# 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

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# 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 Effici ency Neutron Counter No. 1 ............... 13

6.2.2 Technical Evaluation: High Effici ency Neutron Counter No. 2 ............... 16

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

6.2.4 Technical Evaluation: Mobile In Si tu 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 Transurani c Waste Characterization Processes Implemented by LANL-CCP ................................................................................................................... ............. 3

Table 2. RTR Container Records Exam ined in This Inspection ................................................... 26

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# 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 In spection 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 Complia nce Inspection Checklist: SuperHENC

Attachment E.4 NDA Continued Compliance Inspection Checklist: MILCC

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

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

Attachment F.3 Replicate Testi ng 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

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# 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 fo r 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 Technica l 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 Obje ct Counting System

ITR Independent Technical Reviewer

keV kiloelectron volt

kg kilogram

LANL Los Alamos National Laboratory

LLD lower limit of detection

LN 2 

# 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 Coun ting System Large Container Counter

MT material type

nCi/g nanocuries per gram

NCR nonconformance report

NDA nondestructive assay

NDE nondestructive examination

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# 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

240 

# Pu Eff 

# 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

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# 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

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# 1.0 EXECUTIVE SUMMARY

This report supports the U.S. E nvironmental Protection Agency’s (EPA’s) determination that the waste characterization program at the U.S. De partment 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), EP A conducts continued compliance inspections of the EPA-approved tran suranic (TRU) waste ch aracterization systems used at the TRU waste sites operated by DOE. Since 2007, the Central Characterization Program (CCP), 1 

# a mobile waste characterization systems pr ovider, 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 conti nued compliance inspection of the site’s program to characterize CH TRU wa stes proposed for disposal at the Waste Isolation Pilot Plant (WIPP). During this inspection, EPA evaluated sa mples of the following waste characterization

activities:

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

 Four nondestructive assay (NDA) systems: Two High Efficiency Neutron Counters (HENCs), the Super High Efficiency Neut ron 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); evaluati on performed as a desktop evaluation.

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

Based on the results of this continued complian ce inspection, EPA confirms that the LANL-CCP CH TRU waste characterization program in the c onfiguration observed duri ng 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 subseque nt EPA Tier 1 (T1) approvals. Attachment A summarizes all of EPA’s approvals of th e LANL-CCP CH TRU wa ste characterization program. EPA will use results of this continued compliance inspection to support the streamlined T1 evaluation and decision proce ss discussed in section 2.0 below.

Based on this inspection, there is one clarifying change to the VE T1 designa tions: any use of VE for summary category group (SCG) S4000 (soils) wa ste is a new T1 change. EPA previously approved the VE processes for characterization of SCG S5000 (heteroge neous 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 re visions to discrepancy resolution (DR) reports is a new AK T2 change.

1 

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

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# 2. Submission to EPA of a list of all AK Expert s (AKEs) and Site Pr oject Mangers (SPMs) who performed work in these roles for th e 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 I ndependent Technical Reviewers (ITRs).

4. Submission to EPA of a list of all NDE (R TR and VE) personnel who performed work during the previous quarter is a new NDE T2 change. Specifi cally, 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). EP A also revised the tier ing 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 a pprovals remain in effect. The language in Table 1 regarding AK documentation applies to all LANL-CCP waste streams.

EPA did not identify any findi ngs 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 discus sed 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 si milar errors has been observed in the past at other TRU Sites. CBFO a nd CCP need to address this systemic problem.

EPA will continue to review CCP’s document a nd record management during future continued compliance inspections and T1 evaluations of all CCP TRU waste char acterization programs.

This report serves as EPA’s public notification of the results of the continued compliance inspection. This information wi ll be provided through the EPA website and by sending emails to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3).3Table 1.Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented by LANL-CCP(Based on May 23–25, 2006, Baseline Inspection and Subsequent Evaluations, Updated February 2014)Process ElementsLANL-CCP Waste Characterization Process – T1 ChangesLANL-CCP Waste Characterization Process – T2 Changes*Acceptable Knowledge,including LoadManagementAny new waste category, as well as any new OSRP wastestreams addressed in AKSRs separate from CCP-AK-LANL-008or new OSRP waste streams beyond LA-OS-00-01.001, LA-OS00-03, and LA-OS-00-04 added to CCP-AK-LANL-008Load management for waste streams other than as documented inCCP-AK-LANL-009Submission of a list of active LANL-CCP CH AKEs and SPMsNotification to EPA upon completion of or substantive modification** to:AK-NDA memorandaAK accuracy reports (annually, at a minimum)AK reassessment memoranda and combination of waste streams that weredistinct at the time of the baseline inspectionAny new or updated WSPFs, including allassociated attachments (e.g., CIS andsummation of aspects) and any changenotices used to modify and updateWSPFs, including additions to waste streams within an approved waste categoryAKSRs (new and updated versions), including CCP-AK-008CCP-TP-005, Attachment 6, and associated memorandaSite procedures requiring CBFO approvalDiscrepancy Resolution Reports (new or updated)Nondestructive Assay New equipment or substantive physical modifications** toapproved equipmentExtension of or changes to approved calibration ranges forapproved equipmentSubmission of a list of LANL-CCP NDA operators, EAs and ITRs thatperformed work during the previous quarterNotification to EPA upon:Substantive modification** to software for approved equipmentSubstantive modification** to operating ranges upon CBFO approvalSubstantive modification** to site procedures requiring CBFO approvalAny change to the MILCC that does not directly impact the EPA-approvedcalibration, including relocation of the system at LANL†Real-Time Radiography NoneSubmission of a list of LANL-CCP RTRoperators and ITRs that performedwork during the previous quarterNotification to EPA upon:New equipment or substantive physical modifications** to approved equipmentSubstantive modification** to site procedures requiring CBFO approvalVisual Examination andVisual ExaminationTechniqueImplementation of any visualexamination process for SCGS4000 waste.Submission of a list of LANL-CCP VEoperators, VE Experts and ITRs thatperformed work during the previous quarterNotification to EPA upon substantive modification** to site procedures requiringCBFO approval, including OSRP visual examination technique procedure4WIPP Waste DataSystemNone Notification to EPA upon substantive modification** to:Site procedures requiring CBFO approvalExcel spreadsheet, Waste Data System data entry summary, characterizationand certification requiring CBFO approvalNew T1s, T2s and significant modifications to existing T1s or T2s are inboldtext; T1s or T2s that were only revised for style are not shown in bold.* 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 ordocumentation of them, excluding changesthat are solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act; or that are editorial in nature or are required toaddress administrative concerns. EPA may request copies of new references that DOE adds during a document revision.† LANL-CCP will report relocation ofany NDA system to EPA immediately.

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# 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 ba seline 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 s ite’s waste characteriza tion program, based on a demonstration that the program’s components, w ith 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 th e authority to conduct continued compliance inspections to verify that the site (1) conti nues to use only the approve d waste characterization processes to characterize the wa ste 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, EP A 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 clea nup 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 ac tive, EPA-approved TRU waste site. The annual continued compliance inspections will cover th e 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 elem ents are personnel training, procedures and equipment capabilities. Each site is also requir ed 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 comm on elements will be independent of EPA’s approvals of T1 change requests a nd will ensure that these waste characterization elements of each active site’s TRU program con tinue to remain in compliance with EPA WIPP requirements at 40 CFR 194.8 and 24..

The results of this continued compliance inspect ion 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 el ements 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 decisi on to maintain the approval of the LANL-CCP waste characterization program for CH TR U wastes. Specifically, this report:

 Describes the sample of the LANL-CCP wast e characterization systems evaluated during this inspection.

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#  Identifies all areas where wa ste characterization systems ha ve 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 comple ted during the course of the inspection and

their relevance to EP A’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 documen ts 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 inspecti on included the evaluation of selected elements of the waste characterization systems in use at LANL-CCP to characteri ze CH TRU wastes that were approved during the base line inspection and subseque nt T1 evaluations. Waste

characterization activities evaluated included AK for Wa ste 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 charact erization; and a desk top evaluation of RTR and VE operations for multiple SCGs.

5.0 INSPECTION PERSONNEL

EPA and its support personnel condu cted interviews with LANL -CCP waste characterization personnel in several disc iplines. The personnel cont acted 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 affiliatio ns and areas of expertise or function.

6.0 TECHNICAL EVALUATION

Sections 6.1 through 6.3 of this report detail the three techni cal areas assessed during this inspection: AK, NDA, and nondestructive examin ation (NDE), consisting of RTR and VE. EPA completed inspection checklists for AK and ND A based on responses of LANL-CCP waste characterization personnel to EPA queries a nd 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 supplem ent its review.

6.1 Acceptable Knowledge

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

TRU waste characterization. LANL-CCP’s AK ch aracterization program is EPA-approved for SCG S5000 (heterogeneous debris) waste, SC G 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 wa ste streams (LA-MHD01.001, LA-MSG04.001, LACIN01.001 and LA-OS-00-01.001) to review as repr esentative 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 tw ice (EPA Docket Nos. A-98-49; II-A4-88 and A-98-49; II-A4-141) and theref ore focused this continued compliance inspection on changes

to the waste streams and associated documenta tion since the last reviews in September 2012 and May 2010. EPA had not previously reviewed Wa ste Stream LA-MHD01.001 and Waste Stream

LA-CIN01.001 and therefore review ed their documentation in great er detail. The AK checklists used for this inspection are incl uded in Attachments D.1 through D.4.

6.1.1 Technical Evaluation: Acceptable Knowledge

(1) EPA examined Central Characterization Pr ogram procedures fo r acceptable knowledge documentation, training of Acceptable K nowledge Experts and disposition of nonconformances and found them to be adequate.

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

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

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

 CCP-QP-005, Revision 23, “Nonconforming It em 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 requ irements of 40 CFR 194. Procedure implementation is evidenced by adequate prep aration and maintenance of th e 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 th e 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-meas ured 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 2 013; 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 ch aracterization program or sooner in response to an AK CH T1 change request.

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# Notification to EPA upon completion of or subs tantive modification to site AK procedures requiring Carlsbad Field Offi ce (CBFO) approval remains a T2 change (see Table 1).

(2) EPA verified that the acceptable knowledge characterization pro cess for containers, including acceptable knowledge assembly, co mpilation 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 documenta tion) for each of the four sample waste

streams.

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

revision of CCP-TP-005. LANL-CCP revised thes e 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 expect s that all LANL-CCP waste characterization personnel are aware of and have acc ess to the current revision of all controlled CCP documents.

EPA also identified an example of source doc uments 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 traceabil ity was adequately demonstrated.

EPA randomly selected one to three containers e ach from each waste stream. These containers are traceable from their building of genera tion 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, supporte d by appropriate source documents, to support the following statements:

 All waste within the waste stream was ge nerated 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 wast e 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. Explanati ons 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 Hea lth and Welfare,” Chapter 10 8, “Nuclear Waste Policy

Act of 1982.”

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#  Waste Stream LA-MHD01.001: Attachment D .1, checklist item AK-4, summarizes the information provided in the AKS R CCP-AK-LANL-006, Revision 12.

 Waste Stream LA-MSG04.001: Attachment D .2, checklist item AK-4, summarizes the information provided in the AKS R CCP-AK-LANL-010, Revision 6.

 Waste Stream LA-CIN01.001: The AK for this wast e 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 itemAK-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 AKS R CCP-AK-LANL-008, Revision 9.

Notification to EPA upon completion of or revisi ons 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 fo rms (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-C IN01.001 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 fam iliarity 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 Chancello r, Lisa Price-Watson and Sherry Aukland. EPA also reviewed complete SPM qualificati on cards for Terri-Anne Groover, Craig Simmons,

Carolina Soaterna and Veronica Waldram. Traini ng 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 eval uation, as part of a new quarterly T2 change submission or during the next co ntinued compliance inspection.

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

LANL-CCP CH waste characterizati on 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.

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# Notification to EPA upon completion of or substan tive 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 accu racy 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 th e 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 AKaccuracy reports were written using CCP-TP005, Attachment 14, Revision 24, when they shou ld have been written using Revision 25. LANL-CCP investigated and f ound 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-review ed 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 completene ss. EPA expects that all LANL-CCP waste characterization personnel are awar e of and have access to the curre nt revision of all controlled

CCP documents.

Notification to EPA upon completion of or subs tantive modification to AK accuracy reports (annually, at a minimum) remains a T2 change (see Table 1).

(9) EPA assessed communication between accepta ble 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. EP A reviewed the curr ent AK-NDA memorandum for each of the other three sample waste stream s, 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, an d the memorandum for Waste Stream LACIN01.001 was revised in 2012. EPA found that the le vel 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 re vision had not been correctly appended to the associated CCP-TP-005, Attachment 7. L ANL-CCP revised the CCP-TP-005, Attachment 7,

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

Notification to EPA upon completion of or s ubstantive 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 c ontainer selected for pa yload management must

also contain at least one TRU is otope whose activity exceeds the lo wer 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 cont ainers from the same TRU waste stream.

LANL-CCP does not perform load management fo r 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 re quirements and found it to be adequate.

T2 notification to EPA upon completion of or s ubstantive modification to the waste-streamspecific documents listed in Table 1 is required on a quarterly ba sis. EPA compared the revision dates of documents provided during this c ontinued compliance insp ection with the T2 notification reports provided to EPA by CBFO. EP A began tracking T2 quarterly reports in the fourth quarter of fiscal year 2009 and, therefore, is unable to ve rify whether document revisions made prior to July 2009 were appropriately included in the T2 notification to EPA.

EPA found that LANL-CCP did not provi de 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 di d provide notification for other AK-NDA memorandum revisions and for other 2013 AK accuracy reports. Therefore, EPA determined that

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

to all LANL-CCP waste streams, unless specifica lly stated otherwise. The tiering changes identified during the LANL-CCP CH baseline inspection and subse quent 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 obs erved several inconsiste ncies 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 iden tified 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 charac terization 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 L ANL-CCP tiering designations consistent with the requirements at

other sites and to reflec t current T2 reporting practices (see Ta ble 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 qua rter 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 ch aracterization compliance.

6.2 Nondestructive Assay

The purpose of this inspection was to confirm th e continued compliance of NDA as part of the LANL waste characterization pr ogram. LANL’s NDA program cons isted 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 dur ing 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 add ition 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 in itially during the baseline and subsequent T1 evaluations. Attachment A lists the specific insp ection 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 th e results of EPA’s onsite confirmation that the systems were essentially unchanged, i.e., that th ey 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 system s 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 th e 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-C CP NDA personnel.

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

Each of these four systems is evaluated in sepa rate 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, resp ectively, and the replicate spreadsheets are in Attachments F.1 through F.6.

6.2.1 Technical Evaluation: High Effi ciency Neutron Counter No. 1

EPA evaluated the continued compliance of the HENC1 with the EPA-approved waste characterization program for NDA at LANL-C CP. EPA used a modified NDA checklist, included in Attachment E.1, which addressed a s ubset of the items evaluated for this system during the initial approval. Th e following aspects of the HENC1 were evaluated during this inspection.

(1) EPA verified that the High Efficiency Neut ron Counter No. 1 was the same instrument that EPA approved previously and that its de sign 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 technica l area 54 (TA-54) at LANL, in the same location as when EPA initia lly inspected and approved it for WIPP assays. The system incorporates two measurement modalitie s, 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 ( 252 

# Cf) source for the Add-aSource (AaS) matrix correction function, to dete rmine 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 obtaine d with the system’s high-purity germanium (HPGe) detector. Gamma data can also provi de direct quantification of a number of radionuclides, including plutonium-238 ( 238 

# Pu), 239 

# Pu, 241 

# Pu, americium-241 ( 241 

# Am), uranium233 ( 233 

# U), 235 

# U, 238 

# U, cesium-137 ( 137 

# Cs) and neptunium-237 ( 237 

# Np). The HPGe detector uses a multicurve efficiency calibration based on the waste matrix density to correct for gamma

attenuation and other losses. L ANL-CCP has not made any major hardware or software changes to the HENC1 system for the neutron moda lity; however, the gamma system’s pulser was replaced on February 20, 2013.

# 14 

# New equipment or substantive physical modifi cations to approved equipment remains a T1 change (see Table 1). Notifica tion to EPA upon substantive m odification 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 wa stes 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 (BDR s). During this inspection, EPA observed the HENC1 assaying Drum No. WMC1014-08, a Perfor mance 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 op erator 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], FW HM 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 ope rational aspects of the HENC 1 operation were acceptable.

Notification to EPA upon substant ive 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 ch anges apart from routine maintenance.

EPA confirmed that the HENC1’s calibration wa s unchanged from the last EPA inspection, as indicated in LANL-CCP records (MCS-HEN C#1-NDA-1002). LANL-CCP has performed eight

calibration verifications since A ugust 2012 (the time of the last EPA inspection of the HENC1), all in response to routine operational measuremen t issues. EPA reviewed six of them; all aspects

of the calibration verifications th at 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 inst rument. 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 assu rance/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 th at 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 an d documentation of calibration verifications were technically acceptable and appr opriately documented. Extension of or changes to approved calibration ranges for approved equi pment remains a T1 change (see Table 1).

# 15 

# (4) EPA confirmed that the determination a nd 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 BD Rs 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 thre sholds for specific nonmeasured radionuclides 242 

# Pu and strontium-90 ( 90 

# Sr). 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 EP A previously determined were adequate. EPA verified that these documents were unchanged fr om 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 Ca rlsbad 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 fo r all NDA personnel was adequate.

The HENC1 has 12 operators/ITRs and five EA s. All NDA personnel associated with the calibration, operation and data re view and approval of the HENC 1 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 provi ded during the inspection.

Submission to EPA of a list of all NDA pers onnel who performed work during the previous quarter is a new NDA T2 change (s ee Table 1). Specifically, the lis t must include all operators, EAs and ITRs. EPA added this requirement to ensu re that EPA has a comp lete picture of LANLCCP waste characterization activities, whic h 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 findi ngs or concerns regarding th e 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 pers onnel who performed work during the previous quarter is a new NDA T2 change (see Table 1).

6.2.2 Technical Evaluation: High Effi ciency Neutron Counter No. 2

EPA evaluated LANL-CCP’s continued co mpliance with the EPA-approved waste characterization program for CH waste using th e 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 th is inspection.

(1) EPA verified that the High Efficiency Neut ron Counter No. 2 was the same instrument that EPA approved previously and that its de sign 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 a nd approved it for WIPP assays. The system incorporates two measurement m odalities, a passive neutron count er and an integral gamma-ray spectrometer. The passive ne utron counter uses multiple 3 

# He proportional counters, in conjunction with a multiplicity shift register and an external 252 

# Cf 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 238 

# Pu, 239 

# Pu, 241 

# Pu, 241 

# Am, 233 

# U, 235 

# U, 238 

# U, 137 

# Cs and 237 

# Np. The HPGe detector uses a multicurve efficiency calibration based on the waste matrix density to correct for gamma attenua tion and other losses.

New equipment or substantive physical modifi cations to approved equipment remains a T1 change (see Table 1). Notifica tion to EPA upon substantive m odification 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 wa s 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 insp ection, 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 th is section. This drum was 95% full and had a net weight of 2.9 kg. EPA observed that HENC2 pers onnel 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 documen ted the daily background and performance check, and checks for the system’s FWHM a nd 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 we re acceptable and that LANL-CCP performed and

# 17 

# documented the assay adequate ly. All operational aspects of the HENC2 operation were acceptable.

Notification to EPA upon substant ive 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 wa s unchanged from the last EPA inspection, as indicated in LANL-CCP records (HENC #2-NDA-1002). LANL-CCP has performed six

calibration verifications since A ugust 2012 (the time of the last EPA inspection of the HENC2), all in response to routine opera tional measurement issues. EPA revi ewed five of them; all aspects

of the calibration verifications th at 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 inst rument. 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 require d by the LANL-CCP operating procedure. LANLCCP performed subsequent QA/QC checks, and all values were accepted relative to the acceptance criteria. Regarding routine maintena nce, 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 Janua ry 8, 2013. Additionally, LANL-CCP personnel

stated that the 252 

# Cf source used for the AaS correction is nearing the end of its operational life. LANL-CCP NDA personnel are aware of this probl em and are currently attempting to obtain a

source.

All aspects of the HENC2’s calibration and the execution an d documentation of calibration verifications were technically acceptable and appr opriately documented. Extension of or changes to approved calibration ranges for approved equi pment 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 doc umented 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 th e system’s LLD, including reporting thresholds for specific nonmeasured radionuclides 242 

# Pu and 90 

# Sr. These aspects are documented in HENC#2-NDA-1002, Revision 3, “Ca libration 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-L ined Calibration Report for the HENC #2 Including Passive Neutron a nd 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 insp ection and continued to be adequate.

(6) EPA established that the High Efficiency Neutron Counter No. 2 successfully participated in drum cycle 20A of the Ca rlsbad 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 EA s. All NDA personnel associated with the calibration, operation and data re view and approval of the HENC 2 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 pers onnel who performed work during the previous quarter is a new NDA T2 change (s ee Table 1). Specifically, the lis t must include all operators, EAs and ITRs. EPA added this requirement to ensu re that EPA has a comp lete picture of LANLCCP waste characterization activities, whic h 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 pa rt of this inspection is to provide EPA with an independent means to verify that the HE NC2 can provide reproduc ible results for the determination of the quantity of 10 WIPP-tracked radionuclides ( 241 

# Am, 137 

# Cs, 238 

# Pu, 239 

# Pu,

240 

# Pu, 242 

# Pu, 90 

# Sr, 233 

# U, 234 

# U and 238 

# U) and the TRU alpha concentration. 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 w ith the reported TMU by comparing the sample standard deviation for a number of replicate measuremen ts 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 meas urements 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 pr eviously 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 statis tical 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 re sults of the statistical analysis are included in Attachments F.1 through F.3.

The χ 2 

# test, which is also known as the goodness-o f-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 expe cted 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 reporte d 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 th e replicate data to see if th ere 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 HE NC2 did not show any st atistically significant differences between the original measurement assa y values and the average of the five replicate measurements for the activities of any of th e target radionuclides or the TRU alpha activity

concentration.

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

Summary of High Efficiency Neutron Counter No. 2

EPA did not identify any findi ngs or concerns regarding th e 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 pers onnel who performed work during the previous quarter is a new NDA T2 change (see Table 1).

6.2.3 Technical Evaluation: Super Hig h Efficiency Neutron Counter

EPA evaluated LANL-CCP’s continued co mpliance with the EPA-approved waste characterization program for CH waste using th e 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 th is inspection.

(1) EPA verified that the Super High Efficiency Neutron Counter was the same instrument that EPA approved previously and that its de sign 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-contain ed 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 ther e have been no substantive ha rdware changes other than the detector replacement and subsequent recalibratio n that EPA reviewed and approved as a T1 change in February 2013.

# 20 

# New equipment or substantive physical modifi cations to approved equipment remains a T1 change (see Table 1). Notifica tion to EPA upon substantive m odification to software for approved NDA equipment remains a T2 change (see Table 1).

(2) EPA assessed the design and operational rang e 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 op erators stated that the SuperHENC has the capability to assay up to six containers a day; ho wever, 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 SW B 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 pe rformed and documented the daily background and performance check, and checks for the sy stem’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 in strument parameters were acceptable and that LANL-CCP performed and documen ted the assay adequately. All operational aspects of the SuperHENC operation were acceptable.

Notification to EPA upon substant ive 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 perfor med eight calibration verifications for the SuperHENC since A ugust 2012, when NDA personnel replaced a gamma detector. All aspects of the calibration verificatio n were technically acceptable and appropriately

documented.

Extension of or changes to approved calibrati on ranges for approved equipment remains a T1 change (see Table 1).

(4) EPA verified that the lower limit of de tection, 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 Supe rHENC at Los Alamos National Laboratory Including Passive Neutron and Gamma Spectrometer Calibration a nd Confirmation,” dated June 15, 2012, Section 6.0. This document includes the tec hnical basis for the re porting thresholds for specific nonmeasured radionuclides 234 

# U, 238 

# Pu, 239 

# Pu, 242 

# Pu and 90 

# Sr. EPA verified that this document was unchanged from EP A’s last T1 inspection.

# 21 

# (5) EPA established that the Super High Effi ciency 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 da ta review and approval of the SuperHENC had current training in the appl icable areas, as evidenced by the LOQI dated November 14, 2013, 3:14 p.m., that wa s provided during the inspection.

Submission to EPA of a list of all NDA pers onnel who performed work during the previous quarter is a new NDA T2 change (s ee Table 1). Specifically, the lis t must include all operators, EAs and ITRs. EPA added this requirement to ensu re that EPA has a comp lete picture of LANLCCP waste characterization activities, whic h 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 Environm ental Protection Agency Replicate Testing

Protocol.

The purpose of the replicate testing performed as pa rt of this inspection is to provide EPA with an independent means to verify that the Supe rHENC can provide reproducible results for the determination of the quantity of 10 WIPP-tracked radionuclides ( 241 

# Am, 137 

# Cs, 238 

# Pu, 239 

# Pu,

240 

# Pu, 242 

# Pu, 90 

# Sr, 233 

# U, 234 

# U and 238 

# U) and the TRU alpha concentration. 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 w ith the reported TMU by comparing the sample standard deviation for a number of replicate measuremen ts 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 meas urements 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 pe rformed. 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 indepe ndence, is used to show how observed data compare with data we would expect to obtain accord ing to a specific hypothesis. EPA applied it in this instance to show whethe r 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 re plicate data to see if there are statistically significant differences between the orig inal 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 orig inal assay values and the average of the five replicate measurements.

The t-test for Drum No. 68211 s howed a statistically “Signifi cant” difference between the original assay value and the average of the five replicate measurements for 237 

# Np. This indicates that there was a statistically si gnificant difference between the or iginal assay and the average of the replicate measurements of 237 

# Np. All other radionuclides detect ed were within the expected ranges. It is important to keep in mind when evaluating replicate da ta that “Significant” results are not always representative of true measurement issues.

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

# Np replicate values versus original values: (1) actua l changes in the physical confi guration of the drum’s contents due to movement or settling, (2) fluctuations in the measurement system’s background, (3) temporal factors such as radioa ctive growth or decay, or (4) actual changes in the measurement system, the aspect that these tests are designe d to query. Although the software identified these variances as “Significant,” this does not necessa rily indicate a measurem ent issue that warrants

additional attention at this time.

EPA reviewers evaluated the results and f ound that the replicate measurements of 237 

# Np were all precise (i.e., very close togeth er). 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 replicat es 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 237 

# Np 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 c ontainer resulted in a sl ight difference in the 237 

# Np detected in Drum No. 68211. Waste shifting is exp ected 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 op eration of the SuperHENC or

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

Submission to EPA of a list of all NDA pers onnel 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 assa ys since EPA’s initial approval. LANL-CCP NDA personnel indicated that they do not anticipate the frequenc y of use will increase in the near future. Despite its lack of use, LANL -CCP continues to r un weekly checks on the instrument to keep the instrument functioni ng properly. The EPA inspectors used a modified

NDA checklist that addressed a subset of the item s evaluated for this system during the initial approval, included in Attachment E.4. EPA ev aluated the following aspects of the MILCC during this inspection.

(1) EPA verified that the Mobile In Situ Obj ect Counting System Large Container Counter was the same instrument that EPA approved pr eviously and that it s 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 operat ional ranges for all of the system’s previously approved assay configurations were unchanged since the last EPA inspection.

New equipment or substantive physical modifi cations to approved equipment remains a T1 change (see Table 1). Notifica tion to EPA upon substantive m odification to software for approved NDA equipment remains a T2 change (see Table 1).

(2) EPA verified that system calibration and calib ration confirmation of the Mobile In Situ Object Counting System Large Container C ounter had been performed and documented as required.

EPA verified that the system’s original ca librations for all previously approved assay configurations were unchanged. LANL-CCP has pe rformed three calibrati on verifications on the MILCC since the initial approval. EPA evaluated one of them and found it to be adequate.

Notification to EPA of any ch ange 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 uncer tainty of assays performed on the Mobile In Situ Object Counting System Large C ontainer Counter had been determined and documented, as required.

EPA verified that the system’s original determin ations of TMU for all previously approved assay configurations were unchanged si nce the last EPA inspection.

# 24 

# (4) EPA verified that the lower limit of de tection, including the minimum detectable concentration of the Mobile In Situ Obj ect Counting System Large Container Counter, had been determined and documented, as required.

The EPA inspection team verified that the syst em’s original determinations of LLDs for all previously approved assay configurations we re 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 Fi eld Office-sponsored Performance Demonstration Program, as required.

The MILCC successfully participated in PDP cycle 20A and supplemen tal 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 da ta review and approval of the MILCC had current training in the appli cable areas, as evidenced by the LOQI dated November 14, 2013, 3:12 p.m., that wa s provided during the inspection.

Submission to EPA of a list of all NDA pers onnel who performed work during the previous quarter is a new NDA T2 change (s ee Table 1). Specifically, the lis t must include all operators, EAs and ITRs. EPA added this requirement to ensu re that EPA has a comp lete picture of LANLCCP waste characterization activities, whic h 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 findi ngs or concerns regarding th e 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 pers onnel 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 a ll NDA personnel who performed work during the previous quarter is a new NDA T2 change (see Table 1). Specifi cally, 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 activit ies, which will inform the scope of NDA components evaluated during futu re 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 EP A-approved waste charac terization program for all NDA systems.

6.3 Nondestructive Examination

EPA performed a records-based, desktop contin uing 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 Vi sual Examination Procedures

The procedures used to generate the data re ported in the BDRs disc ussed 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-028 6 

# states:

4.3.6 Place items back into the containe r 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 a nd process for construction of the training/test cont ainers requires mandatory items to be consistently placed at the bottom of the container and waste-streamspecific items to be placed on top. This arra ngement may not present the most stringent challenge to operators during their demonstrati on of capability examinations. EPA will monitor test/training container constr uction at future inspections.

Notification to EPA upon substant ive 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 complian ce with EPA-approved RTR procedures for CH

waste characterization. LANL-CCP ’s RTR characterization progr am 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 S 3000 waste containers du ring this evaluation.

(1) EPA examined real-time radiography charac terization records and found them to be adequate.

EPA reviewed the audio/visual and written record s 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 a nd 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. Th e operator determined that the waste matched the waste stream description and verified the waste matrix code (WMC). No prohibited ite ms 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 i ndependent observation and replicate scan, for the

BDRs examined.

LANL-CCP reviewed the data at the data-generat ion 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 becau se it included a large number of containers. LANL-CCP explained to EPA that the contai ners had been characterized but not shipped when a change to the WIPP permit 7 

# occurred. Due to the permit change, LANL-CCP had to write an NCR for the unshipped containers containing residual liqui d. 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 Inve ntory Sheets for container Nos. NDE-Training-09, NDETraining-19, NDE-Test-20, NDE-Tra ining-29 and NDE-Training-30.

 Training container eval uation data sheets for selected operators.

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

 Qualification cards for selected personnel.

7 

# New Mexico Environment Depart ment, “WIPP Hazardous Waste Facil ity 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 wh en the BDRs discussed in section 6.3.1 were generated.

EPA determined that operators were trained in a ccordance with CCP proce dures and that training records were readily available for review. EPA id entified three errors in the training material

reviewed. These errors are:

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

is an SWB.

 CCP-TP-028, Attachment 1, No. 11 states “Lead ed glove or leaded apron.” Because the inventory records the actual c ontents of the training contai ner, this optional statement does not appear to be appropriate.

 The original inventory for container NDE-T raining-30 was incomplete. An extra bottle containing liquid was identified by an opera tor during the training examination. LANLCCP opened the training container and correct ed the inventory for this container.

These errors do not warrant the issuance of a c oncern. EPA will monitor the accuracy of records generated by LANL-CCP through future inspections.

Submission to EPA of a list of all RTR pers onnel 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, whic h 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 pers onnel 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 complian ce with EPA-approved VE procedures for CH

waste characterization. LANL-CCP ’s VE characterization program is EPA-approved for SCG S5000 (heterogeneous debris) wast e and SCG S3000 (homogeneous solids). EPA reviewed VE

records for SCG S5000 waste contai ners during this evaluation.

# 28 

# (1) EPA examined visual examination charac terization records a nd found them to be adequate.

EPA reviewed BDR Nos. LAVE550084 (55-ga llon drum), LAVE550088 (55-gallon drum), LA13-OSR-VE-009 (sealed source) and LA13-OS R-VE-013 (sealed source). EPA determined that characterization records were complete and properly processed in accordance with applicable procedures. No NCRs had been ge nerated for the containers in these BDRs.

(2) EPA examined contact-handled visual examin ation training records and found them to be adequate.

EPA reviewed training records for selected ope rators. EPA determined that VE operators continued to be trained in accordance with CCP pr ocedures and that traini ng records continued to

be available for review.

Submission to EPA of a list of all VE personnel who performed work duri ng the previous quarter is a new VE T2 change (see Table 1). Specificall y, 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 duri ng 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 EP A-approved waste charac terization 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 (soi ls) waste is now explicitly defined as a T1

# 29 

# change (see Table 1). Submissi on to EPA of a list of all NDE (RTR and VE) personnel who performed work during the previous quarter is a new NDE T2 cha nge (see Table 1). Specifically,

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

7.0 FINDINGS AND CONCERNS

EPA did not identify any findi ngs 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 discus sed 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 si milar errors has been observed in the past at other TRU Sites. CBFO a nd CCP need to address this systemic problem.

EPA will continue to review CCP’s document a nd record management during future continued compliance inspections and T1 evaluations of all CCP TRU waste char acterization 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 comp liance 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 cha nge. EPA previously approved the VE processes for characterization of SCG S5000 (heterogen eous 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 re visions to DRs is a new AK T2 change.

2. Submission to EPA of a list of AKEs and SP Ms 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 (R TR and VE) personnel who performed work during the previous quarter is a new NDE T2 change. Specifi cally, 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 consis tency with recent EPA T1 appr oval 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 a pprovals 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 th e 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 ch anges that have been made to LANL-CCP’s procedures and practices to pr event recurrence of the document and record management issues.

EPA will use results of this continued complia nce inspection to suppor t the streamlined T1 evaluation and decision process di scussed 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 EP A’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-str eam-specific AK records). In addition, EPA may not revisit the elements discussed in this report until the next continued compliance insp ection, 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 Qualific ation Plan, Revision 35, June 6, 2013

CCP-QP-005, CCP TRU Nonconforming Item Repor ting and Control, Revision 23, June 25,

2013

CCP-QP-005, Revision 21, Attach ment 1 – CCP Nonconforman ce 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 Te rri-Anne Groover, June 24, 2009

SPM Qualification card for Craig Simmons, February 7, 2005

SPM Qualification card for Ca rolina Soaterna, May 31, 2011

SPM Qualification card for Ver onica Waldram, August 4, 2009

AK Tracking Spreadsheet (LANL), provided November 20, 2013

Repackaged AK Tracking Spreadshee t (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 Nondefens e TRU Waste, Charles L. Foxx, TWCP-887, August 21, 1997

C082, Interview with J. Foxx a nd Supporting Documentation re: De fense 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 Prac tices, 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 Rineha rt 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 fo r Waste Stream LA-CIN01.001, James M. Schoen,

various dates

CCP-AK-LANL-006, Central Char acterization 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, Attach ment 1 – CCP Nonconforman ce Report (NCR), NCR-LANL0618-12, Revision 1, Originated Marc h 27, 2012, Closed September 13, 2012

CCP-QP-005, Revision 21, Attach ment 1 – CCP Nonconforman ce Report (NCR), NCR-LANL1492-12, Revision 0, Originated Augu st 8, 2012, Closed December 5, 2012

CCP-QP-005, Revision 21, Attach ment 1 – CCP Nonconforman ce Report (NCR), NCR-LANL0615-12, Revision 0, Originated March 16, 2012, Closed May 1, 2012

CCP-QP-005, Revision 21, Attach ment 1 – CCP Nonconforman ce Report (NCR), NCR-LANL1023-12, Revision 0, Originated Septembe r 19, 2012, Closed September 20, 2012

CCP-QP-005, Revision 21, Attach ment 1 – CCP Nonconforman ce Report (NCR), NCR-LANL1635-12, Revision 0, Originated August 30, 2012, Closed November 14, 2012

CCP-QP-005, Revision 21, Attach ment 1 – CCP Nonconforman ce Report (NCR), NCR-LANL0713-12, Revision 0, Originated Ma y 8, 2012, Closed January 24, 2013

CCP-QP-005, Revision 22, Attach ment 1 – CCP Nonconforman ce Report (NCR), NCR-LANL2050-12, Revision 0, Originated Novemb er 26, 2012, Closed April 8, 2013

CCP-QP-005, Revision 22, Attach ment 1 – CCP Nonconforman ce Report (NCR), NCR-LANL0011-13, Revision 0, Originated February 1, 2013 , Interim Disposition Approved February 5,

2013

CCP-TP-005, Revision 24, CCP Acceptable Know ledge Documentation, Attachment 1 – Acceptable Knowledge Documentation Check list, Waste Stream LA-CIN01.001, December 19,

2012

CCP-TP-005, Revision 24, CCP Acceptable Know ledge Documentation, Attachment 4 – Acceptable Knowledge Source Document Info rmation List, Waste Stream LA-CIN01.001, December 14, 2012

CCP-TP-005, Revision 24, CCP Acceptable Know ledge Documentation, Attachment 10 – Acceptable Knowledge Re-eva luation Checklist, Waste St ream LA-CIN01.001, October 23, 2012, October 30, 2012, and December 4, 2012

# B-4 

# CCP-TP-005, Revision 24, CCP Acceptable Know ledge Documentation, Attachment 11 – Acceptable Knowledge Source Document Disc repancy Resolution – Example Form, Waste Stream LA-CIN01.001, various dates

CCP-TP-005, Revision 24, CCP Acceptable Know ledge Documentation, Attachment 1 – Acceptable Knowledge Documentation Checkli st, Waste Stream LA-MHD01.001, December 17,

2012

CCP-TP-005, Revision 24, CCP Acceptable Know ledge Documentation, Attachment 4 – Acceptable Knowledge Source Document In formation List, Waste Stream LA-MHD01.001, December 14, 2012

CCP-TP-005, Revision 24, CCP Acceptable Know ledge Documentation, Attachment 10 – Acceptable Knowledge Re-evalu ation Checklist, Waste Stre am LA-MHD01.001, various dates

CCP-TP-005, Revision 24, CCP Acceptable Know ledge Documentation, Attachment 11 – Acceptable Knowledge Source Document Disc repancy Resolution – Example Form, Waste Stream LA-MHD01.001, various dates

CCP-TP-005, Revision 26, CCP Acceptable Know ledge Documentation, Attachment 7 – Radionuclides, Waste Stream LA-CIN01.001, November 6, 2013, including LA-CIN01.001 AK/NDA Memo, Revision 1, Jame s M. Schoen, December 12, 2012

CCP-TP-005, Revision 26, CCP Acceptable Knowle dge Documentation, Attachment 6 – Waste Form, Waste Material Parameters, Prohibite d Items, and Packaging, Waste Stream LACIN01.001, November 20, 2013, including Waste Materi al Parameter Analysis Memorandum for Waste Stream LA-CIN01.001, LANL TA-55 Cement ed TRU Waste, Steve Schafer, May 2, 2007

CCP-TP-005, Revision 26, CCP Acceptable Know ledge Documentation, Attachment 7 – Radionuclides, Waste Stream LA-MHD 01.001, November 20, 2013, including LA-MHD01.001 AK/NDA Memo, Revision 8, Jame s M. Schoen, March 3, 2010

CCP-TP-005, Revision 26, CCP Acceptable Knowle dge Documentation, Attachment 6 – Waste Form, Waste Material Parameters, Prohibite d Items, and Packaging, Waste Stream LAMHD01.001, November 19, 2013, including Waste Ma terial Parameter Analysis Memorandum for Waste Stream LA-MHD01.001, LANL TA-55 Mi xed Heterogeneous Debris Waste, Steve Schafer, December 13, 2011

CCP-TP-005, various revisions, CCP Acceptable Knowledge Documentation, Attachment 13 –

CCP Waste Stream Characterization Checklis t – Example Form, Waste Stream LA-CIN01.001,

various dates

CCP-TP-005, various revisions, CCP Acceptable Knowledge Documentation, Attachment 13 –

CCP Waste Stream Characterization Checklis t – 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 Summar y, 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) Produc tion for the Galileo Mission, G.H. Rinehart, LA-11166-MS, April 1998

D074, Lightweight Radioisotope Heater Unit (LWRHU) Produc tion 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. Musgra ve, TWCP-AK-2.1-011, September 20, 2001

D080, Process Acceptable Knowledge Summary Re port 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 Seve nteen (17) Homogeneous Containers from Debris Waste Stream LA-MHD01.001, Ra ndy Fitzgerald, February 7, 2012

# B-6 

# DR033, Discrepancy Resolution – Removal of Elev en (11) Homogeneous Drums from Debris Waste Stream (LA-MHD01.001), Ra ndy Fitzgerald, February 7, 2012

DR035, Removal of Twenty-Three (23) Homogene ous Drums from Debris Waste Stream (LAMHD01.001), Amy Johns, June 8, 2012

DR040, Removal of Five (5) Homogeneous Dr ums 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-C IN01.001 (cemented) Container No. 53706, Randy Fitzgerald, July 9, 2012

DR044, Removal of 114 Heterogeneous Drums fr om 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 Wast e Stream LA-CIN01.001, Amy Johns, October 22,

2012

DR046, Removal of 35 Heterogeneous Drums fr om Cemented Waste Stream (LA-CIN01.001), Amy Johns, October 30, 2012

DR048, Acceptable Knowledge Source Document Discrepancy Resolution – Waste Stream LAMHD01.001 Radiological Characterizati on, 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 Wast e, LIR404-00-05.2, January 5, 1999

M019, Generator Documentation, LANL, various document numbers, various dates

M156, Project 2010 Container Specific Databa se Information for LA-MHD01.001, C. Smith, May 25, 2004

M157, Project 2010 Database Summary of Wa ste 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 Fo rms from Imagic Software, LANL Waste Generators, various dates

M222, Concert Database (converted to Acce ss 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 Repor t, Steve Schafer, April 25, 2006

Memorandum from M.F. Ramirez to NTPC Reco rds Custodian: Transmittal of Los Alamos National Laboratory Site Waste Stream Pr ofile Form LA-MHD01.001, Revision 1, for Waste Stream LA-MHD01.001, May 20, 2013, includ ing: CCP-TP-002, Revision 25, CCP Reconciliation of DQOs and Reporting Charact erization Data, Attachment 2 – CCP Waste Stream Profile Form (Example), Waste Stream LA-MHD01.001, Revision 1, May 22, 2013;

Characterization Information Summar y, 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. Step zinski: Acceptable Know ledge Accuracy Report: Los Alamos National Laboratory Waste St ream 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 – Exam ple 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 Accepta ble 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. Step zinski: Acceptable Know ledge Accuracy Report: Los Alamos National Laboratory Waste Str eam 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, Wast e 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 Accu racy Report – Example Form, Waste Stream LA-MHD01.001, Lots 180 through 226, November 20, 2013

Memorandum from S.M. Peterman to CCP Reco rds 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 Charact erization 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 Str eam 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 – Exam ple Form, Waste Stream LA-CIN01.001, Lots 7 through 60, July 1, 2013; CCP-TP-005, Revi sion 26, CCP Acceptable Knowledge Documentation, Attachment 14 – CCP Accepta ble Knowledge Accuracy Report – Example Form, Waste Stream LA-CIN01.001, Lo ts 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, Ju ly 1, 2013, including CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, A ttachment 14 – CCP Acceptable Knowledge Accuracy Report – Example Form, Waste St ream 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 Re port – 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 thr ough 6, July 11, 2012, in cluding CCP-TP-005, Revision 24, CCP Acceptable Knowledge Docume ntation, 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 Docume ntation, 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 Documentati on, 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, Pe riod Generation, and Calculati on of Individual and Total

Radionuclide Masses and Activi ties 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 Ge neration for Waste Streams LA-MHD04.001 and LA-MSG04.001, and Calculation of Individual and Total Radionuclid e 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 Char acterization 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, Attach ment 1 – CCP Nonconforman ce Report (NCR), NCR-LANL3637-11, Revision 0, Originated October 6, 2011, Closed May 21, 2012

CCP-QP-005, Revision 23, Attach ment 1 – CCP Nonconforman ce Report (NCR), NCR-LANL0681-13, Revision 0, Originated September 17, 2 013, Interim Disposition Approved September 19, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowle dge Documentation, Attachment 8 – Waste Containers List, April 12, 2012

# B-10 

# CCP-TP-005, Revision 24, CCP Acceptable Knowle dge Documentation, Attachment 6 – Waste Form, Waste Material Parameters, Prohibited It ems, and Packaging, January 16, 2013, including Waste Material Parameter Analysis Memo randum 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 Know ledge Documentation, Attachment 1 – Acceptable Knowledge Documentation Check list, July 30, 2012, and February 12, 2013

CCP-TP-005, Revision 24, CCP Acceptable Know ledge Documentation, Attachment 4 – Acceptable Knowledge Source Document Information List, February 11, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowle dge Documentation, Attachment 13 – CCP

Waste Stream Characterization Chec klist – Example Form, June 5, 2013

CCP-TP-005, Revision 24, CCP Acceptable Know ledge Documentation, Attachment 10 – Acceptable Knowledge Re-evalu ation Checklist, June 7, 2012

CCP-TP-005, Revision 24, CCP Acceptable Know ledge Documentation, Attachment 11 – Acceptable Knowledge Source Document Discre pancy Resolution –Example Form, June 7, 2012

CCP-TP-005, Revision 25, CCP Acceptable Knowle dge Documentation, Attachment 13 – CCP

Waste Stream Characterization Chec klist – Example Form, June 27, 2013

CCP-TP-005, Revision 26, CCP Acceptable Know ledge Documentation, Attachment 7 – Radionuclides, November 19, 2013, includi ng LA-MSG04.001 AK/NDA Memo, Revision 2, May 12, 2012

Characterization Information Summar y, 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 F acility Decontamination Project 1978–1981 Raymond Garde, E.J. Cox, Allen M. Valentin e, 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. Smit h, P2010-0608, TWCP 23596, AK-00-23, Revision 0, July 8, 2004

D069, A History of Waste Disposal at Tec hnical 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 (RSW D) Records from TA-50 Documenting TA-21 Repackaged Waste, various dates

M020, RSWD/TWSR Records fo r LA-MSG04.001, various dates

Memorandum from M.F. Ramirez to NTPC Reco rds 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, Re vision 24, CCP Reconciliation of DQOs and Reporting Characterization Data, Attachme nt 2 – CCP Waste Stream Profile Form (Example), Waste Stream LA-MSG04.001, Re vision 0, June 19, 2013; Characterization Information Summary, WSPF No. LA-MSG04.001, Lo t 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 Di sposal 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 Suppor ting Pu-239 Defense Re lationship, TWCP17036, July 8, 2003

C005, Memo to K. Hargis re: Transfer Planning Le tter 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-Ow ned Sealed Sources, T. Feske, TWCP-10113, September 12, 2002

C066, Interview of Jim Matzkev and Jerry McAl pin 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 Spr eadsheet, 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 Spr eadsheet, 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 Char acterization 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, Attach ment 1 – CCP Nonconforman ce Report (NCR), NCR-LANL3637-11, Revision 0, Originated October 6, 2011, Closed May 21, 2012

CCP-QP-005, Revision 23, Attach ment 1 – CCP Nonconforman ce Report (NCR), NCR-LANL0587-13, Revision 1, Originated August 14, 2013, Closed September 17, 2013

CCP-TP-005, Revision 24, CCP Acceptable Knowle dge Documentation, Attachment 6 – Waste Form, Waste Material Parameters, Prohi bited Items, and Packaging, July 18, 2012

CCP-TP-005, Revision 26, CCP Acceptable Knowle dge Documentation, Attachment 8 – Waste Containers List, October 29, 2013

CCP-TP-005, Revision 26, CCP Acceptable Know ledge Documentation, Attachment 7 – Radionuclides, November 20, 2013, including M 133, 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 Revisi ons 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 Know ledge Documentation, Attachment 1 – Acceptable Knowledge Documentat ion Checklist, October 30, 2013

CCP-TP-005, Revision 26, CCP Acceptable Know ledge 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 Discre pancy Resolution –Example Form, various

dates

CCP-TP-005, various revisions, CCP Acceptable Knowledge Documentation, Attachment 13 –

CCP Waste Stream Characterization Ch ecklist – Example Form, various dates

Characterization BDR LA12- OSR-CH-054, January 2, 2013

Characterization BDR LA 13-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 an d PuBe Neutron Test Sources (UCNI), J. Foster, TWCP-05634, March 1, 1991

D023, WIPP Eligibility Determinat ion of U.S. Army Research Laboratory Pu-239 Fission Foils, S. Leonard, TWCP-25636, June 1, 1999

D025, Transuranic Waste Defense Determina tion Approval Forms, Joel Grimm, NNSA, February 17, 2006

D030, Transuranic Waste Defense Determinatio n Approval Forms, Waste Stream LA-OS-NS04, Julia Whitworth, P210-2296, various dates

D031, Waste Determination of Encapsulated Ra dioactive Sources Containing Small Quantities of Lithium, M.W. Pearson, Julia Whitwort h, Timothy Burns and John U. Moon, LA-UR-08- 03351, April 1, 2008

DR001, Discrepancy Resolution re: Difference be tween NMMSS and Shipping Data for Seven LLNL Sealed Sources, J. Whitw orth, 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 Pu8B e47-A&B from SRS, J. Whitworth, TWCP25633, June 15, 2005

DR005, Discrepancy Resolution re: Pu Valu e on Source M-1228, J. Whitworth, TWCP-24926, May 3, 2005

DR006, Discrepancy Resolution re: Pu Valu e 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 Da tabase, J. Whitworth, DR010, August 8, 2005

DR011, Discrepancy Resolution of Manufacturing Orders for Am Be Neutron Sources Made by Monsanto Research Corp. for Schlumberger We ll 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 Base d 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 Se aled 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-OS R-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-OS R-VE-018 and Characterization BDR LA13-

OSR-CH-18 Drums: LAD0000066719 and LA 00000067500, LA-UR-13-27552, various dates

M307, AK Documentation for VE BDR LA13-OS R-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-OS R-VE-020 and Characterization BDR LA13- OSR-CH-020 Drum: LA00000062756, LA-UR-13-27855, various dates

Memorandum from R.R. Chavez to CCP Record s Custodian: Transmittal of Waste Stream

Profile Forms for Waste Streams LA-M HD01.001, 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 Characteriza tion Data, CCP Waste Stream Profile Form, Waste Stream LA-OS-00-01.001, Revision 0, June 29, 2005; Char acterization Information Summary, WSPF No. LA-OS-00-01.001, Lot 1, June 23, 2005; Summa tion of Aspects of AK Summary Report:

LA-OS-00-01.001

Memorandum from S.M. Peterman to C.A. Step zinski: Acceptable Know ledge Accuracy Report: Los Alamos National Laboratory Waste Stream Number LA-OS-00-01.0 01, WIPP Eligible Offsite Recovery Sealed Sources, Lots 22 through 36, March 30, 2011, including CCP-TP-005, Revision 19, CCP Acceptable Knowledge Docume ntation, Attachment 14 – CCP Acceptable Knowledge Accuracy Report – Example Fo rm, 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 Accepta ble 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 Nu mber LA-OS-00-01.001, WIPP Eligible Off-site Resources Sealed Sources, Lots 47 through 78, June 27, 2013, includi ng CCP-TP-005, Revision 24, CCP Acceptable Knowledge Documentation, Attachment 14 – CCP Acceptable Knowledge Accuracy Report – Example Form, Waste Stre am LA-OS-00-01.001, Lots 47 through 78, June 27, 2013; CCP-TP-005, Revision 26, CCP Acceptabl e Knowledge Documentation, Attachment 14 – CCP Acceptable Knowledge Accuracy Repo rt – 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 S ealed Sources), Lots 37 through 46, July 11, 2012, including CCP-TP-005, Revision 24, CCP Accepta ble Knowledge Documentation, Attachment 14 – CCP Acceptable Knowledge Accuracy Repo rt – 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), CC P-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 Effi ciency Neutron Counter (SuperHENC) Using NDA 2000, Revision 2, August 26, 2013

CCP-TP-063, CCP Operating the High Effici ency Neutron Counter Using NDA 2000, Revision 15, August 23, 2013

CCP-TP-064, CCP Calibrating the High Efficien cy Neutron Counter and the Super High Efficiency Neutron Counter Us ing NDA 2000, Revision 7, August 23, 2013

CCP-TP-076, CCP Operating the Mobile IS OCS Large Container Counter Using NDA 2000, Revision 0, May 16, 2013

CCP-TP-077, CCP Calibrating the Mobile ISOC S 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 M obile 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 Confir mation, 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 Indi viduals, November 14, 2013, 3:12 p.m.

LANL-HENC2-TMU-101, Total Measurement Uncer tainty for the HENC #2 with Integral Gamma Spectrometer, Revision 0, April 10, 2006

LANL-NDA-1003-Lead-Lined, Lead-Lined Ca libration Report for the HENC #2 Including Passive Neutron and Gamma Spect rometer, Revision 3, June 3, 2010

LANL-SHENC3-NDA-1004, Calibration Report for the SuperHENC at Los Alamos National Laboratory Including Passive Neutron and Gamm a Spectrometer Calibration and Confirmation, Revision 4, June 15, 2012

MCS-HENC#1-NDA-1002, Calibration Report for th e HENC #1 Including Passive Neutron and Gamma Spectrometer Calibration and C onfirmation, Revision 6, October 3, 2007

MCS-HENC#1-NDA-1005-Lead-Lined, Lead-Lin ed 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, Oct ober 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 Qualific ation Plan, Revision 35, June 6, 2013

CCP-TP-028, CCP Radiographic Test Drum and Training Container C onstruction, Revision 8, June 17, 2013

CCP-TP-113, CCP Standard C ontact-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 Examin ation and Packaging, Revision 6, June 6, 2013

CCP-QP-005, CCP TRU Nonconforming Item Repor ting and Control, Revision 23, June 25,

2013

NDE Training Container Invent ory 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 Individua ls, dated between 2012 and 2013

Qualification records for selected VE and RTR personnel

RTR operator training DVDs a nd 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 ManagementD-1ATTACHMENT D.1: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: WASTE STREAM LA-MHD01.001EPA Inspection No.: LANL-CC-2013Waste Stream: LA-MHD01.001Inspection Date: November 19–21, 2013Technical ElementsObjective Evidence and CommentsAK-1:Do AK, training and nonconformanceprocedures adequately reflect the requirements of40 CFR 194?Yes. This report and its attachments provide examples of adequate implementation of each listed document at thelocation 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–NCRs.CCP-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, 8.AK-2:Is the AK characterization process,including AK assembly, compilation andverification, adequate?Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, compilation and verification.a.Attachment 1, Revision 24, Acceptable Knowledge Documentation Checklist: Complete.b.Attachment 2, Revision 23, Record of Communication: Completed when appropriate (e.g., Reference C124).c.Attachment 3s, various revisions, Acceptable Knowledge Source Document Summary: Attached to all inspectedsource documents.d.Attachment 4, Revision 24, AcceptableKnowledge 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 Items, and Packaging: Complete.Initially provided as Revision 23 when should have been Revision 24; was revised during inspection. It andassociated WMP analysis memorandumsupport estimates in AKSR and discussed in AK checklist item AK-4b.g.Attachment 7, Revision 26, Radionuclides: Complete. Revised during inspection to incorporate most currentversion of NDA memorandum. Supports estimates given in AKSR and discussed in AK checklist item AK-4c. Seealso discussion in checklist item AK-8.h.Attachment 8, Revision N/A, Waste Containers List: Complete, dated 11/13/2012. LANL-CCP created a differentformat for Attachment 8; this format includes all required components. Revised periodically to maintain completelist of containers; revised during inspection (ink correction)to correct number of waste containers in waste stream.Add-container memoranda (i.e., Reference C225) support evaluations of containers prior to adding to the AKtracking spreadsheet and Attachment 8.i.Attachment 9 is no longer required and attachment number is reserved for future use.j.Attachment 10, Revision 24, Acceptable KnowledgeRe-evaluation Checklist: Complete. There were sixAttachment 10s written in 2012: one to change radionuclide range, four to remove containers that were <50%heterogeneous debris, one to return containers that had been erroneously removed due to WMC misidentification.In 2013, started appending to DRs and not storing separately.k.Attachment 11, Revision 24, Acceptable Knowledge Source Document Discrepancy Resolution: Completed asappropriate; see AK checklist item AK-6.l.Attachment 12, Example Form and Content Guide for AK Summary Reports: Reference tool, not a form forcompletion; see review of completed AKSR in AK checklist item AK-4.m.Attachment 13, various revisions, CCP Waste Stream Characterization Checklist: Completed as appropriate.n.Attachment 14, various revisions, CCP Acceptable Knowledge Accuracy Report: Completed as appropriate; seeAK checklist item AK-7.o.Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: Notapplicable to this waste stream.D-2EPA Inspection No.: LANL-CC-2013Waste Stream: LA-MHD01.001Inspection Date: November 19–21, 2013AK-3:Are waste containers traceable fromretrieval through CCP’s EPA-approvedcharacterization process?Yes. Tracked Container Nos. 91027, S802581 and 66621.91027: daughter drum from container S811897. Per the repackaging spreadsheet, S811897 was repackaged into 2 55-gallon drums, including 91027, on 3/12/2012. S811897 was generated 12/08/1981 and contained debris from PF-4.AKE stated that S811897 was added to AKTSS on 4/1/2008. 91027 was added to AKTSS 4/12/2012 (Add ContainerMemorandum not provided). Physical characterization: LA-HERTR-12-022 resulted in NCR-LANL-0615-12,3/16/2012, for prohibited item; remediated 4/12/2012 and re-characterized in LA-HERTR-12-0034, 4/13/2012.Radiological characterization: 3LANDA0059, assay on 5/4/2012 resulted in NCR-LANL-1023-12, 9/19/2012, for232U outside expected AK bounds. AK was revised, NDA determined acceptable, NCR closed 9/20/2012. Drum No.91027 is included inLA-MHD01.001, Lot 323. Per AKtracking spreadsheet, container was emplaced at WIPP facilityon 10/3/2012. (References AKSR, Rev. 12; AKTSS; CIS signed 9/20/2012, DR048 and M273)S802581: generated 2/15/1980 and indicated to contain homogenous solids from PF-4. Was initially added to LACIN01.001 but removed 8/30/2012 after RTR identified that the container was more than 50% debris. Added to LAMHD01.001 10/5/2012 (Add Container Memorandum not provided). Physical characterization: LA-RTR2-12-0132,11/26/2012, rejected for impenetrable item(s); reran through HERTR 3/23/13 (Reference LA-HERTR-13-0030).Radiological characterization: 1LANDA1757, assay on 4/24/13. Drum No. S802581 is included in LA-MHD01.001,Lot 380. Per AK tracking spreadsheet, container not yet emplaced at WIPP facility. (References CIS signed5/21/2013, 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-MHD01.001 4/6/2012. Physicalcharacterization: LA-RTR2-12-0113, 9/24/2012. Radiological characterization: 2LANDA1059, assay on 9/26/2012.Drum No. 66621 is included in LA-MHD01.001, Lot 332. Per AKtracking spreadsheet, container was emplaced atWIPP facility on 12/8/2012. (References Add ContainerMemorandum dated 4/6/2012, CIS signed 11/6/2012 andM275)AK-4:Does the AK summary report includesufficient information, supported by appropriatesource documents, to support the statementsbelow?a.All waste within the waste stream wasgenerated from a single process/activity.b.All waste within the waste stream is similar inmaterial and physical form.c.All waste within the waste stream has similarradiological properties.d.All of the waste in the waste stream is defensein origin.e.None of the waste in the waste stream is highlevel waste.f.None of the waste in the waste stream is spentnuclear 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 through future operations. Therewere distinctly different operations in PF-4, but the wasteswere historically packaged indiscriminately and cannotbe separated into separate waste streams. Operations wereprimarily in two categories:extraction and recovery ofPu (primarily239Pu and240Pu) and238Pu heat source programs (References C144, C145, C192, C194, C197, C220,D025, D045, M019, M216, M217, M219 and M222).b.LA-MHD01.001 is a heterogeneous debris waste stream consisting of a variety of debris, including metal, glass,graphite, plastic, cellulosic materials, rubber and filters. Each container may also contain some hydroxidecake/filter materials, salts and ash residues, but less than 50% by volume (References D025, D041, D084, DR001,DR005, M019, M156, M157, M158, M216, M217, M219, M222, M224, M226, M238, M273, M274 and M275).c.All of the waste is from operations related to processing239Pu,240Pu and238Pu. The predominate radionuclidesexpected in the waste stream are239Pu and238U, while over 95% of the total activity is from238Pu,239Pu and241Pu.U is not usually part of the Pu MTs handled in PF-4, but238U was introduced into the process as special material(References C125, C186, C194, C209, C219, C222, D025, D073, D074, D076, D080, D083, M019, M156, M159,M216, M217, M219, M222, M238,M273, M274, M275 and M309).d.The extraction and recovery of Pu operations were in direct support of LANL’s weapon’s development R&Dprogram.238Pu operations were both defense and non-defense related; however, all of the238Pu was irradiated inthe defense production K Reactor at SRS. Additionally, all of the PF-4 wastes were comingled regardless ofdefense or non-defense origin and cannot be separated(References C040, C057, C082, C192, C204, C212, D041D-3EPA Inspection No.: LANL-CC-2013Waste Stream: LA-MHD01.001Inspection Date: November 19–21, 2013and M308).e.LA-MHD01.001 contains only wastes associated withR&D/fabrication and associated recovery, facility andequipment maintenance, D&D, waste repackaging, and below-grade retrieval operations. These operations did notinvolve separation or reprocessing ofconstituent elements from reactor fuel,and, therefore, the waste is not HLW(References D023, M015, P094 and P118).f.LA-MHD01.001 does not contain irradiated fuel elements withdrawn from a reactor, or pieces of such irradiatedfuel elements. Therefore, the waste stream does not contain SNF(References D023, M015 and P118).AK-5:Are the waste stream profile form andrelated attachments complete andadequate/accurate? Related attachments include:a.Characterization information summaryb.Summation of aspectsYes. WSPF, Revision 1: dated 5/22/2013. WSPF is complete; package includes complete CIS for Lot 368 containersand complete summation of aspects based on the current-at-the-time AKSR (CCP-AK-LANL-006, Revision 12). TheWSPF was revised to add content codes.AK-6:Are nonconformances and discrepancyresolutions documented appropriately?Yes. NCR-LANL-0011-13: containers RTR’d as homogenous; NCR open pending AK reevaluation to movecontainers out of waste stream.NCR-LANL-0713-12: containers RTR’d as homogenous; NCR closed, containers rejected and reassigned to LACIN01.001.DR032, DR033, DR035, DR040, DR042, DR048 and DR049 were written in 2012, six are for removal of containers<50% heterogeneous debris.AK-7:Is the AK accuracy report technicallyadequate? Has it been updated annually?Yes. The 2011 report was written on Attachment 14, Revision19. It should have been written using Revision 21. 2013report was written on Attachment 24. It should have been written using Revision 25. LANL-CCP investigated andfound that all of one SPM’s 2013 Attachment 14s werewritten using the wrong Revision. NCR-LANL-0734-13 waswritten for all 2013 Attachment 14s and three 2011 Attachment 14s. EPA reviewed the revised Attachment 14s.AK-8:Is AK-NDA communication adequatelydocumented?Yes. AK-NDA communication documented in CCP-TP-005, Revision 26, Attachment 7, dated 11/20/2013, and theattached NDA memorandum signed 4/22/2010. Attachment 7was modified to change theexpected percentages. Theexpected predominate radionuclides did not change; therefore, the NDA memorandum was not revised. Attachment 7states that it supersedes the table in the NDA memorandum. No single isotopic distribution is applicable to the wholewaste stream; therefore the EA will acquire container-specific information if AK is to be applied in radiologicalcharacterization. Attachment 7 was modified during inspection to include the 2010 NDA memorandum.AK-9:Has notification of applicable T2 changesbeen provided to EPA as required in the LANLCCP CH tiering table?Yes. EPA tracking began with 4thquarter FY 2009. Tier 2 change notification required for:a.AK accuracy reports (annually, at a minimum) – Received correct notificationfor 2011, 2012 and 2013 reports.b.AK reassessment memoranda and combination of waste streams – N/A. No additional waste streams have beencombined with LA-MHD01.001.c.AK-VE memoranda – N/A. Not applicable to LA-MHD01.001.d.AK-NDA memoranda – revised March 2010 and signed4/22/2010. EPA received correct notification in 3rdquarter FY 2010 T2 report.e.AKSRs – EPA received T2 notifications for Revisions 10 (3rdquarter FY 2010), 11 (3rdquarter FY 2011) and 12(1stquarter FY 2013). All other revisions werebefore EPA started tracking T2 notifications.f.WSPFs, new, revised and CNs – EPA received T2 notification for Revision 1 (3rdquarter FY 2013).D-4ATTACHMENT D.2: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: WASTE STREAM LA-MSG4.001EPA Inspection No.: LANL-CC-2013Waste Stream: LA-MSG04.001Inspection Date: November 19–21, 2013Technical ElementsObjective Evidence and CommentsAK-1:Do AK, training and nonconformanceprocedures adequately reflect the requirements of40 CFR 194?Yes. See Attachment D.1, AK checklist item AK-1.AK-2:Is the AK characterization process,including AK assembly, compilation andverification adequate?Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, compilation and verification.a.Attachment 1, Revision 24, Acceptable Knowledge Documentation Checklist: Complete; revised since last review.b.Attachment 2, Revision 23, Record of Communication: Completed when appropriate (e.g., Reference C035).c.Attachment 3, various revisions, Acceptable Knowledge Source Document Summary: Completed for all inspectedsource documents. The Attachment 3sfor C037 and C038 were generated since the last review of this wastestream. Both were appropriately completed using Revision 24 of the form.d.Attachment 4, Revision 24, Acceptable Knowledge Information List: Revised since the last evaluation to addC038.e.Attachment 5, Hazardous Constituents:Outside EPA’s purview; not reviewed.f.Attachment 6, Revision 24, Waste Form, Waste Material Parameters, Prohibited Items, and Packaging: Complete.It and associated WMP analysis memorandum support estimates in AKSR and discussed in checklist Item (4b).g.Attachment 7, Revision 26, Radionuclides: Complete; was revised during the inspection to correct the expected241Am range. Supports estimates given in AKSR and discussed in AK checklist item AK-4c. See also discussion inchecklist item AK-8.h.Attachment 8, Revision 24, Waste Containers List: Has not been updated since the last evaluation; however,during the inspection LANL-CCP identified that the wrong version of Attachment 8 was in Records. This wasremediated during the inspection. C038 was added tothe record as an add-container memorandum for oneadditional SWB of soil waste.i.Attachment 9 is no longer required and attachment number is reserved for future use.j.Attachment 10, Revision 24, Acceptable Knowledge Re-evaluation Checklist: Checklist has not been revised andadditions have not been necessary since the initial evaluation. DR was completed as indicated in Attachment 10.k.Attachment 11, Revision 24, Acceptable Knowledge Source Document Discrepancy Resolution: No DRs havebeen generated since the last evaluation (see AK checklist item AK-6).l.Attachment 12, Example Form and Content Guide for AK Summary Reports: Reference tool, not a form forcompletion; see review of completed AKSR in AK checklist item AK-4.m.Attachment 13, Revisions 24 and 25,CCP Waste Stream Characterization Checklist: Completed for Lots 1 and 2.n.Attachment 14, CCP Acceptable Knowledge Accuracy Report: Not yet completed;see AK checklist item AK-7.o.Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: Notapplicable to this waste stream.AK-3:Are waste containers traceable fromretrieval through CCP’s EPA-approvedcharacterization process?Yes. Tracked Container No. 89988, which is a daughter drum from Container no. S813240. Per the repackagingspreadsheet, S813240 was repackaged into 7 55-gallon drums, including 89988, on 9/13/2011. S813240 was generated1/29/1981 and contained soil from the tunnel under room 213. 89988 was added to waste stream on originalAttachment 8. Physical characterization: LA-RTR-11-0116, examined on 9/26/2011. Rad. characterization:2LANDA0878, examined on 9/27/2011; NCR-LANL-3637-11 for mismatch between NDA results and AK wasD-5EPA Inspection No.: LANL-CC-2013Waste Stream: LA-MSG04.001Inspection Date: November 19–21, 2013resolved by revising AK and closed on 5/21/2012. Drum No. 89988 is included in LA-MSG04.001, Lot 2. Per AKtracking spreadsheet, container was emplaced at WIPP facility on 7/11/2013. (References CIS signed 6/27/2013 andM020)AK-4:Does the AK summary report includesufficient information, supported by appropriatesource documents, to support the statementsbelow?a.All waste within the waste stream wasgenerated from a single process/activity.b.All waste within the waste stream is similar inmaterial and physical form.c.All waste within the waste stream has similarradiological properties.d.All of the waste in the waste stream is defensein origin.e.None of the waste in the waste stream is highlevel waste.f.None of the waste in the waste stream is spentnuclear fuel.Yes. CCP-AK-LANL-010, Revision 6, contains all required items and, except for WMP estimations, was notsignificantly revised since the last evaluation.a.LA-MSG04.001 was produced by D&D ofTA-21 DP West facility. DP West opened in 1945 as the world’s firstindustrial Pu processing facility. Over the years, thefacility shifted to R&D and finally closed in 1978. D&Defforts since that time have generated containers of contaminated soils from spills or the removal of acid wells andlines, tunnels below buildings, MDAs, tank systems, and various locations in the immediate vicinity of DP West(References C033, D006, D035, D069, M003, M004 and P036).b.LA-MSG04.001 is composed primarilyof soils/gravels. The WMP estimates were recalculated since the lastreview. The new estimates are based on RTR data for Lot1 containers with additional WMPs identified as per theAK record (References Attachment 6& memo and BDR No. LA-RTR2-11-0116).c.Primary radionuclides expectedin the waste stream are238U and239Pu (by mass), with over 95% of theradiological activity expected to be contributed by239Pu. All of DP West Facility’s operations are expected to havecontributed to the soil contamination and therefore LA-MSG04.001’s radiological properties. (References D069and M008).d.DP West operations recovered Pu from residues and scraps from around the DOE complex, contributing todefense nuclear materials production and defense nuclear waste and materials byproducts management. All238Pupassed through the same gloveboxes, so all wastes are considered comingled; defense and non-defense wastes areinseparable (References D059 and M012).e.LA-MSG04.001 wastes are from D&D of the DP West facility, which did not involve reprocessing or separatingthe 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 irradiated fuel elements(References D059 and BDR No. LA-RTR2-11-0116).AK-5:Are the waste stream profile form andrelated attachments complete andadequate/accurate? Related attachments include:a.Characterization information summaryb.Summation of aspectsYes. WSPF, Revision 0: dated 6/19/2013. WSPF is complete; package includes complete CIS for Lot 1 containers andcomplete summation of aspects based on the current-at-the-time AKSR (CCP-AK-LANL-004, Revision 1).AK-6:Are nonconformances and discrepancyresolutions documented appropriately?Yes. NCR-LANL-0681-13 is new since the last evaluation.It was appropriately initiated and was still awaiting finaldisposition at time of inspection. LANL-CCP AKEs indicated that disposition will include an evaluation to determineif the NDA results change the predominate radionuclides – no change to AK if no change to predominateradionuclides. LANL-CCP AKEs are also planning to revise the NDA memo to remove the requirement toautomatically write an NCR if the measured radionuclides are outside the expected range since this was removed fromprocedure CCP-TP-005.No DRs have been written for LA-MSG04.001 since the previous evaluation.AK-7:Is the AK accuracy report technicallyadequate? Has it been updated annually?N/A. LANL-CCP has not yet written an AK accuracy reportfor LA-MSG04.001. The waste stream was certified byCBFO in June 2013. The first AK accuracy evaluation for this waste streamwill be conducted in June 2014.D-6EPA Inspection No.: LANL-CC-2013Waste Stream: LA-MSG04.001Inspection Date: November 19–21, 2013AK-8:Is AK-NDA communication adequatelydocumented?Yes. AK-NDA communication documented in CCP-TP-005, Revision 26, Attachment 7, dated 11/19/2013, and theattached NDA memorandum dated 5/12/2012. Attachment 7 was revised during this inspection to correct the241Amexpected range. The NDA memorandum has not been revised since the last evaluation; the modification to Attachment7 did not affect the contents of the NDA memorandum.AK-9:Has notification of applicable T2 changesbeen provided to EPA as required in the LANLCCP CH tiering table?Yes. EPA tracking began with 4thquarter FY 2009. Tier 2 change notification required for:a.AK accuracy reports (annually, at a minimum) – N/A. There have been no accuracy reports for this waste stream.b.AK reassessment memoranda and combination of wastestreams – N/A. Not applicable to LA-MSG04.001.c.AK-VE memoranda – N/A. Not applicable to LA-MSG04.001.d.AK-NDA memoranda – EPA received notification of the revised NDA memorandum in the 4thquarter FY 2012T2 report. NDA memorandum was revised 5/12/2012, butnot signed until August 2012. Therefore notification inthe 4thquarter was correct.e.AKSRs – The LANL-CCP requirement to submit T2 notification for all AKSR revisions was implemented12/12/2012 (EPA approval No. A-98-49; II-A4-168). T2 notification provided for Revision 5 (3rdquarter FY2012) and Revision 6 (2ndquarter FY 2013).f.WSPFs, new and updated – The WSPF initial issuance was in June 2013 and T2 notification happenedappropriately with the 3rdquarter report.D-7ATTACHMENT D.3: AK CONTINUED COMPLIANCE INSPECTION CHECKLIST: WASTE STREAM LA-CIN01.001EPA Inspection No.: LANL-CC-2013Waste Stream: LA-CIN01.001Inspection Date: November 19–21, 2013Technical ElementsObjective Evidence and CommentsAK-1:Do AK, training and nonconformanceprocedures adequately reflect the requirements of40 CFR 194?Yes. See Attachment D.1, AK checklist item AK-1.AK-2:Is the AK characterization process,including AK assembly, compilation andverification, adequate?Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, compilation and verification.a.Attachment 1, Revision 24, Acceptable Knowledge Documentation Checklist: Complete.b.Attachment 2, Revision 23, Record of Communication: Completed when appropriate (e.g., Reference C124).c.Attachment 3s, various revisions, Acceptable Knowledge Source Document Summary: Attached to all inspectedsource documents.d.Attachment 4, Revision 24, AcceptableKnowledge 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 Items, and Packaging: Complete.Initially provided as Revision 23 when should have been Revision 24; was revised during inspection. It andassociated WMP analysis memorandumsupport estimates in AKSR and discussed in AK checklist item AK-4b.g.Attachment 7, Revision 26, Radionuclides: Complete. Supports estimates given in AKSR and discussed in AKchecklist item AK-4c. See also discussion in checklist item AK-8.h.Attachment 8, Revision N/A, Waste Containers List: Complete. LANL-CCP created a different format forAttachment 8; this format includes all required components. Revised periodically to maintain complete list ofcontainers. Add-container memoranda (i.e., Reference C234)support evaluations of containers prior to adding tothe AK tracking spreadsheet and Attachment 8.i.Attachment 9 is no longer required and attachment number is reserved for future use.j.Attachment 10, Revision 24, Acceptable Knowledge Re-evaluation Checklist: Complete. Three Attachment 10swere written in 2012, all to remove containers that were >50% heterogeneous debris.k.Attachment 11, various revisions, Acceptable Knowledge Source Document Discrepancy Resolution: Completedas appropriate; see AK checklist item AK-6.l.Attachment 12, Example Form and Content Guide for AK Summary Reports: Reference tool, not a form forcompletion; see review of completed AKSR in AK checklist item AK-4.m.Attachment 13, various revisions, CCP Waste StreamCharacterization Checklist: Completed as appropriate.n.Attachment 14, various revisions, CCP Acceptable Knowledge Accuracy Report: Completed as appropriate; seeAK checklist item AK-7.o.Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: Notapplicable to this waste stream.AK-3:Are waste containers traceable fromretrieval through CCP’s EPA-approvedcharacterization process?Yes. Tracked Container Nos. 53769, 54268 and S833076.53769: generated 9/2/1987 and contained homogenous solids from PF-4 (Los Alamos Certified Waste StorageRecord). It was overpacked into an 85-gal. drum, retaining the same drum number, on 8/11/1993. Added to LACIN01.001 in initial waste stream Attachment 8. Physical characterization: LA-HERTR-12-0065, 7/21/2012.Radiological characterization: 2LANDA1021, assay on 7/23/2012. Drum No. 53769 is included in LA-CIN01.001,Lot 19. Per AK tracking spreadsheet, container was emplaced at WIPP facility on 9/16/2012. (References CIS signedD-8EPA Inspection No.: LANL-CC-2013Waste Stream: LA-CIN01.001Inspection Date: November 19–21, 20138/22/2012 and revised 12/10/2012 and M219)54268: generated 4/14/1992 and contained homogenous solids from PF-4. Added to LA-CIN01.001 in initial wastestream Attachment 8. Physical characterization: LA-HERTR-13-0058, 5/17/2013. Radiological characterization:2LANDA1208, assay on 8/8/2013. Drum No. 54268 was not yet included in a lot at time of inspection. Per AKtracking spreadsheet, container has not been emplaced at WIPP facility. (Reference M219)S833076: generated 5/17/1983 andcontained leached solids from PF-4. Added to LA-CIN01.001 in initial wastestream Attachment 8. Physical characterization: LA-HERTR-12-0082, 8/15/2012. Radiological characterization:1LANDA1621, assay on 8/16/2012. Drum No. S833076 is included in LA-CIN01.001, Lot 41. Per AK trackingspreadsheet, container was emplaced atWIPP facility on 3/14/2013. (ReferencesCIS signed 12/28/2012 and revised1/29/2013 and M238)AK-4:Does the AK summary report includesufficient information, supported by appropriatesource documents, to support the statementsbelow?a.All waste within the waste stream wasgenerated from a single process/activity.b.All waste within the waste stream is similar inmaterial and physical form.c.All waste within the waste stream has similarradiological properties.d.All of the waste in the waste stream is defensein origin.e.None of the waste in the waste stream is highlevel waste.f.None of the waste in the waste stream is spentnuclear fuel.Yes. CCP-AK-LANL-006, Revision 12, contains all required items. See Attachment D.1, AK checklist item AK-4.AK-5:Are the waste stream profile form andrelated attachments complete andadequate/accurate? Related attachments include:a.Characterization information summaryb.Summation of aspectsYes. WSPF, Revision 0: dated 6/9/2010. WSPF is complete; package includes complete CIS for Lot 1 containers andcomplete summation of aspects based on the current-at-the-time AKSR (CCP-AK-LANL-006, Revision 10).AK-6:Are nonconformances and discrepancyresolutions documented appropriately?Yes. NCR-LANL-0618-12, Rev. 1: RTRidentified leaded rubber gloves, which were not explicitly called out asexpected. AK determined gloves accountedfor. NCR closed, container use-as-is.NCR-LANL-1492-12: RTR identified waste packaging not in AK; standing order modified to clarify possiblepackaging configurations after repackaging. NCR closed, container use-as-is.DR043–DR046 written in 2012 for removal of containers>50% heterogeneous debris. LANL-CCP has started fastscanning questionable containers to verify WMC. A DRwill always be written to move containers between wastestreams, but doing the initial WMC confirmation by fast scan avoids needing an NCR.D-9EPA Inspection No.: LANL-CC-2013Waste Stream: LA-CIN01.001Inspection Date: November 19–21, 2013AK-7:Is the AK accuracy report technicallyadequate? Has it been updated annually?Yes. The 2011 report was written on Attachment 14, Revision19. It should have been written using Revision 21. 2013report was written on Attachment 24. It should have beenwritten using Revision 25. See discussion in AttachmentD.1, AK checklist item AK-7.AK-8:Is AK-NDA communication adequatelydocumented?Yes. AK-NDA communication documented in CCP-TP-005, Revision 26, Attachment 7, dated 11/6/2013, and theattached NDA memorandum dated 12/12/2012. Attachment 7 was modified to include the current NDAmemorandum, which updated the descriptions of AK usage and NDA capabilities and updated the table of expectedradionuclides.AK-9:Has notification of applicable T2 changesbeen provided to EPA as required in the LANLCCP CH tiering table?Yes. EPA tracking began with 4thquarter FY 2009. Tier 2 change notification required for:a.AK accuracy reports (annually, at a minimum) – Received correct notification for 2011, 2012 and 2013 reports.b.AK reassessment memoranda and combination of wastestreams – N/A. Not applicable to LA-CIN01.001.c.AK-VE memoranda – N/A. Not applicable to LA-CIN01.001.d.AK-NDA memoranda – Was revised December 2012, EPA did not receive notification of revision in any T2report.e.AKSRs – EPA received T2 notifications for Revisions 10 (3rdquarter FY 2010), 11 (3rdquarter FY 2011) and 12(1stquarter FY 2013). All other revisions werebefore EPA started tracking T2 notifications.f.WSPFs, new, revised and CNs – EPA received T2 notification for Revision 1 (3rdquarter FY 2013).D-10ATTACHMENT D.4: AK CONTINUEDCOMPLIANCE INSPECTION CHECKLIST: WASTE STREAM LA-OS-00-01.001EPA Inspection No.: LANL-CC-2013Waste Stream: LA-OS-00-01.01Inspection Date: November 19–21, 2013Technical ElementsObjective Evidence and CommentsAK-1:Do AK, training and nonconformanceprocedures adequately reflect the requirements of40 CFR 194?Yes. See Attachment D.1, AK checklist item AK-1.AK-2:Is the AK characterization process,including AK assembly, compilation andverification, adequate?Yes. Completed CCP-TP-005 attachments provide objective evidence of AK assembly, compilation and verification.a.Attachment 1, Revision 26, Acceptable Knowledge Documentation Checklist: Complete; revised since last review.b.Attachment 2, Revision 23, Record of Communication: Completed when appropriate (e.g., Reference C066).c.Attachment 3, various revisions, Acceptable Knowledge Source Document Summary: Completed for all inspectedsource documents.d.Attachment 4, Revision 26, Acceptable Knowledge Information List: Complete; revised since the last inspection.e.Attachment 5, Hazardous Constituents:Outside EPA’s purview; not reviewed.f.Attachment 6, Revision 24, Waste Form, Waste Material Parameters, Prohibited Items, and Packaging: Complete.It and associated WMP analysis memorandum support estimates in AKSR and discussed in AK checklist itemAK-4b.g.Attachment 7, Revision 26, Radionuclides: Complete. Includes a radiological characterization memorandumbecause NDA is not used. Revised during inspection toinclude radionuclide activitycontributions. Supportsestimates given in AKSR and discussed in AK checklistitem AK-4c. See also discussion in checklist item AK-8.h.Attachment 8, Revision 26, Waste Containers List: Complete. Revised periodically to maintain complete list ofcontainers. Add-container memoranda (i.e., Reference C076)support evaluations of containers prior to adding tothe AK tracking spreadsheet and Attachment 8.i.Attachment 9 is no longer required and attachment number is reserved for future use.j.Attachment 10, Acceptable KnowledgeRe-evaluation Checklist: N/A. Thereare no Attachment 10s associatedwith LA-OS-00-01.001.k.Attachment 11, various revisions, Acceptable Knowledge Source Document Discrepancy Resolution: Completedas appropriate (see AK checklist item AK-6).l.Attachment 12, Example Form and Content Guide for AK Summary Reports: Reference tool, not a form forcompletion; see review of completed AKSR in AK checklist item AK-4.m.Attachment 13, various revisions, CCP WasteStream Characterization Checklist: Completed.n.Attachment 14, various revisions, CCP Acceptable Knowledge Accuracy Report: Completed; see AK checklistitem AK-7.o.Attachment 15, CCP TRU Waste Correlation and Surrogate Summary Form: Notapplicable to this waste stream.AK-3:Are waste containers traceable fromretrieval through CCP’s EPA-approvedcharacterization process?Yes. Tracked Container Nos. 64589 and 66729.64589: Container was generated and closed on 8/10/2010, and initially added to waste stream on 3/28/2013. NCRLANL-0587-13, Rev. 1, written8/14/2013 because containerswere added and characterized prior to having a defensedetermination in place. Containerswere removed from waste stream 6/11/2013; defense determination signed8/2/2013; containers re-added to AK tracking spreadsheet 8/6/2013. Physical characterization: LA13-OSR-VE-007during packaging 8/10/2010. Radiological characterization: LA13-OSR-CH-007, 3/28/2013. Container No. 64589 isD-11EPA Inspection No.: LANL-CC-2013Waste Stream: LA-OS-00-01.01Inspection Date: November 19–21, 2013included in LA-OS-00-01.001, Lot 82. Per AK tracking spreadsheet, container was emplaced at WIPP facility on10/2/2013. (References C074; C076; CIS signed 8/23/2013 and NCR-LANL-0587-13, Rev. 1)66729: Container was generated and closed on 11/27/2012, and added to waste stream on 1/3/2013. Physicalcharacterization: LA12-OSR-VE-054 during packaging 11/29/2012. Radiological characterization: LA12-OSR-CH054, 1/2/2013. Container No. 66729 is included in LA-OS-00-01.001, Lot 72. Per AK tracking spreadsheet, containerwas emplaced at WIPP facility on 4/28/2013.(References C073 andCIS signed 3/5/2013)AK-4:Does the AK summary report includesufficient information, supported by appropriatesource documents, to support the statementsbelow?a.All waste within the waste stream wasgenerated from a single process/activity.b.All waste within the waste stream is similar inmaterial and physical form.c.All waste within the waste stream has similarradiological properties.d.All of the waste in the waste stream is defensein origin.e.None of the waste in the waste stream is highlevel waste.f.None of the waste in the waste stream is spentnuclear 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 1950s–1970s, AEC and othermanufacturers produced various types of TRU sealed sources to enhance nuclear, medical, industrial, etc. research.The sealed sources are considered “nuclear material” until being declared “waste” after receipt at LANL.(References C002, C004, C005, C006, C066, D003, D004, M001, M031, M133, P001 and P004).b.LA-OS-00-01.001 is a debris waste stream consisting entirely of recovered sealed sources. The waste consists ofsolid, inorganic, actinide metals or metal oxides inprotective metal coverings (References D005, M005 andM133).c.All of the sealed sources were manufactured and have detailed records of their components. NDA is not conductedand radiological characterization is conducted by review of AK. LANL-CCP issued a freeze file for the AKSR toclarify that two primary radionuclides(by activity) in the waste stream are238Pu and241Am (References D031,M001 and M133).d.OSRP recovers defense and non-defense sealed sources. Only the defense sources are in LA-OS-00-01.001. Thesources are defense in origin because they were derived from defense nuclear materials production and byproductsmanagement and they are being recovered to support defense nuclear material securityand safeguards. As a resultof NCR-LANL-0587-13, Rev. 1, AK tracking spreadsheet now identifies which defense determination applies toeach 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 (References M305, M306,M307 and M308).f.LA-OS-00-01.001 contains only sealedsources, which by definition are notspent nuclear fuel (References M305,M306, M307 and M308).AK-5:Are the waste stream profile form andrelated attachments complete andadequate/accurate? Related attachments include:a.Characterization information summaryb.Summation of aspectsYes. WSPF, Revision 0: dated 6/29/2005. WSPF is complete; package includes complete CIS for Lot 1 containers andcomplete summation of aspects based on the current-at-the-time AKSR (CCP-AK-LANL-008, Revision 2).CN #1, dated 12/5/2006: revised current volume generated, modified WMP estimates, etc.CN #2, dated 6/15/2010: revised current volume generated and added projected volume, expanded defense generationcategories listed, modified WMP and radionuclide information to match current waste stream, etc.AK-6:Are nonconformances and discrepancyresolutions documented appropriately?Yes. NCR-LANL-0587-13, Revision 1 is new since the lastinspection. It was appropriately written and closed; seeAK checklist items AK-3 and AK-4d.NCR-LANL-0734-13 was written during this inspection; see AK checklist itemAK-7.Attachment 3s for DR001–DR010 were revised in 2012 tomatch the “AK documentation types” with the associatedDRs. DR011 and DR012 are new since the last inspection: DR011 for conflicting information in source documents;DR012 for trying to add a container that had already been emplaced tothe tracking spreadsheet.D-12EPA Inspection No.: LANL-CC-2013Waste Stream: LA-OS-00-01.01Inspection Date: November 19–21, 2013AK-7:Is the AK accuracy report technicallyadequate? Has it been updated annually?Yes. The 2011 report was written on Attachment 14, Revision19. It should have been written using Revision 21. 2013report was written on Attachment 24. It should have beenwritten using Revision 25. See discussion in AttachmentD.1, AK checklist item AK-7.AK-8:Is AK-NDA communication adequatelydocumented?N/A. Radiological characterization is done using AK. NDAis not used for LA-OS-00-01.001; therefore, AK-NDAcommunication is not applicable.AK-9:Has notification of applicable T2 changesbeen provided to EPA as required in the LANLCCP CH tiering table?Yes. EPA tracking began with 4thquarter FY 2009. Tier 2 change notification required for:a.AK accuracy reports (annually, at a minimum) – Received correct notificationfor 2011 and 2012 reports. EPA didnot receive notification for the 2013 report. LANL-CCP submitted notificationfor a long list of waste streams andoverlooked LA-OS-00-01.001. EPA will revisit during next inspection.b.AK reassessment memoranda and combination of wastestreams – N/A. Not applicable to LA-OS-00-01.001.c.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 (2ndquarter FY 2010) and 9 (3rdquarter FY 2012). Allother reviews were before EPA started tracking T2 notifications.f.WSPFs, new, revised and CNs – EPA received T2 notification for CN #2 (3rdquarter FY 2010).E-1ATTACHMENT E.1: NDA CONTINUED COMPLIANCE INSPECTION CHECKLIST: HENC1TechnicalElementsObjective EvidenceAdditional CommentsGeneralHENC1-1:Confirm the NDA system is theHENC1, its location and number and note anysignificant changes since the last EPA inspection.LANL HENC1 is located in Trailer 53-506 on Pad 10 in Area G of TA-54 atLANL.EPA inspectors found the HENC1to be located in Pad 10 in Area Gof TA-54, not moved since theprevious inspection.HENC1-2:Describe the HENC1. The system incorporates two measurement modalities: a passive neutron counterand an integral gamma-ray spectrometer. The passive neutron counter usesmultiple3He proportional counters, along with a multiplicity shift register and anexternal252Cf source for the AaS matrix correction function, to determine thespontaneously fissioning mass content of waste containers, referred to as the240PuEff. The240PuEffis defined as the amount of240Pu that would produce theobserved true coincidence rate, after correcting for the neutron moderationproperties of the waste matrix. The quantities of individual radionuclides arerelated to the240PuEffby applying the ratios of other TRU or target radionuclides,including spontaneously fissioning radionuclides (i.e.,235U). These ratios aredetermined by MGA of the gamma-ray spectrumN/AHENC1-3:Identify the consensus standards thatwere used for the system calibration.The consensus standards used in thecalibration are ASTM C-1030, C-1133, C1215 and E-181.As stated in MCS-HENC#1-NDA-1002, Revision 6, and confirmedduring interview with NDApersonnel.HENC1-4:Describe the system’s operationalhistory 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 stated in MCS-HENC#1-NDA1002, Revision 6, and confirmedduring interview with NDApersonnel.HENC1-5:Identify the container types assayedon the HENC1 and the number of BDRsassembled during the last year.The HENC1 can only assay 55-gallon drums. Visual inspection confirms nocontainers larger than 55 gallonscould be assayed by theinstrument.HENC1-6:Confirm that the HENC1 is able toreport quantitative values for the WIPP-trackedradionuclides.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 stated in MCS-HENC#1-NDA1002, Revision 6. This was alsoconfirmed with NDA personnelduring inspection.HENC1-7:Confirm the HENC1’s calibration ofrecord.The calibration of record is documented in MCS-HENC#1-NDA-1002, Revision6, and is the same as what was reviewed during the most recent HENC1 T1approval.Confirmed with NDA personnelduring inspection.E-2TechnicalElementsObjective EvidenceAdditional CommentsHENC1-8:Identify the procedures that governthis function, their current revisions and wherethe 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).These procedures are the mostcurrent revisions. Copies of eachwere found and easily accessible atthe HENC1 operator station.HENC1-9:Confirm that the methods used toderive the isotopic contribution for unmeasuredradionuclides are MGA and MGA-U and noteany significant changes since the last EPAinspection.MGA and MGA-U are integral parts of the HENC1’s operation, as shown inCCP-TP-063, Revision 15Confirmed through interviews withLANL-CCP HENC1 personnelduring inspection. MGA-U isinstalled but not in use frequently,according to LANL-CCP.HENC1-10:Where is the actual efficiencycalibration for the HENC1 documented?It is documented in MCS-HENC#1-NDA-1002, Revision 6, and its attachments. N/AHENC1-11:Confirm the HENC1 operationalrange with respect to matrix (density) and activityand note any significant changes since the lastEPA inspection.Passive neutron: LLD to 16.278 g240PuEfffor multiplying wastesPassive neutron: LLD to 35.0 g240PuEfffor nonmultiplying wastesGamma: LLD to 217 g of total Pu limited by dead time; acceptabledensity range for gamma is 0.018–2.1 g/cc.This was confirmed with NDApersonnel. It is the sameoperational range that has beenpreviously approved by EPA.Calibration Verification and ConfirmationHENC1-12:Identify the date of the lastcalibration verification. Have any others beencompleted in the last year?10/4/2013: Containers were moved in Area G. Pad 10, which lowered thebackground and triggered a warning flag because background was lower thanpreviously anticipated. This was appropriately documented.There have been eight calibration verifications performed on the HENC1 sincethe last EPA inspection in August 2012.This was confirmed with NDApersonnel. All records wereprovided to EPA.HENC1-13:Confirm the pedigree of allradionuclide standards that were used forcalibration confirmation and/or verifications. Listor reference all standards used or cite a referencewhere the standards are listed.The standards are summarized inTable 1 of MCS-HENC#1-NDA-1002,Revision 6; the source certifications are listed in Attachment 1.EPA reviewed all sourcecertificates found in MCSHENC#1-NDA-1002, Revision 6,Attachment 1. All standards areindependently certified andacceptable to use for the HENC1calibration.HENC1-14:Requirements for accuracy andprecision must be met, as specified in the WasteAcceptance Criteria (DOE/WIPP-02-3122),Appendix A, Table A-3.2 for calibrationverifications.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 6replicates.Accuracy and precision criteriawere met for all calibrationverifications.LLDHENC1-15:Confirm that the LLD for theHENC1 has been determined and note anysignificant changes since the last EPA inspection.Section 11 of MCS-HENC#1-NDA-1002, Revision 6, documents the LLDdetermination of measured radioisotopes for a sample drum. LLDs for allmeasured radionuclides in debris and homogeneous solids were below the 100nCi/g TRU threshold.Interviews with LANL-CCPHENC1 personnel duringinspection.E-3TechnicalElementsObjective EvidenceAdditional CommentsHENC1-16:Confirm if the HENC1 is used todiscriminate TRU/non-TRU wastes at the 100nCi/g criterion and that it has the requiredsensitivity, and note any significant changessince the last EPA inspection.The HENC1 can discriminate between TRU and non-TRU waste based on theLLDs reported in Section 11 of MCS-HENC#1-NDA-1002, Revision 6, for allmeasured radionuclides except239Pu in debris.Total nCi/g of each drum isreported in the BDR associatedwith the drum.HENC1-17:Identify any/all instances where anLLD value for a nonmeasuredradionuclide is notprovided based on a lack of technical feasibility.Because an LLD is a measurement-based parameter, it is not technically feasibleto calculate for radionuclides that are not directly measured. Plutonium isotopes238Pu,240Pu and242Pu are not usually directly measured by gamma spectrometryand are instead derived by ratios to measured239Pu. The reporting threshold for90Sr is computed based on the reported137Cs LLD using an activity ratiodetermined from AK. LANL-CCP states that it is not technically feasible toprovide an LLD equivalent for234U and it is derived by algorithm from measuredvalues of235U and238U.This is confirmed in section 11 ofMCS-HENC#1-NDA-1002,Revision 6.Quality ControlHENC1-18:All operators have current CCPtraining as verified on LOQI.LOQI provided for 11/14/2013, contains 12 operators, all with current training. EPA verified that the operatorslisted in the LOQI match thoselisted in the logbook. Several othernames appeared in the logbook thatdid not appear on the LOQI. EPAwas informed that those people nolonger workat LANL.HENC1-19:Confirm the HENC1’s status withrespect to the CBFO NDA PDP and last cycle.The HENC1 participated in CBFO PDP cycle 20A. EPA verified the successfulparticipation with LANL-CCP.HENC1-20:All HENC1 data must be reviewedand approved by qualified personnel. Identify thename and function of the individuals performingtechnical review and approval of HENC1 BDRs.The BDRs obtained by EPA were reviewed by Dominic Archuleta and IsraelAragon. Both are listed on the LOQI as ITRs.All individuals performing thetechnical review are qualified asconfirmed in the LOQI dated11/14/2013.HENC1-21:Identify any hardware and/orsoftware changes made to the HENC1 since thelast EPA inspection. Determine if changes aresignificant, where theyare documented and howthey affect the HENC1’s baseline approval.The gamma system’s pulser was replaced on 2/21/2013 and was documentedappropriately in a calibration verification.Confirmed during interviews withLANL-CCP personnel duringinspection.HENC1-22:Identify any NCRs within the lastyear.There have been no system NCRs on the HENC1 since the last inspection.Confirmed during interviews withLANL-CCP personnel duringinspection.TMUHENC1-23:Identify any changes to the methodor details of the TMU calculation since baseline.No changes to the TMU were made since EPA’s lastinspection. Confirmed during interviews withLANL-CCP personnel duringinspection.E-4TechnicalElementsObjective EvidenceAdditional CommentsHENC1-24:Evaluate the magnitude of the TMUvalues observed in theHENC1 BDRs that wereexamined during this inspection.The BDR TMU values were as expected in both BDRs reviewed. Confirmedduring interviews withLANL-CCP personnel duringinspection.Background and Performance ChecksHENC1-25:Confirm that HENC1 backgroundmeasurements have been taken daily.All records evaluated indicate compliant background performance. During interviews with NDApersonnel, EPA confirmed thisoccurs. The logbook entriesselected at random by EPA toreview contained evidence of thesemeasurements. Dated 5/10/2013and 4/22/2013.HENC1-26:Assess how often backgroundradiation was problematic to the extent thatmeasurement personnel had to make adjustments.Background for the HENC1 was problematic after drums were removed fromarea, causing a lower background than anticipated.During interviews with NDApersonnel, EPA confirmedbackground checks occur daily buthave not been a problem.HENC1-27:Confirm that system performancechecks have been performed at least once peroperational day. Confirm that performance checksinclude gamma and neutron efficiency, matrixcorrection checks, and gamma peak position andresolution checks.Performance checks are done once per day as stated in CCP-TP-063, Revision15.During interviews with NDApersonnel, EPA confirmed thisoccurs. The logbook entriesselected at random dated5/10/2013 and 4/22/2013 containedevidence of these checks.Data ManagementHENC1-28:HENC1 BDRs contain:Testing facility name, testing batch number,container numbers and signature of the SPM ordesignee.Table of contents.Background and performance check data orcontrol charts for the relevant time period.Data validation per the QAPD and siteprocedures.Separate testing report sheets for eachcontainer.EPA reviewed HENC1 BDR Nos. 1LANLDA1850 and 1LANDA1857 and foundthem to contain appropriate information.EPA did identify an issue in 1LANLDA1850. On the ITR checklist, the ITRincorrectly checked the box indicating thatthe QC measurements were outside ofthe established controls. The issue wasinvestigated and appeared to be anisolated instance. An NCR was issued to correct this checkbox.N/AE-5TechnicalElementsObjective EvidenceAdditional CommentsHENC1-29:HENC1 RDSs must include:Title “Radioassay Data Sheet.”Method/procedure used.Date of radioassay.Activities and associated TMU for individualradionuclides.TRU alpha concentration and its associatedTMU.Operator and reviewer signatures.EPA reviewed HENC1 BDR Nos. 1LANLDA1850 and 1LANDA1857 and foundthat each drum contained in the two BDRs had an RDS containing the correctelements.NoneE-6ATTACHMENT E.2: NDA CONTINUED COMPLIANCE INSPECTION CHECKLIST: HENC2TechnicalElementsObjective EvidenceAdditional CommentsGeneralHENC2-1:Confirm the NDA system is theHENC2, its location and number and note anysignificant 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 inspectors found the HENC2to be located in Pad 10 in Area Gof TA-54, not moved since theprevious inspection.HENC2-2:Describe the HENC2. The system incorporates two measurement modalities—a passive neutron counterand an integral gamma-ray spectrometer. The passive neutron counter usesmultiple3He proportional counters, along with a multiplicity shift register and anexternal252Cf source for the AaS matrix correction function, to determine thespontaneously fissioning mass content of waste containers, referred to as the240PuEff. The240PuEffis defined as the amount of240Pu that would produce theobserved true coincidence rate, after correcting for the neutron moderationproperties of the waste matrix. The quantities of individual radionuclides arerelated to the240PuEffby applying the ratios of other TRU or target radionuclides,including all spontaneously fissioning radionuclides (i.e.,235U). These ratios areroutinely determined by MGA of the gamma-ray spectrum obtained with theintegral gamma-ray spectrometer.N/AHENC2-3:Identify the consensus standards thatwere used for the system calibration.The consensus standards that are usedin the calibration are ASTM C-1030, C1133, C-1207 and C-1500.As stated in HENC#2-NDA-1002,Revision 3 and confirmed byinterviewing NDA personnel.HENC2-4:Describe the system’s operationalhistory since the last EPA inspection.From 11/13/2012 to 11/13/2013, the HENC2 assayed 1,154 containers, whichwere compiled in 164 BDRs.As stated in HENC#2-NDA-1002,Revision 3 and confirmed duringinterview with NDA personnel.LANL-CCP indicated that about25% of drums assayed are leadlined.HENC2-5:Identify the container types assayedon the HENC2 and the number of BDRsassembled during the last year.The HENC2 can only assay 55-gallon drums with or without poly liners and canalso assay 55-gallons drums with lead liners.Confirmed by visual inspection ofinstrument.HENC2-6:Confirm that the HENC2 is able toreport quantitative values for the WIPP-trackedradionuclides.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 stated in HENC#2-NDA-1002,Revision 6 and confirmed by NDApersonnel during inspection.HENC2-7:Confirm the HENC2’s calibration ofrecord.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 recentHENC2 T1 approval.Confirmed with NDA personnelduring inspection.E-7TechnicalElementsObjective EvidenceAdditional CommentsHENC2-8:Identify the procedures that governthis function, their current revisions and wherethe results of these calculations are documented.CCP-TP-063, Revision 15; CCP-TP-064, Revision 7; and CCP-TP-103, Revision12.These procedures are current andcopies of each were found andeasily accessible at the HENC2operator station.HENC2-9:Confirm that the methods used toderive the isotopic contribution for unmeasuredradionuclides are MGA and MGA-U and noteany significant changes since the last EPAinspection.MGA and MGA-U are integral parts of the HENC2 operation, as shown in CCPTP-63, Revision 15. MGA-U is only usedwhen there is sufficient uranium toprovide usable statistics.Confirmed through interviews withLANL-CCP HENC2 personnelduring inspection.HENC2-10:Where is the actual efficiencycalibration for the HENC2 documented?It is documented in HENC#2-NDA-1002, Revision 3, and its attachments. N/AHENC2-11:Confirm the HENC2 operationalrange with respect to matrix (density) and activityand note any significant changes since the lastEPA inspection.Passive neutron: LLD to 16.278 g240PuEfffor multiplying wastesPassive neutron: LLD to 35.0 g240PuEfffor nonmultiplying wastesGamma: LLD to 217 g of total Pu limited by dead time; density range for gammais 0.018–2.1 g/cc.This was confirmed with NDApersonnel. It is the sameoperational range that has beenpreviously approved by EPA.Calibration Verification and ConfirmationHENC2-12:Identify the date of the lastcalibration verification. Have any others beencompleted in the last year?On 7/25/2013, a flag on the neutronQA/QC measurement indicated a below-3-lower limit. These were no obvious issueswith electronics after diagnostics. Itwas previously identified that the252Cf source is in the latter stages of life andwill need to be replaced in the near future. Six calibration verifications have beenperformed since the last LANL inspection in August 2012.LANL-CCP indicated that a new252Cf source had not been orderedfor this instrument. LANL-CCP isaware the source will need to bereplaced in the near future.HENC2-13:Confirm the pedigree of allradionuclide standards that were used forcalibration confirmation and/or verifications. Listor reference all standards used or cite a referencewhere the standards are listed.The standards are summarized in Table1 of HENC#2-NDA-1002, Revision 3.Source certifications are listed in Attachment 1 of the same document.EPA reviewed all sourcecertificates and found all areindependently certified andacceptable to use for the HENC2calibration.HENC2-14:Requirements for accuracy andprecision must be met, as specified inDOE/WIPP-02-3122, Appendix A, Table A-3.2for calibration verifications.The calibration verification results are contained in CCP-LANL-HENC2-003,Revision 3. The % R was between 70 and 130% and % RSD was less than 14%for six replicates.Accuracy and precision criteriawere met for all calibrationverifications.LLDHENC2-15:Confirm that the LLD for theHENC2 has been determined and note anysignificant changes since the last EPA inspection.Section 11 of HENC#2-NDA-1002, Revision 3 documents the LLDdetermination of measured radioisotopes for a sample drum. LLDs for allmeasured radionuclides in debris and homogeneous solids were below the 100nCi/g TRU threshold.Interviews with LANL-CCPHENC2 personnel duringinspection.E-8TechnicalElementsObjective EvidenceAdditional CommentsHENC2-16:Confirm if the HENC2 is used todiscriminate TRU/non-TRU wastes at the 100nCi/g criterion and that it has the requiredsensitivity and note any significant changes sincethe last EPA inspection.The HENC2 can discriminate between TRU and non-TRU waste based on theLLDs reported in Section 11 of HENC#2-NDA-1002, Revision 3 for allmeasured radionuclides except239Pu in debris.Total nCi/g of each drum isreported in the BDR associatedwith the drum.HENC2-17:Identify any/all instances where anLLD value for a nonmeasuredradionuclide is notprovided based on a lack of technical feasibility.Because an LLD is a measurement-based parameter, it is not technically feasibleto calculate for radionuclides that are not directly measured. Plutonium isotopes238Pu,240Pu and242Pu are not usually directly measured by gamma spectrometryand are instead derived by ratios to measured239Pu. The reporting threshold for90Sr is computed based on the reported137Cs LLD using a ratio determined fromAK. LANL-CCP states that it is not technically feasible to provide an LLDequivalent for234U, and it is derived by algorithm from measured values of235Uand238U.This is confirmed in Section 11 ofHENC#2-NDA-1002, Revision 3.Quality ControlHENC2-18:All operators have current CCPtraining as verified on LOQI.LOQI dated 11/14/2013 contains 12 operators, all with current training. EPA verified that the operators onthe LOQI match those listed in thelogbook.HENC2-19:Confirm the HENC2’s status withrespect to the CBFO NDA PDP and last cycle.The HENC2 successfully participated in the CBFO PDP cycle 20A. EPA verified the successfulparticipation in the PDP letter.HENC2-20:All HENC2 data must be reviewedand approved by qualified personnel. Identify thename and function of the individuals performingtechnical review and approval of HENC2 BDRs.The ITRs that reviewed the BDRs selected by EPA include Maria Escarcengaand Dominic Archuleta; both have valid training as listed on the LOQI dated11/14/2013.All individuals performing thetechnical review are qualified.EPA reviewed BDR Nos.2LANDA1234 and 2LANDA1229.HENC2-21:Identify any hardware and/orsoftware changes made to the HENC2 since thelast EPA inspection. Determine if changes aresignificant, where theyare documented and howthey affect the HENC2’s baseline approval.The drum rotator was replaced in November 2012 and a calibration verificationwas performed post-replacement to document that themachine was operating asexpected.Confirmed during interviews withLANL-CCP personnel duringinspection.HENC2-22:Identify any NCRs within the lastyear.There have been no system NCRs on the HENC2 since the last inspection. Confirmed during interviews withLANL-CCP personnel duringinspection.TMUHENC2-23:Identify any changes to the methodor details of the TMU calculation since baseline.No changes to the TMU were made since EPA’s lastinspection. Confirmed during interviews withLANL-CCP personnel duringinspection.HENC2-24:Evaluate the magnitude of the TMUvalues observed in theHENC2 BDRs that wereexamined during this inspection.Confirmed during interviews withLANL-CCP personnel duringinspection.E-9TechnicalElementsObjective EvidenceAdditional CommentsBackground and Performance ChecksHENC2-25:Confirm that HENC2 backgroundmeasurements have been taken daily.All records evaluated indicate compliant background performance. During interviews with NDApersonnel, EPA confirmed thisoccurs. The logbook entriesselected at random by EPA toreview contained evidence of thesemeasurements.HENC2-26:Assess how often backgroundradiation was problematic to the extent thatmeasurement personnel had to make adjustments.Due to the location of HENC2 relative to the other NDA equipment on Pad 10 ofArea G, the HENC2 has had fewer issues than the other equipment.During interviews with NDApersonnel, EPA confirmedbackground checks occur daily buthave not been a problem.HENC2-27:Confirm that system performancechecks have been performed at least once peroperational day. Confirm that performance checksinclude gamma and neutron efficiency, matrixcorrection checks and gamma peak position andresolution checks.Performance checks are done once per day as stated in CCP-TP-063, Revision15.During interviews with NDApersonnel, EPA confirmed thisoccurs. The logbook entriesselected by EPA to review dated8/22/2013 and 10/2/2013 containedevidence of these checks.Data ManagementHENC2-28:HENC2 BDRs contain:Testing facility name, testing batch number,container numbers and signature of the SPM ordesignee.Table of contents.Background and performance check data orcontrol charts for the relevant time period.Data validation per the QAPD and siteprocedures.Separate testing report sheets for eachcontainer.EPA reviewed HENC2 BDR Nos. 2LANDA1234 and 2LANDA1229 and foundthem to contain appropriate information.N/AHENC2-29:HENC2 RDSs must include:Title “Radioassay Data Sheet.”Method/procedure used.Date of radioassay.Activities and associated TMU for individualradionuclides.TRU alpha concentration and its associatedTMU.Operator and reviewer signatures.EPA reviewed HENC2 BDR Nos. 2LANDA1234 and 2LANDA1229 and foundthat each drum contained in the two BDRs had an RDS containing the correctelements.N/AE-10ATTACHMENT E.3: NDA CONTINUED COMPLIANCE INSPECTION CHECKLIST: SuperHENCTechnicalElementsObjective EvidenceAdditional CommentsGeneralSHENC-1:Confirm the NDA system is theSHENC, its location and number and note anysignificant changes since the last EPA inspection.The SHENC is located in TA-54 on Pad 10in Area G, Building No. 547. TheSHENC is a self-contained NDA unit thatis physically housed in a mobilemanufactured enclosure made up of a “High-Cube” freight container measuringapproximately 48 feet long by 81⁄2 feet wide by 131⁄2 feet high.EPA inspectors found the SHENCto be located in TA-54 on Pad 10in Area G at LANL, not movedsince the previous inspection.SHENC-2:Describe the SHENC and note anysignificant changes since the last EPA inspection.The SHENC consists of a passive neutron counter and an integral gamma-rayspectrometer. The combination of neutron and isotopic distribution informationallows quantification of238Pu,239Pu,240Pu,241Am,233U,235U,238U,137Cs,237Np.N/ASHENC-3:Identify the consensus standards thatwere used for the system calibration and note anysignificant changes since the last EPA inspection.ASTM standards C-1030, C-1133, C-1207 and C-1500 are used in thecalibration, as documented in LANL-SHENC3-NDA-1004, Revision 4.As stated in LANL-SHENC3-NDA-1004, Revision 4, andconfirmed during interview withNDA personnel.SHENC-4:Describe the system’s operationalhistory since the 2011 T1 approval.The SHENC was previously deployed at the Hanford Site’s Plutonium FinishingPlant, though it was not certified for WIPP assays at that site. It was moved toLANL where it was refurbished to operate under the Canberra NDA2000Software. Its operational range was extended through a T1 change in August2012.As stated in LANL-SHENC3-NDA-1004, Revision 4, andconfirmed during interview withNDA personnel.SHENC-5:Identify the container types assayedon the SHENC and the number of BDRscompleted in the last calendar year.The system is designed to measure SWBs containing four 55-gallon drums ofretrievably stored SCG S5000 debris and SWBs containing direct-loaded S5000debris. From 11/13/2012 to 11/13/2013, the SHENC assayed 306 containers thatwere compiled in 102 BDRs. The SHENC can assay a maximum of sixcontainers per day.LANL-CCP indicated that, in aperfect world, six SWBs could beassayed in a day but that four is amore typical operation day.SHENC-6:Confirm that the SHENC is able toreport quantitative values for the WIPP-trackedradionuclides and note any significant changessince 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 stated in LANL-SHENC3-NDA-1004, Revision 4, andconfirmed with NDA personnelduring inspection.SHENC-7:Confirm the SHENC’s calibration ofrecord.Both operational modes of the SHENC werecalibrated before its initial use; thedates and technical details of the calibrations are documented in the calibrationreport.Confirmed with NDA personnelduring inspection.SHENC-8:Identify the procedures that governthis function, the current revision of each andwhere the results of these calculations aredocumented.CCP-TP-059, operating procedure, Revision 2.CCP-TP-064, calibration procedure, Revision 7.CCP-TP-103, data validation procedure, Revision12.These procedures are the mostcurrent revisions, and copies ofeach were found and easilyaccessible in the SHENC trailer.SHENC-9:Confirm that the methods used toderive the isotopic contribution for unmeasuredradionuclides are MGA and MGA-U and note anysignificant changes since the last EPA inspection.MGA and MGA-U are integral parts of the SHENC operation, as described inCCP-TP-059.Confirmed through interviewswith LANL-CCP SHENCpersonnel during inspection.E-11TechnicalElementsObjective EvidenceAdditional CommentsSHENC-10:Confirm the SHENC operationalrange with respect to matrix (density) and activityand note any significant changes since the lastEPA inspection.The ranges of applicability of the system‘s calibrations for both passive neutronand absolute gamma operational modes are specified in the calibration report.The ranges are expressed in terms of240PuEFFand AaS for passive neutron andphoton energy and matrix mass for the absolute gamma mode. The SHENC’spassive neutron use is restricted to the coincidence mode; the multiplicity modeis not used for WIPP assays.EPA confirmed this with NDApersonnel. This range is the sameas that previously approved byEPA.Calibration Verification and ConfirmationSHENC-11:Identify the date of the lastcalibration verification. Have any others beencompleted in the last year?On 7/31/2013, the SuperHENC logbook indicated a flag on the 122 keV FWHMparameter for detector #1, meaning the result exceed the three-control limit.An investigation was performed and indicated that there were no physicalproblems with the detector. Statistics over the previous two months indicatedthat the FWHM mean had increased slightly and the mean was adjusted slightlyto reflect this change. Additionally, the observed values for152Eu for bothdetectors had decreased slightly due tothe age of the sources, and their meanwas decreased slightly for both detectorsto reflect this decay. Including thiscalibration verification, a total of nine calibration verifications have beencompleted since the last EPA inspection in August 2012.Confirmed with NDA personnelduring the inspection.SHENC-12:Confirm the pedigree of allradionuclide standards that were used forcalibration confirmation and/or verifications. Listor reference all standards used or cite a referencewhere they are listed.Sources are summarized in Table 3 of LANL-SHENC3-NDA-1004, Revision 4.Source certifications are listed in Attachment 1.EPA reviewed all sourcecertificated found in LANLSHENC3-NDA-1004, Attachment1. All standards are independentlycertified and acceptable to use forthe SHENC calibration.SHENC-13:Requirements for accuracy andprecision must be met, as specified in DOE/WIPP02-3122, Appendix A, Table A-3.2 for calibrationverifications.The initial calibration verification is documented in LANL-SHENC3-NDA1004. The results of all subsequent calibration verifications are documented inthe SuperHENC Calibration Verification Reports cited in Attachment B. The %R was between 70 and 130% and % RSD was less than 14% for 6 replicates inall cases.Accuracy and precision criteriawere met for all calibrationverifications.LLDSHENC-14:Confirm that the LLD for theSHENC has been determined and note anysignificant changes since the last EPA inspection.The LLD for the SHENC is determinedin Section 11 of LANL-SHENC3-NDA1004, Revision 4. To determine the MDAs, sets of 3 replicates were performedfor a surrogate matrix SWB with no reference sources inside, and NDA 200calculated the MDAs from these measurements by applying WG isotopics.Confirmed through interviewswith LANL-CCP SHENCpersonnel during inspection.E-12TechnicalElementsObjective EvidenceAdditional CommentsSHENC-15:Confirm if the SHENC is used todiscriminate TRU/non-TRU wastes at the 100nCi/g criterion and that it has the requiredsensitivity.The LLD for the SHENC for a typical debris waste assay is determined inSection 11 of LANL-SHENC3-NDA-1004, Revision 4. All LLDs are below the100 nCi/g threshold. The SHENC meets the required detection threshold.The total nCi/g of each drum isreported in the BDR associatedwith the drum. In severalinstances, a drum with an activityof less than 100 nCi/g was foundin the BDRs. LANL-CCPindicated these drums will be loadmanaged.SHENC-16:Identify any/all instances where anLLD value for a nonmeasuredradionuclide is notprovided based on a lack of technical feasibilityand note any significant changes since the lastEPA inspection.Because an LLD is a measurement-based parameter, it is not technically feasibleto calculate for radionuclides that are not directly measured. Plutonium isotopes238Pu,240Pu and242Pu are not usually directly measured by gamma spectrometryand are instead derived by ratios to measured239Pu. The reporting threshold for90Sr is computed based on the reported137Cs LLD using an activity ratiodetermined from AK NDA memos. LANL-CCP states that it is not technicallyfeasible to provide an LLD equivalent for234U, and that it is derived byalgorithm from measured values of235U,238U and238Pu.This is confirmed in LANLSHENC3-NDA-1004, Revision 4,Section 7.Quality ControlSHENC-17:All operators have current CCPtraining as verified on LOQI.LOQI dated 11/14/2013 contains 10 operators, all withcurrent training. EPA verified that the operatorslisted in the LOQI match thoselisted in the logbook.SHENC-18:Confirm the SHENC’s status withrespect to the CBFO NDA PDP and last cycle.The SHENC successfully participatedin cycle B13A of the CBFO NDAPDP. EPA verified the successfulparticipation in the PDP approvalletter.SHENC-19:All SHENC data must be reviewedand approved by qualified personnel. Identify thename and function of the individuals performingtechnical 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 individuals performing thetechnical review are qualified.EPA reviewed BDR Nos.3LANDA0215 and3LANDA0219.SHENC-20:Identify any NCRs within the lastyear.There have been no system NCRs on the SHENC inthe last year. Confirmed during interviews withLANL-CCP personnel duringinspection.TMUSHENC-21:Identify any changes to the methodor details of the TMU calculation since the lastEPA inspection.No changes to the TMU were made since EPA’s lastinspection. Confirmed during interviews withLANL-CCP personnel duringinspection.E-13TechnicalElementsObjective EvidenceAdditional CommentsSHENC-22:Evaluate the magnitude of the TMUvalues observed in the SHENC BDRs that wereexamined during this inspection.The TMU values contained in the BDRs were asexpected. Confirmed during interviews withLANL-CCP personnel duringinspection. EPA reviewed BDRNos. 3LANDA0215 and3LANDA0219.Background and Performance ChecksSHENC-23:Confirm that SHENC backgroundmeasurements have been taken daily.Confirmed that SHENC background measurements have been taken daily. EPA confirmed this duringinterviews with NDA personnel.The logbook entries selected byEPA to review, dated 5/18/2013and 7/8/2013, contained evidenceof these checks.SHENC-24:Assess how often backgroundradiation was problematic to the extent thatmeasurement personnel had to make adjustments.No instances of problematic backgrounds were observed in the last year. EPA confirmed this duringinterviews with NDA personnel.SHENC-25:Confirm that system performancechecks have been performed at least once peroperational day. Confirm that performance checksinclude gamma and neutron efficiency, matrixcorrection checks and gamma peak position andresolution checks.Performance checks are done once per day as stated in CCP-TP-059. EPA confirmed this duringinterviews with NDA personnel.The logbook entries selected byEPA to review, dated 5/18/2013and 7/8/2013, contained evidenceof these checks.Data ManagementSHENC-26:SHENC BDRs contain:Testing facility name, testing batch number,container numbers and signature of the SPM ordesignee.Table of contents.Background and performance check data orcontrol charts for the relevant time period.Separate testing report sheets for each container.EPA reviewed SHENC BDR Nos. 3LANDA0215 and 3LANDA0219 and foundthem to contain appropriate information.N/ASHENC-27:SHENC RDSs must include:Title “Radioassay Data Sheet.”Method/procedure used.Date of radioassay.Activities and associated TMU for individualradionuclides.TRU alpha concentration and its associatedTMU.Operator and reviewer signatures.EPA reviewed SHENC BDR Nos. 3LANDA0215 and 3LANDA0219 and foundthat each drum they contained had anRDS containing the correct elements.N/AE-14ATTACHMENT E.4: NDA CONTINUED COMPLIANCE INSPECTION CHECKLIST: MILCCTechnicalElementsObjective EvidenceAdditional CommentsGeneralMILCC-1:Confirm the NDA system is theMILCC, its location and number.The instrument is located in the east end of Dome 283 in Area G at TA-54 atLANL. It is also referred to as the MCS/LANL “Box Counter” in somedocumentation.This was confirmed with NDApersonnel during evaluation. EPAinspectors visually confirmed theinstrument’s location.MILCC-2:Describe the MILCC. The detectors are BEGe detectors, i.e., planar detectors that provide excellentresponse and energy resolution from 45 keV to 3 MeV. The detectors areidentified as Nos. 08004606and 07048046and were ISOCS characterized in2001 and 2006, respectively. The two MILCC detectors are placed equidistantfrom, on opposite sides, of the container to be assayed. Two distances are fixedfor each container type, the selection of which is determined by the dead time ofthe detector, the near and far-field positions. The far-field position is designed toaccommodate the measurement of containers with high dead times. A 90°collimator is utilized on the gamma detector for far-field measurements.This was confirmed with NDApersonnel during evaluation.MILCC-3:Identify the consensus standards thatwere used for the system calibration.LANL-CCP used consensus standards ASTM C-1030, C-1133, C-1207 and C1500 for the MILCC calibration.This is stated in CI-MILCC-NDA-1006 and was confirmedwith NDA personnel duringevaluation.MILCC-4:Identify the container and wastestypes assayed on the MILCC.The MILCC is capable of assaying debris, soils and gravel, and homogeneoussolid wastes in 55-gallon drums, CMBs and SWBs.The MILCC is limited by wastedensity and dead time. TheMILCC is calibrated to assaywastes with densities of 0 to 2.50g/cc. All LANL TRU waste isexpected to fall in this range. Itwas conveyed to inspectors thatLANL-CCP intends to addanother calibration for 85-gallondrums containing an overpacked55-gallon drums. EPA inspectorsreminded LANL-CCP that thiswould require a T1 change.MILCC-5:Identify the period of performancerelevant to the MILCC and the number of BDRsand waste containers this system assayed duringthe period.The MILCC is a new system with a limited performance history. LANL-CCPprovided a BDR containing three containers for each of the three containertypes, MILCC BDR Nos. 4LANDA0012 (CMB), and 4LANDA0016 (55-gallondrum), which EPA inspectors reviewed.Including the containers initiallyassayed at risk, the MILCC hasassayed 38 containers, which arecontained in 10 BDRs. No validassays have been completed since7/29/2013.E-15TechnicalElementsObjective EvidenceAdditional CommentsMILCC-6:Confirm that the MILCC is able toreport quantitative values for the WIPP-trackedradionuclides.Direct Measurements:238Pu,239Pu,241Am,233U,235U,238U,137Cs,237Np.Nuclides by Scaling:90Sr,234U,242Pu. Pu and other TRU isotopic ratios aredetermined using the MGA or FRAM software, or AK.This was confirmed with NDApersonnel during evaluation.MILCC-7:Confirm the MILCC’s calibration ofrecord.The calibration is documented in CI-MILCC-NDA-1006, Revision 0. Eachdetector factory characterization report was provided to EPA reviewers.This was confirmed with NDApersonnel during evaluation.MILCC-8:Identify the procedures that governthis function and where the results of thesecalculations 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).These were confirmed with NDApersonnel. Copies of the currentoperating and calibrationprocedures were available in thecontrol room to operators.MILCC-9:Confirm the methods used to derivethe isotopic contribution for unmeasuredradionuclides.241Am and Pu isotopics are determined by MGA or FRAM software whenenough mass exists.This was confirmed with NDApersonnel during evaluation.Calibration Verification and ConfirmationMILCC-10:Confirm the pedigree of allradionuclide standards that were used forcalibration confirmation and/or verifications. Listor 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 reviewed all sourcecertificates found in CI-MILCCNDA-1006, Revision 0,Attachment 1. All standards areindependently certified andacceptable to use for the MILCCcalibration.MILCC-11:Confirm the MILCC operationalrange with respect to matrix (density) and activity.Acceptable density range for gamma is approximately 0.0–2.50g/cc; activity islimited by spectral parameters (peakshape and resolution)and system deadtime.This was confirmed with NDApersonnel during evaluation.MILCC-12:Identify the date of the last calibrationverification. Have any others been completed in thelast year?All work in LANL Area G was halted for two weeks. During that time, thedewars containing liquid nitrogen (LN2) were not filled and the detectorswarmed. When operations were resumed,both detectors were filled with LN2and allowed to cool overnight. The following day calibration was verified andLANL-CCP personnel determined that the detector was functioning properly.There have been six calibration verifications done on the MILCC, including10/22/2013, and all were appropriately documented.LANL-CCP took appropriateactions to verify that the MILCCwas functioning properly.MILCC-13:Requirements for accuracy andprecision must be met, as specified in DOE/WIPP02-3122, Appendix A, Table A-2 for calibrationverifications.The calibration confirmation results are contained in section 6.0 of MILCCCalibration Report, CI-MILCC-NDA-1006. The % R was between 70 and 130%and % RSD was less than 14%.This was confirmed with NDApersonnel during the EPAevaluation.E-16TechnicalElementsObjective EvidenceAdditional CommentsLLDMILCC-14:Confirm that the LLD for the MILCChas been determined.Typical MDAs are found by performing three replicate assays on each containertype and detector position with matrixcontainers without radioactive sources.MDAs are then averaged and converted to MDCs using matrix weight. TheMDAs documented in section 8 of CI-MILCC-NDA-1006, Revision 0, indicatethat the instrument meets the TRU discrimination criterion of 100 nCi/g with theexception of241Am in a metals SWB in far-field geometry. This is only anexample of a typical assay.MDAs are variable and depend onmeasurement conditions such asbackground rate and matrix type.LANL-CCP provided exampleMDAs and MDCs for a metalsSWB and a 55-gallon drum inboth near- and far-field positions.MILCC-15:Confirm if the MILCC is used todiscriminate TRU/non-TRU wastes at the 100nCi/g criterion and that it has the requiredsensitivity.See previous entry. This was confirmed with NDApersonnel during the EPAevaluation.MILCC-16:Identify any/all instances where anLLD value for a nonmeasuredradionuclide is notprovided based on a lack of technical feasibility.Because an LLD is a measurement-based parameter, it is not technically feasibleto calculate for radionuclides that are not directly measured.242Pu is derivedfrom the measured mass of239Pu times an appropriatescaling factor computedfrom measured or declared massfractions. LANL-CCP states the234U scalingfactor 0.014 is used for wastes containing235U, and the scaling factor 0.427 isused for wastes containing primarily238Pu. Since MDAs for235U and238Pu varyaccording to measurement conditions, the reporting thresholds for234U will alsovary.90Sr activity is assumed equal to137Cs activity in wastes containing fissionproducts. Typical gamma reporting thresholds for these nuclides are shown inCI-MILCC-NDA-1006, Revision 0, Tables 8e through 8h.This is confirmed in section 8 ofCI-MILCC-NDA-1006, Revision0, and was discussed with NDApersonnel. All reportingthresholds were determined to bewithin acceptable limits.Quality ControlMILCC-17:All operators have current CCPtraining as verified on LOQI.An 11/14/2013 LOQI was provided to EPA reviewers. Seven operators werelisted on the LOQI, all withcurrent training requirements met. Two of theoperators are also listed as EAs.EPA confirmed the qualificationsof each operator on theirrespective qualification cards.MILCC-18:Confirm the MILCC’s status withrespect to the CBFO NDA PDP and last cycle.The MILCC was in the process of participating in the PDP drum cycle 20A andsupplemental box cycle B13C duringthe EPA evaluation. The items to beassayed included 4 drums and 2 SWBs.LANL-CCP provided EPA with acopy of the approval letter, whenissued, as a courtesy.MILCC-19:All MILCC data must be reviewedand approved by qualified personnel. Identify thename and function of the individuals performingtechnical 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 andRichard Baumann.Qualification cards were reviewedby EPA inspectors for allpersonnel listed.MILCC-20:Identify any NCRs within the lastyear.There were no NCRs issued to this system since the last inspection. There havebeen several NCRs related to specific assays; however, this is expected on theMILCC because all assays are first done in the near field. Invalid assays arethen NCR’d and run in the far-field position.This was discussed with NDApersonnel during the evaluation. Ifa sufficient assay cannot beobtained using a 30-minute counttime, LANL-CCP may consider alonger assay.E-17TechnicalElementsObjective EvidenceAdditional CommentsTMUMILCC-21:Evaluate the magnitude of the TMUvalues observed in the MILCC BDRs that wereexamined during this evaluation.The TMU for the MILCC is documentedin “Total Measurement Uncertaintyfor the MCS/LANL ISOCS ‘Box Counter,’” Revision 2, March 27, 2013. Thecomponents of uncertainty included in the TMU determination consist ofcalibration source uncertainties, ISOCS model uncertainties, detectorpositioning, matrix in homogeneity, nonuniform source distribution, fill-heightuncertainty, self-attenuation of SNM “lumps,” counting statistics, backgroundfluctuations, radionuclideinterferences and isotopic measurement uncertainty.The ISOCS uncertainty estimator, a companion program to the MILCC, is usedto calculate TMU.EPA evaluated the two BDRsprovided. TMU was within theexpected range in all instances.Background and Performance ChecksMILCC-22:Confirm that MILCC backgroundmeasurements have been taken daily.Background measurements are required inCCP-TP-076, Revision 0. Evidenceof daily background measurements was seen in the logbook pages reviewed.EPA reviewed the logbook entriesfrom 7/15/2013, 7/24/2013 and11/19/2013. All entries showedthat background measurementswere made and acceptable.MILCC-23:Assess how often backgroundradiation was problematic to the extent thatmeasurement personnel had to make adjustments.This was originally a problem when the MILCC was first assembled. Wastesstored in Dome 283 were removed. This reduced background to acceptablelevels. Background has not been a problem since these wastes were relocated.This was discussed with NDApersonnel during the evaluation.MILCC-24:Confirm that system performancechecks have been performed at least once peroperational day. Confirm that performance checksinclude gamma matrix correction checks andgamma 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 thelogbook pages reviewed.EPA reviewed the logbook entriesfrom 7/15/2013, 7/24/2013 and11/19/2013. All entries showedthat performance checkmeasurements were made andacceptable.MILCC-25:MILCC BDRs contain:Testing facility name, testing batch number,container numbers and signature of the SPM ordesignee.Table of contents.Background and performance check data orcontrol charts for the relevant time period.Separate testing report sheets for each container.EPA reviewed MILCC BDR Nos. 4LANDA0016 (55-gallon drums) and4LANDA0012 (CMB). The BDRs contained all required information.NAE-18TechnicalElementsObjective EvidenceAdditional CommentsMILCC-26:MILCC RDSs must include:Title “Radioassay Data Sheet.”Method/procedure used.Date of radioassay.Activities and associated TMU for individualradionuclides.TRU alpha concentration and its associatedTMU.Operator and reviewer signatures.EPA reviewed MILCC BDR Nos. 4LANDA0016 (55-gallon drums) and4LANDA0012 (CMB). The RDSs contained all required information.NAF-1ATTACHMENT F.1: REPLICATE TESTING DATA FOR DRUM NO. 68428 – HENC2Instrument: HENC2Drum: 68428Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A234U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A238U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A238Pu Activity (Ci)1.56E-02 4.09E-03 2.62E-01 1.47E-02 3.83E-03 2.61E-01 1.51E-02 3.98E-03 2.64E-01239Pu Activity (Ci)5.79E-01 1.28E-01 2.21E-01 5.47E-01 1.20E-01 2.20E-01 5.63E-01 1.25E-01 2.22E-01240Pu Activity (Ci)1.36E-01 3.56E-02 2.62E-01 1.28E-01 3.34E-02 2.61E-01 1.32E-01 3.47E-02 2.63E-01242Pu Activity (Ci)7.88E-06 2.07E-06 2.63E-01 7.44E-06 1.94E-06 2.61E-01 7.65E-06 2.02E-06 2.64E-01241Am Activity (Ci)5.88E+00 3.20E+00 5.44E-01 5.85E+00 3.19E+00 5.45E-01 5.74E+00 3.13E+00 5.45E-0190Sr Activity (Ci)N/AN/A N/AN/AN/A N/AN/AN/A137Cs Activity (Ci)N/AN/A N/AN/AN/A N/AN/AN/ATRU 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 1.14E+05 4.84E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A234U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A238U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A238Pu Activity (Ci)1.44E-02 3.75E-03 2.60E-01 1.50E-02 3.89E-03 2.59E-01 1.45E-02 3.74E-03 2.58E-01239Pu Activity (Ci)5.37E-01 1.17E-01 2.18E-01 5.57E-01 1.22E-01 2.19E-01 5.40E-01 1.17E-01 2.17E-01240Pu Activity (Ci)1.26E-01 3.27E-02 2.60E-01 1.30E-01 3.39E-02 2.61E-01 1.26E-01 3.26E-02 2.59E-01242Pu Activity (Ci)7.29E-06 1.90E-06 2.61E-01 7.58E-06 1.97E-06 2.60E-01 7.34E-06 1.89E-06 2.58E-01241Am Activity (Ci)5.84E+00 3.18E+00 5.45E-01 5.89E+00 3.21E+00 5.45E-01 5.99E+00 3.26E+00 5.45E-0190Sr Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/ATRU 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 1.19E+05 4.89E-01F-2Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A234U Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A238U Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A238Pu Activity (Ci)1.56E-02 4.09E-03 1.47E-02 3.05E-04 2.07E-02 2.23E-02 1.00E+00239Pu Activity (Ci)5.79E-01 1.28E-01 5.49E-01 1.11E-02 2.01E-02 2.99E-02 1.00E+00240Pu Activity (Ci)1.36E-01 3.56E-02 1.28E-01 2.61E-03 2.03E-02 2.14E-02 1.00E+00242Pu Activity (Ci)7.88E-06 2.07E-06 7.46E-06 1.53E-07 2.06E-02 2.19E-02 1.00E+00241Am Activity (Ci)5.88E+00 3.20E+00 5.86E+00 9.04E-02 1.54E-02 3.19E-03 1.00E+0090Sr Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/ATRU Alpha Conc. (nCi/g)2.41E+05 1.17E+05 2.39E+05 3.03E+03 1.27E-02 2.70E-03 1.00E+00Quantity of InteresttPr(x<|t|)χ2Testt-Test233U Activity (Ci)N/A N/A Not Applicable Not Applicable234U Activity (Ci)N/A N/A Not Applicable Not Applicable238U Activity (Ci)N/A N/A Not Applicable Not Applicable238Pu Activity (Ci)2.57E+00 6.17E-02 Not Significant Not Significant239Pu Activity (Ci)2.49E+00 6.72E-02Not Significant Not Significant240Pu Activity (Ci)2.66E+00 5.64E-02Not Significant Not Significant242Pu Activity (Ci)2.50E+00 6.69E-02Not Significant Not Significant241Am Activity (Ci)1.82E-01 8.65E-01Not Significant Not Significant90Sr Activity (Ci)N/A N/A Not Applicable Not Applicable137Cs Activity (Ci)N/A N/A Not Applicable Not ApplicableTRU Alpha Conc. (nCi/g)5.42E-01 6.17E-01Not Significant Not SignificantF-3ATTACHMENT F.2: REPLICATETESTING DATA FOR DRUM NO. 68434– HENC2Instrument: HENC2Drum: 68434Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A234U Activity (Ci)N/A 7.47E-03 1.87E-01 3.97E-02 7.49E-03 1.89E-01 3.96E-02 7.41E-03 N/A238U Activity (Ci)2.84E-04 4.98E-05 1.75E-01 2.91E-04 5.10E-05 1.75E-01 2.89E-04 5.09E-05 1.76E-01238Pu Activity (Ci)2.56E+02 4.79E+01 1.87E-01 2.56E+02 4.83E+01 1.89E-01 2.56E+02 4.78E+01 1.87E-01239Pu Activity (Ci)2.30E-01 5.39E-02 2.34E-01 2.30E-01 5.42E-02 2.36E-01 2.30E-01 5.38E-02 2.34E-01240Pu Activity (Ci)1.14E-01 2.68E-02 2.35E-01 1.14E-01 2.70E-02 2.37E-01 1.14E-01 2.68E-02 2.35E-01242Pu Activity (Ci)1.15E-04 2.71E-05 2.36E-01 1.15E-04 2.72E-05 2.37E-01 1.15E-04 2.70E-05 2.35E-01241Am Activity (Ci)2.98E-01 6.95E-02 2.33E-01 2.98E-01 6.99E-02 2.35E-01 2.98E-01 6.94E-02 2.33E-0190Sr Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/ATRU 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 1.65E+07 1.87E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A234U Activity (Ci)N/A 7.50E-03 1.88E-01 3.96E-02 7.48E-03 1.89E-01 3.97E-02 7.48E-03 N/A238U Activity (Ci)2.80E-04 4.93E-05 1.76E-01 2.83E-04 4.99E-05 1.76E-01 2.94E-04 7.04E-05 2.39E-01238Pu Activity (Ci)2.57E+02 4.84E+01 1.88E-01 2.55E+02 4.82E+01 1.89E-01 2.56E+02 4.83E+01 1.89E-01239Pu Activity (Ci)2.31E-01 5.44E-02 2.35E-01 2.29E-01 5.41E-02 2.36E-01 2.30E-01 5.42E-02 2.36E-01240Pu Activity (Ci)1.15E-01 2.70E-02 2.35E-01 1.14E-01 2.69E-02 2.36E-01 1.14E-01 2.69E-02 2.36E-01242Pu Activity (Ci)1.16E-04 2.73E-05 2.35E-01 1.15E-04 2.72E-05 2.37E-01 1.15E-04 2.72E-05 2.37E-01241Am Activity (Ci)2.99E-01 7.01E-02 2.34E-01 2.98E-01 6.98E-02 2.34E-01 2.98E-01 6.99E-02 2.35E-0190Sr Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/ATRU 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 1.67E+07 1.89E-01F-4Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A234U Activity (Ci)3.99E-02 7.47E-03 3.97E-02 8.37E-05 2.11E-03 5.02E-04 1.00E+00238U Activity (Ci)2.84E-04 4.98E-05 2.87E-04 5.77E-06 2.01E-02 5.37E-02 1.00E+00238Pu Activity (Ci)2.56E+02 4.79E+01 2.56E+02 7.07E-01 2.76E-03 8.73E-04 1.00E+00239Pu Activity (Ci)2.30E-01 5.39E-02 2.30E-01 7.07E-04 3.07E-03 6.89E-04 1.00E+00240Pu Activity (Ci)1.14E-01 2.68E-02 1.14E-01 4.47E-04 3.92E-03 1.11E-03 1.00E+00242Pu Activity (Ci)1.15E-04 2.71E-05 1.15E-04 4.47E-07 3.88E-03 1.09E-03 1.00E+00241Am Activity (Ci)2.98E-01 6.95E-02 2.98E-01 4.47E-04 1.50E-03 1.66E-04 1.00E+0090Sr Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/ATRU Alpha Conc. (nCi/g)8.85E+07 1.65E+07 8.84E+07 1.64E+05 1.86E-03 3.97E-04 1.00E+00Quantity of InteresttPr(x<|t|)χ2Testt-Test233U Activity (Ci)N/A N/A Not Applicable Not Applicable234U Activity (Ci)2.40E+00 7.43E-02 Not Significant Not Significant238U Activity (Ci)-5.38E-01 6.19E-01 Not Significant Not Significant238Pu Activity (Ci)0.00E+00 1.00E+00 Not Significant Not Significant239Pu Activity (Ci)-3.58E-14 1.00E+00Not Significant Not Significant240Pu Activity (Ci)-4.08E-01 7.04E-01Not Significant Not Significant242Pu Activity (Ci)-4.08E-01 7.04E-01Not Significant Not Significant241Am Activity (Ci)-4.08E-01 7.04E-01Not Significant Not Significant90Sr Activity (Ci)N/A N/A Not Applicable Not Applicable137Cs Activity (Ci)N/A N/A Not Applicable Not ApplicableTRU Alpha Conc. (nCi/g)4.44E-01 6.80E-01Not Significant Not SignificantF-5ATTACHMENT F.3: REPLICATETESTING DATA FOR DRUM NO. 68571– HENC2Instrument: HENC2Drum: 68571Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A234U Activity (Ci)N/A 1.42E-04 2.23E-01 6.15E-04 1.40E-04 2.28E-01 5.46E-04 1.28E-04 N/A238U Activity (Ci)1.27E-04 2.74E-05 2.16E-01 1.11E-04 2.70E-05 2.43E-01 1.10E-04 2.45E-05 2.23E-01238Pu Activity (Ci)5.87E-02 1.57E-02 2.67E-01 5.84E-02 1.57E-02 2.69E-01 5.87E-02 1.57E-02 2.67E-01239Pu Activity (Ci)2.19E+00 4.97E-01 2.27E-01 2.17E+00 4.96E-01 2.29E-01 2.19E+00 4.98E-01 2.27E-01240Pu Activity (Ci)5.12E-01 1.37E-01 2.68E-01 5.09E-01 1.37E-01 2.69E-01 5.12E-01 1.37E-01 2.68E-01242Pu Activity (Ci)2.97E-05 7.96E-06 2.68E-01 2.96E-05 7.93E-06 2.68E-01 2.97E-05 7.96E-06 2.68E-01241Am Activity (Ci)7.57E+00 4.17E+00 5.51E-01 7.56E+00 4.16E+00 5.50E-01 7.53E+00 4.14E+00 5.50E-0190Sr Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/ATRU 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 3.42E+04 4.06E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A234U Activity (Ci)N/A 1.48E-04 2.10E-01 7.16E-04 1.51E-04 2.11E-01 5.55E-04 1.18E-04 N/A238U Activity (Ci)1.20E-04 2.80E-05 2.33E-01 1.29E-04 2.89E-05 2.24E-01 1.20E-04 2.81E-05 2.34E-01238Pu Activity (Ci)5.95E-02 1.59E-02 2.67E-01 5.82E-02 1.56E-02 2.68E-01 5.92E-02 1.59E-02 2.69E-01239Pu Activity (Ci)2.22E+00 5.05E-01 2.27E-01 2.17E+00 4.93E-01 2.27E-01 2.21E+00 5.02E-01 2.27E-01240Pu Activity (Ci)5.19E-01 1.39E-01 2.68E-01 5.08E-01 1.36E-01 2.68E-01 5.16E-01 1.38E-01 2.67E-01242Pu Activity (Ci)3.01E-05 8.07E-06 2.68E-01 2.95E-05 7.89E-06 2.67E-01 3.00E-05 8.03E-06 2.68E-01241Am Activity (Ci)7.56E+00 4.16E+00 5.50E-01 7.61E+00 4.19E+00 5.51E-01 7.55E+00 4.16E+00 5.51E-0190Sr Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/ATRU 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 3.43E+04 4.05E-01F-6Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A234U Activity (Ci)6.36E-04 1.42E-04 6.27E-04 8.02E-05 1.28E-01 1.28E+00 8.65E-01238U Activity (Ci)1.27E-04 2.74E-05 1.18E-04 7.78E-06 6.59E-02 3.22E-01 9.88E-01238Pu Activity (Ci)5.87E-02 1.57E-02 5.88E-02 5.43E-04 9.24E-03 4.80E-03 1.00E+00239Pu Activity (Ci)2.19E+00 4.97E-01 2.19E+00 2.28E-02 1.04E-02 8.42E-03 1.00E+00240Pu Activity (Ci)5.12E-01 1.37E-01 5.13E-01 4.66E-03 9.08E-03 4.61E-03 1.00E+00242Pu Activity (Ci)2.97E-05 7.96E-06 2.98E-05 2.59E-07 8.69E-03 4.23E-03 1.00E+00241Am Activity (Ci)7.57E+00 4.17E+00 7.56E+00 2.95E-02 3.90E-03 2.00E-04 1.00E+0090Sr Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/ATRU Alpha Conc. (nCi/g)8.47E+04 3.44E+04 8.46E+04 2.41E+02 2.85E-03 1.96E-04 1.00E+00Quantity of InteresttPr(x<|t|)χ2Testt-Test233U Activity (Ci)N/A N/A Not Applicable Not Applicable234U Activity (Ci)1.00E-01 9.25E-01 Not Significant Not Significant238U Activity (Ci)1.06E+00 3.50E-01 Not Significant Not Significant238Pu Activity (Ci)-1.68E-01 8.75E-01 Not Significant Not Significant239Pu Activity (Ci)-8.01E-02 9.40E-01Not Significant Not Significant240Pu Activity (Ci)-1.57E-01 8.83E-01Not Significant Not Significant242Pu Activity (Ci)-2.82E-01 7.92E-01Not Significant Not Significant241Am Activity (Ci)2.48E-01 8.17E-01Not Significant Not Significant90Sr Activity (Ci)N/A N/A Not Applicable Not Applicable137Cs Activity (Ci)N/A N/A Not Applicable Not ApplicableTRU Alpha Conc. (nCi/g)2.27E-01 8.31E-01Not Significant Not SignificantF-7ATTACHMENT F.4: REPLICATE TESTING DATA FOR DRUM NO. 68107 – SUPERHENCInstrument: SHENCContainer: 68107Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A234U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A238U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A238Pu Activity (Ci)7.53E-01 1.04E-01 1.38E-01 7.61E-01 1.28E-01 1.68E-01 7.47E-01 1.05E-01 1.41E-01239Pu Activity (Ci)1.05E+01 1.38E+00 1.31E-01 1.06E+01 1.41E+00 1.33E-01 1.04E+01 1.39E+00 1.34E-01240Pu Activity (Ci)3.95E+00 5.18E-01 1.31E-01 3.99E+00 7.21E-01 1.81E-01 3.92E+00 5.23E-01 1.33E-01242Pu Activity (Ci)8.00E-04 1.06E-04 1.33E-01 8.07E-04 1.37E-04 1.70E-01 7.93E-04 1.07E-04 1.35E-01241Am Activity (Ci)2.01E+00 2.63E-01 1.31E-01 2.03E+00 4.08E-01 2.01E-01 2.04E+00 4.10E-01 2.01E-0190Sr Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/ATRU 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 1.27E+04 9.07E-02Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A234U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A238U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A238Pu Activity (Ci)7.46E-01 1.04E-01 1.39E-01 7.50E-01 1.05E-01 1.40E-01 7.46E-01 1.04E-01 1.39E-01239Pu Activity (Ci)1.04E+01 1.39E+00 1.34E-01 1.05E+01 1.40E+00 1.33E-01 1.04E+01 1.39E+00 1.34E-01240Pu Activity (Ci)3.91E+00 5.22E-01 1.34E-01 3.93E+00 5.25E-01 1.34E-01 3.91E+00 5.22E-01 1.34E-01242Pu Activity (Ci)7.92E-04 1.07E-04 1.35E-01 7.96E-04 1.08E-04 1.36E-01 7.92E-04 1.07E-04 1.35E-01241Am Activity (Ci)2.09E+00 4.21E-01 2.01E-01 2.07E+00 4.17E-01 2.01E-01 2.09E+00 4.21E-01 2.01E-0190Sr Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/ATRU 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 1.27E+04 9.01E-02F-8Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A234U Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A238U Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A238Pu Activity (Ci)7.53E-01 1.04E-01 7.50E-01 6.53E-03 8.72E-03 1.58E-02 1.00E+00239Pu Activity (Ci)1.05E+01 1.38E+00 1.05E+01 8.94E-02 8.55E-03 1.68E-02 1.00E+00240Pu Activity (Ci)3.95E+00 5.18E-01 3.93E+00 3.35E-02 8.51E-03 1.67E-02 1.00E+00242Pu Activity (Ci)8.00E-04 1.06E-04 7.96E-04 6.53E-06 8.21E-03 1.52E-02 1.00E+00241Am Activity (Ci)2.01E+00 2.63E-01 2.05E+00 2.68E-02 1.31E-02 4.17E-02 1.00E+0090Sr Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/ATRU Alpha Conc. (nCi/g)1.41E+05 1.23E+04 1.41E+05 1.22E+03 8.69E-03 3.97E-02 1.00E+00Quantity of InteresttPr(x<|t|)χ2Testt-Test233U Activity (Ci)N/A N/A Not Applicable Not Applicable234U Activity (Ci)N/A N/A Not Applicable Not Applicable238U Activity (Ci)N/A N/A Not Applicable Not Applicable238Pu Activity (Ci)4.47E-01 6.78E-01 Not Significant Not Significant239Pu Activity (Ci)4.08E-01 7.04E-01Not Significant Not Significant240Pu Activity (Ci)4.91E-01 6.49E-01Not Significant Not Significant242Pu Activity (Ci)5.87E-01 5.89E-01Not Significant Not Significant241Am Activity (Ci)-1.43E+00 2.26E-01Not Significant Not Significant90Sr Activity (Ci)N/A N/A Not Applicable Not Applicable137Cs Activity (Ci)N/A N/A Not Applicable Not ApplicableTRU Alpha Conc. (nCi/g)0.00E+00 1.00E+00Not Significant Not SignificantF-9ATTACHMENT F.5: REPLICATETESTING DATA FOR DRUM NO. 68214– SUPERHENCInstrument: SHENCContainer: 68214Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A234U Activity (Ci)1.87E-04 4.87E-05 2.60E-01 1.88E-04 4.90E-05 2.61E-01 1.89E-04 4.92E-05 2.60E-01238U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A238Pu Activity (Ci)1.21E+00 3.15E-01 2.60E-01 1.13E+00 2.95E-01 2.61E-01 1.22E+00 3.18E-01 2.61E-01239Pu Activity (Ci)8.62E-02 2.24E-02 2.60E-01 8.02E-02 2.10E-02 2.62E-01 8.69E-02 2.28E-02 2.62E-01240Pu Activity (Ci)3.67E-02 9.56E-03 2.60E-01 3.42E-02 8.94E-03 2.61E-01 3.71E-02 9.66E-03 2.60E-01242Pu Activity (Ci)1.23E-04 3.20E-04 2.60E+00 1.15E-04 3.00E-05 2.61E-01 1.24E-04 3.24E-05 2.61E-01241Am Activity (Ci)4.29E-02 9.20E-03 2.14E-01 4.25E-02 9.28E-03 2.18E-01 4.28E-02 9.35E-03 2.18E-0190Sr Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/ATRU 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 7.04E+02 2.30E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A234U Activity (Ci)1.86E-04 4.86E-05 2.61E-01 2.02E-04 5.28E-05 2.61E-01 1.86E-04 4.86E-05 2.61E-01238U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A238Pu Activity (Ci)1.18E+00 3.08E-01 2.61E-01 1.28E+00 3.34E-01 2.61E-01 1.18E+00 3.08E-01 2.61E-01239Pu Activity (Ci)8.40E-02 2.19E-02 2.61E-01 9.13E-02 2.38E-02 2.61E-01 8.40E-02 2.19E-02 2.61E-01240Pu Activity (Ci)3.58E-02 9.34E-03 2.61E-01 3.89E-02 1.01E-02 2.60E-01 3.58E-02 9.34E-03 2.61E-01242Pu Activity (Ci)1.20E-04 3.13E-05 2.61E-01 1.30E-04 3.40E-05 2.62E-01 1.20E-04 3.13E-05 2.61E-01241Am Activity (Ci)4.24E-02 9.21E-03 2.17E-01 4.22E-02 9.22E-03 2.18E-01 4.34E-02 9.48E-03 2.18E-0190Sr Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/ATRU 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 6.81E+02 2.30E-01F-10Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A234U Activity (Ci)1.87E-04 4.87E-05 1.90E-04 6.72E-06 3.53E-02 7.62E-02 9.99E-01238U Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A238Pu Activity (Ci)1.21E+00 3.15E-01 1.20E+00 5.59E-02 4.66E-02 1.26E-01 9.98E-01239Pu Activity (Ci)8.62E-02 2.24E-02 8.53E-02 4.12E-03 4.83E-02 1.35E-01 9.98E-01240Pu Activity (Ci)3.67E-02 9.56E-03 3.64E-02 1.75E-03 4.82E-02 1.34E-01 9.98E-01242Pu Activity (Ci)1.23E-04 3.20E-04 1.22E-04 5.59E-06 4.59E-02 1.22E-03 1.00E+00241Am Activity (Ci)4.29E-02 9.20E-03 4.27E-02 4.67E-04 1.09E-02 1.03E-02 1.00E+0090Sr Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)0.00E+00 N/A N/A N/A N/A N/A N/ATRU Alpha Conc. (nCi/g)3.03E+03 6.96E+02 3.00E+03 1.38E+02 4.58E-02 1.56E-01 9.97E-01Quantity of InteresttPr(x<|t|)χ2Testt-Test233U Activity (Ci)N/A N/A Not Applicable Not Applicable234U Activity (Ci)-4.35E-01 6.86E-01 Not Significant Not Significant238U Activity (Ci)N/A N/A Not Applicable Not Applicable238Pu Activity (Ci)1.96E-01 8.54E-01 Not Significant Not Significant239Pu Activity (Ci)2.04E-01 8.48E-01Not Significant Not Significant240Pu Activity (Ci)1.77E-01 8.68E-01Not Significant Not Significant242Pu Activity (Ci)1.96E-01 8.54E-01Not Significant Not Significant241Am Activity (Ci)4.69E-01 6.63E-01Not Significant Not Significant90Sr Activity (Ci)N/A N/A Not Applicable Not Applicable137Cs Activity (Ci)N/A N/A Not Applicable Not ApplicableTRU Alpha Conc. (nCi/g)1.86E-01 8.62E-01Not Significant Not SignificantF-11ATTACHMENT F.6: REPLICATETESTING DATA FOR DRUM NO. 68211– SUPERHENCInstrument: SHENCContainer: 68211Quantity of InterestOriginal Measurement Replicate #1 Replicate #2ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A234U Activity (Ci)2.18E-04 3.40E-05 1.56E-01 2.11E-04 3.39E-05 1.61E-01 2.16E-04 3.71E-05 1.72E-01238U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A238Pu Activity (Ci)1.78E+00 2.53E-01 1.42E-01 1.76E+00 2.51E-01 1.43E-01 1.74E+00 2.48E-01 1.43E-01239Pu Activity (Ci)1.48E+01 2.04E+00 1.38E-01 1.47E+01 2.02E+00 1.37E-01 1.45E+01 2.00E+00 1.38E-01240Pu Activity (Ci)8.93E+00 1.23E+00 1.38E-01 8.86E+00 1.22E+00 1.38E-01 8.75E+00 1.21E+00 1.38E-01242Pu Activity (Ci)2.40E-03 3.34E-04 1.39E-01 2.38E-03 3.31E-04 1.39E-01 2.35E-03 3.27E-04 1.39E-01241Am Activity (Ci)1.12E+01 2.26E+00 2.02E-01 1.12E+01 2.25E+00 2.01E-01 1.10E+01 2.21E+00 2.01E-0190Sr Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/ATRU 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 1.13E+04 8.97E-02237Np Activity (Ci) 9.73E-05 1.27E-05 1.31E-01 9.65E-05 1.26E-05 1.31E-01 9.54E-05 1.25E-05 1.31E-01235U Activity (Ci) 5.39E-06 8.42E-07 1.56E-01 5.23E-06 8.40E-07 1.61E-01 5.35E-06 9.18E-07 1.72E-01Quantity of InterestReplicate #3 Replicate #4 Replicate #5ReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertaintyReportedValueAbsoluteUncertaintyRelativeUncertainty233U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A234U Activity (Ci)1.99E-04 3.46E-05 1.74E-01 2.22E-04 3.69E-05 1.66E-01 2.19E-04 3.76E-05 1.72E-01238U Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A238Pu Activity (Ci)1.75E+00 2.49E-01 1.42E-01 1.76E+00 2.51E-01 1.43E-01 1.76E+00 2.51E-01 1.43E-01239Pu Activity (Ci)1.46E+01 2.01E+00 1.38E-01 1.47E+01 2.03E+00 1.38E-01 1.47E+01 2.03E+00 1.38E-01240Pu Activity (Ci)8.81E+00 1.22E+00 1.38E-01 8.86E+00 1.22E+00 1.38E-01 8.86E+00 1.22E+00 1.38E-01242Pu Activity (Ci)2.37E-03 3.30E-04 1.39E-01 2.38E-03 3.31E-04 1.39E-01 2.38E-03 3.32E-04 1.39E-01241Am Activity (Ci)1.11E+01 2.24E+00 2.02E-01 1.11E+01 2.23E+00 2.01E-01 1.11E+01 2.23E+00 2.01E-0190Sr Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/A137Cs Activity (Ci)N/A N/A N/A N/A N/A N/A N/A N/A N/ATRU 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 1.14E+04 8.98E-02F-12Quantity of InterestOriginal MeasurementSampleMeanSampleStandardDeviationRelativeStandardDeviationχ2Pr(x<|c2|)ReportedValueAbsoluteUncertainty233U Activity (Ci)0.00E+00 N/A N/A N/A N/A 0.00E+00 N/A234U Activity (Ci)2.18E-04 3.40E-05 2.13E-04 9.02E-06 4.23E-02 2.18E-04 3.40E-05238U Activity (Ci)0.00E+00 N/A N/A N/A N/A 0.00E+00 N/A238Pu Activity (Ci)1.78E+00 2.53E-01 1.75E+00 8.94E-03 5.10E-03 1.78E+00 2.53E-01239Pu Activity (Ci)1.48E+01 2.04E+00 1.46E+01 8.94E-02 6.11E-03 1.48E+01 2.04E+00240Pu Activity (Ci)8.93E+00 1.23E+00 8.83E+00 4.87E-02 5.51E-03 8.93E+00 1.23E+00242Pu Activity (Ci)2.40E-03 3.34E-04 2.37E-03 1.30E-05 5.50E-03 2.40E-03 3.34E-04241Am Activity (Ci)1.12E+01 2.26E+00 1.11E+01 7.07E-02 6.37E-03 1.12E+01 2.26E+0090Sr Activity (Ci)0.00E+00 N/A N/A N/A N/A 0.00E+00 N/A137Cs Activity (Ci)0.00E+00 N/A N/A N/A N/A 0.00E+00 N/ATRU Alpha Conc. (nCi/g)1.28E+05 1.15E+04 1.27E+05 7.07E+02 5.57E-03 1.28E+05 1.15E+04237Np Activity (Ci) 9.73E-05 1.27E-05 9.56E-05 5.27E-07 5.51E-03 6.89E-03 1.00E+00235U Activity (Ci) 5.39E-06 8.42E-07 5.28E-06 2.26E-07 4.27E-02 2.87E-01 9.91E-01Quantity of InteresttPr(x<|t|)χ2Testt-Test233U Activity (Ci)N/A N/A Not Applicable Not Applicable234U Activity (Ci)4.66E-01 6.66E-01 Not Significant Not Significant238U Activity (Ci)N/A N/A Not Applicable Not Applicable238Pu Activity (Ci)2.65E+00 5.68E-02 Not Significant Not Significant239Pu Activity (Ci)1.63E+00 1.78E-01Not Significant Not Significant240Pu Activity (Ci)1.91E+00 1.28E-01Not Significant Not Significant242Pu Activity (Ci)1.96E+00 1.22E-01Not Significant Not Significant241Am Activity (Ci)1.29E+00 2.66E-01Not Significant Not Significant90Sr Activity (Ci)N/A N/A Not Applicable Not Applicable137Cs Activity (Ci)N/A N/A Not Applicable Not ApplicableTRU Alpha Conc. (nCi/g)1.29E+00 2.66E-01Not Significant Not Significant237Np Activity (Ci) 2.87E+00 4.53E-02Not SignificantSignificant235U Activity (Ci) 4.29E-01 6.90E-01Not Significant Not Significant237Np Activity (Ci) 9.51E-05 1.24E-05 1.30E-01 9.57E-05 1.25E-05 1.31E-01 9.55E-05 1.25E-05 1.31E-01235U Activity (Ci) 4.92E-06 8.56E-07 1.74E-01 5.49E-06 9.13E-07 1.66E-01 5.43E-06 9.31E-07 1.72E-01