Docket
NO:
OAR­
2002­
0005­
0001
Criteria
for
the
Certification
and
Recertification
of
the
Waste
Isolation
Pilot
Plant's
Compliance
with
the
Disposal
Regulations;
Alternative
Provisions
Background
Information
Document
for
Amendments
to
40
CFR
194.8
(b)

U.
S.
Environmental
Protection
Agency
Office
of
Radiation
and
Indoor
Air
Washington,
DC
20460
July
2002
TABLE
OF
CONTENTS
I.
INTRODUCTION
...........................................................
1
A.
Current
Provisions
and
Summary
of
Pertinent
Elements
........................
1
B.
Waste
Components
and
Waste
Descriptions
.................................
2
B.
1
Radiological
Waste
Components
...................................
3
B.
2
Non­
Radiological
Waste
Components
...............................
5
B.
3
General
Waste
Descriptions
......................................
5
C.
Description
of
Waste
Generators
.........................................
6
D.
Current
Inspection
Process
..............................................
8
II.
DESCRIPTION
OF
TECHNICAL
ELEMENTS
EXAMINED
........................
12
DURING
INSPECTIONS
A.
Acceptable
Knowledge
................................................
13
A.
1.
Overview
of
Technical
Elements
.................................
13
A.
2.
Technical
Description
of
System
or
Measurement
Device(
s)
............
14
A.
3.
Effect
of
Waste
Matrix
Type
on
Measurement
.......................
17
A.
4.
Scope
of
Possible
EPA
Approvals
for
Acceptable
Knowledge
..........
17
B.
Nondestructive
Assay
(NDA)
...........................................
18
B.
1
Overview
of
Technical
Elements
..................................
18
B.
2:
Technical
Description
of
System
or
Measurement
Device(
s)
............
19
B.
2.1
General
System
Information
.............................
19
B.
2.2
Neutron
Systems
.......................................
21
B.
2.3
Passive­
Active
Neutron
Counters
.........................
23
B.
2.4
Photon
Emission
and
NDA
...............................
23
B.
2.5
Gamma
Ray
Spectrometry
Systems
........................
25
B.
2.6
Calorimetry
Instruments
................................
25
B.
3:
Effect
of
Waste
Matrix
or
Waste
Type
on
Measurement
................
25
B.
3.1
Neutron
Counting
Systems
...............................
26
B.
3.2
Photon
Measuring
Systems
..............................
27
B.
4
Scope
of
Possible
EPA
Approvals
for
Nondestructive
Assay
............
27
C.
Visual
Examination
and
Radiography
.....................................
28
C.
1
Overview
of
Technical
Elements
.................................
29
C.
1.1
RTR
Document
Review
..................................
29
C.
1.2
Additional
Verification­
RTR
.............................
31
C.
1.3
VE
Document
Review
..................................
33
C.
1.4
Additional
Verification­
VE
..............................
35
C.
2
Technical
Description
of
System
or
Measurement
Device(
s)
...........
37
C.
2.1
Radiography
..........................................
37
C.
2.2
Visual
Examination
....................................
38
C.
3
Effect
of
Waste
Matrix
or
Waste
Type
on
Measurement
...............
39
C.
4
Scope
of
Possible
EPA
Approvals
for
Radiography
and
Visual
Exam
....
39
D.
WIPP
Waste
Information
System
and
Data
Validation
........................
40
D.
1
Overview
of
Technical
Elements
.................................
40
D.
1.1
Data
Validation/
Verification
and
WWIS
Inspection
Components
41
D.
1.2
Demonstration
of
WWIS
Implementation
..................
42
D.
1.3
Personnel
Qualifications
...............................
42
D.
2
Technical
Description
of
Measurement
Device
......................
43
D.
3
Effect
of
Waste
Matrix
or
Waste
Type
on
Measurement
................
43
D.
4
Scope
of
EPA
Approvals
for
Data
Validation/
Verification
and
the
WWIS
..
44
III.
SUMMARY
OF
RESULTS
AND
LESSONS
LEARNED
...........................
45
A.
Summary
of
Results
...................................................
45
B.
Lessons
Learned
......................................................
50
IV.
SUMMARY
OF
PUBLIC
COMMENTS
ON
EPA
INSPECTIONS
....................
52
V.
CONCLUSIONS
...........................................................
56
REFERENCES
...............................................................
57
ACRONYM
LIST
A&
PCT
Active
and
Passive
Computed
Tomography
AK
Acceptable
Knowledge
Am
Americium
APNEA
Active
and
Passive
Neutron
Examination
and
Assay
ASME
American
Society
of
Mechanical
Engineers
BID
Background
Information
Document
BIR
Baseline
Inventory
Report
CA
Compliance
Assessment
CAO
U.
S.
Department
of
Energy
Carlsbad
Area
Office
(now
the
Carlsbad
Field
Office)
CAR
Corrective
Action
Report
CBFO
U.
S.
Department
of
Energy
Carlsbad
Field
Office
CCA
Compliance
Certification
Application
CCD
Charge
Collection
Device
CCP
Centralized
Characterization
Project
Cf
Californium
CH­
TRU
Contact­
Handled
Transuranic
Waste
Cm
Curium
CPR
cellulosics,
plastics,
rubber
Cs
Cesium
CT
Computed
Tomography
DOE
U.
S.
Department
of
Energy
DR
Digital
Radiography
DTP
Detailed
Technical
Procedure
EEG
Environmental
Evaluation
Group
eV
Electron
Volt
FRAM
Fixed
Energy
Response
Function
Analysis
with
Multiple
Efficiencies
FY
Fiscal
Year
GEA
Gamma
Energy
Assay
2
H
Deuterium
3
H
Tritium
HANDSS­
55
Handling
and
Segregating
System
He
Helium
HENC
High
Efficiency
Neutron
Counter
HPGe
High
Purity
Germanium
IDC
Item
Description
Code
INEEL
Idaho
National
Engineering
and
Environmental
Laboratory
IPAN
Imaging
Passive
Active
Neutron
Counter
KV
Kilovolt
kVp
kilovolts
peak
LANL
Los
Alamos
National
Laboratory
LDA
Linear
Diode
Array
LLNL
Lawrence
Livermore
National
Laboratory
MCS
Mobile
Characterization
Services
msec
Millisecond
NCR
Nonconformance
Reports
NDA
Nondestructive
Assay
NDE
Nondestructive
Evaluation
NMC
Neutron
Multiplicity
Counters
NMED
New
Mexico
Environment
Department
Np
Neptunium
NQA
Nuclear
Quality
Assurance
NRC
U.
S.
Nuclear
Regulatory
Commission
NTS
Nevada
Test
Site
OJT
On­
The­
Job
Training
ORIA
EPA
Office
of
Radiation
and
Indoor
Air
PA
Performance
Assessment
PADC
Passive
Active
Drum
Counter
PAN
Passive­
Active
Neutron
PCB
polychlorinated
biphenyls
PDP
Performance
Demonstration
Program
Pu
Plutonium
QA
Quality
Assurance
QAPjP
Quality
Assurance
Project
Plan
QAPP
Quality
Assurance
Program
Plan
QC
Quality
Control
RCRA
Resource
Conservation
and
Recovery
Act
of
1976
RFETS
Rocky
Flats
Environmental
Technology
Site
RH­
TRU
Remote­
Handled
Transuranic
Waste
RTG
Radioisotopic
Thermal
Generators
RTR
Real­
Time
Radiography
SGS
Segmented
Gamma
Scanner
SGSAS
Segmented
Gamma
Scanner
Assay
System
SOP
Standard
Operating
Procedures
Sr
Strontium
SRIC
Southwest
Research
and
Information
Center
SRS
Savannah
River
Site
SWEPP
SGRS
Stored
Waste
Examination
Pilot
Plant
Gamma
Ray
Spectrometer
SWEPP
PAN
Stored
Waste
Examination
Pilot
Plant
Passive
Active
Neutron
Counter
TGS
Tomographic
Gamma
Scanners
TGS
CAN
Tomographic
Gamma
Can
Scanners
TMFA
Transuranic
and
Mixed
Waste
Focus
Area
TRU
Transuranic
TRUCON
Transuranic
Package
Transporter­
II
Content
Codes
TSDF
Treatment,
Storage,
Disposal,
Recycling
Facilities
TWBIR
Transuranic
Waste
Baseline
Inventory
Report
U
Uranium
UCL90
Upper
90
Percent
Confidence
Limit
V
Volt
VE
Visual
Examination
VEE
VE
Expert
WAC
Waste
Acceptance
Criteria
WAGS
Waste
Assay
Gamma
Spectrometer
WAP
Waste
Analysis
Plan
WIPP
Waste
Isolation
Pilot
Plant
WMC
Waste
Matrix
Code
WMP
Waste
Material
Parameters
WWIS
WIPP
Waste
Information
System
1
I.
INTRODUCTION
The
purpose
of
this
Background
Information
Document
(BID)
is
to
explain
the
Agency's
Waste
Isolation
Pilot
Plant
(WIPP)
transuranic
(TRU)
waste
generator
inspection
process
in
support
of
alternative
provisions
for
40
CFR
Part
194.8,
"Approval
Process
for
Waste
Shipment
from
Waste
Generator
Sites
for
Disposal
at
the
WIPP."
Specifically,
the
Agency
is
proposing
to
revise
section
194.8(
b).
This
document
presents:

I.
The
current
regulatory
provisions
and
the
basis
for
inspections,
a
summary
of
wastes
that
require
inspection,
and
an
overview
of
the
current
inspection
approach.

II.
A
summary
discussion
of
the
major
technical
elements
examined
during
waste
characterization
inspections
at
generator
sites,
including
acceptable
knowledge
(AK),
nondestructive
assay
(NDA),
radiography
(such
as
real­
time
radiography,
or
RTR),
visual
examination
(VE),
and
data
validation/
data
transfer
(via
the
WIPP
Waste
Information
System,
or
WWIS).
These
discussions
present
what
inspectors
examined
and
how
the
results
impact
EPA's
assessment
of
the
waste
characterization
process.
Technical
descriptions
of
measurement
and
examination
devices
are
included,
as
well
as
discussion
of
the
impact
of
different
waste
matrices
on
the
effectiveness
of
the
measuring
or
examination
device,
and
the
range
of
waste
types
that
the
Agency
may
be
able
to
approve
in
the
course
of
an
inspection.

III.
A
summary
of
results
and
general
conclusions
reached
by
Agency
inspectors
from
May
1998
through
the
present.
This
section
identifies
the
number,
scope,
and
results
of
technical
inspections
at
the
generator/
storage
sites.

IV.
Examples
of
public
comments
on
inspection
notices
and
docketed
materials.

V.
Conclusions.

I.
A
Current
Provisions
and
Summary
of
Pertinent
Elements
As
specified
in
§194.24(
b)(
2)
of
the
Compliance
Criteria,
the
U.
S.
Department
of
Energy
(DOE)
was
required
to
conduct
an
analysis
to
identify
waste
components
important
to
performance
assessment
(PA).
Section
194.24(
c)
deals
with
the
identification
of
waste
limits
associated
with
these
critical
components,
as
well
as
how
the
limits
are
included
in
performance
assessments
(§
194.32)
and
compliance
assessments
(§
194.54).
In
addition,
DOE
must
specify
how
waste
components
will
be
identified,
quantified,
tracked,
and
controlled.
Important
components
are
summarized
in
Section
I.
B
of
this
BID.

Waste
characterization,
as
defined
in
§194.24(
c),
is
necessary
to
ensure
that
waste
emplaced
in
the
repository
is
consistent
with
the
parameters
established
in
the
performance
2
assessment
(§
194.32)
and
compliance
assessment
(§
194.54),
and
that
limitations
(or
constraints)
on
radionuclides
and
other
waste
components
established
by
EPA's
certification
decisions
are
not
exceeded.
Waste
characterization
is
also
used
to
ensure
that
the
actual
waste
inventory
is
consistent
with
the
waste
inventory
estimates
presented
in
DOE's
Baseline
Inventory
Report
(BIR),
which
was
used
in
performance
and
compliance
assessment
(PA
and
CA)
calculations.
Waste
characterization
activities
performed
by
DOE
to
demonstrate
compliance
with
§194.24(
c)
include
a
"system
of
controls,"
involving
characterization
techniques
as
well
as
waste
tracking
and
WIPP
inventory
identification
and
management.

In
the
WIPP
certification
rulemaking,
EPA
evaluated
waste
characterization
information
provided
by
DOE
in
its
Compliance
Certification
Application
(CCA)
and
amended
the
Compliance
Criteria
by
adding
section
194.8.
Section
194.8
specifies
the
waste
characterization
approval
process
for
DOE
waste
generator
sites.
Condition
3
of
the
certification
provides
that
DOE
may
not
ship
waste
to
the
WIPP
from
any
waste
stream
­
other
than
wastes
from
specified
waste
streams
­
until
EPA
has
approved
processes
for
characterizing
such
waste
streams
in
accordance
with
the
section
194.8
approval
process.
Section
194.8(
b)
requires
that,
"[
f]
or
each
waste
stream
or
group
of
waste
streams
at
a
site
proposed
for
disposal
at
WIPP,"
DOE
must
provide
information
on
how
process
knowledge
will
be
used
for
waste
characterization
of
the
waste
stream(
s),
and
must
implement
a
system
of
controls
at
the
site,
in
accordance
with
§194.24(
c)(
4).
Section
194.8(
b)
also
states
that
EPA
will
conduct
an
".
.
.
an
inspection
of
a
Department
audit
for
the
purpose
of
evaluating
the
use
of
process
knowledge
and
the
implementation
of
a
system
of
controls
for
each
waste
stream
or
group
of
waste
streams
at
a
waste
generator
site."
Moreover,
DOE
must
demonstrate
that
each
site
has
procedures
in
place
to
communicate
with
DOE's
WIPP
Waste
Information
System
(WWIS).
The
WWIS
is
an
electronic
database
that
contains
information
related
to
the
characterization,
certification,
shipment,
and
emplacement
of
TRU
waste
at
the
WIPP.

In
accordance
with
section
194.8,
EPA
must
announce
scheduled
inspections
in
the
Federal
Register,
place
relevant
DOE
documents
in
the
docket,
and
solicit
public
comment
on
those
documents
for
at
least
30
days.
EPA
also
must
provide
written
audit
or
inspection
decisions
and
place
these
decisions
in
the
public
dockets.
Section
194.8
also
provides
that
subsequent
to
any
positive
determination
of
compliance
under
this
approval
process,
EPA
intends
to
conduct
inspections,
in
accordance
with
§194.21
and
§194.24(
h),
to
confirm
the
continued
compliance
of
the
programs
approved.
The
results
of
such
inspections
are
made
available
to
the
public
through
the
Agency's
public
dockets,
as
described
in
§194.67.

I.
B
Waste
Components
and
Waste
Descriptions
As
required
by
§
194.24(
b)(
2)
and
§
194.24(
c),
DOE
identified
the
waste
components
that
were
expected
to
have
a
significant
effect
on
disposal
system
performance
and
the
emplacement
limits
for
these
components
in
Chapter
4
(Table
4­
10)
of
the
Compliance
Certification
Application
and
in
Appendices
WCA
and
WCL
(Docket
A­
93­
02,
Item
II­
G­
1,
Volume
XIX).
DOE
must
3
determine
the
quantities
of
these
components
in
TRU
waste
containers.
Based
on
DOE's
analysis,
EPA
regulates
the
waste
components
discussed
below.

I.
B.
1
Radiological
Waste
Components
As
discussed
in
Section
24.
A.
6
of
CARD
24
(Docket
A­
93­
02,
Item
V­
B­
2),
EPA
concluded
that
DOE
appropriately
identified
ten
isotopes
most
significant
to
the
PA,
which
EPA
listed
as
241
Am,
244
Cm,
137
Cs,
238
Pu,
239
Pu,
240
Pu,
241
Pu,
90
Sr,
233
U,
and
234
U
(the
cesium
and
strontium
isotopes
and
233
U
are
important
to
remote­
handled
TRU
waste).
These
ten
isotopes
significant
to
PA
comprise
about
99
percent
of
the
EPA
units
anticipated
within
the
WIPP
waste
inventory.
CARD
31,
Application
of
Release
Limits,
contains
an
explanation
of
EPA
units
for
radioisotopes
(Docket
A­
93­
02,
Item
V­
B­
2).
EPA
determined
that
about
90
percent
of
the
total
anticipated
inventory
of
6.55
x
10
6
curies
at
closure
is
expected
to
be
contributed
by
the
following
seven
isotopes:
241
Am,
238
Pu,
239
Pu,
240
Pu,
241
Pu,
244
Cm,
and
234
U
(Figure
1).
See
also
EPA's
Technical
Support
Document
for
Section
194.24:
Consolidated
Technical
Support
Document
–
Compliance
Certification
Review
of
Waste
Characterization
Requirements
(Docket
A­
93­
02,
Item
V­
B­
15).

DOE
identified
the
following
ten
radionuclides
in
Appendix
WCL
(Docket
A­
93­
02,
Item
II­
G
,Volume
XIX)
as
subject
to
identification
and
quantification:

°
238
Pu,
239
Pu,
240
Pu,
and
242
Pu;
°
241
Am;
°
233
U,
234
U,
and
238
U;
°
90
Sr;
and
°
137
Cs.

EPA
examines
tracking
of
the
Appendix
WCL
list
during
inspections
because
the
amount
of
241
Pu
and
244
Cm
may
be
derived
from
measurements
of
isotopes
on
the
WCL
list.
DOE
must
track
these
isotopes
against
the
inventory
estimates
used
in
the
performance
assessment
(the
inventory
estimates
are
listed
in
CARD
31,
Table
3).
As
stated
in
Appendix
WCL,
"[
T]
he
performance
assessment
is
sensitive
to
relative
changes
in
inventory
curie
content
as
a
function
of
radionuclide
decay
and
ingrowth
over
time.
The
magnitude
of
change
in
the
total
curie
content
depends
on
the
initial
ratios
of
the
total
activities
of
the
assayed
radionuclides
at
the
time
of
repository
closure.
Accordingly,
the
results
of
the
performance
assessment
analysis
are
conditional
on
the
ratios
assumed.
.
.."
Consequently,
the
inventory
estimates
upon
which
EPA's
initial
certification
is
based
function
as
constraints
on
the
amount
of
the
key
isotopes
that
may
be
disposed
in
the
WIPP.
Changes
to
the
inventory
estimates
would
necessitate
further
analysis
by
DOE
of
the
effect(
s)
on
the
performance
assessment,
and
perhaps,
a
modification
of
the
certification.

Figure
1.
Percentage
of
Total
Inventory
Contributed
by
PA­
Significant
Isotopes
(Curies)
4
Pu­
240
2.89%
U­
234
0.01%
All
Others
11.93%
Cm­
244
0.43%

Am­
241
6.02%

Pu­
239
10.69%
Pu­
241
32.94%
Pu­
238
35.09%

Source:
EPA
T
echnical
S
upport
Document
for
Section
194.24
(Air
Docket
A­
93­
02,
Item
V­
B­
15,
Section
4.2.3)

I.
B.
2
Non­
Radiological
Waste
Components
5
In
addition,
DOE
identified
other
waste
components
that
were
expected
to
have
a
significant
effect
on
disposal
system
performance
and
which
require
limits
(Appendix
WCL,
Table
WCL­
1).
The
non­
radiological
waste
components
with
limiting
values
are:

°
Ferrous
metals
(iron):
minimum
of
2x10
7
kilograms;
°
Cellulosics/
plastic/
rubber:
maximum
of
2x10
7
kilograms;
°
Free
water
emplaced
with
waste:
maximum
of
1684
cubic
meters;
and
°
Nonferrous
metals
(metals
other
than
iron):
minimum
of
2x10
3
kilograms
I.
B.
3
General
Waste
Descriptions
EPA
examines
general
waste
descriptions
prepared
by
DOE
sites
to
understand
how
radiological/
non­
radiological
components
are
grouped
and
assessed.
Wastes
can
be
assigned
waste
material
parameters
that
encompass
those
components
with
limiting
values
identified
by
DOE.
The
DOE
identified
(Appendix
BIR
of
the
CCA)
the
following
12
different
waste
material
parameters
and
3
different
contents
packaging
materials
which
are
tracked
by
sites
and
which
allows
quantification
of
non­
radionuclide
waste
components:

Waste
Material
Parameters
°
Iron­
base
metal/
alloys
°
Aluminum­
base
metal/
alloys
°
Other
metal/
alloys
°
Other
inorganic
materials
°
Vitrified
materials
°
Cellulosics
°
Rubber
°
Plastics
°
Solidified
inorganic
materials
°
Solidified
organic
materials
°
Cement
(solidified)
°
Soils
Contents
Packaging
Materials
°
Steel
°
Plastic
°
Lead
(for
RH­
TRU
waste
only)

Waste
generator
sites
typically
group
waste
by
"waste
streams,"
which
are
defined
as
".
.
.
waste
material
generated
from
a
single
process
or
from
an
activity
that
is
similar
in
material,
physical
form,
and
hazardous
constituents"
(Appendix
WAP).
Waste
streams
are
not
defined
by
6
their
radionuclide
content,
but
instead
are
grouped
by
chemical,
physical,
and
process
similarities.
The
Transuranic
Waste
Baseline
Inventory
Report
(TWBIR,
Appendix
BIR)
identified
569
different
waste
streams
that
will
be
emplaced
in
the
repository.
These
wastes
are
also
be
categorized
into
broader
Summary
Waste
Category
Groups,
defined
as
S5000
(debris),
S4000
(soil/
gravel),
and
S3000
(solidified)
waste.
Generator
sites
tend
to
group
waste
by
Summary
Waste
Category
Group
for
inspection
purposes.

I.
C
Description
of
Waste
Generators
The
wastes
to
be
emplaced
in
the
WIPP
originate
from
generator/
storage
sites
within
the
DOE
Weapons
Complex
and
National
Laboratories.
Waste
must
be
defense­
related
TRU
waste,
and
the
range
of
wastes
at
each
generator/
storage
site
is
dependent
upon
the
site's
past
and
current
missions.
The
generator/
storage
sites
and
the
volumes
of
contact­
handled
TRU
(CH­
TRU)
and
RH­
TRU
waste
expected
are
identified
in
Table
1.

Table
1
Anticipated
Waste
Volumes
for
Disposal
at
WIPP
7
Storage
Generator
Site
Anticipated
CH­
TRU
Waste
(cubic
meters)
Anticipated
RH­
TRU
Waste
(cubic
meters)

Ames
Laboratory
0.42
None
Reported
Argonne
National
Laboratory­
East
140
None
Reported
Argonne
National
Laboratory
­
West
750
1,300
Battelle
Columbus
Laboratories
None
Reported
580
Bettis
Atomic
Power
Laboratory
120
6.7
Energy
Technology
Engineering
Center
1.7
0.89
Hanford
Site*
46,000
22,000
INEEL*
29,000
220
Lawrence
Livermore
National
Laboratory*
940
None
Reported
LANL*
18,000
190
Mound
Plant
270
None
Reported
Nevada
Test
Site*
630
None
Reported
Oak
Ridge
National
Laboratory*
1600
2,900
Paducah
Gaseous
Diffusion
Plant
1.9
None
Reported
Pantex
Plant
0.62
None
Reported
RFETS*
5,100
None
Reported
Sandia
National
Laboratory
14
None
Reported
Savannah
River
Site*
9,600
None
Reported
Teledyne
Brown
Engineering
0.21
None
Reported
U.
S.
Army
Material
Command
2.5
None
Reported
University
of
Missouri
Research
Center
1.0
None
Reported
Totals
110,000
27,000
CH­
TRU
=
contact­
handled
transuranics;
INEEL
=
Idaho
National
Engineering
and
Environmental
Laboratory;
LANL
=
Los
Alamos
National
Laboratories;
RFETS
=
Rocky
Flats
Environmental
Technology
Site;
RH­
TRU
=
remote­
handled
transuranics
(*)
Major
Sites
Source:
DOE
CCA,
Chapter
4.

These
totals
do
not
include
wastes
excluded
at
the
time
of
the
Compliance
Application
(i.
e.,
uncharacterized
and
classified
wastes).
There
are
additional
wastes
that
could
be
added
to
the
anticipated
inventory
in
the
event
that
the
classified
waste
streams
are
declassified
or
the
unclassified
wastes
are
identified
and
characterized.
Waste
streams
from
three
of
the
eight
major
sites
(Savannah
River,
Rocky
Flats,
and
Los
Alamos
National
Laboratories
[LANL]),
are
expected
to
contribute
over
85
percent
of
the
total
activity
for
seven
key
isotopes.
1
The
potential
contents
of
a
waste
stream
or
group
of
waste
streams
determine
which
processes
can
be
used
to
adequately
characterize
the
waste.
For
example,
if
acceptable
knowledge
information
suggests
that
the
waste
form
is
heterogeneous,
the
site
should
select
a
nondestructive
assay
technique
appropriate
for
such
waste
in
order
for
adequate
measurements
to
be
obtained.
Radiography
and
visual
examination
help
both
to
confirm
and
quantify
waste
components,
such
as
cellulosics,
rubbers,
plastics,
and
metals.
Once
the
nature
of
the
waste
has
been
confirmed,
the
assay
techniques
then
quantify
the
radioactive
isotopes
in
the
waste.
In
the
given
example,
a
TRU
waste
site
may
be
able
to
characterize
either
a
wide
range
of
heterogeneous
waste
streams
or
only
a
few.
Under
the
current
regulation,
the
scope
of
a
particular
inspection
is
determined
by
a
site's
stated
limits
on
the
applicability
of
proposed
waste
characterization
processes.

2
Process
knowledge
refers
to
knowledge
of
waste
characteristics
derived
from
information
on
the
materials
or
processes
used
to
generate
the
waste.
This
information
may
include
administrative,
procurement,
and
quality
control
documentation
associated
with
the
generating
process,
or
past
sampling
and
analytic
data.
Usually,
the
major
elements
of
process
knowledge
include
information
about
the
process
used
to
generate
the
waste,
material
inputs
to
the
process,
and
the
time
period
during
which
the
waste
was
generated.
EPA
has
used
the
term
"acceptable
knowledge"
synonymously
with
"process
knowledge."
Acceptable
knowledge
is
discussed
further
in
Section
II.

8
I.
D
Current
Inspection
Process
EPA
evaluates
the
ability
of
each
generator
site's
waste
characterization
program
to
adequately
characterize
TRU
waste
through
the
inspection
process
as
established
in
§194.8(
b).
Inspections
at
generator/
storage
sites
are
conducted
to
verify
that
characterization
activities
are
performed
in
accordance
with
approved
site
procedures
and
that
the
characterization
activities
are
adequate
and
appropriate
to
characterize
and
quantify
waste
from
specific
waste
streams
and
waste
containers
so
that
the
waste
will
not
exceed
the
approved
limits.
By
approving
waste
characterization
systems
and
processes,
EPA
concludes
the
following:
(1)
the
site
personnel
are
capable
of
identifying
and
measuring
the
radioactive
components
(such
as
plutonium)
in
the
TRU
waste
that
must
be
tracked
for
compliance
1
;
and
(2)
the
characterization
program
can
demonstrate
that
the
waste
stream(
s)
examined
meet
Condition
3
of
the
Compliance
Certification
Criteria.

The
approval
process
described
at
40
CFR
194.8(
b)
requires
DOE
to
provide
EPA
with
two
types
of
information:
(1)
information
on
process
knowledge
2
for
waste
streams
proposed
for
disposal
at
WIPP,
and
(2)
information
on
the
system
of
controls
in
place
at
the
generator
site.
The
Agency
solicits
public
comments
on
DOE
site
documentation
and
announces
the
date
of
the
upcoming
inspection.

An
EPA
inspection/
surveillance
team
visits
the
site
to
verify
that
process
knowledge
and
other
elements
of
the
system
of
controls
are
technically
adequate
and
being
implemented
properly.
Specifically,
the
EPA
inspection/
surveillance
team
verifies
compliance
with
40
CFR
194.24(
c)(
4),
which
states:

Any
compliance
application
shall:
Provide
information
which
demonstrates
that
3
The
introductory
text
of
paragraph
40
CFR
194.24(
c)
states:
"For
each
waste
component
identified
and
assessed
pursuant
to
[40
CFR
194.24(
b)],
the
Department
shall
specify
the
limiting
value
(expressed
as
an
upper
or
lower
limit
of
mass,
volume,
curies,
concentration,
etc.),
and
the
associated
uncertainty
(i.
e.,
margin
of
error)
for
each
limiting
value,
of
the
total
inventory
of
such
waste
proposed
for
disposal
in
the
disposal
system."

9
a
system
of
controls
has
been
and
will
continue
to
be
implemented
to
confirm
that
the
total
amount
of
each
waste
component
that
will
be
emplaced
in
the
disposal
system
will
not
exceed
the
upper
limiting
value
or
fall
below
the
lower
limiting
value
described
in
the
introductory
text
of
paragraph
(c)
of
this
section.
3
The
system
of
controls
shall
include,
but
shall
not
be
limited
to:
measurement;
sampling;
chain
of
custody
records;
record
keeping
systems;
waste
loading
schemes
used;
and
other
documentation.

As
waste
generator
sites
establish
waste
characterization
programs
for
new
waste
streams
(or
groups
of
waste
streams),
the
Agency
assesses
their
compliance
with
the
requirements
of
Sections
194.24(
c)(
3)
through
(5).
The
Agency
conducts
inspections
at
each
site
to
evaluate
the
use
of
process
knowledge
and
the
establishment
of
a
system
of
characterization
and
controls
for
each
waste
stream
or
group
of
waste
streams.
The
typical
elements
that
are
subject
to
inspection
include
NDA,
VE
and/
or
Radiography,
AK,
and
software
controls
to
include
operation
and
interface
with
the
WWIS.
Elements
related
to
the
control
of
characterization
systems,
such
as
training
records
and
document
control,
are
also
subject
to
inspection.
The
scope
of
a
specific
inspection
is
dictated
by
the
systems
that
are
in
use
for
a
group
of
waste
streams,
how
many
of
these
systems
have
been
previously
inspected
and
approved
by
the
Agency,
and
if
the
nature
of
the
waste
stream
changes
the
performance
of
any
elements
of
the
characterization
system.
For
EPA
to
confirm
that
a
system
of
controls
has
been
adequately
executed,
DOE
must
demonstrate
that
measurement
techniques
and
other
control
methods
can
be
implemented
for
waste
streams
that
DOE
plans
to
emplace
in
the
WIPP.
The
number
of
waste
streams
or
groupings
of
waste
streams
that
can
be
approved
is
dependent
upon
how
well
the
generator
site
systems
perform
for
a
variety
of
wastes.
While
EPA
can
and
has
approved
relatively
broad
groupings
that
mirror
the
specific
authorization
being
sought
by
sites,
EPA
has
also
restricted
its
approval
to
those
waste
streams
it
felt
could
be
adequately
characterized
by
the
systems
examined.

The
Agency's
compliance
decision
is
conveyed
by
a
letter
from
EPA
to
DOE.
A
copy
of
the
letter,
as
well
as
the
results
of
the
inspection(
s),
are
placed
in
EPA's
docket.

To
summarize,
the
approval
process
for
site­
specific
waste
characterization
controls
is
as
follows
(See
Figure
2):

a.
One
or
more
Federal
Register
notices
for
the
inspection
and
placement
of
related
documents
in
the
docket;

b.
30­
day
public
comment
period
on
docketed
information
from
the
site
to
be
inspected;
10
A
fe
d
er
a
l
r
e
g
i
s
t
e
r
n
o
t
i
c
e
f
o
r
t
h
e
i
n
s
p
e
c
t
i
o
n
o
f
a
s
i
t
e
a
n
d
pla
c
e
m
e
nt
of
r
e
l
a
t
e
d
s
i
t
e
p
r
o
c
e
d
u
r
e
s
a
n
d
r
e
p
o
r
t
s
i
n
t
h
e
d
o
c
k
e
t
A
g
e
n
c
y
p
r
e
p
a
r
e
s
f
o
r
s
i
t
e
i
n
s
p
e
c
t
i
o
n
/a
u
d
i
t
b
y
c
omple
t
i
n
g
t
h
e
f
o
l
l
o
w
i
n
g
t
a
s
k
s
:
°
Pr
e
p
a
r
a
t
i
o
n
o
f
d
r
a
f
t
c
h
e
c
kl
ists
°
R
e
vie
w
of
si
te
p
r
o
c
e
d
u
r
e
s
a
n
d
r
e
p
o
r
t
s
°
Mo
di
f
i
c
a
t
i
o
n
o
f
c
h
e
c
k
l
i
s
t
s
a
s
n
e
e
d
e
d
b
a
s
e
d
u
p
o
n
si
t
e
­
s
p
e
ci
f
ic
pro
c
e
d
u
r
e
s
C
o
n
d
u
ct
Si
t
e
I
n
s
p
e
c
t
i
o
n
/A
u
d
i
t
Fig
ur
e
2
Si
te
A
p
pro
v
al
Pro
c
e
s
s
c.
Performance
of
site
inspection
based
on
information
provided
by
DOE:

°
Review
of
site
procedures
and
other
information,
and
modification
of
EPA
checklists,
if
necessary,
to
incorporate
site­
specific
information;

°
On­
site
verification
of
the
technical
adequacy
or
qualifications
of
personnel,
procedures,
and
equipment
by
means
of
interviews,
demonstrations,
and
completion
of
checklists;
and
d.
Preparation
of
report
documenting
EPA's
inspection(
s)
and
written
notice
to
DOE
of
EPA's
compliance
decision.

Under
40
CFR
194.21
and
194.24(
h),
EPA
is
authorized
to
perform
follow­
up
inspections
to
verify
that
a
TRU
waste
site
is
shipping
waste
that
belongs
only
to
those
waste
streams
or
groups
of
waste
streams
that
have
been
characterized
by
the
approved
processes.
In
the
event
that
the
inspection
finds
that
the
generator/
storage
site
is
not
adequately
meeting
the
waste
characterization
requirements
of
§§
194.24(
c)(
3)
through
(5),
the
agency
will
not
certify
the
generator/
storage
site
until
the
inadequacies
are
resolved
and
the
resolution
verified
usually
through
further
inspection.
11
A
federal
register
notice
for
the
inspection
of
a
site
and
placement
of
related
site
procedures
and
reports
in
the
docket
Agency
prepares
for
site
inspection/
audit
by
completing
the
following
tasks:

°Preparation
of
draft
checklists
°Review
of
site
procedures
and
reports
°Modification
of
checklists
as
needed
based
upon
site­
specific
procedures
Has
the
Agency
determined
that
the
site
should
be
certified
based
upon
inspection
results?
(Y/
N)

Agency
grants
approval
for
audited
scope
Conduct
Site
Inspection/
Audit
Yes
No
Figure
2
Site
Approval
Process
12
II.
DESCRIPTION
OF
TECHNICAL
ELEMENTS
EXAMINED
DURING
INSPECTIONS
Specific
waste
characterization
processes,
techniques,
and
elements
important
to
demonstrating
40
CFR
194.24(
c)
compliance
are
examined
by
EPA
during
inspections,
including:

°
Acceptable
Knowledge
(AK).
AK
is
a
program
whereby
historic
process
data
and
other
data
are
assembled,
assessed,
and
evaluated
to
calculate
the
radionuclide
content,
in
terms
of
both
overall
quantity
and
the
presence
of
specific
isotopes.
This
information
is
typically
compared
to
assay
and
other
measured
data
to
assess
the
viability
of
the
AK
results,
but
also
often
provides
direct
information
used
by
NDA
personnel
in
the
form
of
a
"check"
for
NDA,
as
a
source
of
isotopic
information,
or
as
a
direct
replacement
for
NDA
measurements
when
sites
believe
their
AK
information
is
preferable
to
that
obtained
through
measurement.
At
present,
sites
are
required
to
analyze
all
TRU
waste
containers
to
determine
isotopic
contents
and
confirm
AK.

°
Nondestructive
Assay
(NDA).
NDA
systems
are
used
to
detect
radionuclide
content,
including
the
quantity
and
isotopic
distribution.
These
systems
typically
involve:
1)
neutron
systems
(e.
g.,
Passive­
Active
Neutron
(PAN)
system)
for
quantification
of
a
plutonium
isotope;
and/
or
2)
Segmented
Gamma
Scanner
(SGS),
or
a
comparable
system,
typically
used
to
identify
specific
radioisotopes.
Currently,
all
waste
containers
are
assayed
to
quantify
10
WIPP­
tracked
radionuclides.
In
certain
properly
justified
cases,
isotopic
information
was
obtained
from
AK.

°
Real­
time
Radiography
(RTR).
RTR
records
continuous
x­
ray
of
drum
contents
that
is
used
to
verify
waste
material
parameters
and
the
correctness
of
the
waste
matrix
code
identified
by
AK,
as
well
as
to
quantify
cellulosics,
plastic,
and
rubbers.

°
Visual
Examination
(VE).
The
process
of
opening
a
statistically
determined
number
of
waste
drums
and
manually
examining
and
recording
their
contents
is
called
VE.
VE
is
used
as
a
quality
control
check
of
RTR.

°
WIPP
Waste
Information
System
(WWIS).
WWIS
is
a
data
tracking
and
validation
system
that
includes
data
collection
and
entry
at
the
site,
and
transmission
to
and
receipt
of
data
at
the
WIPP
site.

These
techniques
are
discussed
in
more
detail
in
the
following
subsections.
EPA
requirements
and
expectations
for
these
techniques
are
derived
both
from
40
CFR
194.24
and
DOE's
own
program
requirements,
as
presented
in
the
CCA
and
revised
over
time
with
EPA's
review
and
approval.
13
II.
A
Acceptable
Knowledge
AK
is
generally
defined
as
the
use
of
process
information
or
other
waste
generator
data
to
determine
waste
content.
AK
is
a
Resource
Conservation
and
Recovery
Act
of
1976
(RCRA)
characterization
process
that
has
been
adopted
by
DOE
as
a
TRU
waste
characterization
methodology
applicable
to
the
radioactive,
as
well
as
the
hazardous,
portion
of
the
waste.
To
date,
two
guidance
documents
address
AK
(EPA
1994,
EPA
1997),
both
of
which
address
characterization
of
the
hazardous,
not
radioactive,
portion
of
the
waste
using
AK.
The
concept
has
been
extended
by
DOE
to
encompass
the
radioactive
portion
of
TRU
waste,
with
the
TRU
waste
AK
characterization
requirements
presented
in
attachment
WAP
of
the
CCA,
as
well
as
in
the
1995
WIPP
TRU
Quality
Assurance
Project
Plan
(QAPjP)
referenced
in
the
CCA.

In
joint
EPA/
NRC
guidance
(1997),
which
is
primarily
applicable
to
low­
level
mixed
waste,
EPA
recognized
the
use
of
AK
to
make
RCRA
hazardous
waste
determinations.
The
guidance
does
not,
however,
speak
to
the
use
of
AK
to
determine
radioactive
component
content,
except
to
state
that
the
NRC
does
not
describe
specific
testing
requirements
for
waste
to
determine
if
it
is
radioactive
(10
CFR
20.2006
requires
that
the
waste
manifest
include,
as
completely
as
practicable,
the
radionuclide
identity
and
quantity
and
the
total
radioactivity).

The
1994
and
1997
guidances
both
state
that
the
use
of
waste
knowledge
by
a
generator
and/
or
treatment,
storage,
disposal,
recycling
facilities
(TSDF)
to
characterize
mixed
waste
is
allowed
–
and
even
recommended
–
to
eliminate
unnecessary
or
redundant
waste
testing.
EPA
broadly
interprets
AK
to
include:

°
Process
knowledge,
which
is
detailed
information
on
waste
obtained
from
existing
published
or
documented
waste
analysis
data,
from
a
waste
generator's
records
,
or
from
wastes
generated
by
processes
similar
to
that
which
generated
the
waste;

°
Available
records
of
radionuclides
analysis;
or
°
Combinations
of
both,
supplemented
by
confirmatory
analysis.

II.
A.
1
Overview
of
Technical
Elements
AK
is
used
by
DOE
in
the
context
of
radioactive
waste
characterization
to
provide
the
following:

°
Waste
stream
identification
°
Radionuclide
isotopic
content,
°
Isotopic
ratios,
°
Low
level
vs.
TRU
designation
°
Overall
radioactivity
based
on
facility
records
and
process
information
14
°
Physical
waste
type
°
Waste
material
parameter
content
As
indicated
in
Section
I,
DOE
is
required
to
identify
and
quantify
specific
WIPP­
tracked
isotopes,
additional
isotopic
information
to
support
waste
limits
presented
in
the
CCA,
as
well
as
inventory
estimates
presented
in
Attachment
BIR
of
the
CCA.
Additionally,
waste
material
parameters
require
identification.
AK
is
used
to
obtain
available
information
pertaining
to
these
required
parameters,
and
this
information
is
available
to
NDA
and
nondestructive
evaluation
(NDE)
personnel
to
facilitate
their
measurement
activities.
Additionally,
information
derived
via
AK
is
compared
to
that
obtained
by
NDA
measurement
to
assess
the
accuracy
of
AK
data.

II.
A.
2
Technical
Description
of
System
or
Measurement
Device(
s)

AK
requirements
are
presented
in
the
WIPP
QAPjP
(Docket
A­
93­
02,
Item
II­
G­
1,
Reference
201),
as
well
as
Appendix
WAP
to
the
CCA.
Since
submission
of
the
CCA,
DOE
has
removed
AK
requirements
from
the
QAPjP
because
it
was
redundant
with
the
RCRA
Waste
Analysis
Plan
(WAP)
with
respect
to
AK
requirements.
As
such,
EPA
uses
the
most
recent
version
of
the
WAP
as
the
governing
document
for
AK
requirements.

AK
is
gathered,
evaluated,
and
assessed
following
a
specific
process
committed
to
by
the
DOE
in
its
CCA
via
associated
attachments
and
references.
This
process,
which
is
examined
by
EPA
during
inspections,
includes:

°
Assembling
AK
information;
°
Compiling
AK
documentation
into
an
auditable
record
(i.
e.,
the
process
should
include
review
of
AK
information
to
determine
the
waste
material
parameters
and
radionuclides
present,
as
well
as
source
info
discrepancy
resolution);
°
Assigning
waste
streams/
waste
matrix
codes;
°
Identifying
physical
forms,
waste
material
parameters,
and
radionuclides
(including,
if
possible,
isotopic
ratios);
°
Resolving
data
discrepancies;
°
Identifying
management
controls
for
discrepant
items/
containers/
waste
streams;
°
Confirming
AK
information
with
other
analytical
results
by
comparing
AK
characterization
data
with
that
obtained
through
NDA,
NDE,
and/
or
visual
examination,
including
discrepancy
resolution;
and
°
Auditing
of
AK
records.

EPA
examines
these
elements
during
inspections
to
ensure
that
the
process
is
being
followed.
Specifically,
EPA
examines
whether
procedures
demonstrate
a
logical
progression
from
general
facility
information
to
more
detailed
waste
stream­
specific
information.
EPA
examines
whether
the
site's
TRU
waste
management
program
has
procedures
to
determine:
15
°
Waste
categorization
schemes
(e.
g.,
consistent
definitions
of
waste
streams)
and
terminology,
°
Breakdown
of
the
types
and
quantities
of
TRU
waste
generated/
stored
at
the
site,
and
°
How
waste
is
tracked
and
managed
at
the
generator
site,
including
historical
and
current
operations.

As
indicated
previously,
EPA
is
particularly
concerned
about
the
completeness
and
accuracy
of
data
collection
with
respect
to
those
elements
critical
to
continued
compliance.
Data
gathered
under
the
AK
process
should
support
identification
of
radionuclides
and
parameters
important
to
WIPP
performance,
as
well
as
information
useful
when
assessing
the
accuracy
of
PA
inventory
assumptions
presented
in
the
BIR.
EPA
examines
the
AK
process
to
see
whether
radionuclide
origin
is
documented
and
that
information
is
collected
for:

°
241
Am,
238
Pu,
239
Pu,
240
Pu,
242
Pu,
233
U,
234
U,
238
U,
90
Sr,
137
Cs,
and
unexpected
radionuclides,
°
Ferrous
metals
(in
containers),
°
Cellulosics,
plastics,
rubber,
and
°
Nonferrous
metals
(in
containers).

In
addition
to
this
information,
EPA
expects
AK
information
to
be
properly
managed
and
recorded
by
following
procedures
requiring
that:

°
AK
information
be
compiled
in
an
auditable
record,
including
a
road
map
for
all
applicable
information.
°
A
reference
list
be
provided
that
identifies
documents,
databases,
QA
protocols,
and
other
sources
of
information
that
support
AK
information.
°
The
overview
of
the
facility
and
TRU
waste
management
operations
in
the
context
of
the
facility's
mission
be
correlated
to
specific
waste
stream
information.
°
Correlations
between
waste
streams,
with
regard
to
time
of
generation,
waste
generating
processes,
and
site­
specific
facilities
be
clearly
described.
For
newly
generated
wastes,
the
rate
and
quantity
of
waste
to
be
generated
shall
be
defined.
°
Nonconforming
waste
be
segregated.

The
AK
record
must
contain
the
following
items:

°
A
map
of
the
site
that
identifies
the
areas
and
facilities
involved
in
TRU
waste
generation,
treatment,
and
storage;
°
Facility
mission
description
related
to
TRU
waste
generation
and
management;
°
Description
of
the
operations
that
generate
TRU
waste
at
the
site
and
process
information,
including:
­
Area(
s)
or
building(
s)
from
which
the
waste
stream
was
or
is
generated,
­
Estimated
waste
stream
volume
and
time
period
of
generation,
­
Waste
generating
process
description
for
each
building
or
area,
16
­
Process
flow
diagrams,
if
appropriate,
­
Generalized
material
inputs
or
other
information
that
identifies
the
radionuclide
content
of
the
waste
stream
and
the
physical
waste
form;
and
°
Types
and
quantities
of
TRU
waste
generated,
including
historical
generation
through
future
projections.

Additionally,
EPA
expects
sites
to
collect
additional
"supplemental,"
or
supporting
information
as
available
to
bolster
information
included
in
the
AK
record,
which
may
include
but
not
be
limited
to
historical
safeguard
data
(for
radionuclides),
waste
package
information,
shipping
records,
etc.
As
a
test
of
AK
data
viability,
NDE
and
NDA
information
are
compared
to
AK
data
to
assess
AK
information
accuracy
(this
is
sometimes
called
"confirmation").
EPA
examines
whether
reevaluation
of
AK
is
performed,
if
NDE/
NDA
or
VE
identify
waste
to
be
of
a
different
waste
matrix
category
(such
as
sludges
vs.
debris)
or
radionuclide
content.
The
reevaluation
should
include,
as
applicable,
waste
reassignment
to
a
new
waste
stream
and
repackaging,
if
appropriate.

All
of
the
requisite
AK
data
are
assembled
in
an
AK
Summary
that
compiles
and
summarizes
information
collected,
including
the
basis
for
all
waste
stream
designations.
EPA
examines
the
AK
Summary
for
several
elements,
including
but
not
limited
to
whether
the
AK
Summary
addresses
radionuclide
content
of
waste,
how
detailed
this
information
is,
the
nature
of
supporting
documentation,
completeness
of
the
AK
Summary
with
respect
to
inclusion
of
all
pertinent
AK
data,
accuracy
of
process
discussions
within
the
AK
Summary,
traceability
of
AK
information
on
a
drum/
container
basis,
and
AK
accuracy
calculations
(which
are
generally
included
in
documents
outside
of
the
AK
Summary).

EPA
examines
the
AK
process
and
the
accuracy
and
viability
of
the
information
obtained
through
this
process.
As
part
of
this
examination,
EPA
performs
a
traceability
analysis
where
drums
are
randomly
selected
and
AK
data
pertinent
to
those
drums
examined.
This
activity
includes
not
only
historic
AK
information,
but
NDA
and
NDE
data
collected
under
EPA/
WIPPapproved
programs,
and
comparison
of
these
data
to
AK
to
demonstrate
that
the
complete
characterization
process
is
attainable
and
approveable.
Additionally,
EPA
examines
the
interface
between
NDA,
NDE,
and
AK
to
see
how
information
is
shared
and
used
between
the
various
characterization
processes.
AK
is
intended
to
serve
as
the
"starting
point"
from
which
basic
waste
information
is
assembled
and
examined;
this
information
is
then
used
to
varying
degrees
by
the
NDE
and
NDA
personnel
when
performing
radionuclide
assay
or
x­
rays
to
assess
drum
waste
material
and
prohibited
item
contents.

AK
information
is
available
to
NDA
operators
to
use
when
performing
drum
analysis
as
a
source
of
matrix
information
and
radionuclide
content
information
against
which
measurements
are
"checked."
Also,
NDA
often
relies
on
AK
to
provide
isotopic
information,
including
isotopic
ratios.
On
a
case
by
case
basis,
EPA
has
allowed
this
AK
information,
if
demonstrated
to
be
viable
and
of
exceptional
quality,
to
be
used
in
the
radionuclide
characterization
process.
For
17
example,
EPA
has
allowed
a
site
to
define
the
isotopic
distribution
using
AK,
but
has
required
verification
of
one
or
two
isotopes
in
each
drum
to
confirm
the
AK­
identified
isotopes
of
a
number
of
radionuclides.
Specifically,
EPA
has
allowed
a
site
(RFETS)
to
identify
weapons
grade
plutonium
isotopic
distributions
for
plutonium
isotopes
using
AK,
but
has
required
measurement
of
two
isotopes
in
each
container
to
confirm
the
AK
isotopes.

II.
A.
3
Effect
of
Waste
Matrix
Type
on
Measurement
The
viability
of
the
AK
process
is
more
directly
related
to
the
adequacy
of
AK
information
available
than
to
the
waste
matrix
type.
Generator
facilities
are
currently
assembling
AK
information
on,
and
characterizing
wastes
with,
the
best
available
AK
information.
These
wastes
typically
have
a
significant
body
of
information
available
through
site
records,
process
information,
historic
assay,
etc.,
and
the
resulting
AK
data
assembly,
assessment,
and
verification
process
is
generally
successful.
However,
existing
wastes
to
be
characterized
in
the
future
may
have
much
less
historic
information
available,
which
means
that
the
AK
process
aspect
of
waste
characterization
could
have
varying
degrees
of
success
with
respect
to
collection
of
mandatory
and
supplemental
information,
acquisition
of
radionuclide
data,
etc.
Therefore,
the
AK
process
is
not
so
much
affected
by
the
waste
matrix,
but
instead
by
the
age
of
the
waste,
the
historic
information
available
for
the
waste,
and
the
success
of
data
collection
efforts
by
the
generator
sites.

II.
A.
4
Scope
of
EPA
Approvals
for
AK
EPA
typically
approves
site
AK
on
a
Summary
Waste
Category
basis,
primarily
because
sites
themselves
limit
the
approvals
being
sought
to
this
categorization.
However,
EPA's
overall
approval
of
any
given
site
may
be
limited
to
groups
within
the
Summary
Waste
Category
group,
depending
upon
the
technical
viability
of
the
various
characterization
processes.
For
example,
even
if
AK
approval
extends
to
all
retrievably
stored
waste,
overall
approval
could
be
limited
if
NDA
approval
can
only
be
extended
to
a
specific
type
of
waste.
EPA
also
approves
the
AK
process
for
relatively
large
groups
of
wastes
that
are
not
necessarily
restricted
by
Summary
Waste
Category
Groupings.
For
example,
wastes
generated
at
Rocky
Flats
and
currently
in
storage
at
INEEL
tend
to
have
relatively
complete
data
records,
regardless
of
the
Summary
Waste
Category
group
in
question.
Even
if
there
is
little
AK
information,
EPA
can
and
has
extended
approval
of
the
process
if
the
site
is
able
to
demonstrate
a
thorough
understanding
of
the
AK
process.
In
short,
EPA
may
approve
whatever
is
appropriate
given
a
site's
ability
to
characterize
waste
using
the
AK
process.
AK
approval
is
restricted
by
the
quantity
and
quality
of
AK
data,
not
by
the
waste
type.

II.
B
Nondestructive
Assay
(NDA)

NDA
is
used
to
identify
and
quantify
the
radioactive
constituents
in
a
container.
Waste
to
be
disposed
of
at
WIPP
is
assayed
on
a
container
basis
to
quantify
the
activity
of
the
18
radionuclides,
particularly
those
identified
in
the
transuranic
waste
baseline
inventory
report
TWBIR
as
most
important
to
the
PA,
and
to
demonstrate
that
the
waste
in
the
container
meets
the
definition
of
TRU
waste.

II.
B.
1
Overview
of
Technical
Elements
NDA
examines
the
ten
isotopes
requiring
quantification,
as
well
as
additional
isotopes.
The
ten
isotopes
are:

°
238
Pu,
239
Pu,
240
Pu,
and
242
Pu;
°
241
Am;
°
233
U,
234
U,
and
238
U;
°
90
Sr;
and
°
137
Cs.

In
addition
to
the
isotopes
listed
as
important
to
PA
and
requiring
quantification,
the
waste
characterization
program
also
is
responsible
for
adequately
calculating
the
emplaced
activities
of
the
isotopes
contributing
to
the
Waste
Unit
(in
this
case,
the
activity
of
the
TRU
alpha
emitting
isotopes
in
Table
4­
8
of
the
CCA).
Section
4.4.1
of
the
CCA
states,

Collectively,
those
elements
of
the
waste
characterization
program
that
support
long­
term
regulatory
compliance
include
the
determination
of
the
radionuclide
inventory
(for
purposes
of
normalizing
radionuclide
releases
as
required
for
comparison
with
40
CFR
Part
191.13(
a)),
the
identification
of
the
physical
and
chemical
waste
form
inventories
(if
applicable),
and
the
verification
that
no
wastes
are
emplaced
in
the
WIPP
that
exceed
the
disposal
system's
safety
and/
or
performance
limitations.

The
normalization
requirement
in
Table
1
referenced
in
40
CFR
Part
191.13(
a)
necessitates
knowledge
of
the
EPA
Waste
Unit,
defined
as
the
total
curies
divided
by
one
million.

EPA
has,
as
part
of
the
inspection
program,
also
required
DOE
to
quantify
isotopes
other
than
those
identified
as
important
in
the
CCA
or
40
CFR
Part
191.
These
additional
isotopes
are
usually
necessary
to
support
the
technical
adequacy
of
the
assay
values
for
isotopes
identified
as
important
to
PA.
Typically,
EPA
may
require
a
site
to
ensure
that
DOE
identify
and
account
for
isotopes
that
may
interfere
with
the
assay
of
isotopes
identified
as
important
to
PA.
One
example
of
additional
required
isotopes
is
237
Np
at
LANL,
when
LANL
was
employing
the
Fixed
Energy
Response
Analysis
using
Multiple
Efficiencies
(FRAM)
system
for
gamma
spectroscopy.
Another
example
is
the
presence
of
244
Cm
or
252
Cf
in
waste
planned
for
assay
using
passive
neutron
methods.
These
special
cases
are
documented
in
the
EPA
inspection
report,
and
are
usually
specific
to
a
given
system
and
a
given
type
of
waste.
19
II.
B.
2
Technical
Description
of
System
or
Measurement
Device(
s)

To
demonstrate
compliance
with
40
CFR
194.24(
c),
DOE
described
general
methods
for
accomplishing
NDA
in
the
CCA.
DOE
described
more
detailed
requirements
for
NDA
programs
in
Chapter
9
of
the
Waste
Characterization
Quality
Assurance
Program
Plan
(QAPP),
a
document
that
has
since
been
replaced
by
the
Waste
Acceptance
Criteria
(WAC)
document.
Each
waste
generator
site
describes
their
specific
NDA
program,
and
how
the
program
complies
with
the
upper
tier
EPA
and
DOE
requirements,
in
a
Quality
Assurance
Project
Plan
(QAPjP).
Site
operating
procedures
for
each
instrument
or
method
are
then
written
to
implement
the
QAPjP
requirements,
along
with
any
other
specific
instrument
or
site
dependent
requirements.

NDA
systems
typically
include
data
collection
and
analysis
software
that
performs
quality
related
functions.
In
accordance
with
40
CFR
194.22
any
NDA
system
used
to
support
EPA
characterization
requirements
must
adhere
to
the
American
Society
of
Mechanical
Engineers
(ASME)
Nuclear
Quality
Assurance
(NQA)
Requirements
for
Software
(ASME,
1990).

Radioactive
components
in
waste
to
be
disposed
of
at
WIPP
may
be
characterized
by
radiochemistry
or
NDA.
NDA
methods
are
by
far
the
preferred
techniques
for
performing
radioassay,
as
they
generally
have
greater
throughput
and
produce
lower
human
exposures
than
do
radiochemistry
techniques.

II.
B.
2.1
General
NDA
System
Information
The
NDA
techniques
approved
for
use
on
WIPP
waste
containers
are
classified
as
active
or
passive.
Passive
NDA
methods
measure
spontaneously
emitted
radiation
produced
by
natural
decay
of
the
radioactive
isotopes
inside
the
waste
container.
Active
NDA
methods
measure
radiation
produced
by
artificially
generated
reactions
in
the
waste
material.
Active
NDA
systems
used
for
assay
of
TRU
waste
generate
reactions
in
the
heavy
metals
within
the
waste
using
a
low
intensity
beam
of
neutrons.
Presently,
most
waste
is
characterized
using
passive­
active
neutron
(PAN)
counters
and
gamma
ray
spectrometry
systems.
A
small
fraction
of
the
waste,
primarily
from
the
production
of
radioisotopic
thermal
generators
(RTG),
is
characterized
by
calorimetry
instruments.

The
neutron
counting
systems
being
used
for
NDA
of
WIPP
waste
containers
are
designed
to
provide
quantification
of
the
plutonium
isotopes
in
TRU
waste.
Neutrons
are
naturally
produced
by
only
a
small
number
of
isotopes;
the
rate
at
which
neutrons
of
certain
energies
are
produced
by
the
waste
container
provides
a
good
measure
of
the
quantity
of
these
isotopes.
Passive
neutron
counting
systems
detect
these
naturally
occurring
neutrons
and
use
various
computational
techniques
to
relate
their
quantity
to
isotopic
activities.

Many
NDA
systems
using
neutron
counting
are
also
capable
of
active
counting.
In
the
active
mode,
a
low
intensity
beam
of
neutrons
is
fired
into
the
waste
container.
This
neutron
beam
20
will
produce
a
series
of
reactions
in
the
fissionable
and
fissile
isotopes
within
the
waste,
with
the
number
of
particles
produced
by
the
reactions
being
proportional
to
the
amount
of
fissile
and
fissionable
isotopes
present
in
the
waste.
The
external
detectors
then
count
these
particles
and
convert
the
particle
response
to
source
strength.
By
using
active
NDA
methods
and
special
sensitive
neutron
detectors,
even
very
small
quantities
of
plutonium
in
the
waste
containers
can
be
detected
and
quantified.

The
gamma
ray
measurement
systems
being
used
to
characterize
WIPP
waste
containers
are
based
on
two
basic
principals.
First,
almost
all
radioactive
materials
produce
gamma
rays.
Second,
the
gamma
ray
pattern
produced
by
any
isotope
is
unique
to
that
isotope;
no
two
isotopes
produce
the
same
number
of
gamma
rays
having
the
same
energies.
Given
a
detector
with
good
enough
resolution
to
count
the
various
gamma
rays
individually
and
a
method
to
determine
what
the
gamma
ray
energy
patterns
mean,
it
is
possible
to
quantitatively
determine
the
isotopes
present
in
a
waste
sample.
Modern
radiation
detectors
coupled
to
sophisticated
computer
programs
that
solve
the
energy
pattern
for
the
presence
of
certain
isotopes
are
capable
of
performing
this
task
for
a
large
number
of
isotopes.
The
gamma
measurement
systems
approved
for
use
in
characterizing
WIPP
waste
are
capable
of
quantifying
the
presence
of
many
of
the
isotopes
defined
by
40
CFR
Part
191,
even
in
the
presence
of
potential
interfering
isotopes
and
background
radiation.

When
the
gamma
and
neutron
NDA
systems
are
used
together,
these
systems
provide
information
about
the
radiological
content
of
a
waste
container.
The
information
that
can
be
produced
by
the
WIPP
waste
NDA
systems
includes,
but
is
not
limited
to,
239
Pu
equivalent
activity,
239
Pu
fissile
gram
equivalent,
total
alpha
activity,
the
decay
heat
of
waste
containers,
and
the
activity
of
the
isotopes
of
interest
to
the
performance
assessment
and
the
applicable
regulations.
The
purpose
of
these
data
relative
to
long­
term
repository
compliance
with
40
CFR
Parts
191
and
194
is
to
establish
the
radionuclide
content
emplaced
in
the
repository.

All
assay
systems
using
radiation
detection
methods
must
be
calibrated
using
a
variety
of
standards
that
simulate
the
various
waste
compositions,
source
distributions
and
interferences
common
to
the
waste
streams
originating
from
a
particular
generator
site.
AK
enhances
the
NDA
systems
by
providing
advance
information
on
the
radiological
characteristics
of
a
waste
stream,
which
allows
the
NDA
systems
to
be
made
particularly
sensitive
to
that
type
of
waste
by
developing
realistic
calibration
standards.
Calibration
records
and
expected
system
performance
curves
are
compared
against
the
actual
results
of
the
measurements
performed
on
the
waste
containers.

II.
B.
2.2
Neutron
Systems
Because
they
have
no
charge,
and
are
not
purely
an
electromagnetic
packet
like
gamma
rays,
neutrons
have
a
unique
set
of
interactions
with
matter.
They
do
not
interact
with
the
electron
cloud
around
a
nucleus,
but
rather
with
the
nucleus
itself.
Thus,
when
a
material
absorbs
neutrons,
the
neutrons
are
interacting
with
and
changing
the
nuclei
of
the
atoms
in
the
absorbing
material,
21
which
can
produce
a
number
of
secondary
reactions.
Neutron
interactions
with
nuclei
may
result
in
the
disappearance
of
the
neutron
and
its
replacement
by
secondary
radiations,
or
a
significant
change
in
the
neutron's
energy
or
direction.
It
may
even
result
in
the
fragmentation
of
the
nucleus
with
which
it
is
interacting
in
a
process
known
as
fission.
The
secondary
radiations
produced
by
neutron
interactions
are
usually
heavy
charged
particles;
it
is
these
charged
particles
produced
by
the
conversion
of
the
neutron
energy
that
are
seen
by
neutron
detectors,
as
discussed
below.
Generally,
the
type
and
probability
of
the
various
neutron
interactions
with
any
given
type
of
nucleus
depend
strongly
on
the
energy
of
the
neutron.

NDA
systems
do
not
require
exact
measures
of
neutron
energy.
For
NDA
purposes,
neutrons
can
simplistically
be
divided
into
two
categories
based
on
their
energy:
high
energy
or
"fast"
neutrons,
and
low
energy
or
"slow"
neutrons,
using
an
arbitrary
energy
division
of
approximately
0.5
electron
volts
(eV).

Neutrons
are
measured
indirectly
by
detecting
secondary
particles
resulting
from
interactions
of
neutrons
with
target
nuclei.
These
possible
interactions
include:

°
(n,
p)
or
(n,
a)
reactions
where
a
nucleus
absorbs
a
neutron
and
emits
a
charged
particle,
which,
along
with
the
recoil
product
nucleus,
causes
ionization
in
the
detector;

°
Neutron
induced
fission,
or
(n,
f)
reactions,
where
the
detector
registers
ionization
produced
by
the
fission
fragments
or
the
prompt
or
delayed
neutrons
and
photons;
and/
or
°
Neutron
scattering,
where
the
recoil
nucleus
produces
ionization
in
the
detector.

The
(n,
p),
(n,
a)
and
(n,
f)
reactions
are
of
greatest
interest
for
neutron
detection
because
they
produce
secondary
radiations
(i.
e.,
charged
particles
that
can
be
detected
directly).
The
neutron
detectors
most
widely
used
in
NDA
systems
are
gas
proportional
detectors
filled
with
a
light
isotope
of
helium
(
3
He).
These
detectors
are
commonly
called
helium
tubes.
A
neutron
detection
system
typically
contains
many
helium
tubes,
maintained
under
an
applied
voltage,
or
electric
field.
The
neutron­
helium
reaction
of
interest
is
shown
below:

3
He
+
n
6
3
H
+
p
+
0.764
MeV
The
term
"cross
section"
is
used
to
describe
the
probability
of
interaction.
Helium
is
used
because
it
has
a
high
cross
section
for
interaction
with
thermal,
or
low
energy,
neutrons,
which
provides
a
high
detection
efficiency
and
pulse
height
resolution.
The
charge
liberated
by
the
neutron­
helium
interaction
produces
initial
ionizations
of
helium
gas.
By
maintaining
the
appropriate
electric
field
within
the
gas,
the
number
of
secondary
ionizations
produced
is
proportional
to
those
produced
initially,
while
the
number
of
actual
ion
pairs
is
multiplied
by
a
factor
of
many
thousands.
The
detection
system
collects
the
ion
pairs
as
charge
which,
with
proper
calibration,
is
correlated
with
the
number
of
neutron
interactions
and
therefore
the
sample
reaction
rate.
22
Because
the
probability
of
neutrons
interacting
with
target
materials
is
a
strong
inverse
function
of
the
neutron's
energy,
high
energy
neutrons
produced
by
spontaneous
or
induced
fission
("
fast"
neutrons)
must
be
slowed
before
they
can
be
efficiently
detected.
This
occurs
through
multiple
collisions
with
atoms
in
the
materials
within
the
detection
system
(i.
e.,
polyethylene,
graphite,
etc.).
Neutron
cross
sections
for
a
given
target
nucleus
are
interaction
specific
(i.
e.,
there
is
a
different
cross
section
for
fission,
elastic
scattering,
inelastic
scattering,
(n,
p)
reaction,
etc.),
and
each
is
strongly
dependent
on
the
neutron
energy.
Cross
sections
are
also
material
specific.
Certain
isotopes
have
large
cross
sections
for
various
reactions,
which
may
make
them
a
preferred
material
for
neutron
detection
systems.

The
main
source
of
neutrons
of
interest
to
NDA
result
from
spontaneous
or
induced
nuclear
fission,
which
is
the
disintegration
of
an
atomic
nucleus
into
two
or
more
lighter
fragments.
In
general,
isotopes
of
plutonium
and
uranium
have
a
low
rate
of
spontaneous
fission
compared
to
the
rate
for
other
decay
modes,
such
as
alpha
emission.
This
is
particularly
so
for
heavy
radionuclides
with
odd
numbers
of
neutrons
and
odd
mass
number,
but
these
isotopes
frequently
have
a
high
thermal
neutron
fission
cross
section,
which
means
these
isotopes
can
be
made
to
undergo
induced
fission
by
bombardment
with
low
energy
neutrons.
Examples
of
these
isotopes
are
233
U,
235
U
and
239
Pu.
Plutonium
isotopes
with
even
mass
numbers
(
238
Pu,
240
Pu,
and
242
Pu)
undergo
higher
rates
of
spontaneous
fission,
and
for
240
Pu
the
rates
of
spontaneous
fission
and
alpha
emission
are
close.
This
is
important
as
240
Pu
is
typically
present
as
an
impurity
in
weapons
grade
plutonium
and
is
a
component
of
TRU
wastes.

Assays
of
TRU
wastes
by
measuring
the
neutrons
emitted
by
spontaneous
fission
are
called
"passive"
mode
assays.
Passive
mode
measurements
count
neutrons
produced
by
isotopes
with
significant
likelihood
of
decay
by
spontaneous
fission,
including
238
Pu,
240
Pu,
242
Pu,
and
244
Cm.
Neutrons
are
also
emitted
by
TRU
radionuclides
in
response
to
induced
fission
caused
by
bombardment
with
energetic
neutrons
supplied
by
the
measurement
system.
Such
assays
measuring
induced
neutrons
are
called
"active"
mode
assays.
Active
mode
assays
provide
information
for
239
Pu
and
241
Pu,
as
well
as
other
fissile
isotopes
present
in
the
TRU
waste
being
assayed
(e.
g.,
235
U),
that
fission
takes
place
in
response
to
neutrons
supplied
by
the
measurement
system.

II.
B.
2.3
Passive­
Active
Neutron
Counters
PAN
counters
are
used
to
quantify
the
amount
of
a
fissile
or
fissionable
nuclide
inside
a
container.
More
precisely,
these
systems
quantify
the
amount
of
a
particular
radionuclide
that
would
result
in
the
number
of
counts
observed.
This
is
referred
to
as
the
effective
mass.
For
active
measurements,
the
239
Pu
effective
mass
is
measured,
while
for
passive
measurements,
the
240
Pu
effective
mass
is
measured.
To
convert
the
effective
mass
measured
into
the
true
mass
of
each
of
the
radionuclides
present,
the
ratio
of
each
nuclide
to
that
of
the
primary
nuclide
being
measured
must
be
known.
These
ratios
can
be
measured
using
a
gamma­
ray
spectrometry
system,
described
in
the
following
section.

To
quantify
the
effective
mass
of
239
Pu
or
240
Pu,
fast
neutrons
from
induced
or
spontaneous
23
fissions
are
detected
and
counted.
Since
two
or
more
neutrons
usually
result
from
a
fission
event,
neutron
counters
are
operated
in
coincidence
mode.
In
coincidence
mode,
an
event
is
only
counted
when
two
or
more
neutrons
are
individually
detected.

Most
PAN
counters
consist
of
a
large
number
of
individual
neutron
detectors
surrounding
the
container
being
assayed.
The
most
common
type
of
neutron
detector
used
is
a
3
He
tube,
which
is
a
long
cylindrical
proportional
gas
counter
filled
with
3
He.
Since
the
probability
of
detection
in
a
3
He
tube
is
much
greater
for
thermal
neutrons
than
for
fast
neutrons,
3
He
tubes
are
usually
surrounded
by
a
moderator.
Fast
neutrons
lose
energy
through
numerous
collisions
in
the
moderator
until
they
are
reduced
in
energy,
or
"thermalized."

As
previously
described,
a
PAN
counter
in
passive
mode
counts
neutrons
from
spontaneously
fissioning
nuclides,
such
as
240
Pu.
In
active
mode
the
PAN
system
counts
neutrons
generated
in
the
waste
container
after
the
container
is
exposed
to
fast
neutrons
from
an
external
source,
which
induce
fissile
nuclides
in
the
waste
to
fission.
The
most
common
source
of
fast
neutrons
is
a
D­
T
neutron
generator,
although
other
sources,
such
as
252
Cf
sources
can
also
be
used.
A
D­
T
neutron
generator
creates
14
MeV
neutrons
by
accelerating
deuterium
(
2
H)
nuclei
into
a
tritium
(
3
H)
target.

Proper
use
and
calibration
of
a
PAN
system
requires
tests
using
known
sources
in
order
to
evaluate
system
efficiency.
Additionally,
the
environmental
neutron
signal
must
be
measured
in
order
to
remove
background
signals
that
are
not
contributed
by
the
waste
components.
Both
the
efficiency
and
the
background
signal
must
be
periodically
checked
in
order
to
ensure
data
quality
is
not
degraded.

II.
B.
2.4
Photon
Emission
and
NDA
Photons
in
the
general
sense
are
packets
of
electromagnetic
energy,
and
are
the
basic
constituents
of
any
electromagnetic
energy,
including
visible
light.
When
these
photons
are
generated
by
de­
excitation
reactions
in
an
atomic
nucleus,
they
are
often
referred
to
as
gamma
radiation
or
gamma
rays.
Gamma
photons
are
essentially
the
same
as
x­
rays,
but
have
different
origins:
gamma
radiation
is
emitted
during
changes
in
the
state
of
nuclei,
while
x­
rays
are
emitted
during
changes
in
the
state
of
inner
or
more
tightly
bound
electrons.
Gamma
radiation
is
a
penetrating
radiation
best
attenuated
by
dense
materials
like
concrete,
lead,
etc.
Gamma
emissions
occur
at
discrete
energies
that
are
characteristic
of
specific
radionuclide
transitions,
enabling
their
identification
by
spectroscopic
techniques,
as
discussed
below.
Gamma
photon
emissions
range
in
energy
from
approximately
one
thousand
electron
volts
(1
KeV)
to
almost
ten
million
electron
volts
(10
MeV).
For
purposes
of
NDA
isotopic
measurements
of
plutonium,
the
photon
emissions
of
interest
occur
between
the
energies
of
approximately
40
to
640
KeV;
for
uranium,
the
photon
emissions
of
interest
occur
between
approximately
100
KeV
and
1
MeV
in
energy.

Their
electromagnetic
nature
causes
photons
to
interact
strongly
with
the
charged
electrons
in
the
atoms
of
all
matter.
The
photon
gives
up
energy
to
an
electron,
which
then
is
released
from
24
its
parent
atom
and
collides
with
other
atoms,
liberating
more
electrons.
The
total
charge
released
is
proportional
to
the
photon
energy,
since
the
higher
the
photon
energy
the
more
energy
is
available
to
release
electrons.
The
charge
resulting
from
this
cascade
of
released
electrons
is
then
collected,
causing
a
signal
indicating
the
presence
of
the
gamma
photon.
The
magnitude
of
the
signal
tells
the
energy
of
the
photon
since
the
electrical
signal
output
to
the
detector
is
proportional
to
the
energy
deposited
in
the
detector.
After
a
large
number
of
these
gamma
photons
have
been
detected,
a
graph
of
the
number
of
gamma
photons
measured
versus
the
energy
of
the
photons
can
be
displayed.
This
graph,
or
spectrum,
results
in
a
"fingerprint"
of
specific
radionuclides
since
the
gamma
photon
energy
release
pattern
is
unique
for
each
isotope.
With
the
appropriate
calibration,
the
spectrum
allows
identification
and
quantification
of
photon
emitting
radionuclides
in
various
media.

There
are
many
types
of
materials
suitable
for
use
in
photon
detectors.
The
NDA
systems
of
interest
primarily
use
modern
solid
state
detectors
constructed
from
germanium,
in
which
the
charge
produced
by
the
photon
interactions
is
collected
directly.
Germanium
is
the
semiconductor
material
of
choice
for
modern
photon
detectors
due
to
its
nearly
ideal
electronic
characteristics
that
allow
electrons
and
"electron
holes"
to
move
freely.
The
ionization
charge
resulting
from
the
photon
interaction
within
the
detector
is
swept
to
an
electrode
by
the
high
electric
field
in
the
semiconductor
material
produced
by
the
voltage
applied
to
the
detector
with
the
system's
high
voltage
power
supply.
The
charge
is
converted
to
a
voltage
pulse
by
a
preamplifier;
this
voltage
is
then
amplified
and
sent
to
a
multi­
channel
analyzer,
which
displays
the
spectrum
of
gamma
counts
detected
versus
energy.
Spectroscopic
evaluation,
including
radionuclide
identification
by
energy
peak
pattern,
background
correction,
pulse
height
determination,
etc.,
can
then
be
performed
on
the
spectrum
either
manually
or
by
computer.
By
applying
calibration
and
correction
factors
appropriate
to
the
waste
matrix,
container,
and
radionuclides,
the
spectroscopic
data
can
be
transformed
into
concentrations
of
specific
photon
emitting
TRU
radionuclides.

II.
B.
2.5
Gamma
Ray
Spectrometry
Systems
Gamma
ray
spectrometry
systems
are
used
to
quantify
the
amount
of
individual
radionuclides,
or
to
measure
the
ratio
of
different
radionuclides,
by
detecting
gamma­
ray
emissions.
Because
radionuclides
emit
gamma
rays
of
discrete
energies,
the
quantity
of
individual
radionuclides
can
be
related
to
the
number
of
gamma
rays
detected
at
a
specific
energy.
Effective
use
of
gamma
ray
spectrometry
systems
requires
the
user
to
define
the
system
efficiency
and
resolution.
These
parameters
must
be
periodically
checked
to
ensure
the
system
is
providing
consistent
results.
The
radiological
background
present
at
the
detector
must
also
be
defined
in
order
to
calculate
accurate
results
for
the
radionuclide
quantities
present
in
the
waste.
The
background
gamma­
ray
spectrum
must
be
periodically
measured
in
order
to
ensure
that
unintended
errors
are
not
introduced
into
the
results.

Most
gamma­
ray
spectrometry
systems
involve
one
or
more
high
resolution
detectors,
with
high
purity
germanium
(HPGe)
being
the
most
common.
These
detectors,
typically
about
three
inches
in
diameter
and
three
inches
in
length,
are
positioned
alongside
the
container.
In
many
25
systems,
commonly
referred
to
as
scanners,
a
collimator
is
used
so
that
the
detector
only
detects
gamma
rays
emitted
from
a
portion
of
the
container.
The
detector,
or
more
commonly
the
container,
is
then
translated
until
the
entire
container
is
measured.

Some
gamma­
ray
scanners
incorporate
a
transmission
source
to
correct
for
gamma­
ray
attenuation
in
the
container.
These
collimated
radioactive
sources
are
positioned
directly
opposite
of
the
detector.
Shutters
are
often
used
to
shield
the
source
from
the
detector
when
it
is
not
being
used.

II.
B.
2.6
Calorimetry
Instruments
Calorimetry
instruments
are
used
to
quantify
radionuclides
for
waste
containers
that
contain
significant
quantities
of
238
Pu.
The
high
specific
activity
of
238
Pu,
used
primarily
for
radioisotopic
thermal
generators,
results
in
a
measurable
heat
flux
that
can
be
correlated
to
the
activity
of
the
radionuclides
in
question.
Like
neutron
counters,
isotopic
ratios
must
be
known
in
order
to
relate
the
heat
flux
to
the
activities
of
individual
radionuclides.
Calorimetry
has
only
been
used
in
a
limited
number
of
instances,
and
EPA
has
approved
its
use
only
at
Rocky
Flats.

II.
B.
3
Effect
of
Waste
Matrix
or
Waste
Type
on
Measurement
The
applicability
of
PAN
counters
and
gamma­
ray
spectrometry
systems
to
characterize
waste
to
be
disposed
of
at
WIPP
depends
primarily
on
the
matrix
properties
of
the
waste
and
the
types
and
quantities
of
radionuclides
present.
For
neutron
counters,
the
matrix
parameters
of
primary
interest
are
the
neutron
absorption
and
moderating
properties.
Large
quantities
of
hydrogen­
containing
materials
will
enhance
neutron
moderation,
making
active
measurements,
and
to
a
lesser
extent
passive
measurements,
more
difficult.
The
presence
of
any
materials
that
enhance
neutron
capture
will
make
any
neutron
measurements,
active
or
passive,
more
difficult.
Passive
and
active
neutron
counters
work
best
with
radionuclides
having
large
cross
sections
for
induced
fission
and
high
spontaneous
fission
rates,
respectively.

Matrix
parameters
that
affect
gamma­
ray
systems
are
matrix
density
and
the
effective
atomic
number.
Denser
materials
and
materials
with
high
atomic
numbers
(Z)
absorb
more
gamma
rays
than
less
dense,
lower
Z
number
materials,
resulting
in
increased
gamma­
ray
attenuation
and
poorer
signal­
to­
source
ratios.
Gamma­
ray
spectrometry
systems
are
best
suited
to
detect
radionuclides
that
emit
gamma
rays
at
energies
between
about
50
keV
and
1
MeV
with
a
high
probability,
or
branching
ratio.
Specific
issues
related
to
waste
properties
are
described
in
the
following
sections
for
each
of
the
neutron
and
gamma
detection
methods.

II.
B.
3.1
Neutron
Counting
Systems
PAN
counters
typically
must
account
for
the
following:

°
Radionuclide
source
(source)
heterogeneity.
Most
neutron
systems
are
calibrated
26
assuming
that
sources
are
uniformly
distributed
throughout
the
container
volume.
When
sources
are
not
uniformly
distributed,
but
are
instead
concentrated
in
parts
of
the
drum,
the
system
will
underestimate
or
overestimate
the
239
Pu
or
240
Pu
effective
mass.

°
Matrix
heterogeneity.
In
addition
to
a
uniformly
distributed
source,
most
neutron
calibrations
are
done
for
matrices
whose
neutron
absorption
and
moderation
properties
are
assumed
to
be
the
same
throughout
the
volume
of
the
container.
Like
non­
uniform
source
distributions,
non­
uniform
matrices
can
result
in
an
underestimation
or
overestimation
of
the
239
Pu
or
240
Pu
effective
mass.

°
Source
self­
shielding.
If
the
fissile
material
is
concentrated
in
a
small
volume
(i.
e.,
a
lump)
the
inner
material
is
shielded
from
interrogating
neutron
flux
during
an
active
measurement.
This
effect,
referred
to
as
self­
shielding,
can
result
in
an
underestimation
of
the
239
Pu
effective
mass.
This
problem
is
not
significant
in
passive
mode,
where
the
mean
free
path
of
the
fast
neutrons
is
much
larger
than
the
size
of
the
fissile
mass.

°
Interfering
nuclides.
Any
fissile
or
spontaneously
fissioning
nuclides,
such
as
244
Cm,
not
accounted
for
in
the
determination
of
the
isotopic
ratios
will
result
in
an
incorrect
estimation
of
the
individual
radionuclide
activities
and
any
derived
quantities.

Containers
are
often
rotated
during
the
measurement
to
reduce
the
effect
of
source
and
matrix
heterogeneity
on
the
measurement.
Some
neutron
counters
incorporate
imaging
algorithms
to
measure
the
spatial
variations
in
the
source
distribution
and
the
matrix
properties.

II.
B.
3.2
Photon
Measuring
Systems
Gamma­
ray
systems
are
affected
by
many
of
the
source
and
matrix
effects
that
affect
neutron
counters,
including
source
heterogeneity,
matrix
heterogeneity,
and
source
self­
shielding.

°
Source
heterogeneity.
Like
neutron
counters,
most
gamma­
ray
systems
are
calibrated
for
uniformly
distributed
sources,
and
nonuniform
source
distributions
are
likely
to
result
in
underestimation
or
overestimation
of
radionuclide
activities.

°
Matrix
heterogeneity.
Gamma­
ray
system
calibrations
generally
assume
that
gamma
attenuation
properties
are
uniform
throughout
the
volume
of
the
container.
Spatial
variations
in
these
properties,
namely
the
density
and
effective
atomic
number,
can
cause
the
radionuclide
activities
to
be
incorrectly
estimated.

°
Source
self­
absorption.
Concentrated
masses,
or
lumps,
of
high
Z
materials,
such
as
uranium
and
plutonium,
can
result
in
underestimation
of
the
radionuclide
activity.
Unlike
the
self­
shielding
effect
in
active
neutron
measurements,
the
difficulty
in
gamma
spectrometry
arises
when
gamma
rays
from
the
interior
of
the
mass
are
absorbed
before
escaping
the
lump.
27
°
Interfering
radionuclides.
Some
radionuclides
emit
gamma
rays
very
close
in
energy
to
those
being
measured.
If
not
properly
accounted
for,
these
interfering
radionuclides
can
result
in
the
incorrect
determination
of
radionuclide
activities
and/
or
isotopic
ratios.

Like
neutron
counters,
effects
due
to
source
and
matrix
heterogeneity
can
be
significantly
reduced
by
rotating
the
container
during
the
measurement.
Additionally,
segmented
gamma
scanners,
using
transmission
sources,
can
account
for
spatial
variations
in
the
source
activity
and
matrix
attenuation
properties
as
a
function
of
height.
A
number
of
systems
also
use
computed
tomography
(CT)
to
measure
the
matrix
properties
and
source
distribution
in
three
dimensions.

II.
B.
4
Scope
of
EPA
Approvals
for
Nondestructive
Assay
EPA
approves
NDA
methods
for
a
waste
stream
or
group
of
waste
streams
based
on
the
demonstrated
capability
of
the
NDA
system
to
quantify
the
radiological
properties
of
the
waste
stream
(s).
This
approach
has
been
used
because
of
the
194.8(
b)
language
specifying
waste
stream
examinations,
and
also
because
DOE
generator
sites
most
often
test
and
qualify
their
NDA
instruments
to
a
given
set
of
waste
as
defined
by
waste
streams.
This
approach,
however,
has
led
to
some
problems
during
waste
certification
inspections
because
waste
streams
are
generally
defined
by
physical
properties
rather
than
by
radiological
properties.
While
there
is
some
correlation
between
the
effectiveness
of
a
given
NDA
method
and
the
physical
properties
of
the
waste
material
(e.
g.,
a
highly
absorbing
or
moderating
matrix
like
organic
sludge),
in
practice
this
approval
system
has
frequently
resulted
in
limited
approvals
relative
to
the
total
population
of
waste
intended
for
approval.
A
few
sites,
such
as
INEEL
and
LANL,
currently
attempt
to
define
their
assay
programs
as
a
process
applicable
to
broad
ranges
of
wastes
that
are
defined
by
their
radiological
and
nuclear
properties
of
interest
to
the
assay
method
(e.
g.,
moderator/
absorber
index
for
neutron
systems),
rather
than
strictly
by
waste
stream
or
Summary
Waste
Category
Group.
Other
generator
sites,
such
as
Savannah
River,
have
programs
that
are
designed
around
the
waste
stream
intended
for
shipment.

A
radioassay
system
should
be
capable
of
characterizing
waste
containers,
provided
the
important
matrix
properties
of
the
containers
are
within
the
bounds
for
which
the
system
is
calibrated.
For
neutron
systems,
the
absorption
and
moderating
properties
of
the
matrix
are
of
primary
interest.
Density
and
atomic
number
of
the
waste
are
of
primary
interest
for
gamma
spectrometry
systems.
Since
NDA
systems,
particularly
neutron
systems,
often
use
different
parameters
to
characterize
the
matrix
properties,
it
is
difficult
to
establish
standard
limits
for
matrix
characteristics
or
to
compare
calibration
limits
from
one
instrument
to
another.

II.
C
Visual
Examination
and
Radiography
Radiography
(e.
g.,
RTR)
is
a
nondestructive,
qualitative
and
quantitative
technique
that
involves
x­
ray
scanning
of
waste
container
contents.
It
is
used
to
identify
and
quantify
waste
28
material
parameters
important
to
PA,
such
as
cellulosic,
plastic,
and
rubber
content.
Radiography
also
is
used
to
identify
items
such
as
liquids,
pyrophorics,
explosives,
compressed
gas
cylinders,
and
sealed
containers
larger
than
4
liters,
which
are
prohibited
from
disposal
by
DOE.
Unlike
nondestructive
assay,
no
radiological
analysis
is
done
with
this
technique.
Radiography
is
considered
to
be
both
qualitative
and
quantitative
because
measurements
are
made
by
an
operator
who
views
a
real­
time
x­
ray
scan
of
the
contents
of
a
waste
container
(e.
g.,
drum
or
standard
waste
box)
to
estimate
values
for
parameters
of
interest.
For
example,
the
operator
(based
on
experience,
on­
the­
job­
training,
and
drum
aids)
estimates
the
container
fill
percentage
(i.
e.,
the
percentage
of
the
drum
filled
with
waste),
the
volume
of
"combustible"
materials,
metals,
etc.

Visual
Examination
(VE)
involves
opening
of
waste
containers
in
glove
boxes
or
other
controlled
structures
and
manually
cataloging
the
contents.
VE
is
currently
used
as
either
a
confirmation
of
Nondestructive
Examination
(NDE)
­
which
to
date
has
been
RTR
­
or
as
a
replacement
for
NDE.
Visual
verification
(which
differs
from
VE
in
that
the
visual
verification
process
is
used
during
repackaging
and
no
videotape
records
are
kept)
is
also
used.
Sites
are
required
to
conduct
VE
on
newly
generated
waste,
on
a
statistically
selected
population
of
waste
containers
examined
through
radiography,
and
on
waste
containers
that
the
site
was
unable
to
characterize
using
either
radiography
and/
or
NDA
due
to
the
presence
of
an
interfering
material,
such
as
lead
shielding.
The
results
of
the
VE
of
the
statistically
selected
population
of
waste
containers
is
used
by
the
site
to
verify
waste
container
determinations
(and
measurements)
made
through
radiography.
The
site
is
required
to
calculate
miscertification
rates
on
an
annual
basis
and,
based
on
these
calculations
(and
estimates
of
the
number
of
waste
containers
to
be
radiographed
in
the
coming
year),
determine
the
required
number
of
waste
containers
to
undergo
VE
in
the
following
year.

II.
C.
1
Overview
of
Technical
Elements
EPA
typically
views
actual
radiography
and
VE
activities
during
inspections,
as
well
as
supporting
documentation
and
procedures.
At
a
minimum,
radiography
and
VE
should
provide
the
following:

°
Identification
of
cellulosics,
plastics,
and
rubber,
including
quantities;
°
Identification
of
prohibited
items,
including
liquids;
and
°
Confirmation
of
Summary
Waste
Category
Group
and
Waste
Matrix
Code.

Under
the
CH­
TRU
program,
every
retrievably
stored
container
must
be
examined
to
determine
the
cellulosics,
plastics,
rubber
(CPR),
and
prohibited
item
content
using
RTR.
Alternatively,
containers
can
be
examined
either
visually
or
by
a
different
NDE
technology,
such
as
CT
or
digital
radiography
(DR),
if
RTR
is
not
possible.
Newly
generated
wastes
do
not
have
to
be
examined
using
RTR
because
the
packaging
process
would
exclude
the
inclusion
of
prohibited
items.

II.
C.
1.1
RTR
Document
Review
29
EPA
examines
site
specific
documents
and
information
related
to
any
of
the
following
areas
during
inspections:

°
Replicate
Scans.
The
sites
must
document
that
the
imaging
system
characteristics
of
the
monitoring
system
are
verified
on
a
routine
basis
and
that
independent
replicate
scans
and
replicate
observations
of
the
audio/
video
output
of
the
RTR
process
are
performed
under
uniform
conditions
and
procedures.

C
Independent
Observations.
The
sites
must
document
that
independent
observations
of
RTR
scans
are
performed
during
each
work
shift.

C
System
Capabilities.
The
site
must
document
that
its
RTR
system
is
appropriate
and
is
capable
of
characterizing
the
typical
waste
configurations
and
parameters
observed
at
the
site.

C
Procedures.
The
site
must
have
procedures
for
ensuring
that
the
RTR
system
is
tested,
inspected,
and
maintained
in
accordance
with
manufacturer
instructions.
In
addition,
EPA
expects
the
site's
procedures
to
address
the
following:

­
The
RTR
system
is
calibrated
through
observation
of
a
test
pattern
at
the
beginning
and
end
of
each
work
shift
(when
operating).
The
RTR
system
must
be
able
to
be
adjusted
to
obtain
optimum
contrast
and
resolution
using
a
line­
pair
gauge
or
equivalent
device.

­
Data
management
is
sufficient
to
ensure
that
the
RTR
results
for
every
waste
container
are
documented,
validated,
and
ultimately
verified
by
VE
of
a
randomly
selected
statistical
population
of
waste
containers.

­
The
RTR
examination
is
captured
on
both
audio/
video
and
documents
the
following
types
of
information
necessary
for
WIPP
WAC
certification:

­­
Item
description
code
(IDC),
­­
TRUCON
code
(Transuranic
Package
Transporter­
II
Content
Code),
­­
Presence
or
absence
of
free
liquids,
­­
Content
inventory,
and
­­
Description
of
contents
packaging
materials.

­
The
following
types
of
information
resulting
from
the
RTR
examination
must
be
recorded:

­­
Waste
container
identification
number;
­­
Date
of
radiography
examination;
­­
TRUCON
code,
IDC,
and
Waste
Matrix
Code,
as
applicable;
30
­­
Any
changes
made
to
Waste
Matrix
Code;
­­
Presence
or
absence
of
waste
container
liner;
­­
Estimated
inventory
of
waste
container
contents;
­­
Description
of
contents
packaging
materials,
including
the
number
of
layers
of
packaging;
­­
Audio/
videotape
identification
number;
­­
Estimate
of
each
applicable
waste
material
parameter
weight;
­­
Identification
of
quality
control
(QC)
replicate;
and
­­
An
operator/
reviewer
signature
and
date
block.

­
Explicit
guidance
is
included
to
account
for
materials
that
interfere
with
the
RTR
examination
(e.
g.,
lead
liners,
leaded
gloves,
stabilized
wastes
or
cement,
etc.).

­
Prohibited
items
must
be
identified
and
procedures
followed
to
ensure
that
the
proper
steps
are
taken
to
isolate
the
particular
waste
container.

­
Appropriate
measures
can
be
taken
when
conditions
adverse
to
quality
occur.

C
Reporting.
EPA
examines
the
data
reports
prepared
by
the
site.
Each
data
report
batch
may
not
include
more
than
20
waste
containers.
The
data
reports
must
contain
the
following
types
of
records:

­
RTR
data
forms,
­
RTR
reports,
­
RTR
videotape,
and
­
Identification
of
any
nonconformance
reports
(NCRs)
and
variances
pertinent
to
the
data
package.

C
C
Data
Quality
Characteristics.
The
site
should
have
a
procedure
for
correctly
calculating
and
reporting
the
relative
percent
difference
between
the
estimated
waste
material
parameter
weights
(as
determined
by
the
RTR
operator)
and
these
same
parameters
as
determined
visually
(i.
e.,
precision).
The
site
must
also
have
a
procedure
for
documenting
the
accuracy
with
which
the
matrix
parameter
category
can
be
determined
through
VE
of
a
randomly
selected
statistical
subpopulation
of
waste
containers.
The
site
must
prepare
and
validate
RTR
data
forms
and
audio/
videotape
for
100
percent
of
the
waste
containers
examined
(i.
e.,
completeness).
The
site
must
also
document
the
comparability
of
the
matrix
parameter
category
determined
by
RTR
with
the
matrix
parameter
category
determined
by
VE
(i.
e.,
comparability).

II.
C.
1.2
Additional
Verification
(RTR)

During
the
course
of
the
on­
site
inspection
of
the
radiography
system
and
site
operating
procedures,
the
EPA
inspection
team
both
observes
the
radiography
operation
and
interviews
31
radiography
operators
and
other
DOE/
contractor
personnel
to
assess
how
well
the
radiography
process
is
being
implemented.
As
part
of
the
EPA
inspection
team's
observation
of
the
radiography
operation,
the
inspection
team
both
views
videotaped
recordings
of
previously
radiographed
waste
containers
and
observes
the
actual
operation
of
the
radiography
equipment.
The
EPA
inspection
team
notes
the
presence
of
required
equipment,
adherence
to
procedures,
and
documentation
of
all
activities.

For
example,
the
EPA
inspection
team
inspects
the
radiography
booth
and
asks
the
radiography
operators
to
point
out
all
of
the
required
radiographic
equipment,
as
described
originally
in
the
TRU
QAPP
(Section
10)
and
Methods
Manual
(CCA
Reference
No.
210),
and
subsequently
in
the
WAP:

C
A
shielded
room
that
is
properly
ventilated
and
lighted,
C
An
x­
ray
producing
device,
C
Controls
which
allow
the
operator
to
vary
voltage,
typically
between
150­
400
kV,
C
An
imaging
system
that
typically
includes
a
fluorescent
screen
and
a
low
light
television
camera,
C
An
enclosure
for
radiation
protection,
C
A
waste
container
handling
system
(including
a
turntable
dolly
assembly),
C
An
audio/
video
recording
system,
C
Safety
interlocks,
and
C
An
operator
control
and
data
acquisition
station.

As
part
of
the
inspection
activities,
the
radiography
operator
is
required
to
demonstrate
the
operation
of
the
radiography
equipment,
including
estimation
of
waste
materials'
parameters
and
volumes,
and
data
entry.

The
EPA
inspection
team
also
interviews
the
radiography
operators
and
DOE
staff/
contractors
involved
in
certifying
and
tracking
operator
training
to
ensure
that
a
formal
operator's
training
program
exists
and
is
completely
implemented.
The
EPA
inspection
team
requires
the
training
staff
and
radiography
operators
to
demonstrate
through
actual
radiography
equipment
operation
and
training
file
documentation
that
operator
training
includes
the
following,
at
a
minimum:

C
Formal
training
­
Project
requirements,
­
State
and
federal
regulations,
­
Basic
principles
of
radiography,
­
Radiographic
image
quality,
and
­
Radiographic
scanning
techniques.

C
Application
techniques
32
­
Radiography
of
waste
forms,
­
Standards,
codes,
and
procedures
for
radiography,
and
­
Site­
specific
instruction.

C
On­
the­
job
training
­
System
operation,
­
Identification
of
packaging
configurations,
­
Identification
of
WMPs,
­
Weight
and
volume
estimation,
and
­
Identification
of
prohibited
items.

The
EPA
inspection
team
observes
the
operator's
examination
of
a
radiography
test
drum
(either
in
real
time
or
by
reviewing
videotape)
and
expects
to
see
the
operator
satisfactorily
identify
its
content.
The
EPA
inspection
team
reviews
the
contents
of
the
radiography
test
drum
to
ensure
that
the
following
required
elements
are
present:

C
Aerosol
can
with
puncture,
C
Horsetail
bag,
C
Pair
of
coveralls,
C
Empty
bottle,
C
Irregular
shaped
pieces
of
wood,
C
Empty
one
gallon
paint
can,
C
Full
container,
C
Aerosol
can
with
fluid,
C
One
gallon
bottle
with
three
tablespoons
of
fluid,
C
One
gallon
bottle
with
one
cup
of
fluid
(upside
down),
C
Leaded
glove
or
leaded
apron,
and
C
Wrench.

Training
drums
must
contain
all
of
the
required
test
elements.
The
EPA
inspection
team
requests
the
radiography
operator
to
discuss
how
the
site
has
determined
that
the
test
drum
contained
test
elements
that
were
typical
of
what
might
be
encountered
at
the
site
(both
content
and
packaging
density).

EPA
expects
there
to
be
a
process
for
ensuring
that
the
RTR
operators
receive
standardized
training
and
certification,
recertification,
retraining,
and
on­
the­
job
training
with
oversight
from
appropriately
qualified
RTR
operators.
RTR
operators
must
have
sufficient
experience
to
operate
the
RTR
system.
EPA
expects
RTR
operators
to
be
instructed
in
the
specific
waste
generating
practices
and
typical
packaging
configurations
expected
for
each
matrix
parameter
category
or
IDC.
33
EPA
inspectors
examine
the
procedures
for
ensuring
that
this
training
occurs,
as
well
as
operator
training/
experience
records
to
ensure
that
the
personnel
operating
the
RTR
system
are
qualified
and
appropriately
trained.
Inspectors
also
interview
the
RTR
operators
and
observes
their
operation
of
the
RTR
system.

EPA
expects
the
generator
sites
to
provide
procedures
regarding
the
operation
of
the
RTR
system,
and
RTR/
VE
records
(see
below)
that
document
that
the
required
technical
elements
are
adequately
addressed
by
these
procedures.
EPA
may
require
the
generator
site
to
provide
RTR
data
packages
and
RTR/
VE
comparison
sheets,
including
calculations
of
miscertification
rates
and
other
information
pertinent
to
making
the
determination
that
the
generator
site
has
a
system
of
controls
in
place
that
adequately
meets
the
requirements
of
§194.24(
c)(
4).

II.
C.
1.3
VE
Document
Review
EPA
examines
VE
documents
and
information
related
to
any
of
the
following
areas
during
inspections:

C
Documentation.
The
VE
procedure
ensures
that
the
inventory
of
unopened
contents
includes
a
description
and
documented
weight
of
all
waste
items,
residual
materials,
poly
liners,
contents
packaging
materials,
and
waste
material
parameters.

C
Reference
Tables.
The
site's
VE
procedure
has
reference
tables,
updated
as
necessary,
to
facilitate
the
development
of
weight
estimates
and
assignment
of
wastes
to
waste
material
parameters,
also
updated
as
necessary
during
the
process.
The
site
must
establish
standard
nomenclature
and
volumetric
conversion
factors.

C
VE
Data.
VE
staff
record
a
description
of
the
location,
container,
and
estimated
volume
of
any
detected
liquid.
All
empty
containers
must
be
weighed
and
recorded,
with
the
gross
weight
of
each
container
recorded
on
the
VE
data
form.
The
site
must
also
record
the
total
number
of
bags
or
packages
found
in
each
waste
container.
Replicate
weight
measurements
must
also
be
made.

C
Miscertification
Rate.
The
site
must
have
a
procedure
to
select
a
random
statistical
sample
of
waste
containers
for
VE
and
correctly
calculate
and
report
an
annual
miscertification
rate.
The
site
may
use
INEEL's
historical
miscertification
rate
of
2
percent
to
calculate
the
number
of
waste
containers
that
must
be
visually
examined
during
the
first
year
of
program
activities.
However,
the
site
must
also
have
a
procedure
for
establishing
a
site­
specific
miscertification
rate
that
is
based
on
the
last
12
(or
more)
months
of
certification
activities.

C
Radiography
Check.
EPA
expects
that
site
procedures
require
the
use
of
data
from
VE
to
check
the
matrix
parameter
category
and
waste
material
parameter
weight
estimates
as
determined
by
radiography.
34
C
Replacement
Containers.
The
facility
must
have
a
procedure
for
selecting
replacement
waste
containers.
The
site's
replacement
strategy
should
be
restricted
to
a
waste
stream
or
waste
stream
lot
that,
through
the
random
selection
process,
happened
to
have
container(
s)
identified
for
VE.
The
procedure
must
ensure
that
VE
is
performed
on
the
replacement
container.
Once
containers
have
been
visually
examined,
the
upper
90
percent
confidence
limit
(UCL90)
for
the
proportion
miscertified
must
be
correctly
calculated.
EPA
expects
the
site
to
use
the
hypergeometric
distribution
for
the
UCL90
calculation.

C
Data
Management.
The
site
must
have
a
procedure
for
data
management
that
is
sufficient
to
ensure
that
the
VE
results
for
every
waste
container
examined
are
documented
and
validated.

C
Documentation.
VE
examination
must
be
captured
on
both
audio
and
video
to
document
IDC,
TRUCON
code,
the
presence
or
absence
of
free
liquids
and
other
prohibited
items,
content
inventory,
and
a
description
of
contents
packaging
materials.

C
Data
Reports.
The
site
must
ensure
that
data
reports
are
prepared
on
a
per­
batch
basis,
which
includes
no
more
than
20
waste
containers,
and
the
data
reports
must
contain
VE
data
forms,
VE
reports,
VE
videotape(
s),
and
identification
of
any
NCRs
and
variances
pertinent
to
the
data
package.
The
site's
data
reporting
procedures
should
ensure
that
the
following
types
of
information
resulting
from
the
VE
are
recorded:

­
Waste
container
identification
number,
­
Date
of
VE,
­
TRUCON
code,
IDC,
and
Waste
Matrix
Code,
as
applicable,
­
Any
changes
made
to
the
Waste
Matrix
Code,
­
Presence
or
absence
of
waste
container
liner,
­
Estimated
inventory
of
waste
container
contents,
­
Description
of
contents
packaging
materials,
including
the
number
of
layers
of
packaging,
­
Audio/
videotape
identification
number,
­
Estimate
of
each
applicable
waste
material
parameter
weight,
­
Identification
of
QC
replicate,
and
­
Operator/
reviewer
signature
and
date
blocks.

C
Interfering
Items.
The
site's
VE
procedure
should
provide
explicit
guidance
on
how
to
handle
materials
that
interfere
with
the
examination,
such
as
metal
containers,
discolored
plastic
bags,
stabilized
wastes
or
cement,
etc.
Also,
the
site's
VE
procedure
must
require
that
prohibited
items
be
identified
and
that
the
proper
steps
be
taken
to
isolate
a
waste
container
with
prohibited
items.

C
Discrepancy
Resolution.
EPA
expects
the
site
to
have
a
procedure
for
resolving
35
discrepancies
between
VE
QC
checks
and
between
RTR
and
VE
observations,
and
to
ensure
that
appropriate
measures
can
be
taken
when
conditions
adverse
to
quality
occur.

II.
C.
1.4
Additional
Verification­
VE
During
the
course
of
the
on­
site
inspection
of
VE
activities
and
site
operating
procedures,
the
inspection
team
observes
VE
activities
and
interviews
VE
experts
and
other
personnel
to
assess
how
well
the
VE
process
is
being
implemented.
As
part
of
the
inspection
team's
observation
of
the
VE,
the
inspection
team
views
videotaped
recordings
of
previously
examined
waste
containers
and
observes
the
actual
VE
of
waste
containers
(when
possible).
Inspectors
note
the
presence
of
required
equipment,
adherence
to
procedures,
and
documentation
of
all
activities.

For
example,
the
EPA
inspection
team
inspects
the
VE
glove
box
(or
room)
and
ask
the
VE
experts
to
point
out
all
of
the
required
equipment,
as
described
in
DOE's
Method
Manual
(CCA
Reference
No.
210),
as
listed
in
the
following
bullets:

C
Check
weights
(certified
to
National
Institute
of
Standards
and
Technologies
standards),
C
Scales,
C
Torque
wrenches,
C
Airflow
meters,
C
Platform
scale,
C
Empty
55­
gallon
drums,
C
Remote
drum
handler,
C
Knifes,
scissors,
platform
ladder,
dolly/
drum
mover,
leather
gloves,
plastic
bags,
tape,
towels,
decontamination
solution,
secondary
containment
bags,
permanent
markers,
rubber
and/
or
surgical
gloves,
C
Video
camera,
C
Audio
recording
system,
and
C
Glove
box
or
negative
pressure
containment
area.

The
EPA
inspection
team
also
interviews
the
VE
experts
and
other
personnel
involved
in
certifying
and
tracking
operator
training
to
ensure
that
a
formal
operator's
training
program
exists
and
is
complete.
There
must
be
a
standardized
training
program
for
visual
inspection
examiners
that
includes
both
formal
classroom
and
on­
the­
job
training
(OJT).
The
program
must
be
specific
to
the
generator
site
and
includes
the
various
waste
configurations
generated/
stored
at
the
site.
The
EPA
inspection
team
interviews
the
VE
experts
to
determine
whether
(and
the
extent
to
which)
they
have
received
training
on
the
specific
waste
generating
processes,
typical
packaging
configurations,
and
waste
material
parameters
expected
to
be
found
in
each
matrix
parameter
category
at
the
site.
EPA
expects
the
VE
training
program
to
include:

°
Formal
training
­
Project
requirements,
36
­
State
and
federal
regulations,
­
Application
techniques,
and
­
Site­
specific
instruction.

°
On­
the­
job
training
­
Identification
of
packaging
configurations,
­
Identification
of
waste
material
parameters,
­
Weight
and
volume
estimation,
and
­
Identification
of
prohibited
items.

EPA
expects
sites
to
provide
procedures
regarding
the
performance
of
VE.
EPA
also
expects
generator
sites
to
provide
VE
data
packages
and
RTR/
VE
comparison
sheets,
including
calculations
of
miscertification
rates
and
other
information
pertinent
to
making
the
determination
that
the
generator
site
has
a
system
of
controls
in
place
that
adequately
meets
the
requirements
of
194.24(
c)(
4).

II.
C.
2
Technical
Description
of
System
or
Measurement
Device(
s)

II.
C.
2.1
Radiography
Radiographic
systems
include
not
only
real­
time
systems,
but
new
systems
that
are
currently
being
brought
on­
line
at
DOE
sites.
These
new
systems
may
offer
advantages
over
RTR
with
respect
to
system
resolution,
etc.

Real­
Time
Radiography
Sites
are
currently
conducting
NDE
examination
of
all
waste
containers
using
standard
radiography
techniques
(i.
e.,
an
x­
ray
tube,
an
image
intensifier,
and
a
charge
coupled
device
camera).
As
part
of
the
RTR
process,
the
RTR
operator
(or
drum
handler)
loads
up
to
three
waste
containers
onto
a
rolling
sled
that
is
then
moved
into
the
RTR
vault.
The
drum(
s)
is
placed
on
a
turntable
that
the
operator
uses
to
rotate
the
drum
and
the
x­
ray
system
components
automatically
move
up
and
down
to
smoothly
transition
through
the
entire
height
of
the
drum
(with
every
revolution
the
height
of
the
x­
ray
system
components
change
to
allow
for
an
automated,
complete
scan
of
the
entire
container
from
top
to
bottom).
Some
sites
do
not
employ
a
turn
table
that
automatically
moves
up
and
down,
but
rely
instead,
on
the
operator
to
manually
adjust
the
height
of
the
drum
manually
to
obtain
a
scan
of
100
percent
of
the
drum's
height.

The
x­
ray­
producing
device
has
controls
that
allow
the
operator
to
vary
the
voltage,
thereby
controlling
image
quality.
It
is
typically
possible
to
vary
the
voltage,
between
150
to
430
kilovolts
(KV),
to
provide
an
optimum
degree
of
penetration
through
the
waste.
For
example,
high­
density
material
should
be
examined
with
the
x­
ray
device
set
on
the
maximum
voltage
to
ensure
maximum
penetration
through
the
waste
container.
Low­
density
material
should
be
37
examined
at
lower
voltage
settings
to
improve
contrast
and
image
definition.

The
imaging
system
typically
uses
a
fluorescent
screen
and
a
low­
light
television
camera.
To
perform
radiography,
the
waste
container
is
scanned
while
the
operator
views
the
television
screen.

The
RTR
operator
controls
the
entire
process
from
a
remote
operator's
booth
and
the
entire
exam
is
recorded
on
audio/
video
tape
(some
sites
use
optical
disks).
The
operator
then
records
the
data
using
data
sheets;
however,
several
sites
use
automated
data
entry
systems.
For
example,
INEEL
RTR
operators
use
an
automated
data
entry
system,
which
has
a
series
of
screens
designed
to
capture
the
required
information.
The
RTR
examination
results
are
used
by
the
site
to
verify
that
the
physical
waste
form
matches
the
waste
stream
description,
to
document
the
waste
matrix
code
group,
to
estimate
waste
material
parameters
and
drum
utilization,
to
confirm
AK,
and
to
identify
prohibited
items.
Sites
also
compare
the
radiography
RTR
examination
results
with
those
obtained
through
VE
to
calculate
miscertification
rates
on
an
annual
basis
and,
based
on
these
calculations
(and
the
expected
number
of
waste
drums
to
be
processed
next
year)
determine
the
required
number
of
waste
containers
to
undergo
VE
in
the
following
year.

II.
C.
2.2
Visual
Examination
Sites
are
currently
conducting
VE
on
a
statistically
selected
subpopulation
of
waste
containers
examined
through
radiography,
and
any
waste
container
that
the
site
was
unable
to
characterize
through
radiography
due
to
the
presence
of
an
interfering
material,
such
as
lead
shielding.
As
part
of
the
VE
process,
the
VE
team
typically
opens
each
waste
container
in
a
specially
designed
glove
box
that
is
approximately
15
feet
long
and
operated
under
a
negativepressure
environment.
At
some
sites,
core
sampling
is
also
conducted
in
this
glove
box.
Although
the
VE
process
is
relatively
straightforward,
it
is
a
physically
demanding
and
intensive
operation
and
typically
consists
of
the
VE
technicians
performing
the
following
steps:

C
Load
the
waste
drum
at
the
back
end
of
the
glove
box,
C
Remove
the
drum
lid
and
empty
the
drum's
contents
in
the
middle
portion
of
the
glove
box,
C
Open
every
individual
waste
package
or
bag,
and
C
Manually
sort
and
categorize
waste
materials
for
subsequent
weighing
and
repackaging
at
the
front
end
of
the
glove
box.

The
entire
process
is
conducted
under
the
supervision
of
the
VE
expert
(VEE)
and
is
recorded
on
both
audio/
video
tape
and
waste
container
inventory
sheets.
The
VE
results
are
used
by
the
site
to
verify
waste
form,
confirm
and/
or
identify
prohibited
items,
and
verify
drum
utilization
and
waste
material
parameter
estimates
made
through
radiography.
The
VEE
also
assesses
the
need
to
open
individual
bags
or
packages
of
waste.
If
individual
bags/
packages
are
not
opened,
estimated
weights
are
recorded.
Estimated
weights
are
established
through
the
use
of
historically
derived
waste
weight
tables
and
an
estimation
of
the
waste
volumes.
It
may
not
be
possible
to
see
through
inner
bags
because
of
discoloration,
dust,
or
because
inner
containers
are
38
sealed.
In
these
instances,
documented
AK
can
be
used
to
identify
the
matrix
parameter
category
and
estimated
waste
material
parameter
weights.
If
AK
is
insufficient
for
individual
bags/
packages,
actual
weights
of
waste
items,
residual
materials,
contents
packaging
materials,
or
waste
material
parameters
are
recorded.
The
sites
also
compare
the
VE
data
to
that
obtained
through
radiography
to
calculate
miscertification
rates
on
an
annual
basis
and,
based
on
these
calculations
(and
the
expected
number
of
waste
drums
to
be
processed
next
year),
determine
the
required
number
of
waste
containers
to
undergo
VE
in
the
following
year.

II.
C.
3
Effect
of
Waste
Matrix
or
Waste
Type
on
Measurement
As
discussed
previously,
the
RTR
operator
can
vary
the
voltage
to
provide
an
optimum
degree
of
penetration
through
the
waste.
For
example,
high­
density
material
needs
to
be
examined
with
the
x­
ray
device
set
on
the
maximum
voltage
to
ensure
maximum
penetration
through
the
waste
container.
In
comparison,
low­
density
materials
need
to
be
examined
at
lower
voltage
settings
to
improve
contrast
and
image
definition.
For
example,
containers
with
lead
liners
or
containers
filled
with
sludges
or
stabilized
(or
cemented)
wastes
cannot
be
readily
penetrated
by
the
x­
ray
energy.
Thus,
containers
with
lead
liners,
or
other
containers
whose
contents
prevent
full
examination,
are
either
repackaged
or
examined
using
VE.

Radiography
systems
also
can
have
difficulty
detecting
cellulosics
in
lead­
lined
drums
because
a
higher
energy
x­
ray
must
be
used
to
scan
through
the
lead
lining.
The
higher
energy
xray
scans
past
the
cellulosics
as
well.
Similarly,
sites
may
be
unable
to
differentiate
between
cellulosics
and
plastics,
as
low
density
materials
can
appear
very
similar.
Densely
packed
drums
with
highly
heterogeneous
waste
materials
can
be
difficult
to
characterize,
as
can
bottles
and
cans
that
are
completely
filled
with
liquid
(there
is
no
observable
meniscus
during
container
motion).

VE
is
a
physically
demanding
task
and
densely
packed
drums
can
take
a
long
time
to
be
completely
examined;
however,
as
long
as
sufficient
time
and
working
space
are
available
there
should
be
no
reduction
in
data
quality.
Likewise,
waste
containers
packed
with
fine
particles
(e.
g.,
soda
ash,
graphite,
or
incinerator
residue)
can
present
a
housekeeping
problem,
but
also
can
be
examined
as
long
as
sufficient
time
and
working
space
are
available.

Inner
containers
that
are
opaque
or
are
packed
with
sharp
metal
objects
are
challenging
and
must
be
handled
with
care.
Opaque
containers
are
generally
opened,
unless
the
VEE
is
able
to
determine
what
the
contents
of
the
container
are
based
on
AK.
The
handling
of
waste
packages
containing
sharp
metallic
objects
is
minimized
and
often
times
set
aside
for
repackaging
so
as
not
to
present
undue
risks
to
the
VE
personnel.

II.
C.
4
Scope
of
EPA
Approvals
for
Radiography
and
Visual
Examination
All
types
of
CH
TRU
wastes
may
be
examined
using
RTR,
except
for
those
that
are
packed
in
lead­
lined
containers
or
have
been
stabilized.
Also,
all
types
of
CH
TRU
wastes
may
be
39
examined
using
VE,
except
for
those
that
have
been
stabilized.

EPA's
approvals
with
respect
to
RTR
and
VE
have
been
limited
to
date
by
the
scope
of
the
approval
sought
by
the
sites.
Reinspection
would
be
required
with
the
introduction
of
new
systems
(e.
g.,
DR/
CT,
VE
technique),
or
specific
wastes
(e.
g.
RH
TRU
waste,
lead­
lined
drums).

II.
D
WIPP
Waste
Information
System
and
Data
Validation
To
ensure
that
the
sites
ship
only
waste
that
conforms
with
the
waste
component
requirements
established
by
DOE,
a
system
of
controls
must
be
implemented
that
includes
tracking
of
information
about
waste
destined
for
the
WIPP.
For
this
purpose,
DOE
uses
a
computerized
waste
tracking
system,
the
WIPP
Waste
Information
System
(WWIS).
The
WWIS
is
a
data
transfer
system
whereby
waste
characterization
and
other
information
is
input
electronically
at
generator
sites
and
is
transferred
to
WIPP
prior
to
waste
shipment.
Additionally,
EPA
examines
the
data
validation
and
verification
processes
for
checking
data
ultimately
input
into
the
WWIS.

II.
D.
1
Overview
of
Technical
Elements
When
EPA
conducts
inspections
to
verify
compliance
with
§194.24(
c)(
4),
EPA
reviews
the
WWIS
for
the
following
items:

C
The
total
quantity
of
waste
(volumetrically);

C
The
quantity
of
the
important
non­
radionuclide
waste
components
for
which
DOE
has
identified
limits;

C
Radionuclide
activity
for
the
ten
WIPP
radionuclides;

C
Radionuclide
activity
uncertainty;

C
Radionuclide
mass;

C
Radionuclide
mass
uncertainty;

C
TRU
alpha
activity;

C
TRU
alpha
activity
uncertainty;

C
Verification
data;

C
Verification
method;
40
C
Visual
examination
of
container;

C
WAC
certification
data;

C
Waste
Matrix
Code
(WMC);
and
C
General
location
of
the
waste
in
WIPP.

II.
D.
1.1
Data
Validation/
Verification
and
WWIS
Inspection
Components
EPA
inspects
the
following
components
of
the
systems
of
control
for
tracking
WIPP
waste
parameters:

°
Documentation.
The
inspection
team
first
reviews
site
documentation
including,
but
not
limited
to,
Standard
Operating
Procedures
(SOPs),
Detailed
Technical
Procedures
(DTPs),
and
QAPjPs.
These
are
reviewed
to
ensure
that
technical
elements
are
adequately
addressed,
that
the
applicable
WAC
and
WAP
technical
elements
and
requirements
are
adequately
addressed
in
site
procedures
or
other
documents,
and
that
the
technical
results
of
procedure
implementation
are
adequate.

°
Data
Collection
and
Entry.
EPA
examines
the
overall
data
collection
and
date
entry
process
for
consistent
implementation
to
ensure
data
integrity
and
accuracy.
Procedures
are
also
examined
to
ensure
that
they
are
acceptable
and
allow
for
submitting
data
to
WIPP
via
the
WWIS
system.

°
Data
Validation.
EPA
ensures
that
procedures
exist
and
are
technically
adequate
for
reviewing/
validating
waste
characterization
data
prior
to
submittal
to
WIPP
via
WWIS.

°
Data
Requirements.
The
Agency
also
determines
whether
data
are
collected
and
formatted
consistently
with
requirements
of
WWIS,
including:

­
Container
number
­
TRU
alpha
activity
­
Site
identifier
­
TRU
alpha
activity
uncertainty
­
Waste
stream
profile
number
­
Matrix
code
­
TRU
alpha
activity
concentration
­
TRUCON
code
­
Decay
heat
­
TRU
alpha
activity
­
Decay
heat
uncertainty
concentration
uncertainty
­
Packaging
number
­
239
Pu
equivalent
activity
­
Assembly
identifier
­
239
Pu
fissile
gram
equivalent
­
Handling
code
­
239
Pu
fissile
gram
equivalent
­
Waste
type
code
uncertainty
­
Radionuclide
name
­
Packaging
layers
41
­
Radionuclide
activity
­
Alpha
surface
contamination
­
Radionuclide
activity
uncertainty
­
Dose
rate
­
Radionuclide
mass
­
Sample
identifier
­
Radionuclide
mass
uncertainty
­
Sample
type
­
Waste
material
parameter
weight
­
Sample
date
­
Radioassay
method
­
Analyte
­
Assay
date
­
Analyte
concentration
­
Characterization
method
­
Analyte
detection
method
­
Characterization
method
date
­
Shipment
number
°
Data
Security.
Procedures
should
be
in
place
to
ensure
that
data
in
the
system
are
secure.

°
WWIS
Verification.
Procedures
should
be
in
place
to
verify
data
submitted
to
the
WIPP
via
the
WWIS
system.

The
sites
must
provide
any
container­
specific
tracking
reports
(e.
g.,
WWIS
Waste
Container
Data
Reports),
data
validation
forms,
and
other
information
as
needed
to
determine
that
the
site
has
a
system
of
controls
in
place
that
adequately
meets
the
requirements
of
§194.24(
c)(
4).

II.
D.
1.2
Demonstration
of
WWIS
Implementation
EPA
inspection
team
observes
a
demonstration
of
data
entry
and
submittal
to
the
WIPP
site
via
the
WWIS
system
and
interviews
system
operators
and
data
tracking/
validation
officials
to
assess
the
extent
to
which
the
specified
processes
are
being
implemented.
The
inspection
team
observes
adherence
to
procedures,
proper
documentation
of
required
data
(e.
g.,
validation
at
the
project
level,
verification
of
data
received
from
the
WWIP
site
after
submittal
of
characterization
data),
and
results
of
system
operation.

No
specific
analytical
equipment
is
required
for
this
process
other
than
the
WWIS
itself
and
any
other
site­
specific
data
entry
systems
used
to
convey
site
information
to
the
WWIS,
including
any
computerized
systems
for
implementing
data
validation
procedures.
EPA
expects
the
sites
to
provide
a
demonstration
of
their
data
systems,
the
ability
to
transmit
and
receive
data
from
the
WWIS
system,
and
the
ability
to
verify
that
accurate
data
have
been
input
into
the
WWIS
system.
EPA
inspectors
examine
the
data
system
used
to
collect
waste
characterization
data
to
ensure
that
all
appropriate
data
fields
required
for
entry
into
the
WWIS
are
accounted
for
and
that
the
data
are
transferrable
to
WWIS
either
manually
or
electronically.
Further,
EPA
evaluates
the
quality
of
the
input
data,
by
reviewing
data
packages
at
the
point
of
project
level
data
validation
(the
point
at
which
data
are
input
into
the
WWIS
for
submittal
to
WIPP).
EPA
expects
a
demonstration
of
the
site's
ability
to
ensure
connectivity
with
the
WWIS
and
that
data
can
be
transmitted
via
the
WWIS
to
WIPP
and
received
from
WIPP
as
entered
into
the
site's
individual
data
system.

II.
D.
1.3
Personnel
Qualifications
42
EPA
checks
that
personnel
conducting
validation/
review
and
verification
and
entry
of
waste
characterization
data
into
the
WWIS
data
system
are
qualified
to
enter
data
and
verify
accuracy
of
waste
characterization
data
for
wastes
destined
for
disposal
at
WIPP.
Specifically,
EPA
examines
procedures
for
ensuring
that
training
occurs
and
operator
training/
experience
records
for:

°
Initial
WWIS
orientation
°
Using
the
WIPP
Waste
Information
System
User's
Manual
for
Use
by
Shippers/
Generators
(DOE/
CAO­
97­
2273)

°
Site­
specific
procedures
for
manual
or
electronic
data
entry
into
WWIS.

II.
D.
2
Technical
Description
of
Measurement
Device
As
previously
described,
the
WWIS
is
an
electronic
database
that
contains
information
related
to
the
characterization,
certification,
shipment,
and
emplacement
of
TRU
waste
at
the
WIPP.
The
data
are
required
to
ensure
that
waste
destined
for
WIPP
meets
applicable
regulatory
conditions,
including
radionuclide
data
on
CH
and
RH
TRU
waste,
cumulative
activity
of
RH
waste,
and
amount
of
important
waste
material
parameters
(e.
g.,
cellulosics).
Individual
generator
sites
are
responsible
for
inputting
waste
data
into
the
WWIS
system
externally.
Generator
sites
have
developed
their
own
unique
systems
for
collecting
the
information
needed
to
be
transmitted
to
WWIS,
including
worksheets,
electronic
spreadsheets,
and
fully
integrated
electronic
data
systems.
Regardless
of
the
mechanism
for
collecting
data,
each
generator
site
is
responsible
for
verifying
and
validating
all
required
data
prior
to
submittal
to
WIPP
via
the
WWIS
system.

In
the
CCA,
DOE
stated
that
the
WWIS
tracks
waste
components
and
associated
uncertainties
against
their
upper
and
lower
limits
and
provides
notification
before
the
waste
component
limits
are
exceeded,
in
accordance
with
40
CFR
Part
194.24(
e)(
1)
and
(2).
Each
site
has
determined
its
own
approach
for
submitting
TRU
waste
characterization
data
to
WIPP
for
shipments
for
disposal.
In
some
cases,
sites
have
developed
separate
databases
to
track
data
generation,
validation,
and/
or
data
submittal
to
WIPP.
At
other
sites,
the
data
input
system
is
manual,
which
may
result
in
a
higher
degree
of
uncertainty
in
data
quality.
However,
issues
with
respect
to
data
quality
may
also
arise
at
sites
using
electronic
data
collection,
verification,
and
transmittal.
For
example,
EPA
observed
during
an
inspection
at
INEEL
that
personnel
had
the
ability
to
change
data
without
receiving
proper
approval
for
such
changes.

II.
D.
3
Effect
of
Waste
Matrix
or
Waste
Type
on
Measurement
The
WWIS
and
data
validation
programs
at
sites
are
not
impacted
by
waste
type,
with
the
exception
of
RH­
TRU
waste.
EPA
determined
in
its
initial
certification
that
DOE
did
not
provide
any
waste
characterization
methods
for
RH­
TRU
waste,
nor
was
there
discussion
specific
to
how
DOE
will
quantify
the
RH­
TRU
waste.
All
of
the
waste
characterization
discussions
in
Chapter
4
43
of
the
CCA
concern
CH­
TRU
waste,
except
for
Chapter
4,
Table
4­
13
(p.
4­
49),
which
is
entitled
"Applicable
CH­
and
RH­
TRU
Waste
Component
Characterization
Methods."
Furthermore,
DOE
provided
no
discussion
regarding
the
applicability
of
CH­
TRU
waste
characterization
methods
to
RH­
TRU
waste.
Therefore,
the
effectiveness
of
existing
WWIS
procedures
and
methods
has
yet
to
be
demonstrated
for
RH­
TRU
waste
streams.

II.
D.
4
Scope
of
EPA
Approvals
for
Data
Validation/
Verification
and
the
WWIS
The
range
of
waste
types
that
EPA
may
approve
at
any
given
time
is
not
affected
by
the
WWIS
or
the
data
validation
processes,
with
the
exception
of
RH­
TRU
waste
as
described
in
section
D.
3.
To
date,
approvals
have
not
specifically
been
limited
by
waste
type,
although
they
may
be
limited
due
to
other
factors
(e.
g.
NDA).
44
III.
SUMMARY
OF
RESULTS
AND
LESSONS
LEARNED
III.
A
Summary
of
Results
Implementation
of
the
inspection
process
described
in
Sections
I
and
II
has
resulted
in
a
program
whereby
EPA
is
compelled
to
provide
authorizations
that
either
mirror
that
sought
by
the
site
(i.
e.,
for
given
waste
streams
or
Summary
Waste
Category
Groups),
or
is
less
than
that
sought
by
a
site
due
to
system
limitations.
Consequently,
EPA
is
required
to
revisit
sites
multiple
times
as
new
systems,
wastes,
or
other
elements
arise.
Table
2
presents
inspections
performed
by
EPA
to
date
under
the
authority
of
§
194.8(
b)
and
the
scope
of
the
resulting
approvals.
As
shown
in
this
Table,
EPA
has
inspected
7
sites,
ranging
from
one
to
9
times
each.
The
broadest
approval
given
by
EPA
has
been
for
specific
Summary
Waste
Category
Groups
of
Retrievably
Stored
Waste
(i.
e.,
debris
waste
at
RFETS),
while
the
most
limited
approval
was
for
a
single
waste
stream
at
the
SRS,
although
this
limited
approval
was
all
that
SRS
sought
at
the
time
of
the
inspection.
DOE
sites
that
have
been
authorized
by
EPA
to
ship
waste
to
the
WIPP
have
adequate
waste
characterization
programs
overall.
In
some
instances,
EPA
was
unable
to
complete
an
inspection
because
of
the
site's
limited
implementation
of
activities
within
the
scope
of
the
inspection.
45
Table
2
§
194.8(
b)
Inspections
Performed
by
EPA
as
of
January,
2002
Generator
Site
Date
of
Inspection
Type
of
Inspection
Inspection
Scope
Elements
Examined
Scope
of
EPA
Approval
Rocky
Flats
(RFETS)
EPA­
RFETS­
6.98­
8
June
22­
25,
1998
194.8
Contact­
handled
debris
waste
NDA,
AK,
RTR,
VE,
WWIS/
DV
Characterization
program
was
approved,
with
NDA
approval
limited
to
the
use
of
IQ­
3
SGS
and
WM3100
PNC
RFETS
EPA­
RFETS­
4.99­
8
April
27­
28,
1999
194.8
Leco
crucibles
and
pyrochemical
salt
NDA,
AK,
VE
Characterization
program
was
approved
and
broadened
to
include
Leco
Crucibles
and
pyrochemical
salt,
with
NDA
approval
expanded
to
include
the
use
of
calorimetry
(CAL/
GAMMA)

RFETS
EPA
RFETS­
11.99­
8
November
16­
18,
1999
194.8
Wet
residue,
dry
residue,
pyrochemical
salts,
incinerator
ash
(including
Leco
crucibles
and
magnesium
oxide
inserts)
NDA/
gravimetric
techniques,
AK,
WWIS/
DV
Characterization
program
was
approved
and
broadened
to
include
wet/
dry
residue,
pyrochemical
salts,
and
incinerator
ash,
with
NDA
approval
expanded
to
include
SGS
Can
Counters,
SGS
Drum
Counters,
and
the
TGS
RFETS
EPA­
RFETS­
9.00­
8
September
18­
21,
2000
194.8
Residues
NDA
Characterization
program
was
approved,
with
NDA
approval
expanded
to
include
NMC,
two
new
TGS
CAN
Scanners,
and
a
skid­
mounted
Tomographic
Gamma
Can/
Drum
Scanner
RFETS
EPA­
RFETS­
1.01­
8
January
29­
February
2,
2001
194.8
Contact
Handled
Retrievably
Stored
Debris/
Solids
NDA
Inspection
postponed
by
DOE
RFETS
EPA­
RFETS­
5.01­
8
May
14­
17,
2001
194.8
Debris
waste
NDA,
WWIS/
DV,
VE,
RTR
Limited
approval
of
SuperHENC,
Building
569
PADC,
Building
569
Tomographic
Gamma
Scanner.
Generator
Site
Date
of
Inspection
Type
of
Inspection
Inspection
Scope
Elements
Examined
Scope
of
EPA
Approval
46
INEEL
EPA­
INEEL­
7.98­
8
July
28­
30,
1998
194.8
Contact­
handled
retrievably
stored
debris
waste
generated
at
Rocky
Flats
AK,
NDA,
VE,
RTR,
WWIS/
DV
Limited
characterization
program
was
approved
for
only
inorganic
solids
and
graphite
debris
waste,
with
NDA
limited
to
Canberra
IQ2
and
SWEPP
PAN
INEEL
EPA­
INEEL­
5.99­
8
May
17­
21,
1999
Originally
planned
to
be
194.8,
revised
to
194.24
Scheduled
to
examine
solids,
debris,
soils,
gravels.
AK,
NDA,
RTR,
WWIS/
DV
Elements
of
system
examined
were
inconclusive
with
regard
to
wastes
examined;
EPA
instead
verified
that
previously
approved
system
was
being
adequately
maintained
INEEL
EPA­
INEEL­
4.00­
8
April
24­
28,
2000
194.8
Contact­
handled
retrievably
stored
debris
waste
generated
at
Rocky
Flats
NDA,
WWIS/
DV,
VE,
RTR
Characterization
program
was
approved
and
broadened
to
include
all
CH
retrievably
stored
debris
waste
generated
at
Rocky
Flats.
NDA
approval
broadened
to
include
SWEPP
SGRS
and
PAN
systems
INEEL
EPA­
INEEL­
12.00­
8
December
5­
7,
2000
and
one
day
follow­
up
on
January
8,
2001
194.8
Contact­
handled
retrievably
stored
homogenous
solids
(S3000)
waste
generated
at
Rocky
Flats
AK,
NDA
Characterization
program
was
approved
and
broadened
to
include
homogenous
solids;
NDA
approval
expanded
to
include
SWEPP
SGRS
and
PAN
systems
re­
examined
for
subject
waste
INEEL
EPA­
INEEL­
7.01­
8
July
25­
26,
2001
194.8
Contact­
handled
retrievably
stored
homogenous
solids
and
debris
waste
generated
at
Rocky
Flats
NDA
Characterization
program
was
approved;
NDA
system
approval
broadened
to
include
WAGS
INEEL
EPA­
INEEL­
10.01­
8
October
29­
31,
2001
194.8
Organic
sludge
NDA,
AK
Inspection
postponed
by
DOE
SRS
EPA­
SRS­
11.00­
8
November
6­
17,
2000
194.8
Waste
stream
SR­
T001­
221F­
HET
(a
contacthandled
debris
waste)
AK,
NDA,
VE,
RTR,
WWIS/
DV
Characterization
program
approved
for
one
waste
stream;
NDA
approved
use
of
PAN
and
SGS
systems
Generator
Site
Date
of
Inspection
Type
of
Inspection
Inspection
Scope
Elements
Examined
Scope
of
EPA
Approval
47
SRS
EPA­
SRS­
9.01­
8
September
24­
26,
2001
194.8
Retrievably
stored,
contact­
handled
debris
waste
generated
at
SRS
and
limited
to
waste
streams
SRW027­
221F
HET
A­
HET­
E
AK,
NDA,
VE,
RTR,
WWIS/
DV
Inspection
postponed
by
DOE
SRS
EPA­
CCP­
10.01­
8
October
15­
19,
2001
194.8
Retrievably
stored,
contact­
handled
debris
waste
generated
at
SRS
and
limited
to
waste
streams
SRW027­
221F
HET
A­
HET­
E
AK,
NDA,
VE,
RTR,
WWIS/
DV
All
elements
approved
for
CCP
systems
at
SRS
only
(i.
e.,
CCP
VE,
IPAN/
GEA,
RTR,
WWIS).

SRS
EPA­
SRS­
12.01­
8
December
12­
16,
2001
194.8
Retrievably
stored,
contact­
handled
debris
waste
generated
at
SRS
and
limited
to
waste
streams
SRW027­
221F
HET
A­
HET­
E
AK,
NDA
Report
pending.

LANL
EPA­
LANL­
6.99­
8
June
14­
18,
1999
194.8
Contact­
handled,
retrievably
stored
debris
and
solidified
homogenous
solid
wastes
(S5000
and
S3000)
AK,
NDA,
VE,
RTR,
WWIS/
DV
All
elements
approved,
NDA
systems
approved
were
the
TGS
and
HENC
NTS
EPA­
NTS­
6.99­
8
June
7­
11,
1999
194.8
Contact­
handled
debris
waste
AK,
NDA,
VE,
RTR,
WWIS/
DV
Waste
characterization
program
did
not
adequately
characterize
the
proposed
waste;
approval
denied.

Hanford
EPA­
HAN­
1.00­
8
January
24­
28,
2000
194.8
Contact­
handled
debris
waste
AK,
NDA,
VE,
RTR,
WWIS/
DV
Characterization
program
was
approved
for
contact­
handled
debris
waste;
NDA
systems
approved
were
two
GEA
systems
and
one
IPAN
system
Generator
Site
Date
of
Inspection
Type
of
Inspection
Inspection
Scope
Elements
Examined
Scope
of
EPA
Approval
48
Hanford
EPA­
HAN­
12.01­
8
December
17­
21,
2001
194.8
Contact­
handled
debris
and
solid
waste
NDA,
VE
Approved
to
characterize
CH­
debris
waste
using
the
SGSAS
NDA
system
and
CH­
solids
using
VE
process
during
repackaging.

AK
=
Acceptable
Knowledge;
CAL/
GAMMA
=
Calorimetry;
CBFO
=
DOE
Carlsbad
Field
Office;
CCP
=
Centralized
Characterization
Project;
DOE
=
U.
S.
Department
of
Energy;
DR/
CT
=
Digital
Radiography/
Computed
Tomography;
DV
=
Data
Validation;
GEA
=
Gamma
Energy
Assay;
EPA
=
U.
S.
Environmental
Protection
Agency;
HENC
=
High
Efficiency
Neutron
Counter;
HGPe
=
High
Purity
Germanium;
INEEL
=
Idaho
National
Engineering
and
Environmental
Laboratory;
IPAN
=
Imaging
Passive
Active
Counter
;
LANL
=
Los
Alamos
National
Laboratories;
LLNL
=
Lawrence
Livermore
National
Laboratory;
NDA
=
Nondestructive
Assay;
NMC
=
Neutron
Multiplicity
Counter;
NTS
=
Nevada
Test
Site;
PADC
=
Passive
Active
Drum
Counter;
RFETS
=
Rocky
Flats
Environmental
Technology
Site;
RTR
=
Real­
Time
Radiography;
SGS
=
Segmented
Gamma
Scanner;
SGSAS
=Segmented
Gamma
Scan
Assay
System
;
SRS
=
Savannah
River
Site;
SWEPP
SGRS
=
Stored
Waste
Examination
Pilot
Plant
Gamma
Ray
Spectrometer
;
SWEPP
PAN
=
Stored
Waste
Examination
Pilot
Plant
Passive
Active
Neutron
Counter
;
TGS
CAN
=
Tomographic
Gamma
Scanner;
TRU
=
Transuranic;
VE
=
Visual
Examination;
WAGS
=
Waste
Assay
Gamma
Spectrometer;
WIPP
=
Waste
Isolation
Pilot
Plan;
WWIS
=
WIPP
Waste
Information
System
49
III.
B
Lessons
Learned
As
a
result
of
our
site
inspection
experience
we
have
identified
a
number
of
general
observations,
or
"lessons
learned,"
related
to
waste
characterization
activities.

°
Implementation
of
waste
characterization
is
not
consistent
across
sites.
Because
one
generator
site
is
capable
of
implementing
an
adequate
program
does
not
mean
that
other
sites
that
use
the
same
equipment
are
also
implementing
an
adequate
program.
For
example,
while
EPA
has
approved
the
use
of
Mobile
Characterization
System
(MCS)
NDA
at
RFETS
(Inspection
EPA­
RFETS­
6.98­
8;
Air
Docket
A­
98­
49,
Item
II­
A4­
4),
EPA
has
not
allowed
the
use
of
the
same
equipment
at
Nevada
Test
Site
due
to
concerns
regarding
quality
control,
measurement
performance,
and
documentation
(Inspection
EPA­
6.99­
8;
Air
Docket
A­
98­
49,
Item
II­
A4­
9).

°
Sites
have
not
been
able
to
characterize
all
of
their
wastes
at
the
time
of
inspection,
and
approvals
have
been
sought
and
given
based
on
sites'
own
limitations.
For
example,
Savannah
River
Site
originally
sought
and
was
granted
EPA
approval
for
characterization
of
a
single
waste
stream,
and
wrote
procedures
specific
to
that
waste
stream
(Inspection
EPA­
SRS­
11.00­
8;
Air
Docket
A­
98­
49,
Item
II­
A4­
16).
EPA
may
extend
approvals
for
all
waste
types
in
some
areas,
but
in
other
instances
the
limitation
is
warranted.
For
example,
use
of
the
WWIS
for
data
transmittal
is
not
conditioned
on
waste
type,
but
the
method
of
nondestructive
analysis
may
be.
INEEL
initially
developed
procedures
and
characterization
activities
focusing
only
on
inorganic
solids
and
graphite
debris
waste
(Inspection
EPA­
INEEL­
7.98­
8,
Air
Docket
A­
98­
49,
Item
II­
A4­
2).
Consequently,
a
single,
one­
size­
fits­
all
approval
typically
is
not
possible
for
all
waste
types
and
processes
at
a
site.

°
AK
and
NDA
personnel
sometimes
do
not
communicate
adequately,
resulting
in
the
use
of
AK
data
by
NDA
personnel
that
the
AK
personnel
did
not
know
existed.
For
example,
Hanford
Site
NDA
personnel
used
AK
radioassay
information
to
help
determine
isotopic
distribution,
but
this
information
was
not
provided
to
the
AK
personnel,
included
in
the
AK
record,
or
integrated
into
AK
Summary
documentation.
The
AK­
NDA
linkage
is
crucial
when
AK
is
used
directly
by
NDA
personnel,
and
EPA
inspectors
examine
AK­
NDA
interface
issues
as
part
of
the
evaluation
of
the
overall
characterization
program.
Problems
with
the
interface
reflect
a
loss
of
control
over
use
of
important
data
by
a
site.

°
EPA
has
performed
some
inspections
for
which
only
limited
examples
of
procedural
implementation
were
provided
by
the
site.
Only
a
few
waste
containers
were
fully
characterized,
and
it
was
difficult
to
determine
how
the
system
would
function
once
the
process
was
fully
operational.
For
example,
initial
approval
of
the
INEEL
waste
characterization
system
for
solids/
solidified
waste
was
sought
based
on
full
characterization
of
only
a
single
drum
of
waste
(Inspection
EPA­
INEEL­
12.00­
8;
Air
Docket
A­
98­
49,
Item
II­
A4­
15).
In
such
instances,
it
is
essential
that
rigorous
application
50
of
controls
be
maintained
after
approval
is
given
and
production
level
characterization
begins.
In
the
case
of
INEEL,
EPA
found
that
this
site
inadvertently
shipped
waste
characterized
using
an
NDA
system
that
was
not
yet
approved
by
EPA,
necessitating
more
inspections
by
EPA.
(Inspection
EPA­
INEEL­
7.01­
8;
Air
Docket
A­
98­
49,
Item
II­
A4­
17).

Once
EPA
has
given
the
initial
approval
to
a
site's
overall
program,
it
is
useful
to
perform
"system
check"
inspections
on
a
regular
basis.
The
frequency
of
inspections
may
lessen
as
the
site
demonstrates
institutional
control
over
the
characterization
process.
EPA
should
have
flexibility
in
scheduling
inspections,
and
this
flexibility
should
be
independent
of
DOE's
own
inspection
process.

°
Often
EPA
inspectors
arrive
at
a
site
to
find
that
the
lower­
tier
procedures
that
they
reviewed
in
advance
have
been
revised
by
the
site,
in
response
to
earlier
CBFO
inspections
and
surveillances
or
for
other
reasons.
EPA
has
experienced
this
problem
at
every
site.
This
situation
interferes
with
the
smooth
progress
of
the
inspection
plan,
because
inspectors
must
take
the
time
to
compare
the
procedures
and
understand
the
changes
before
proceeding
with
the
substance
of
the
inspection.

°
Consistent
with
40
CFR
194.8(
b),
EPA's
approach
to
site
approvals
has
been
to
authorize
characterization
only
for
certain
waste
streams
or
groupings
of
waste
streams
(i.
e.,
Summary
Waste
Category
Groups).
Consistent
with
its
QA
procedures,
DOE's
approach
has
been
to
certify
sites'
characterization
programs
overall
and
then
authorize
shipment
only
of
waste
streams
presented
by
the
site.
This
difference
in
approach
to
site
approvals/
certification
has
been
confusing
for
DOE
sites,
particularly
during
EPA's
early
inspections
in
1998
and
1999.
51
IV.
SUMMARY
OF
PUBLIC
COMMENTS
ON
EPA
INSPECTIONS
This
section
presents
several
examples
of
the
public
comments
that
EPA
has
received
on
their
inspection
results.
As
of
January
2002,
we
have
published
a
total
of
twenty­
one
Federal
Register
notices
related
to
those
inspections.
In
response
to
the
twenty­
one
notices,
we
have
received
nine
sets
of
comments.
Of
the
comments
received,
four
were
from
the
Environmental
Evaluation
Group
(or
EEG,
New
Mexico's
independent
scientific
oversight
organization
for
the
WIPP)
and
focused
specifically
on
documents
in
the
docket
[see
Docket
A­
98­
49,
Category
II­
A3,
Items
11,
21,
22,
and
31].
EEG
observers
usually
attend
EPA
inspections,
and
so
have
the
opportunity
to
discuss
their
comments
directly
with
DOE
personnel
during
the
inspection.

Other
than
comments
from
EEG,
we
received
five
sets
of
comments.
Four
of
these
sets
were
requests
to
extend
the
public
comment
period,
which
we
did
in
one
instance
[see
Docket
A98
49,
Category
II­
A3,
Items
3,
8,
27,
and
30],
and
the
remaining
set
contained
specific
comments
on
documents
in
the
docket
[see
Docket
A­
98­
49,
Category
II­
A3,
Item
29].
We
respond
to
comments
sent
to
the
docket
in
our
inspection
reports,
which
are
filed
in
Docket
A­
98­
49,
Category
II­
A4.
Representative
examples
of
comments
are
presented
below.

EPA­
INEEL­
7.01­
8
(July
25­
26,
2001);
Air
Docket
A­
98­
49,
Item
II­
A4­
17
EPA
received
two
sets
of
comments
in
EPA
Air
Docket
A­
98­
49
in
response
to
our
Federal
Register
notice
of
July
13,
2001.
The
comments
are
filed
as
(1)
Item
II­
A3­
27
and
(2)
IIA3
29.
Examples
of
significant
comments
follows.

Issue
A:
Information
provided
in
Docket
A­
98­
49
was
not
sufficient
to
enable
the
public
or
EPA
to
reach
conclusions
about
the
compliance
of
the
WAGS
system.
Therefore,
EPA
should
extend
the
public
comment
period.

1.
Based
on
the
documents
in
the
docket,
it
is
impossible
for
EPA
or
the
public
to
know
how
many
drums
were
certified
using
the
WAGS
system
because
none
of
the
documents
in
the
docket
describe
what
characterization
and
quality
assurance
(QA)
procedures
were
used
on
the
1,917
drums
with
waste
in
the
69
shipments
that
INEEL
made
to
WIPP
between
December
7,
2000
and
June
27,
2001
(INEEL
shipments
KN001201
and
1202,
IN010031
to
010097
­­
WIPP
Waste
Information
System
data).
[1]

2.
The
docket
provides
no
basis
for
EPA,
or
the
public,
to
conclude
that
the
WAGS
System
actually
operated
in
a
manner
equivalent
to
the
SGRS
system
for
any
or
all
of
the
period
that
it
was
being
used
as
part
of
the
waste
characterization
process.
[1]

3.
Neither
EPA,
nor
the
public,
can
conclude
that
the
drums
shipped
to
WIPP
were
adequately
characterized,
so
the
question
of
what
should
now
be
done
with
those
drums
at
WIPP
cannot
be
answered
based
on
documents
currently
available
to
the
public.
We
believe
that
52
EPA
cannot
make
any
decision
about
the
status
of
those
drums
without
adequate
documentation
being
made
available
to
the
public.
[1]

4.
Based
on
the
documents
in
the
docket,
we
cannot
conclude
that
the
WAGS
system
meets
the
quality
assurance
requirements
of
40
CFR
194.8(
a).
[1]

5.
Based
on
the
documents
in
the
docket,
we
also
cannot
conclude
that
the
WAGS
system
meets
the
waste
characterization
requirements
of
40
CFR
194.8(
b).
[1]

6.
The
docket
provides
no
documentation
regarding
how
INEEL
or
EPA
determined
which
drums
were
characterized
using
the
WAGS
system,
how
the
WAGS
system
was
used
and
how
its
use
changed
during
the
time
period
in
question,
as
to
the
nature
of
the
process
knowledge
documentation
for
those
drums,
or
other
relevant
information.
Thus,
based
on
what
is
available
in
the
docket,
the
public
cannot
adequately
comment
on
the
status
of
those
drums,
nor
does
EPA
have
adequate
information
to
make
its
determinations.
[1]

7.
As
specified
in
its
Federal
Register
notice
of
July
13,
2001
(66
Fed.
Reg.
36723),
EPA
is
providing
its
normal
30­
day
public
comment
period
on
"waste
characterization
program
documents."
However,
the
current
situation
is
not
normal,
it
is
the
most
complex
yet
faced
by
EPA
involving
a
site's
waste
characterization
program.
In
such
an
abnormal
situation,
a
longer
public
comment
period
is
necessary,
and
it
is
clearly
allowed
by
40
CFR
194.8.
In
addition,
the
fact
that
important
documents
are
not
yet
available
necessitates
an
extension
of
the
public
comment
period
to
allow
public
comment
on
the
appropriate
documentation.
[1]

Response
to
Issue
A:

We
decided
not
to
extend
the
comment
period.
We
believe
that
30
days
was
sufficient
time
to
allow
the
public
to
raise
questions
or
concerns
about
the
WAGS
system,
and
that
the
information
that
we
docketed
was
appropriate,
for
the
reasons
explained
below.

When
we
open
a
comment
period
under
40
CFR
194.8,
the
primary
purpose
of
the
public
comment
period
is
to
allow
the
public
to
provide
potentially
relevant
information
to
EPA
or
to
raise
compliance
concerns
or
questions,
so
that
EPA
is
aware
of
those
concerns
and
questions
and
can
seek
resolution
to
them
prior
to
making
a
final
compliance
decision.
Any
specific
processes
or
waste
streams
about
which
we
are
seeking
public
input
are
defined
in
the
inspection
notice
that
we
provide
in
the
Federal
Register.
As
we
explained
in
our
May
1998
Certification
Decision
(see,
for
example,
EPA
Air
Docket
A­
93­
02,
Item
V­
C­
1,
pp.
2­
8
to
2­
11
and
6­
26),
EPA's
compliance
decision
under
194.8
must
be
based
on
our
independent
inspections
of
waste
characterization
processes.
Inspections
involve
review
of
many
different
documents,
interviews
with
staff,
and
on­
site
demonstrations,
which
are
then
summarized
and
made
public
in
our
inspection
reports.
It
is
neither
possible
nor
appropriate
to
attempt
to
place
all
information
that
may
be
relevant
to
the
scope
of
our
inspection
in
our
docket
before
we
conduct
an
inspection.
53
We
docketed
key
documents
that
we
determined
were
pertinent
to
the
proposed
WAGS
system.
In
light
of
the
WAGS­
related
nonconformance
that
we
identified
in
June
2001
(see
Issue
B
below),
and
in
anticipation
of
public
concern,
we
included
additional
DOE
documents
that
directly
pertained
to
the
nonconformance.
It
was
not
our
expectation
that
the
public
would
be
able
to
reach
conclusions
about
either
the
WAGS
system's
technical
adequacy
or
the
WAGS­
related
nonconformance
based
solely
on
the
docketed
materials.
EPA
makes
the
determination
of
compliance
following
a
site
inspection.

With
regard
to
comment
A.
1,
we
obtained
objective
evidence
during
our
July
2­
3
inspection
at
INEEL
that
established
the
status
of
all
drums
characterized
by
the
WAGS
system
and
shipped
to
the
WIPP
site.
This
information
is
contained
in
our
report
for
inspection
no.
EPAINEEL
7.01­
24
(Docket
A­
98­
49,
Item
II­
A1­
28).

EPA­
RFETS­
4.99­
8
(April
27­
28,
1999);
Air
Docket
A­
98­
49,
Item
II­
A4­
6
EPA
received
one
set
of
comments
from
the
EEG
in
response
to
the
items
announced
in
the
Federal
Register
on
March
25,
1999
(64
FR
14418).
The
letter
from
EEG,
dated
April
23,
1999,
may
be
found
in
EPA
Air
Docket
A­
98­
49,
Item
II­
A3­
11.
Below
are
some
examples
of
significant
issues
raised
in
EEG's
letter
and
EPA's
response
to
those
issues.
EPA
inspectors
discussed
some
of
the
issues
with
DOE
Carlsbad
Field
Office
(CAO)
personnel
(Sam
Vega,
Van
Bynum,
and
Mark
Doherty)
and
RFETS
personnel
(Gerald
O'Leary
and
Mark
Castagneri)
during
the
inspection,
in
the
presence
of
Ben
Walker
of
EEG.

EEG
Issue
D:
Sites
such
as
RFETS
must
meet
requirements
for
certain
waste
material
parameters
that
have
not
been
shown
to
affect
the
WIPP's
performance.
RFETS
should
consider
the
relative
importance
of
waste
material
parameters.

1.
The
RFETS
QAPjP
follows
the
CAO's
Transuranic
Waste
Characterization
Quality
Assurance
Program
Plan
(TRU
Waste
QAPP,
CAO­
94­
1010,
Revision
0)
in
continuing
to
consider
all
of
the
TWBIR
waste
material
parameters
equally.
.
.
[The
RFETS
QAPjP],
and
the
overall
RFETS
TRU
waste
program,
should
develop
training
and
awareness
of
the
relative
importance
of
obtaining
defensible
measurements
for
the
two
types
of
waste
material
parameters
[i.
e.,
cellulosics/
plastics/
rubbers
and
ferrous
metals]
that
have
been
shown
to
be
important
to
containment
of
waste
in
the
repository.

EPA's
Response
to
Issue
D:

This
comment
suggests
that,
by
treating
"all
of
the
TWBIR
waste
material
parameters
equally,"
RFETS
(and
DOE
generally)
may
be
compromising
in
some
fashion
the
analysis
of
waste
parameters
that
are
central
to
compliance
with
EPA's
disposal
regulations.
EPA
did
not
find
evidence
during
the
inspection
to
support
the
claim
that
RFETS
is
not
properly
accounting
for
the
important
waste
parameters.
As
for
other
parameters,
EPA
does
not
have
a
basis
to
require
54
programmatic
changes
in
the
WIPP
project
unless
they
are
shown
to
be
necessary
for
compliance
with
our
regulations.

EEG
Issue
N:
The
docketed
items
were
well
done
but
may
be
insufficient
for
assessing
RFETS
compliance.

1.
[EEG's]
comments.
.
.
should
be
considered
as
describing
deviations
in
what,
for
the
most
part,
appears
to
be
a
very
well­
planned
program
adequate
to
meet
the
EPA's
waste
characterization
planning
requirements
specified
in
40
CFR
194.8.
.
.
The
EEG
does,
however,
point
out
that
documentation
the
EPA
may
need
for
thorough
analysis
of
RFETS
compliance
with
40
CFR
194
may
not
be
covered
by
the
documents
provided
to
the
WIPP
docket
for
public
review.

EPA's
Response
to
Issue
N:

EPA
agrees
that
the
RFETS
TRU
Waste
Management
Manual
and
Quality
Assurance
Project
Plan
are
well­
prepared
documents.
EPA
cannot
rely
solely
on
such
documents,
however,
to
evaluate
transuranic
waste
sites'
quality
assurance
and
waste
characterization
programs.
As
we
have
noted
elsewhere,
inspections
and
inspections
are
appropriate
mechanisms
for
verifying
compliance
with
Conditions
2
and
3
of
our
certification
of
the
WIPP
(see,
for
example,
63
FR
27359).
Prior
to,
during,
and
after
inspections
EPA
may
review
a
wide
variety
of
procedures,
records,
and
data
in
order
to
reach
a
determination
that
the
programs
under
review
are
adequately
established
and
executed.
EPA
requires
DOE
to
submit
a
site's
top
governing
documents
prior
to
an
inspection
to
afford
the
public
an
opportunity
to
comment
on
the
site's
programs
and
to
raise
issues
that
the
Agency
should
consider
in
deciding
whether
or
not
to
approve
those
programs.
55
V.
CONCLUSIONS
EPA's
inspection
process
examines
the
technical
elements
important
to
demonstrating
compliance
with
40
CFR
194.24
waste
characterization
systems
of
control.
EPA
inspectors
examine
Acceptable
Knowledge
(i.
e.,
the
historical
documentation
that
provides
radionuclide,
waste
material
parameter,
and
other
information),
Nondestructive
Assay
(for
radionuclide
quantifications),
Visual
Examination/
Radiography
(to
assess
physical
waste
contents),
and
data
transfer
and
data
validation.
Evaluation
of
these
technical
elements
is
sufficiently
comprehensive
to
assess
the
technical
adequacy
of
the
system
of
controls
for
waste
characterization.

Inspections
conducted
to
date
have
demonstrated
that
the
application
of
technical
elements
listed
above
varies
considerably
from
site
to
site.
The
regulatory
language
governing
site
inspections
has
led
EPA
to
respond
to
issues
involving
one
or
more
technical
elements
by
restricting
the
scope
of
site
approval.
As
a
result,
EPA
inspectors
must
return
to
an
approved
site
if
the
site
seeks
to
ship
additional
waste
streams,
use
equipment
not
previously
inspected,
or
make
significant
changes
to
procedures
or
methods
for
waste
characterization.
56
REFERENCES
EPA
1994.
U.
S.
Environmental
Protection
Agency.
Waste
Analysis
at
Facilities
that
Generate,
Treat,
Store,
and
Dispose
of
Hazardous
Waste.
EPA
Office
of
Solid
Waste.
Directive
Number
9938.4­
03.
April
26,
1994.

EPA/
NRC
1997.
U.
S.
Environmental
Protection
Agecy
&
U.
S.
Nuclear
Regulatory
Commission.
Joint
NRC/
EPA
Guidance
on
Testing
Requirements
for
Mixed
Radioactive
and
Hazardous
Waste.
62
FR
62079­
62094.
November
20,
1997.
