pad 10 in Area G of TA-54 at LANL. 

EPA to be of Tprev

HENC1-2: Describe the HENC1. The system incorporates two measurement modalities: a passive neutron counter 

and an integral gamma-ray spectrometer. The passive neutron counter uses multiple 3He proportional counters, along with a multiplicity shift register and an 

external 252Cf source for the AaS matrix correction function, to determine the 

spontaneously fissioning mass content of waste containers, referred to as the 

240PuEff. The 240PuEff is defined as the amount of 240Pu that would produce the 

observed true coincidence rate, after correcting for the neutron moderation properties of the waste matrix. The quantities of individual radionuclides are related to the 240PuEff by applying the ratios of other TRU or target radionuclides, 

including spontaneously fissioning radionuclides (i.e., 235U). These ratios are 

determined by MGA of the gamma-ray spectrum 

N/A 

HENC1-3: Identify the consensus standards that 

were used for the system calibration. 

The consensus standards used in the calibration are ASTM C-1030, C-1133, C1215 and E-181. As s

1002durinpers

HENC1-4: Describe the system’s operational 

history since the last EPA inspection. 

From 11/13/2012 to 11/13/2013, the HENC1 assayed 1,475 55-gallon drums; results are contained in 199 BDRs. 

As s1002durinpers

HENC1-5: Identify the container types assayed 

on the HENC1 and the number of BDRs assembled during the last year. 

The HENC1 can only assay 55-gallon drums. Visu

contcoulinstr

HENC1-6: Confirm that the HENC1 is able to 

report quantitative values for the WIPP-tracked radionuclides. 

Direct Measurements: 239Pu, 241Am, 233U, 235U, 238U, 137Cs. 

Isotopic Fractions: 238Pu, 240Pu, 241Pu, 242Pu by correlation, 241Am relative to Pu. 

Radionuclides by Scaling: 90Sr, 234U. 

As s1002confdurin

HENC1-7: Confirm the HENC1’s calibration of 

record. 

The calibration of record is documented in MCS-HENC#1-NDA-1002, Revision 6, and is the same as what was reviewed during the most recent HENC1 T1 approval. 

Condurin
E-2 

Technical Elements Objective Evidence 

HENC1-8: Identify the procedures that govern 

this function, their current revisions and where the results of these calculations are documented. 

CCP-TP-063, operating procedure (Revision 15). CCP-TP-064, calibration procedure (Revision 7). CCP-TP-103, data validation procedure (Revision 11). 

Thescurrewere the H

HENC1-9: Confirm that the methods used to 

derive the isotopic contribution for unmeasured radionuclides are MGA and MGA-U and note any significant changes since the last EPA inspection. 

MGA and MGA-U are integral parts of the HENC1’s operation, as shown in CCP-TP-063, Revision 15 

ConLANdurininstaacco

HENC1-10: Where is the actual efficiency 

calibration for the HENC1 documented? 

It is documented in MCS-HENC#1-NDA-1002, Revision 6, and its attachments. N/A 

HENC1-11: Confirm the HENC1 operational 

range with respect to matrix (density) and activity and note any significant changes since the last EPA inspection. 

Passive neutron: LLD to 16.278 g 240PuEff for multiplying wastes 

Passive neutron: LLD to 35.0 g 240PuEff for nonmultiplying wastes 

Gamma: LLD to 217 g of total Pu limited by dead time; acceptable density range for gamma is 0.018–2.1 g/cc. 

This persoperprev

Calibration Verification and Confirmation HENC1-12: Identify the date of the last 

calibration verification. Have any others been completed in the last year? 

10/4/2013: Containers were moved in Area G. Pad 10, which lowered the background and triggered a warning flag because background was lower than previously anticipated. This was appropriately documented. There have been eight calibration verifications performed on the HENC1 since the last EPA inspection in August 2012. 

This persprov

HENC1-13: Confirm the pedigree of all 

radionuclide standards that were used for calibration confirmation and/or verifications. List or reference all standards used or cite a reference where the standards are listed. 

The standards are summarized in Table 1 of MCS-HENC#1-NDA-1002, Revision 6; the source certifications are listed in Attachment 1. 

EPA certiHENAttaindeaccecalib

HENC1-14: Requirements for accuracy and 

precision must be met, as specified in the Waste Acceptance Criteria (DOE/WIPP-02-3122), Appendix A, Table A-3.2 for calibration verifications. 

The calibration confirmation results are contained in MCS-HENC#1-NDA-1002, Revision 6. % R was between 70 and 130% and % RSD was less than 14% for 6 replicates. 

Accuwere verif

LLD HENC1-15: Confirm that the LLD for the 

HENC1 has been determined and note any significant changes since the last EPA inspection.

Section 11 of MCS-HENC#1-NDA-1002, Revision 6, documents the LLD determination of measured radioisotopes for a sample drum. LLDs for all measured radionuclides in debris and homogeneous solids were below the 100 nCi/g TRU threshold. 

InterHENinsp
E-3 

Technical Elements Objective Evidence 

HENC1-16: Confirm if the HENC1 is used to 

discriminate TRU/non-TRU wastes at the 100 nCi/g criterion and that it has the required sensitivity, and note any significant changes since the last EPA inspection. 

The HENC1 can discriminate between TRU and non-TRU waste based on the LLDs reported in Section 11 of MCS-HENC#1-NDA-1002, Revision 6, for all measured radionuclides except 239Pu in debris. 

Totarepowith 

HENC1-17: Identify any/all instances where an 

LLD value for a nonmeasured radionuclide is not 

provided based on a lack of technical feasibility. 

Because an LLD is a measurement-based parameter, it is not technically feasible to calculate for radionuclides that are not directly measured. Plutonium isotopes 

238Pu, 240Pu and 242Pu are not usually directly measured by gamma spectrometry 

and are instead derived by ratios to measured 239Pu. The reporting threshold for 

90Sr is computed based on the reported 137Cs LLD using an activity ratio 

determined from AK. LANL-CCP states that it is not technically feasible to provide an LLD equivalent for 234U and it is derived by algorithm from measured 

values of 235U and 238U. 

This MCSRevi

Quality Control HENC1-18: All operators have current CCP 

training as verified on LOQI. 

LOQI provided for 11/14/2013, contains 12 operators, all with current training. EPA 

listelistenamdid nwas long

HENC1-19: Confirm the HENC1’s status with 

respect to the CBFO NDA PDP and last cycle. 

The HENC1 participated in CBFO PDP cycle 20A. EPA 

parti

HENC1-20: All HENC1 data must be reviewed 

and approved by qualified personnel. Identify the name and function of the individuals performing technical review and approval of HENC1 BDRs. 

The BDRs obtained by EPA were reviewed by Dominic Archuleta and Israel Aragon. Both are listed on the LOQI as ITRs. 

All itechconf11/1

HENC1-21: Identify any hardware and/or 

software changes made to the HENC1 since the last EPA inspection. Determine if changes are significant, where they are documented and how they affect the HENC1’s baseline approval. 

The gamma system’s pulser was replaced on 2/21/2013 and was documented appropriately in a calibration verification. 

ConLANinsp

HENC1-22: Identify any NCRs within the last 

year. 

There have been no system NCRs on the HENC1 since the last inspection. Con

LANinsp

TMU HENC1-23: Identify any changes to the method 

or details of the TMU calculation since baseline. 

No changes to the TMU were made since EPA’s last inspection. Con

LANinsp
E-4 

Technical Elements Objective Evidence 

HENC1-24: Evaluate the magnitude of the TMU 

values observed in the HENC1 BDRs that were examined during this inspection. 

The BDR TMU values were as expected in both BDRs reviewed. Con

LANinsp

Background and Performance Checks HENC1-25: Confirm that HENC1 background 

measurements have been taken daily. 

All records evaluated indicate compliant background performance. Duri

persoccuselecreviemeaand 

HENC1-26: Assess how often background 

radiation was problematic to the extent that measurement personnel had to make adjustments.

Background for the HENC1 was problematic after drums were removed from area, causing a lower background than anticipated. 

Duripersbackhave 

HENC1-27: Confirm that system performance 

checks have been performed at least once per operational day. Confirm that performance checks include gamma and neutron efficiency, matrix correction checks, and gamma peak position and resolution checks. 

Performance checks are done once per day as stated in CCP-TP-063, Revision 15. 

Duripersoccuselec5/10evid

Data Management HENC1-28: HENC1 BDRs contain: 

 Testing facility name, testing batch number, 

container numbers and signature of the SPM or designee. 

 Table of contents. 

 Background and performance check data or 

control charts for the relevant time period. 

 Data validation per the QAPD and site 

procedures. 

 Separate testing report sheets for each 

container. 

EPA reviewed HENC1 BDR Nos. 1LANLDA1850 and 1LANDA1857 and found them to contain appropriate information. EPA did identify an issue in 1LANLDA1850. On the ITR checklist, the ITR incorrectly checked the box indicating that the QC measurements were outside of 

the established controls. The issue was investigated and appeared to be an isolated instance. An NCR was issued to correct this checkbox. 

N/A 
E-5 

Technical Elements Objective Evidence 

HENC1-29: HENC1 RDSs must include: 

 Title “Radioassay Data Sheet.” 

 Method/procedure used. 

 Date of radioassay. 

 Activities and associated TMU for individual 

radionuclides. 

 TRU alpha concentration and its associated 

TMU. 

 Operator and reviewer signatures. 

EPA reviewed HENC1 BDR Nos. 1LANLDA1850 and 1LANDA1857 and found that each drum contained in the two BDRs had an RDS containing the correct elements. 

Non
E-6 

ATTACHMENT E.2: NDA CONTINUED COMPLIANCE INSPECTION CHECKLIST: H

Technical Elements Objective Evidence 

GeneralHENC2-1: Confirm the NDA system is the 

HENC2, its location and number and note any significant changes since the last EPA inspection.

LANL HENC No. 2 is located in Trailer 54-498 on Pad 10 in Area G of TA-54 EPA 

to be of Tprev

HENC2-2: Describe the HENC2. The system incorporates two measurement modalities—a passive neutron counter 

and an integral gamma-ray spectrometer. The passive neutron counter uses multiple 3He proportional counters, along with a multiplicity shift register and an 

external 252Cf source for the AaS matrix correction function, to determine the 

spontaneously fissioning mass content of waste containers, referred to as the 

240PuEff. The 240PuEff is defined as the amount of 240Pu that would produce the 

observed true coincidence rate, after correcting for the neutron moderation properties of the waste matrix. The quantities of individual radionuclides are related to the 240PuEff by applying the ratios of other TRU or target radionuclides, 

including all spontaneously fissioning radionuclides (i.e., 235U). These ratios are 

routinely determined by MGA of the gamma-ray spectrum obtained with the integral gamma-ray spectrometer. 

N/A 

HENC2-3: Identify the consensus standards that 

were used for the system calibration. 

The consensus standards that are used in the calibration are ASTM C-1030, C1133, C-1207 and C-1500. As s

Reviinter

HENC2-4: Describe the system’s operational 

history since the last EPA inspection. 

From 11/13/2012 to 11/13/2013, the HENC2 assayed 1,154 containers, which were compiled in 164 BDRs. 

As sReviinterLAN25% lined

HENC2-5: Identify the container types assayed 

on the HENC2 and the number of BDRs assembled during the last year. 

The HENC2 can only assay 55-gallon drums with or without poly liners and can also assay 55-gallons drums with lead liners. 

Coninstr

HENC2-6: Confirm that the HENC2 is able to 

report quantitative values for the WIPP-tracked radionuclides. 

Direct Measurements: 239Pu, 238Pu, 237Np, 241Am, 233U, 235U, 238U, 137Cs. 

Isotopic Fractions: 240Pu, 241Pu, 242Pu by correlation, 241Am relative to Pu. 

Radionuclides by Scaling: 90Sr, 234U. 

As sRevipers

HENC2-7: Confirm the HENC2’s calibration of 

record. 

The calibration of record is documented in HENC#2-NDA-1002, Revision 3. This is the same calibration document that was reviewed during the most recent HENC2 T1 approval. 

Condurin
E-7 

Technical Elements Objective Evidence 

HENC2-8: Identify the procedures that govern 

this function, their current revisions and where the results of these calculations are documented. 

CCP-TP-063, Revision 15; CCP-TP-064, Revision 7; and CCP-TP-103, Revision 12. 

Thescopieasiloper

HENC2-9: Confirm that the methods used to 

derive the isotopic contribution for unmeasured radionuclides are MGA and MGA-U and note any significant changes since the last EPA inspection. 

MGA and MGA-U are integral parts of the HENC2 operation, as shown in CCPTP-63, Revision 15. MGA-U is only used when there is sufficient uranium to 

provide usable statistics. 

ConLANdurin

HENC2-10: Where is the actual efficiency 

calibration for the HENC2 documented? 

It is documented in HENC#2-NDA-1002, Revision 3, and its attachments. N/A 

HENC2-11: Confirm the HENC2 operational 

range with respect to matrix (density) and activity and note any significant changes since the last EPA inspection. 

Passive neutron: LLD to 16.278 g 240PuEff for multiplying wastes 

Passive neutron: LLD to 35.0 g 240PuEff for nonmultiplying wastes Gamma: LLD to 217 g of total Pu limited by dead time; density range for gamma is 0.018–2.1 g/cc. 

This persoperprev

Calibration Verification and Confirmation HENC2-12: Identify the date of the last 

calibration verification. Have any others been completed in the last year? 

On 7/25/2013, a flag on the neutron QA/QC measurement indicated a below-3-

lower limit. These were no obvious issues with electronics after diagnostics. It was previously identified that the 252Cf source is in the latter stages of life and 

will need to be replaced in the near future. Six calibration verifications have been performed since the last LANL inspection in August 2012. 

LAN

252C

for tawarrepla

HENC2-13: Confirm the pedigree of all 

radionuclide standards that were used for calibration confirmation and/or verifications. List or reference all standards used or cite a reference where the standards are listed. 

The standards are summarized in Table 1 of HENC#2-NDA-1002, Revision 3. Source certifications are listed in Attachment 1 of the same document. 

EPA certiindeaccecalib

HENC2-14: Requirements for accuracy and 

precision must be met, as specified in DOE/WIPP-02-3122, Appendix A, Table A-3.2 for calibration verifications. 

The calibration verification results are contained in CCP-LANL-HENC2-003, Revision 3. The % R was between 70 and 130% and % RSD was less than 14% for six replicates. 

Accuwere verif

LLD HENC2-15: Confirm that the LLD for the 

HENC2 has been determined and note any significant changes since the last EPA inspection.

Section 11 of HENC#2-NDA-1002, Revision 3 documents the LLD determination of measured radioisotopes for a sample drum. LLDs for all measured radionuclides in debris and homogeneous solids were below the 100 nCi/g TRU threshold. 

InterHENinsp
E-8 

Technical Elements Objective Evidence 

HENC2-16: Confirm if the HENC2 is used to 

discriminate TRU/non-TRU wastes at the 100 nCi/g criterion and that it has the required sensitivity and note any significant changes since the last EPA inspection. 

The HENC2 can discriminate between TRU and non-TRU waste based on the LLDs reported in Section 11 of HENC#2-NDA-1002, Revision 3 for all measured radionuclides except 239Pu in debris. 

Totarepowith 

HENC2-17: Identify any/all instances where an 

LLD value for a nonmeasured radionuclide is not 

provided based on a lack of technical feasibility. 

Because an LLD is a measurement-based parameter, it is not technically feasible to calculate for radionuclides that are not directly measured. Plutonium isotopes 

238Pu, 240Pu and 242Pu are not usually directly measured by gamma spectrometry 

and are instead derived by ratios to measured 239Pu. The reporting threshold for 

90Sr is computed based on the reported 137Cs LLD using a ratio determined from 

AK. LANL-CCP states that it is not technically feasible to provide an LLD equivalent for 234U, and it is derived by algorithm from measured values of 235U 

and 238U. 

This HEN

Quality Control HENC2-18: All operators have current CCP 

training as verified on LOQI. 

LOQI dated 11/14/2013 contains 12 operators, all with current training. EPA 

the Llogb

HENC2-19: Confirm the HENC2’s status with 

respect to the CBFO NDA PDP and last cycle. 

The HENC2 successfully participated in the CBFO PDP cycle 20A. EPA 

parti

HENC2-20: All HENC2 data must be reviewed 

and approved by qualified personnel. Identify the name and function of the individuals performing technical review and approval of HENC2 BDRs. 

The ITRs that reviewed the BDRs selected by EPA include Maria Escarcenga and Dominic Archuleta; both have valid training as listed on the LOQI dated 11/14/2013. 

All itechEPA 2LA

HENC2-21: Identify any hardware and/or 

software changes made to the HENC2 since the last EPA inspection. Determine if changes are significant, where they are documented and how they affect the HENC2’s baseline approval. 

The drum rotator was replaced in November 2012 and a calibration verification was performed post-replacement to document that the machine was operating as expected. 

ConLANinsp

HENC2-22: Identify any NCRs within the last 

year. 

There have been no system NCRs on the HENC2 since the last inspection. Con

LANinsp

TMU HENC2-23: Identify any changes to the method 

or details of the TMU calculation since baseline. 

No changes to the TMU were made since EPA’s last inspection. Con

LANinsp

HENC2-24: Evaluate the magnitude of the TMU 

values observed in the HENC2 BDRs that were examined during this inspection. 

ConLANinsp
E-9 

Technical Elements Objective Evidence 

Background and Performance Checks HENC2-25: Confirm that HENC2 background 

measurements have been taken daily. 

All records evaluated indicate compliant background performance. Duri

persoccuselecreviemea

HENC2-26: Assess how often background 

radiation was problematic to the extent that measurement personnel had to make adjustments.

Due to the location of HENC2 relative to the other NDA equipment on Pad 10 of Area G, the HENC2 has had fewer issues than the other equipment. 

Duripersbackhave 

HENC2-27: Confirm that system performance 

checks have been performed at least once per operational day. Confirm that performance checks include gamma and neutron efficiency, matrix correction checks and gamma peak position and resolution checks. 

Performance checks are done once per day as stated in CCP-TP-063, Revision 15. 

Duripersoccuselec8/22evid

Data Management HENC2-28: HENC2 BDRs contain: 

 Testing facility name, testing batch number, 

container numbers and signature of the SPM or designee. 

 Table of contents. 

 Background and performance check data or 

control charts for the relevant time period. 

 Data validation per the QAPD and site 

procedures. 

 Separate testing report sheets for each 

container. 

EPA reviewed HENC2 BDR Nos. 2LANDA1234 and 2LANDA1229 and found them to contain appropriate information. 

N/A 

HENC2-29: HENC2 RDSs must include: 

 Title “Radioassay Data Sheet.” 

 Method/procedure used. 

 Date of radioassay. 

 Activities and associated TMU for individual 

radionuclides. 

 TRU alpha concentration and its associated 

TMU. 

 Operator and reviewer signatures. 

EPA reviewed HENC2 BDR Nos. 2LANDA1234 and 2LANDA1229 and found that each drum contained in the two BDRs had an RDS containing the correct elements. 

N/A 
E-10 

ATTACHMENT E.3: NDA CONTINUED COMPLIANCE INSPECTION CHECKLIST: Sup

Technical Elements Objective Evidence 

General SHENC-1: Confirm the NDA system is the 

SHENC, its location and number and note any significant changes since the last EPA inspection. 

The SHENC is located in TA-54 on Pad 10 in Area G, Building No. 547. The SHENC is a self-contained NDA unit that is physically housed in a mobile manufactured enclosure made up of a “High-Cube” freight container measuring approximately 48 feet long by 81⁄2 feet wide by 131⁄2 feet high. 

EPA to be in Asinc

SHENC-2: Describe the SHENC and note any 

significant changes since the last EPA inspection. 

The SHENC consists of a passive neutron counter and an integral gamma-ray spectrometer. The combination of neutron and isotopic distribution information allows quantification of 238Pu, 239Pu, 240Pu, 241Am, 233U, 235U, 238U, 137Cs, 237Np. 

N/A 

SHENC-3: Identify the consensus standards that 

were used for the system calibration and note any significant changes since the last EPA inspection. 

ASTM standards C-1030, C-1133, C-1207 and C-1500 are used in the calibration, as documented in LANL-SHENC3-NDA-1004, Revision 4. 

As sNDAconfNDA 

SHENC-4: Describe the system’s operational 

history since the 2011 T1 approval. 

The SHENC was previously deployed at the Hanford Site’s Plutonium Finishing Plant, though it was not certified for WIPP assays at that site. It was moved to LANL where it was refurbished to operate under the Canberra NDA2000 Software. Its operational range was extended through a T1 change in August 2012. 

As sNDAconfNDA 

SHENC-5: Identify the container types assayed 

on the SHENC and the number of BDRs completed in the last calendar year. 

The system is designed to measure SWBs containing four 55-gallon drums of retrievably stored SCG S5000 debris and SWBs containing direct-loaded S5000 debris. From 11/13/2012 to 11/13/2013, the SHENC assayed 306 containers that were compiled in 102 BDRs. The SHENC can assay a maximum of six containers per day. 

LANperfassamor

SHENC-6: Confirm that the SHENC is able to 

report quantitative values for the WIPP-tracked radionuclides and note any significant changes since the last EPA inspection. 

Direct Measurements: 239Pu, 238Pu, 241Am, 233U, 235U, 238U, 137Cs. 

Isotopic Fractions: 240Pu, 241Pu, 242Pu by correlation, 241Am relative to Pu. 

Radionuclides by Scaling: 90Sr, 242Pu, 234U. 

As sNDAconfduri

SHENC-7: Confirm the SHENC’s calibration of 

record. 

Both operational modes of the SHENC were calibrated before its initial use; the dates and technical details of the calibrations are documented in the calibration report. 

Conduri

SHENC-8: Identify the procedures that govern 

this function, the current revision of each and where the results of these calculations are documented. 

CCP-TP-059, operating procedure, Revision 2. CCP-TP-064, calibration procedure, Revision 7. CCP-TP-103, data validation procedure, Revision12. 

Thecurreach acce

SHENC-9: Confirm that the methods used to 

derive the isotopic contribution for unmeasured radionuclides are MGA and MGA-U and note any significant changes since the last EPA inspection. 

MGA and MGA-U are integral parts of the SHENC operation, as described in CCP-TP-059. 

Conwith pers
E-11 

Technical Elements Objective Evidence 

SHENC-10: Confirm the SHENC operational 

range with respect to matrix (density) and activity and note any significant changes since the last EPA inspection. 

The ranges of applicability of the system‘s calibrations for both passive neutron and absolute gamma operational modes are specified in the calibration report. The ranges are expressed in terms of 240PuEFF and AaS for passive neutron and 

photon energy and matrix mass for the absolute gamma mode. The SHENC’s passive neutron use is restricted to the coincidence mode; the multiplicity mode is not used for WIPP assays. 

EPA persas thEPA

Calibration Verification and ConfirmationSHENC-11: Identify the date of the last 

calibration verification. Have any others been completed in the last year? 

On 7/31/2013, the SuperHENC logbook indicated a flag on the 122 keV FWHM parameter for detector #1, meaning the result exceed the three- control limit. An investigation was performed and indicated that there were no physical 

problems with the detector. Statistics over the previous two months indicated that the FWHM mean had increased slightly and the mean was adjusted slightly to reflect this change. Additionally, the observed values for 152Eu for both 

detectors had decreased slightly due to the age of the sources, and their mean was decreased slightly for both detectors to reflect this decay. Including this calibration verification, a total of nine calibration verifications have been completed since the last EPA inspection in August 2012. 

Conduri

SHENC-12: Confirm the pedigree of all 

radionuclide standards that were used for calibration confirmation and/or verifications. List or reference all standards used or cite a reference where they are listed. 

Sources are summarized in Table 3 of LANL-SHENC3-NDA-1004, Revision 4. Source certifications are listed in Attachment 1. 

EPA certiSHE1. Acertithe S

SHENC-13: Requirements for accuracy and 

precision must be met, as specified in DOE/WIPP02-3122, Appendix A, Table A-3.2 for calibration verifications. 

The initial calibration verification is documented in LANL-SHENC3-NDA1004. The results of all subsequent calibration verifications are documented in the SuperHENC Calibration Verification Reports cited in Attachment B. The % R was between 70 and 130% and % RSD was less than 14% for 6 replicates in all cases. 

Accwere verif

LLD SHENC-14: Confirm that the LLD for the 

SHENC has been determined and note any significant changes since the last EPA inspection. 

The LLD for the SHENC is determined in Section 11 of LANL-SHENC3-NDA1004, Revision 4. To determine the MDAs, sets of 3 replicates were performed for a surrogate matrix SWB with no reference sources inside, and NDA 200 calculated the MDAs from these measurements by applying WG isotopics. 

Conwith pers
E-12 

Technical Elements Objective Evidence 

SHENC-15: Confirm if the SHENC is used to 

discriminate TRU/non-TRU wastes at the 100 nCi/g criterion and that it has the required sensitivity. 

The LLD for the SHENC for a typical debris waste assay is determined in 

Section 11 of LANL-SHENC3-NDA-1004, Revision 4. All LLDs are below the 100 nCi/g threshold. The SHENC meets the required detection threshold. 

The repowith instaof lein thindicman

SHENC-16: Identify any/all instances where an 

LLD value for a nonmeasured radionuclide is not 

provided based on a lack of technical feasibility and note any significant changes since the last EPA inspection. 

Because an LLD is a measurement-based parameter, it is not technically feasible to calculate for radionuclides that are not directly measured. Plutonium isotopes 

238Pu, 240Pu and 242Pu are not usually directly measured by gamma spectrometry 

and are instead derived by ratios to measured 239Pu. The reporting threshold for 

90Sr is computed based on the reported 137Cs LLD using an activity ratio 

determined from AK NDA memos. LANL-CCP states that it is not technically feasible to provide an LLD equivalent for 234U, and that it is derived by 

algorithm from measured values of 235U, 238U and 238Pu. 

This SHESect

Quality Control SHENC-17: All operators have current CCP 

training as verified on LOQI. 

LOQI dated 11/14/2013 contains 10 operators, all with current training. EPA 

listeliste

SHENC-18: Confirm the SHENC’s status with 

respect to the CBFO NDA PDP and last cycle. 

The SHENC successfully participated in cycle B13A of the CBFO NDA PDP. EPA 

partilette

SHENC-19: All SHENC data must be reviewed 

and approved by qualified personnel. Identify the name and function of the individuals performing technical review and approval of SHENC BDRs. 

The BDRs provided to EPA were reviewed by Ryan Hammon and Tim Barton, both of whom were listed on the LOQI. 

All itechEPA 3LA3LA

SHENC-20: Identify any NCRs within the last 

year. 

There have been no system NCRs on the SHENC in the last year. Con

LANinsp

TMU SHENC-21: Identify any changes to the method 

or details of the TMU calculation since the last EPA inspection. 

No changes to the TMU were made since EPA’s last inspection. Con

LANinsp
E-13 

Technical Elements Objective Evidence 

SHENC-22: Evaluate the magnitude of the TMU 

values observed in the SHENC BDRs that were examined during this inspection. 

The TMU values contained in the BDRs were as expected. Con

LANinspNos3LA

Background and Performance Checks SHENC-23: Confirm that SHENC background 

measurements have been taken daily. 

Confirmed that SHENC background measurements have been taken daily. EPA 

interThe EPA and of th

SHENC-24: Assess how often background 

radiation was problematic to the extent that measurement personnel had to make adjustments. 

No instances of problematic backgrounds were observed in the last year. EPA 

inter

SHENC-25: Confirm that system performance 

checks have been performed at least once per operational day. Confirm that performance checks include gamma and neutron efficiency, matrix correction checks and gamma peak position and resolution checks. 

Performance checks are done once per day as stated in CCP-TP-059. EPA 

interThe EPA and of th

Data Management SHENC-26: SHENC BDRs contain: 

 Testing facility name, testing batch number, 

container numbers and signature of the SPM or designee. 

 Table of contents. 

 Background and performance check data or 

control charts for the relevant time period. 

 Separate testing report sheets for each container.

EPA reviewed SHENC BDR Nos. 3LANDA0215 and 3LANDA0219 and found them to contain appropriate information. 

N/A 

SHENC-27: SHENC RDSs must include: 

 Title “Radioassay Data Sheet.” 

 Method/procedure used. 

 Date of radioassay. 

 Activities and associated TMU for individual 

radionuclides. 

 TRU alpha concentration and its associated 

TMU. 

 Operator and reviewer signatures. 

EPA reviewed SHENC BDR Nos. 3LANDA0215 and 3LANDA0219 and found that each drum they contained had an RDS containing the correct elements. 

N/A 
E-14 

ATTACHMENT E.4: NDA CONTINUED COMPLIANCE INSPECTION CHECKLIST: M

Technical Elements Objective Evidence 

General MILCC-1: Confirm the NDA system is the 

MILCC, its location and number. 

The instrument is located in the east end of Dome 283 in Area G at TA-54 at LANL. It is also referred to as the MCS/LANL “Box Counter” in some documentation. 

This persinspinstr

MILCC-2: Describe the MILCC. The detectors are BEGe detectors, i.e., planar detectors that provide excellent 

response and energy resolution from 45 keV to 3 MeV. The detectors are identified as Nos. 08004606 and 07048046 and were ISOCS characterized in 

2001 and 2006, respectively. The two MILCC detectors are placed equidistant 

from, on opposite sides, of the container to be assayed. Two distances are fixed for each container type, the selection of which is determined by the dead time of the detector, the near and far-field positions. The far-field position is designed to accommodate the measurement of containers with high dead times. A 90° collimator is utilized on the gamma detector for far-field measurements. 

This pers

MILCC-3: Identify the consensus standards that 

were used for the system calibration. 

LANL-CCP used consensus standards ASTM C-1030, C-1133, C-1207 and C1500 for the MILCC calibration. This 

NDAwith eval

MILCC-4: Identify the container and wastes 

types assayed on the MILCC. 

The MILCC is capable of assaying debris, soils and gravel, and homogeneous solid wastes in 55-gallon drums, CMBs and SWBs. 

The densMILwastg/ccexpewas LANanotdrum55-gremiwou

MILCC-5: Identify the period of performance 

relevant to the MILCC and the number of BDRs and waste containers this system assayed during the period. 

The MILCC is a new system with a limited performance history. LANL-CCP provided a BDR containing three containers for each of the three container types, MILCC BDR Nos. 4LANDA0012 (CMB), and 4LANDA0016 (55-gallon drum), which EPA inspectors reviewed. 

Incluassaassacontassa7/29
E-15 

Technical Elements Objective Evidence 

MILCC-6: Confirm that the MILCC is able to 

report quantitative values for the WIPP-tracked radionuclides. 

Direct Measurements: 238Pu, 239Pu, 241Am, 233U, 235U, 238U, 137Cs, 237Np. 

Nuclides by Scaling: 90Sr, 234U, 242Pu. Pu and other TRU isotopic ratios are 

determined using the MGA or FRAM software, or AK. 

This pers

MILCC-7: Confirm the MILCC’s calibration of 

record. 

The calibration is documented in CI-MILCC-NDA-1006, Revision 0. Each detector factory characterization report was provided to EPA reviewers. 

This pers

MILCC-8: Identify the procedures that govern 

this function and where the results of these calculations are documented. 

CCP-TP-076, operating procedure (Revision 0, 5/2013). CCP-TP-077, calibration procedure (Revision 0, 5/2013). CCP-TP-103, data review procedure (Revision 12, 11/2013). 

Thepersoperproccont

MILCC-9: Confirm the methods used to derive 

the isotopic contribution for unmeasured radionuclides. 

241Am and Pu isotopics are determined by MGA or FRAM software when 

enough mass exists. 

This pers

Calibration Verification and ConfirmationMILCC-10: Confirm the pedigree of all 

radionuclide standards that were used for calibration confirmation and/or verifications. List or reference all standards used. 

Sources are summarized in Table 6.1 of CI-MILCC-NDA-1006, Revision 0, with source certificates in Attachment 1. 

EPA certiNDAAttaindeaccecalib

MILCC-11: Confirm the MILCC operational 

range with respect to matrix (density) and activity.

Acceptable density range for gamma is approximately 0.0–2.50 g/cc; activity is 

limited by spectral parameters (peak shape and resolution) and system dead 

time. 

This pers

MILCC-12: Identify the date of the last calibration 

verification. Have any others been completed in the last year? 

All work in LANL Area G was halted for two weeks. During that time, the 

dewars containing liquid nitrogen (LN2) were not filled and the detectors 

warmed. When operations were resumed, both detectors were filled with LN2 

and allowed to cool overnight. The following day calibration was verified and LANL-CCP personnel determined that the detector was functioning properly. There have been six calibration verifications done on the MILCC, including 10/22/2013, and all were appropriately documented. 

LANactiowas 

MILCC-13: Requirements for accuracy and 

precision must be met, as specified in DOE/WIPP02-3122, Appendix A, Table A-2 for calibration verifications. 

The calibration confirmation results are contained in section 6.0 of MILCC Calibration Report, CI-MILCC-NDA-1006. The % R was between 70 and 130% and % RSD was less than 14%. 

This perseval
E-16 

Technical Elements Objective Evidence 

LLD MILCC-14: Confirm that the LLD for the MILCC 

has been determined. 

Typical MDAs are found by performing three replicate assays on each container type and detector position with matrix containers without radioactive sources. MDAs are then averaged and converted to MDCs using matrix weight. The MDAs documented in section 8 of CI-MILCC-NDA-1006, Revision 0, indicate that the instrument meets the TRU discrimination criterion of 100 nCi/g with the exception of 241Am in a metals SWB in far-field geometry. This is only an 

example of a typical assay. 

MDmeabackLANMDSWB both 

MILCC-15: Confirm if the MILCC is used to 

discriminate TRU/non-TRU wastes at the 100 nCi/g criterion and that it has the required sensitivity. 

See previous entry. This 

perseval

MILCC-16: Identify any/all instances where an 

LLD value for a nonmeasured radionuclide is not 

provided based on a lack of technical feasibility. 

Because an LLD is a measurement-based parameter, it is not technically feasible 

to calculate for radionuclides that are not directly measured. 242Pu is derived 

from the measured mass of 239Pu times an appropriate scaling factor computed 

from measured or declared mass fractions. LANL-CCP states the 234U scaling 

factor 0.014 is used for wastes containing 235U, and the scaling factor 0.427 is 

used for wastes containing primarily 238Pu. Since MDAs for 235U and 238Pu vary 

according to measurement conditions, the reporting thresholds for 234U will also 

vary. 90Sr activity is assumed equal to 137Cs activity in wastes containing fission 

products. Typical gamma reporting thresholds for these nuclides are shown in CI-MILCC-NDA-1006, Revision 0, Tables 8e through 8h. 

This CI-M0, anpersthrewith

Quality Control MILCC-17: All operators have current CCP 

training as verified on LOQI. 

An 11/14/2013 LOQI was provided to EPA reviewers. Seven operators were listed on the LOQI, all with current training requirements met. Two of the operators are also listed as EAs. 

EPA of earesp

MILCC-18: Confirm the MILCC’s status with 

respect to the CBFO NDA PDP and last cycle. 

The MILCC was in the process of participating in the PDP drum cycle 20A and supplemental box cycle B13C during the EPA evaluation. The items to be assayed included 4 drums and 2 SWBs. 

LANcopy issu

MILCC-19: All MILCC data must be reviewed 

and approved by qualified personnel. Identify the name and function of the individuals performing technical review and approval of MILCC BDRs. 

Data review in the BDRs obtained by EPA was performed by two ITRs: Tim Burton and Israel Aragon. Other qualified ITRs include: Ryan Hammon, Dominic Archuleta and Maria Escarcenga. EAs include Jared Francis and Richard Baumann. 

Quaby Epers

MILCC-20: Identify any NCRs within the last 

year. 

There were no NCRs issued to this system since the last inspection. There have been several NCRs related to specific assays; however, this is expected on the MILCC because all assays are first done in the near field. Invalid assays are then NCR’d and run in the far-field position. 

This 

persa suobtatimelong
E-17 

Technical Elements Objective Evidence 

TMU MILCC-21: Evaluate the magnitude of the TMU 

values observed in the MILCC BDRs that were examined during this evaluation. 

The TMU for the MILCC is documented in “Total Measurement Uncertainty 

for the MCS/LANL ISOCS ‘Box Counter,’” Revision 2, March 27, 2013. The components of uncertainty included in the TMU determination consist of calibration source uncertainties, ISOCS model uncertainties, detector 

positioning, matrix in homogeneity, nonuniform source distribution, fill-height uncertainty, self-attenuation of SNM “lumps,” counting statistics, background 

fluctuations, radionuclide interferences and isotopic measurement uncertainty. 

The ISOCS uncertainty estimator, a companion program to the MILCC, is used to calculate TMU. 

EPA provexpe

Background and Performance Checks MILCC-22: Confirm that MILCC background 

measurements have been taken daily. 

Background measurements are required in CCP-TP-076, Revision 0. Evidence of daily background measurements was seen in the logbook pages reviewed. 

EPA from 11/1that were 

MILCC-23: Assess how often background 

radiation was problematic to the extent that measurement personnel had to make adjustments. 

This was originally a problem when the MILCC was first assembled. Wastes stored in Dome 283 were removed. This reduced background to acceptable levels. Background has not been a problem since these wastes were relocated. 

This pers

MILCC-24: Confirm that system performance 

checks have been performed at least once per operational day. Confirm that performance checks include gamma matrix correction checks and gamma peak position and resolution checks. 

Performance measurements are required in CCP-TP-076, operating procedure (Revision 0, 5/2013). Evidence of daily performance checks was seen in the logbook pages reviewed. 

EPA from 11/1that meaacce

MILCC-25: MILCC BDRs contain: 

 Testing facility name, testing batch number, 

container numbers and signature of the SPM or designee. 

 Table of contents.  Background and performance check data or 

control charts for the relevant time period. 

 Separate testing report sheets for each container.

EPA reviewed MILCC BDR Nos. 4LANDA0016 (55-gallon drums) and 4LANDA0012 (CMB). The BDRs contained all required information. 

NA 
E-18 

Technical Elements Objective Evidence 

MILCC-26: MILCC RDSs must include: 

 Title “Radioassay Data Sheet.”  Method/procedure used.  Date of radioassay.  Activities and associated TMU for individual 

radionuclides. 

 TRU alpha concentration and its associated 

TMU. 

 Operator and reviewer signatures. 

EPA reviewed MILCC BDR Nos. 4LANDA0016 (55-gallon drums) and 4LANDA0012 (CMB). The RDSs contained all required information. 

NA 
F-1 

ATTACHMENT F.1: REPLICATE TESTING DATA FOR DRUM NO. 68428 – HENC

Instrument: HENC2 Drum: 68428 

Quantity of Interest 

Original Measurement Replicate #1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

233U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 234U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 238U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 238Pu Activity (Ci) 1.56E-02 4.09E-03 2.62E-01 1.47E-02 3.83E-03 2.61E-01 1.51E-02 239Pu Activity (Ci) 5.79E-01 1.28E-01 2.21E-01 5.47E-01 1.20E-01 2.20E-01 5.63E-01 240Pu Activity (Ci) 1.36E-01 3.56E-02 2.62E-01 1.28E-01 3.34E-02 2.61E-01 1.32E-01 242Pu Activity (Ci) 7.88E-06 2.07E-06 2.63E-01 7.44E-06 1.94E-06 2.61E-01 7.65E-06 241Am Activity (Ci) 5.88E+00 3.20E+00 5.44E-01 5.85E+00 3.19E+00 5.45E-01 5.74E+00 90Sr Activity (Ci) N/A N/A N/A N/A N/A N/A 137Cs Activity (Ci) N/A N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 2.41E+05 1.17E+05 4.84E-01 2.39E+05 1.16E+05 4.84E-01 2.35E+05 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 234U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 238U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 238Pu Activity (Ci) 1.44E-02 3.75E-03 2.60E-01 1.50E-02 3.89E-03 2.59E-01 1.45E-02 239Pu Activity (Ci) 5.37E-01 1.17E-01 2.18E-01 5.57E-01 1.22E-01 2.19E-01 5.40E-01 240Pu Activity (Ci) 1.26E-01 3.27E-02 2.60E-01 1.30E-01 3.39E-02 2.61E-01 1.26E-01 242Pu Activity (Ci) 7.29E-06 1.90E-06 2.61E-01 7.58E-06 1.97E-06 2.60E-01 7.34E-06 241Am Activity (Ci) 5.84E+00 3.18E+00 5.45E-01 5.89E+00 3.21E+00 5.45E-01 5.99E+00 90Sr Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 137Cs Activity (Ci) N/A N/A N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 2.38E+05 1.16E+05 4.86E-01 2.41E+05 1.17E+05 4.84E-01 2.43E+05 
F-2 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <|c

Reported Value Absolute Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N234U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N238U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N238Pu Activity (Ci) 1.56E-02 4.09E-03 1.47E-02 3.05E-04 2.07E-02 2.23E-02 1.00E239Pu Activity (Ci) 5.79E-01 1.28E-01 5.49E-01 1.11E-02 2.01E-02 2.99E-02 1.00E240Pu Activity (Ci) 1.36E-01 3.56E-02 1.28E-01 2.61E-03 2.03E-02 2.14E-02 1.00E242Pu Activity (Ci) 7.88E-06 2.07E-06 7.46E-06 1.53E-07 2.06E-02 2.19E-02 1.00E241Am Activity (Ci) 5.88E+00 3.20E+00 5.86E+00 9.04E-02 1.54E-02 3.19E-03 1.00E90Sr Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N137Cs Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A NTRU Alpha Conc. (nCi/g) 2.41E+05 1.17E+05 2.39E+05 3.03E+03 1.27E-02 2.70E-03 1.00E

Quantity of Interest t Pr(x <|t|) χ2 Test t-Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) N/A N/A Not Applicable Not Applicable 238U Activity (Ci) N/A N/A Not Applicable Not Applicable 238Pu Activity (Ci) 2.57E+00 6.17E-02 Not Significant Not Significant 239Pu Activity (Ci) 2.49E+00 6.72E-02 Not Significant Not Significant 240Pu Activity (Ci) 2.66E+00 5.64E-02 Not Significant Not Significant 242Pu Activity (Ci) 2.50E+00 6.69E-02 Not Significant Not Significant 241Am Activity (Ci) 1.82E-01 8.65E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable 137Cs Activity (Ci) N/A N/A Not Applicable Not Applicable TRU Alpha Conc. (nCi/g) 5.42E-01 6.17E-01 Not Significant Not Significant 
F-3 

ATTACHMENT F.2: REPLICATE TESTING DATA FOR DRUM NO. 68434 – HENC

Instrument: HENC2 Drum: 68434 

Quantity of Interest 

Original Measurement Replicate #1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

233U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 234U Activity (Ci) N/A 7.47E-03 1.87E-01 3.97E-02 7.49E-03 1.89E-01 3.96E-02 238U Activity (Ci) 2.84E-04 4.98E-05 1.75E-01 2.91E-04 5.10E-05 1.75E-01 2.89E-04 238Pu Activity (Ci) 2.56E+02 4.79E+01 1.87E-01 2.56E+02 4.83E+01 1.89E-01 2.56E+02 239Pu Activity (Ci) 2.30E-01 5.39E-02 2.34E-01 2.30E-01 5.42E-02 2.36E-01 2.30E-01 240Pu Activity (Ci) 1.14E-01 2.68E-02 2.35E-01 1.14E-01 2.70E-02 2.37E-01 1.14E-01 242Pu Activity (Ci) 1.15E-04 2.71E-05 2.36E-01 1.15E-04 2.72E-05 2.37E-01 1.15E-04 241Am Activity (Ci) 2.98E-01 6.95E-02 2.33E-01 2.98E-01 6.99E-02 2.35E-01 2.98E-01 90Sr Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 137Cs Activity (Ci) N/A N/A N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 8.85E+07 1.65E+07 1.86E-01 8.84E+07 1.67E+07 1.89E-01 8.83E+07 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 234U Activity (Ci) N/A 7.50E-03 1.88E-01 3.96E-02 7.48E-03 1.89E-01 3.97E-02 238U Activity (Ci) 2.80E-04 4.93E-05 1.76E-01 2.83E-04 4.99E-05 1.76E-01 2.94E-04 238Pu Activity (Ci) 2.57E+02 4.84E+01 1.88E-01 2.55E+02 4.82E+01 1.89E-01 2.56E+02 239Pu Activity (Ci) 2.31E-01 5.44E-02 2.35E-01 2.29E-01 5.41E-02 2.36E-01 2.30E-01 240Pu Activity (Ci) 1.15E-01 2.70E-02 2.35E-01 1.14E-01 2.69E-02 2.36E-01 1.14E-01 242Pu Activity (Ci) 1.16E-04 2.73E-05 2.35E-01 1.15E-04 2.72E-05 2.37E-01 1.15E-04 241Am Activity (Ci) 2.99E-01 7.01E-02 2.34E-01 2.98E-01 6.98E-02 2.34E-01 2.98E-01 90Sr Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 137Cs Activity (Ci) N/A N/A N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 8.87E+07 1.67E+07 1.88E-01 8.83E+07 1.66E+07 1.88E-01 8.84E+07 
F-4 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <

Reported Value Absolute Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 234U Activity (Ci) 3.99E-02 7.47E-03 3.97E-02 8.37E-05 2.11E-03 5.02E-04 1.00E238U Activity (Ci) 2.84E-04 4.98E-05 2.87E-04 5.77E-06 2.01E-02 5.37E-02 1.00E238Pu Activity (Ci) 2.56E+02 4.79E+01 2.56E+02 7.07E-01 2.76E-03 8.73E-04 1.00E239Pu Activity (Ci) 2.30E-01 5.39E-02 2.30E-01 7.07E-04 3.07E-03 6.89E-04 1.00E240Pu Activity (Ci) 1.14E-01 2.68E-02 1.14E-01 4.47E-04 3.92E-03 1.11E-03 1.00E242Pu Activity (Ci) 1.15E-04 2.71E-05 1.15E-04 4.47E-07 3.88E-03 1.09E-03 1.00E241Am Activity (Ci) 2.98E-01 6.95E-02 2.98E-01 4.47E-04 1.50E-03 1.66E-04 1.00E90Sr Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 8.85E+07 1.65E+07 8.84E+07 1.64E+05 1.86E-03 3.97E-04 1.00E

Quantity of Interest t Pr(x <|t|) χ2Test t-Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) 2.40E+00 7.43E-02 Not Significant Not Significant 238U Activity (Ci) -5.38E-01 6.19E-01 Not Significant Not Significant 238Pu Activity (Ci) 0.00E+00 1.00E+00 Not Significant Not Significant 239Pu Activity (Ci) -3.58E-14 1.00E+00 Not Significant Not Significant 240Pu Activity (Ci) -4.08E-01 7.04E-01 Not Significant Not Significant 242Pu Activity (Ci) -4.08E-01 7.04E-01 Not Significant Not Significant 241Am Activity (Ci) -4.08E-01 7.04E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable 137Cs Activity (Ci) N/A N/A Not Applicable Not Applicable TRU Alpha Conc. (nCi/g) 4.44E-01 6.80E-01 Not Significant Not Significant 
F-5 

ATTACHMENT F.3: REPLICATE TESTING DATA FOR DRUM NO. 68571 – HENC

Instrument: HENC2 Drum: 68571 

Quantity of Interest 

Original Measurement Replicate #1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

233U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 234U Activity (Ci) N/A 1.42E-04 2.23E-01 6.15E-04 1.40E-04 2.28E-01 5.46E-04 238U Activity (Ci) 1.27E-04 2.74E-05 2.16E-01 1.11E-04 2.70E-05 2.43E-01 1.10E-04 238Pu Activity (Ci) 5.87E-02 1.57E-02 2.67E-01 5.84E-02 1.57E-02 2.69E-01 5.87E-02 239Pu Activity (Ci) 2.19E+00 4.97E-01 2.27E-01 2.17E+00 4.96E-01 2.29E-01 2.19E+00 240Pu Activity (Ci) 5.12E-01 1.37E-01 2.68E-01 5.09E-01 1.37E-01 2.69E-01 5.12E-01 242Pu Activity (Ci) 2.97E-05 7.96E-06 2.68E-01 2.96E-05 7.93E-06 2.68E-01 2.97E-05 241Am Activity (Ci) 7.57E+00 4.17E+00 5.51E-01 7.56E+00 4.16E+00 5.50E-01 7.53E+00 90Sr Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 137Cs Activity (Ci) N/A N/A N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 8.47E+04 3.44E+04 4.06E-01 8.45E+04 3.44E+04 4.07E-01 8.43E+04 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 234U Activity (Ci) N/A 1.48E-04 2.10E-01 7.16E-04 1.51E-04 2.11E-01 5.55E-04 238U Activity (Ci) 1.20E-04 2.80E-05 2.33E-01 1.29E-04 2.89E-05 2.24E-01 1.20E-04 238Pu Activity (Ci) 5.95E-02 1.59E-02 2.67E-01 5.82E-02 1.56E-02 2.68E-01 5.92E-02 239Pu Activity (Ci) 2.22E+00 5.05E-01 2.27E-01 2.17E+00 4.93E-01 2.27E-01 2.21E+00 240Pu Activity (Ci) 5.19E-01 1.39E-01 2.68E-01 5.08E-01 1.36E-01 2.68E-01 5.16E-01 242Pu Activity (Ci) 3.01E-05 8.07E-06 2.68E-01 2.95E-05 7.89E-06 2.67E-01 3.00E-05 241Am Activity (Ci) 7.56E+00 4.16E+00 5.50E-01 7.61E+00 4.19E+00 5.51E-01 7.55E+00 90Sr Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 137Cs Activity (Ci) N/A N/A N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 8.49E+04 3.44E+04 4.05E-01 8.48E+04 3.46E+04 4.08E-01 8.47E+04 
F-6 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <

Reported Value Absolute Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 234U Activity (Ci) 6.36E-04 1.42E-04 6.27E-04 8.02E-05 1.28E-01 1.28E+00 8.65238U Activity (Ci) 1.27E-04 2.74E-05 1.18E-04 7.78E-06 6.59E-02 3.22E-01 9.88238Pu Activity (Ci) 5.87E-02 1.57E-02 5.88E-02 5.43E-04 9.24E-03 4.80E-03 1.00E239Pu Activity (Ci) 2.19E+00 4.97E-01 2.19E+00 2.28E-02 1.04E-02 8.42E-03 1.00E240Pu Activity (Ci) 5.12E-01 1.37E-01 5.13E-01 4.66E-03 9.08E-03 4.61E-03 1.00E242Pu Activity (Ci) 2.97E-05 7.96E-06 2.98E-05 2.59E-07 8.69E-03 4.23E-03 1.00E241Am Activity (Ci) 7.57E+00 4.17E+00 7.56E+00 2.95E-02 3.90E-03 2.00E-04 1.00E90Sr Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 8.47E+04 3.44E+04 8.46E+04 2.41E+02 2.85E-03 1.96E-04 1.00E

Quantity of Interest t Pr(x <|t|) χ2 Test t-Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) 1.00E-01 9.25E-01 Not Significant Not Significant 238U Activity (Ci) 1.06E+00 3.50E-01 Not Significant Not Significant 238Pu Activity (Ci) -1.68E-01 8.75E-01 Not Significant Not Significant 239Pu Activity (Ci) -8.01E-02 9.40E-01 Not Significant Not Significant 240Pu Activity (Ci) -1.57E-01 8.83E-01 Not Significant Not Significant 242Pu Activity (Ci) -2.82E-01 7.92E-01 Not Significant Not Significant 241Am Activity (Ci) 2.48E-01 8.17E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable 137Cs Activity (Ci) N/A N/A Not Applicable Not Applicable TRU Alpha Conc. (nCi/g) 2.27E-01 8.31E-01 Not Significant Not Significant 
F-7 

ATTACHMENT F.4: REPLICATE TESTING DATA FOR DRUM NO. 68107 – SUPERH

Instrument: SHENC Container: 68107 

Quantity of Interest 

Original Measurement Replicate #1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

233U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 234U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 238U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 238Pu Activity (Ci) 7.53E-01 1.04E-01 1.38E-01 7.61E-01 1.28E-01 1.68E-01 7.47E-01 239Pu Activity (Ci) 1.05E+01 1.38E+00 1.31E-01 1.06E+01 1.41E+00 1.33E-01 1.04E+01 240Pu Activity (Ci) 3.95E+00 5.18E-01 1.31E-01 3.99E+00 7.21E-01 1.81E-01 3.92E+00 242Pu Activity (Ci) 8.00E-04 1.06E-04 1.33E-01 8.07E-04 1.37E-04 1.70E-01 7.93E-04 241Am Activity (Ci) 2.01E+00 2.63E-01 1.31E-01 2.03E+00 4.08E-01 2.01E-01 2.04E+00 90Sr Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 137Cs Activity (Ci) N/A N/A N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 1.41E+05 1.23E+04 8.72E-02 1.43E+05 1.35E+04 9.44E-02 1.40E+05 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 234U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 238U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 238Pu Activity (Ci) 7.46E-01 1.04E-01 1.39E-01 7.50E-01 1.05E-01 1.40E-01 7.46E-01 239Pu Activity (Ci) 1.04E+01 1.39E+00 1.34E-01 1.05E+01 1.40E+00 1.33E-01 1.04E+01 240Pu Activity (Ci) 3.91E+00 5.22E-01 1.34E-01 3.93E+00 5.25E-01 1.34E-01 3.91E+00 242Pu Activity (Ci) 7.92E-04 1.07E-04 1.35E-01 7.96E-04 1.08E-04 1.36E-01 7.92E-04 241Am Activity (Ci) 2.09E+00 4.21E-01 2.01E-01 2.07E+00 4.17E-01 2.01E-01 2.09E+00 90Sr Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 137Cs Activity (Ci) N/A N/A N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 1.41E+05 1.27E+04 9.01E-02 1.41E+05 1.27E+04 9.01E-02 1.41E+05 
F-8 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <|c

Reported Value Absolute Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N234U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N238U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N238Pu Activity (Ci) 7.53E-01 1.04E-01 7.50E-01 6.53E-03 8.72E-03 1.58E-02 1.00E239Pu Activity (Ci) 1.05E+01 1.38E+00 1.05E+01 8.94E-02 8.55E-03 1.68E-02 1.00E240Pu Activity (Ci) 3.95E+00 5.18E-01 3.93E+00 3.35E-02 8.51E-03 1.67E-02 1.00E242Pu Activity (Ci) 8.00E-04 1.06E-04 7.96E-04 6.53E-06 8.21E-03 1.52E-02 1.00E241Am Activity (Ci) 2.01E+00 2.63E-01 2.05E+00 2.68E-02 1.31E-02 4.17E-02 1.00E90Sr Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A N137Cs Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A NTRU Alpha Conc. (nCi/g) 1.41E+05 1.23E+04 1.41E+05 1.22E+03 8.69E-03 3.97E-02 1.00E

Quantity of Interest t Pr(x <|t|) χ2 Test t-Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) N/A N/A Not Applicable Not Applicable 238U Activity (Ci) N/A N/A Not Applicable Not Applicable 238Pu Activity (Ci) 4.47E-01 6.78E-01 Not Significant Not Significant 239Pu Activity (Ci) 4.08E-01 7.04E-01 Not Significant Not Significant 240Pu Activity (Ci) 4.91E-01 6.49E-01 Not Significant Not Significant 242Pu Activity (Ci) 5.87E-01 5.89E-01 Not Significant Not Significant 241Am Activity (Ci) -1.43E+00 2.26E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable 137Cs Activity (Ci) N/A N/A Not Applicable Not Applicable TRU Alpha Conc. (nCi/g) 0.00E+00 1.00E+00 Not Significant Not Significant 
F-9 

ATTACHMENT F.5: REPLICATE TESTING DATA FOR DRUM NO. 68214 – SUPERH

Instrument: SHENC Container: 68214 

Quantity of Interest 

Original Measurement Replicate #1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

233U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 234U Activity (Ci) 1.87E-04 4.87E-05 2.60E-01 1.88E-04 4.90E-05 2.61E-01 1.89E-04 238U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 238Pu Activity (Ci) 1.21E+00 3.15E-01 2.60E-01 1.13E+00 2.95E-01 2.61E-01 1.22E+00 239Pu Activity (Ci) 8.62E-02 2.24E-02 2.60E-01 8.02E-02 2.10E-02 2.62E-01 8.69E-02 240Pu Activity (Ci) 3.67E-02 9.56E-03 2.60E-01 3.42E-02 8.94E-03 2.61E-01 3.71E-02 242Pu Activity (Ci) 1.23E-04 3.20E-04 2.60E+00 1.15E-04 3.00E-05 2.61E-01 1.24E-04 241Am Activity (Ci) 4.29E-02 9.20E-03 2.14E-01 4.25E-02 9.28E-03 2.18E-01 4.28E-02 90Sr Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 137Cs Activity (Ci) N/A N/A N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 3.03E+03 6.96E+02 2.30E-01 2.83E+03 6.51E+02 2.30E-01 3.06E+03 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 234U Activity (Ci) 1.86E-04 4.86E-05 2.61E-01 2.02E-04 5.28E-05 2.61E-01 1.86E-04 238U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 238Pu Activity (Ci) 1.18E+00 3.08E-01 2.61E-01 1.28E+00 3.34E-01 2.61E-01 1.18E+00 239Pu Activity (Ci) 8.40E-02 2.19E-02 2.61E-01 9.13E-02 2.38E-02 2.61E-01 8.40E-02 240Pu Activity (Ci) 3.58E-02 9.34E-03 2.61E-01 3.89E-02 1.01E-02 2.60E-01 3.58E-02 242Pu Activity (Ci) 1.20E-04 3.13E-05 2.61E-01 1.30E-04 3.40E-05 2.62E-01 1.20E-04 241Am Activity (Ci) 4.24E-02 9.21E-03 2.17E-01 4.22E-02 9.22E-03 2.18E-01 4.34E-02 90Sr Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 137Cs Activity (Ci) N/A N/A N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 2.96E+03 6.81E+02 2.30E-01 3.20E+03 7.39E+02 2.31E-01 2.96E+03 
F-10 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <

Reported Value Absolute Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 234U Activity (Ci) 1.87E-04 4.87E-05 1.90E-04 6.72E-06 3.53E-02 7.62E-02 9.99238U Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 238Pu Activity (Ci) 1.21E+00 3.15E-01 1.20E+00 5.59E-02 4.66E-02 1.26E-01 9.98239Pu Activity (Ci) 8.62E-02 2.24E-02 8.53E-02 4.12E-03 4.83E-02 1.35E-01 9.98240Pu Activity (Ci) 3.67E-02 9.56E-03 3.64E-02 1.75E-03 4.82E-02 1.34E-01 9.98242Pu Activity (Ci) 1.23E-04 3.20E-04 1.22E-04 5.59E-06 4.59E-02 1.22E-03 1.00E241Am Activity (Ci) 4.29E-02 9.20E-03 4.27E-02 4.67E-04 1.09E-02 1.03E-02 1.00E90Sr Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A 137Cs Activity (Ci) 0.00E+00 N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 3.03E+03 6.96E+02 3.00E+03 1.38E+02 4.58E-02 1.56E-01 9.97

Quantity of Interest t Pr(x <|t|) χ2Test t-Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) -4.35E-01 6.86E-01 Not Significant Not Significant 238U Activity (Ci) N/A N/A Not Applicable Not Applicable 238Pu Activity (Ci) 1.96E-01 8.54E-01 Not Significant Not Significant 239Pu Activity (Ci) 2.04E-01 8.48E-01 Not Significant Not Significant 240Pu Activity (Ci) 1.77E-01 8.68E-01 Not Significant Not Significant 242Pu Activity (Ci) 1.96E-01 8.54E-01 Not Significant Not Significant 241Am Activity (Ci) 4.69E-01 6.63E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable 137Cs Activity (Ci) N/A N/A Not Applicable Not Applicable TRU Alpha Conc. (nCi/g) 1.86E-01 8.62E-01 Not Significant Not Significant 
F-11 

ATTACHMENT F.6: REPLICATE TESTING DATA FOR DRUM NO. 68211 – SUPERH

Instrument: SHENC Container: 68211 

Quantity of Interest 

Original Measurement Replicate #1 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty

Reported 

Value 

233U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 234U Activity (Ci) 2.18E-04 3.40E-05 1.56E-01 2.11E-04 3.39E-05 1.61E-01 2.16E-04 238U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 238Pu Activity (Ci) 1.78E+00 2.53E-01 1.42E-01 1.76E+00 2.51E-01 1.43E-01 1.74E+00 239Pu Activity (Ci) 1.48E+01 2.04E+00 1.38E-01 1.47E+01 2.02E+00 1.37E-01 1.45E+01 240Pu Activity (Ci) 8.93E+00 1.23E+00 1.38E-01 8.86E+00 1.22E+00 1.38E-01 8.75E+00 242Pu Activity (Ci) 2.40E-03 3.34E-04 1.39E-01 2.38E-03 3.31E-04 1.39E-01 2.35E-03 241Am Activity (Ci) 1.12E+01 2.26E+00 2.02E-01 1.12E+01 2.25E+00 2.01E-01 1.10E+01 90Sr Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 137Cs Activity (Ci) N/A N/A N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 1.28E+05 1.15E+04 8.98E-02 1.28E+05 1.14E+04 8.91E-02 1.26E+05 237Np Activity (Ci) 9.73E-05 1.27E-05 1.31E-01 9.65E-05 1.26E-05 1.31E-01 9.54E-05 235U Activity (Ci) 5.39E-06 8.42E-07 1.56E-01 5.23E-06 8.40E-07 1.61E-01 5.35E-06 

Quantity of Interest 

Replicate #3 Replicate #4 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

Absolute 

Uncertainty 

Relative 

Uncertainty 

Reported 

Value 

233U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 234U Activity (Ci) 1.99E-04 3.46E-05 1.74E-01 2.22E-04 3.69E-05 1.66E-01 2.19E-04 238U Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 238Pu Activity (Ci) 1.75E+00 2.49E-01 1.42E-01 1.76E+00 2.51E-01 1.43E-01 1.76E+00 239Pu Activity (Ci) 1.46E+01 2.01E+00 1.38E-01 1.47E+01 2.03E+00 1.38E-01 1.47E+01 240Pu Activity (Ci) 8.81E+00 1.22E+00 1.38E-01 8.86E+00 1.22E+00 1.38E-01 8.86E+00 242Pu Activity (Ci) 2.37E-03 3.30E-04 1.39E-01 2.38E-03 3.31E-04 1.39E-01 2.38E-03 241Am Activity (Ci) 1.11E+01 2.24E+00 2.02E-01 1.11E+01 2.23E+00 2.01E-01 1.11E+01 90Sr Activity (Ci) N/A N/A N/A N/A N/A N/A N/A 137Cs Activity (Ci) N/A N/A N/A N/A N/A N/A N/A TRU Alpha Conc. (nCi/g) 1.27E+05 1.14E+04 8.98E-02 1.27E+05 1.14E+04 8.98E-02 1.27E+05 
F-12 

Quantity of Interest 

Original Measurement 

Sample 

Mean 

Sample 

Standard 

Deviation 

Relative 

Standard 

Deviation χ2 Pr(x <

Reported Value Absolute Uncertainty 

233U Activity (Ci) 0.00E+00 N/A N/A N/A N/A 0.00E+00 234U Activity (Ci) 2.18E-04 3.40E-05 2.13E-04 9.02E-06 4.23E-02 2.18E-04 3.40238U Activity (Ci) 0.00E+00 N/A N/A N/A N/A 0.00E+00 238Pu Activity (Ci) 1.78E+00 2.53E-01 1.75E+00 8.94E-03 5.10E-03 1.78E+00 2.53239Pu Activity (Ci) 1.48E+01 2.04E+00 1.46E+01 8.94E-02 6.11E-03 1.48E+01 2.04E240Pu Activity (Ci) 8.93E+00 1.23E+00 8.83E+00 4.87E-02 5.51E-03 8.93E+00 1.23E242Pu Activity (Ci) 2.40E-03 3.34E-04 2.37E-03 1.30E-05 5.50E-03 2.40E-03 3.34241Am Activity (Ci) 1.12E+01 2.26E+00 1.11E+01 7.07E-02 6.37E-03 1.12E+01 2.26E90Sr Activity (Ci) 0.00E+00 N/A N/A N/A N/A 0.00E+00 137Cs Activity (Ci) 0.00E+00 N/A N/A N/A N/A 0.00E+00 TRU Alpha Conc. (nCi/g) 1.28E+05 1.15E+04 1.27E+05 7.07E+02 5.57E-03 1.28E+05 1.15E237Np Activity (Ci) 9.73E-05 1.27E-05 9.56E-05 5.27E-07 5.51E-03 6.89E-03 1.00E235U Activity (Ci) 5.39E-06 8.42E-07 5.28E-06 2.26E-07 4.27E-02 2.87E-01 9.91

Quantity of Interest t Pr(x <|t|) χ2 Test t-Test

233U Activity (Ci) N/A N/A Not Applicable Not Applicable 234U Activity (Ci) 4.66E-01 6.66E-01 Not Significant Not Significant 238U Activity (Ci) N/A N/A Not Applicable Not Applicable 238Pu Activity (Ci) 2.65E+00 5.68E-02 Not Significant Not Significant 239Pu Activity (Ci) 1.63E+00 1.78E-01 Not Significant Not Significant 240Pu Activity (Ci) 1.91E+00 1.28E-01 Not Significant Not Significant 242Pu Activity (Ci) 1.96E+00 1.22E-01 Not Significant Not Significant 241Am Activity (Ci) 1.29E+00 2.66E-01 Not Significant Not Significant 90Sr Activity (Ci) N/A N/A Not Applicable Not Applicable 137Cs Activity (Ci) N/A N/A Not Applicable Not Applicable TRU Alpha Conc. (nCi/g) 1.29E+00 2.66E-01 Not Significant Not Significant 237Np Activity (Ci) 2.87E+00 4.53E-02 Not Significant Significant 235U Activity (Ci) 4.29E-01 6.90E-01 Not Significant Not Significant 

237Np Activity (Ci) 9.51E-05 1.24E-05 1.30E-01 9.57E-05 1.25E-05 1.31E-01 9.55E-05 235U Activity (Ci) 4.92E-06 8.56E-07 1.74E-01 5.49E-06 9.13E-07 1.66E-01 5.43E-06