                                      EPA AIR E-DOCKET NO: EPA-HQ-OAR-2017-0650
                   WASTE CHARACTERIZATION INSPECTION REPORT
                               PROPOSED APPROVAL
EPA BASELINE INSPECTION NO. EPA-AMWTP-FLUOR INSPECTION NO. 08.17-8
OF THE ADVANCED MIXED WASTE TREATMENT PROJECT
CONTACT-HANDLED TRANSURANIC WASTE
CHARACTERIZATION PROGRAM:
August 8 - 10, 2017
U.S. Environmental Protection Agency
Radiation Protection Division
Center for Waste Management and Regulations
1200 Pennsylvania Avenue, NW
Washington, DC 20460
                                 January 2018
Table of Contents
Section	Page
Acronyms and Initializations	iii
1.0	Executive Summary	1
2.0	Purpose of Baseline Inspections	5
3.0	Purpose of This Report	6
4.0	Scope of Inspection	6
5.0	Inspection Personnel	8
6.0	Technical Evaluation	8
6.1	Advanced Mixed Waste Treatment Project Background	8
6.2	Acceptable Knowledge (AK)	9
6.2.1	Acceptable Knowledge Conclusion	13
6.3	Nondestructive Assay (NDA)	14
6.3.1	Integrated Waste Assay System Units Z-211-102, Z-211-103, Z-390-100 and Z-390-101	15
6.3.2	Retrieval Box Assay System	20
6.3.3	SWEPP Gamma-Ray Spectrometer	24
6.3.4	Waste Assay Gamma System	27
6.3.5	Nondestructive Assay Conclusion	29
6.4	Real-Time Radiography (RTR)	30
6.4.1	Real-Time Radiography Conclusion	33
6.5	Visual Examination (VE)	34
6.5.1	Visual Examination Conclusion	37
7.0	Response to Comments	37
8.0	Summary of Results	38
8.1	Environmental Protection Agency Findings and Concerns	38
8.2	Conclusions	38
                                LIST OF TABLES
Table 1. Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented by the AMWTP	4
Table 2. Evaluated BDRs by Assay System	15

Attachments
Attachment A: Approval Summary for the AMWTP's Contact-Handled Waste Characterization Program	A-1
Attachment B: Baseline Inspection Personnel List	B-1
Attachment C: Acceptable Knowledge Baseline Inspection Checklist	C-1
Attachment D: Nondestructive Assay Baseline Inspection Checklist: Z-211 Integrated Waste Assay System (IWAS) Z-211-102 and Z-211-103	D-1
Attachment D.1: Replicate Testing Data for Container No. 10597312  -  IWAS Z-211-102	D-6
Attachment D.2: Replicate Testing Data for Container No. 10612378  -  IWAS Z-211-102	D-8
Attachment D.3: Replicate Testing Data for Container No. 10596959  -  IWAS Z-211-103	D-10
Attachment D.4: Replicate Testing Data for Container No. 10597411  -  IWAS Z-211-103	D-12
Attachment D.5: Replicate Testing Data for Container No. 10610103  -  IWAS Z-211-103	D-14
Attachment E: Nondestructive Assay Baseline Inspection Checklist: Z-390 Integrated Waste Assay System (IWAS) Z-390-100 and Z-390-101	E-1
Attachment F: Nondestructive Assay Baseline Inspection Checklist: Retrieval Box Assay System (RBAS)	F-1
Attachment G: Nondestructive Assay Baseline Inspection Checklist: Waste Assay Gamma Spectrometer (WAGS)	G-1
Attachment H: Nondestructive Assay Baseline Inspection Checklist: SWEPP Gamma-Ray Spectrometer	H-1
Attachment H.1: Replicate Testing Data for Container No. 10565693  -  SWEPP Gamma-Ray Spectrometer	H-6
Attachment H.2: Replicate Testing Data for Container No. 10566849  -  SWEPP Gamma-Ray Spectrometer	H-8
Attachment H.3: Replicate Testing Data for Container No. 10568514  -  SWEPP Gamma-Ray Spectrometer	H-10
Attachment I: Nondestructive Examination Baseline Inspection Checklist: Real-Time Radiography	I-1
Attachment J: Nondestructive Examination Baseline Inspection Checklist: Visual Examination	J-1
Attachment K: Documents Reviewed During the Baseline Inspection	K-1



Acronyms and Initializations
AAS	Add-A-Source
ABS	absorber index
ABSMOD	Absorber Moderator Index
AK	acceptable knowledge
AKA	acceptable knowledge assessment
AKD	acceptable knowledge document
AKE	Acceptable Knowledge Expert
AKR	acceptable knowledge resolution
AKSR	acceptable knowledge summary report
Am	americium
AMWTP	Advanced Mixed Waste Treatment Project
AN	active neutron
ARP	Accelerated Retrieval Project
Ba	barium
BDR	batch data report
BEGe	broad-energy germanium
BoK	Basis of Knowledge
CBFO	Carlsbad Field Office
CCE	chemical compatibility evaluation
CCP	Central Characterization Program
Cd	cadmium
Cf	californium
CFR	Code of Federal Regulations
CH	contact-handled
Ci	curie
CIS	Characterization Information Summary
CRR	Characterization Reconciliation Report
Cs	cesium
CTAC	Carlsbad Technical Assistance Contractor
Cu	copper
DOE	U.S. Department of Energy
DQO	data quality objective
DRR	document review record
DU	depleted uranium
EA	Expert Analyst
EPA	U.S. Environmental Protection Agency
FGE	fissile gram equivalent
FR	Federal Register
FRAM	Fixed-Energy Response Function Analysis with Multiple Efficiencies
FRP	fiberglass reinforced plastic
g	gram or grams
g/cm[3]	grams per cubic centimeter
He	helium
HLW	high-level waste
HPGe	high-purity germanium
HS	heat source
IDC	item description code
INL	Idaho National Laboratory
IQI	Image Quality Indicator
ITR	Independent Technical Reviewer
IWAS	Integrated Waste Assay System
IWMDL	Interface Waste Management Documents List
keV	kiloelectron volt
LANL	Los Alamos National Laboratory
LLD	lower limit of detection
LLW	low-level radioactive waste
LOQI	list of qualified individuals
MDA	minimum detectable activity
MDC	minimum detectable concentration
MOD	moderator index
MGA	Multi-Group Analysis
nCi/g	nanocuries per gram
NCR	nonconformance report
NDA	nondestructive assay
NDE	nondestructive examination
NIST	National Institute of Standards and Technology
Np	neptunium
NTP	National TRU Program
Pb	lead
PDP	Performance Demonstration Program
PN	passive neutron
Pu	plutonium
PuEff	effective plutonium
QA	quality assurance
RBAS 	Retrieval Box Assay System
RDS	Radioassay Data Sheet
RTR	real-time radiography
RWARS-EA	RBAS WIPP Analysis Reporting Software for Expert Analysis
RWMC	Radioactive Waste Management Complex
SATR	site acceptance test report
SCG	summary category group
SGRS	SWEPP Gamma-Ray Spectrometer
SNF	spent nuclear fuel
SPM	Site Project Manager
Sr	strontium
SRP	Sludge Repackaging Project
SWB	Standard Waste Box
SWEPP	Stored Waste Examination Pilot Plant
T1	Tier 1
T2	Tier 2
TMU	total measurement uncertainty
TRU	transuranic
U	uranium
VE	visual examination
VEE	Visual Examination Expert
WAGS	Waste Assay Gamma Spectrometer
WCO	Waste Certification Official
WDS	WIPP Waste Data System
WG	weapons-grade
WHB	WIPP Waste Handling Building
WIPP	Waste Isolation Pilot Plant
WMC	waste matrix code
WMP	waste material parameter
WSPF	waste stream profile form
WTS	Waste Tracking System


Executive Summary
This report supports the U.S. Environmental Protection Agency (EPA)'s proposed baseline approval of the contact-handled (CH) transuranic (TRU) waste characterization program implemented by the Advanced Mixed Waste Treatment Project (AMWTP) at the U.S. Department of Energy's (DOE's) Idaho National Laboratory (INL), located near Idaho Falls, Idaho, consistent with the limitations described in this report. This baseline inspection:
 Evaluates AMWTP-implemented changes to the Acceptable Knowledge (AK) process, referred to as Enhanced AK, addressing the waste characterization process deficiencies noted by the DOE Accident Investigation Board; and
 Is subject to public comment on the EPA's proposed approval of the waste characterization components inspected as part of the baseline inspection.
 In October 2006, the EPA approved the AMWTP's contact-handled (CH) TRU waste characterization program. (EPA Docket No. A-98-49; II-A4-66, October 2006) Between 2006 and 2015, the EPA conducted continued compliance inspections to verify that the AMWTP continue to characterize CH TRU waste using the EPA-approved waste characterization program components. The EPA also approved Tier 1 changes that added new waste streams, equipment, processes and procedures or significantly revised the EPA-approved waste characterization activities. However, the changes to the DOE's WIPP Waste Acceptance Criteria due to the February 2014, radiation release necessitated that the AMWTP make changes to their waste characterization program particularly acceptable knowledge. The EPA determined that these changes to the Waste Acceptance Criteria and the Enhanced Acceptable Knowledge process implemented at TRU generator sites are significantly different from the processes the EPA evaluated during previous site-specific inspections. As a result, the EPA informed the DOE that a new AMWTP baseline inspection and approval would be a necessary step to evaluate the technical adequacy of the newly-implemented Enhanced Acceptable Knowledge process at the AMWTP. 
The EPA conducted a baseline inspection (EPA Inspection No. EPA-AMWTP-Fluor Inspection No. 08.17-8) of the waste characterization program for the CH TRU debris, solid, and soil waste at the AMWTP on August 8 - 10, 2017, in accordance with 40 CFR Part 194 of the Code of Federal Regulations [40 CFR 194.8(b)]. Upon the Agency's final approval, the DOE may resume emplacing AMWTP CH TRU waste in the Waste Isolation Pilot Plant (WIPP). Also upon the EPA's final approval of the AMWTP's newly-implemented changes, the DOE may resume disposal of AMWTP CH TRU waste streams characterized in the manner discussed in this report.
The scope of the baseline inspection included:
 The acceptable knowledge process, focusing on the Enhanced AK process for CH TRU waste.
 The nondestructive assay (NDA) process, specifically, four Canberra Integrated Waste Assay Systems (IWAS), the Retrieval Box Assay System (RBAS), the Waste Assay Gamma Spectrometer (WAGS) and the Stored Waste Examination Pilot Plant (SWEPP) Gamma-Ray Spectrometer (SGRS).
 Visual examination (VE) and real-time radiography (RTR) using three RTR units for characterizing the physical waste components of TRU waste containers belonging to all CH waste summary categories (S5000, heterogeneous debris; S4000, soils; and S3000, homogeneous solids).
Attachment K is a list of all documentation reviewed, including all documentation revised during the inspection process and the batch data reports.
This baseline inspection evaluated the AMWTP's CH TRU waste characterization program for technical adequacy. When approved, the AMWTP will be allowed to continue using the program components to characterize contact-handled waste in accordance with the conditions and restrictions discussed in this report. The EPA is proposing to approve the AMWTP waste characterization program implemented to characterize contact-handled transuranic waste as documented in this report. Specifically, the proposed approval includes:
       The AK process for transuranic waste at the AMWTP, including the Enhanced AK process
       The four NDA systems (IWAS, RBAS, WAGS and SGRS) for characterizing CH TRU waste
       The VE and RTR processes to identify waste material parameters and the physical form of CH TRU waste.
Any changes to the waste characterization activities after the date of the baseline inspection must be reported to and, if applicable, approved by the EPA according to Table 1. All Tier 1 changes must be submitted for approval before their implementation and will be evaluated by the EPA. Upon approval, the EPA will post the results of the evaluations through the EPA website and the WIPPNEWS list. The AMWTP must submit Tier 2 changes that have been implemented four times a year, at the end of each fiscal quarter.
The EPA's final approval decision about the AMWTP's CH TRU waste characterization program will be conveyed to the DOE separately by letter following the Agency's review of public comments received responding to the proposed approval discussed in this report. This information will be provided through the EPA website and by emails to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3).

Table 1. Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented by the AMWTP
               (Based on August 8 - 10, 2017 Baseline Inspection)
                               Process Elements
AMWTP Waste Characterization Process  -  Tier 1 (T1) Changes Requiring EPA Approval
  AMWTP Waste Characterization Process  -  Reporting of Tier 2 (T2) Changes*
Acceptable Knowledge, including Payload Management 
None
Submission of a list of active AMWTP CH AKEs and SPMs who performed work during the previous quarter
Notification to the EPA upon completion of or substantive modification** to:
 RPT-TRUW-05, RPT-TRUW-07 and RPT-TRUW-12
 AK accuracy reports (annually, at a minimum)
 WSPFs and any associated change notices
 AKSRs and generator-site-specific AK documents
 Site procedures requiring CBFO approval
 The payload management status of approved waste streams
 Enhanced AK documents such as IWMDL forms and AKA, CCE, CCEM and BoK memoranda
Nondestructive Assay 
New equipment or substantive physical modifications** to approved equipment
Extension of or changes to approved calibration ranges for approved equipment
Submission of a list of AMWTP NDA operators, EAs and ITRs who performed work during the previous quarter
Notification to the EPA upon substantive modification** to: 
 Software for approved equipment
 Operating ranges upon CBFO approval 
 Site procedures requiring CBFO approval
Real-Time Radiography 
New equipment or substantive physical modifications** to approved equipment
Implementation of any new real-time radiography process
Submission of a list of AMWTP RTR operators and ITRs who performed work during the previous quarter
Notification to the EPA upon substantive modification** to site procedures requiring CBFO approval
Visual Examination
Implementation of any new visual examination process
Submission of a list of AMWTP VE operators, VE Experts and ITRs that performed work during the previous quarter
Notification to the EPA upon substantive modification** to site procedures requiring CBFO approval
 *	The AMWTP will report all T2 changes to the EPA every three months. 
 **	"Substantive modification" refers to a change with the potential to affect the AMWTP's CH waste characterization processes or documentation of them, excluding changes that are solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act; or that are editorial in nature or are required to address administrative concerns. The EPA may request copies of new references that DOE adds during a document revision.
 

Purpose of Baseline Inspections
On May 18, 1998, the EPA certified that the WIPP would comply with the radioactive waste disposal regulations in 40 CFR Part 191. In that certification, the EPA also included Condition 3, which states that "the Secretary shall not allow shipment of any waste from...any waste generator site other than [LANL] for disposal at the WIPP until the Agency has approved the processes for characterizing those waste streams for shipment using the process set forth in §194.8." The approval process described in 40 CFR 194.8 requires the DOE to (1) provide the EPA with information on AK for waste streams proposed for disposal at the WIPP, and (2) implement a system of controls used to confirm that the total amount of each waste component that will be emplaced in the WIPP will not exceed limits identified in the most recent WIPP Compliance Certification Application. 
The rule applying to this baseline inspection can be found in the Federal Register (Vol. 69, No. 136, pp. 42571 - 42583, July 16, 2004). According to these regulatory changes, the EPA must perform a baseline inspection of a TRU waste generator site's waste characterization program to determine technical adequacy of the processes, procedures and equipment implemented for characterizing WIPP-bound waste. This review is based on the demonstration that the program's components, with applicable conditions and limitations, can adequately characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes destined for disposal at the WIPP. An EPA Inspection Team conducts an onsite inspection to verify that the site's system of controls is technically adequate and properly implemented. Specifically, the EPA's Inspection Team verifies compliance with 40 CFR 194.24(c)(4), which states the following:
      Any compliance application shall: . . . Provide information which demonstrates that 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 of this section. 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. 
In other words, the purpose of the baseline inspection is to evaluate the implementation of 40 CFR Part 194 requirements by assessing whether the DOE sites that characterize TRU waste prior to disposal at the WIPP are capable of adequately doing so. The EPA may also conduct follow-up inspections to address issues remaining from the baseline inspection or to seek further clarification/discussion related to waste characterization processes evaluated during a baseline inspection. By approving the waste characterization systems and processes at the AMWTP for CH TRU waste, the EPA confirms that it has evaluated the capabilities of systems and processes implemented by the site to accomplish two tasks: (1) identification and measurement of waste components, such as plutonium (Pu), that must be tracked for compliance and (2) confirmation that the waste in any given container has been properly identified as belonging to the group of approved waste streams. 
Purpose of This Report
This report documents the basis for the EPA's proposed approval of the AMWTP waste characterization program for CH TRU wastes. Specifically, this report:
 Describes the AMWTP waste characterization systems proposed for approval.
 Delineates a specific set of CH wastes proposed for approval.
 Provides objective evidence supporting the proposed approval basis for all waste characterization systems.
 Identifies all relevant system limitations and/or conditions for each waste characterization system and/or waste containers that are subject to this proposed approval.
Scope of Inspection
The scope of Baseline Inspection No. EPA-AMWTP-Fluor Inspection No. 08.17-8 included the technical adequacy of the waste characterization systems used by the AMWTP to characterize solid (S3000), soil (S4000) and debris (S5000) CH TRU waste. The EPA conducted this baseline inspection of the AMWTP on August 8 - 10, 2017, at INL near Idaho Falls, Idaho.
The purpose of this inspection was to determine the site's compliance with 40 CFR 194.24. The EPA Inspection Team evaluated the AMWTP waste characterization systems with respect to AK, seven NDA systems, and VE and RTR as nondestructive examination systems.
The EPA performed this inspection by executing the following:
 Obtained and reviewed site procedures, reports and other technical information used to characterize CH TRU waste.
 Observed NDA, VE and RTR processes implemented at the AMWTP.
 Prepared technical questions prior to the inspection based on the activities listed in (1) above.
 Interacted with Carlsbad Field Office (CBFO) and the AMWTP personnel to arrange inspection logistics.
 Evaluated the AMWTP's implementation of waste characterization processes for adequacy and demonstrating compliance with 40 CFR 194.24 requirements.
 Conducted the baseline inspection to verify the technical adequacy and/or qualifications of CH waste characterization personnel, procedures, processes and equipment, as documented in the AMWTP's records.
 Evaluated the correlations of containers to identify common attributes.
 Communicated all pertinent information to CBFO and AMWTP personnel.
 Conducted entrance, exit and daily briefings for CBFO and AMWTP management personnel for all segments of the inspection.
 Obtained and reviewed AMWTP documents that were revised and/or created in response to inspection.
 Issued the draft inspection report and proposed approval.
During an inspection, the EPA does not approve characterization data; that function is the sole responsibility of the entity being evaluated  -  the AMWTP in this case. The EPA evaluates the site's waste characterization processes to characterize CH TRU waste. The AMWTP evaluation consisted of reviewing training records and interviewing waste characterization personnel to assess their understanding of (1) the EPA's TRU waste characterization and WIPP waste disposal requirements, (2) waste characterization processes implemented and available as alternatives and (3) the AMWTP's documentation and record-keeping procedures. 
In addition, the EPA evaluation focused on observing equipment operations and waste characterization practices at the AMWTP controlled by site procedures, and inspecting records related to each of the waste characterization processes within the inspection's scope. An important aspect of this evaluation is the objective evidence documenting the effectiveness of the waste characterization processes. Objective evidence typically takes the form of AK, NDA, VE and RTR records, including batch data reports. During this inspection, the EPA selected samples of each of these items, based on the number and variety of items each waste characterization process produced, consistent with standard auditing techniques. Based on an evaluation of the waste characterization processes in conjunction with the objective evidence, the EPA determined the technical adequacy of these processes and associated records within the inspection's scope.
The DOE documents that the EPA reviewed for this evaluation are cited throughout the report and are listed in Attachment K. Any of these documents can be requested from the following address:
   Director, NTP Compliance Division
Carlsbad Field Office
U.S. Department of Energy
P.O. Box 3090
Carlsbad, NM 88221-3090
Inspection Personnel
The EPA and its support personnel conducted interviews with AMWTP personnel in several disciplines during the site visit to the AMWTP. The members of the EPA Inspection Team and personnel contacted are listed in Attachment B.
Technical Evaluation
Sections 6.2 through 6.5 of this report detail the four technical areas assessed during this inspection: AK, NDA, RTR and VE. Completed inspection checklists are included in Attachments C, D, E, F, G, H, I and J.
Advanced Mixed Waste Treatment Project Background 
The AMWTP is located in the Idaho National Laboratory (INL) site, approximately 80 miles west of Idaho Falls, Idaho. The primary mission of the AMWTP since December 2008 has been characterization and treatment of TRU waste from across the DOE complex. 
Previous EPA Inspections/Approvals
The EPA initially approved the AMWTP's CH TRU waste characterization program in October 2006 (A-98-49; II-A4-66; October 3, 2006). Between 2006 and 2015, as shown in Attachemnt A, the EPA conducted continued compliance inspections to verify that the AMWTP continued to characterize CH TRU waste using the EPA-approved waste characterization program components. The EPA also approved Tier 1 changes that added new waste streams, equipment, processes and procedures or significantly revised the EPA-approved waste characterization activities. However, the changes to the DOE's WIPP Waste Acceptance Criteria due to the February 2014, radiation release necessitated that the AMWTP make changes to their waste characterization program particularly acceptable knowledge. The EPA determined that these changes to the Waste Acceptance Criteria and the Enhanced Acceptable Knowledge process implemented at TRU generator sites are significantly different from the processes the EPA evaluated during previous site-specific inspections. As a result, the EPA informed the DOE that a new AMWTP baseline inspection and approval would be a necessary step to evaluate the technical adequacy of the new Enhanced Acceptable Knowledge process at the AMWTP. 
After June 2015, when the WIPP Waste Acceptance Criteria, Rev. 8.0, became effective, the AMWTP revised the EPA-approved AK process to incorporate the revised AK requirements. As stated previously, the Agency determined that these AK changes to be significantly different than what the EPA had approved as part of the October 2006 baseline approval, thus requiring a new baseline inspection and approval. The EPA's decision to conduct a baseline inspection of the AMWTP does not imply a change to the regulatory framework in 40 CFR Part 194. 
Acceptable Knowledge (AK)
Waste Characterization Element Description
The EPA evaluated the AMWTP's AK waste characterization program for CH TRU waste characterization, focusing on the new Enhanced AK process. The EPA conducted this inspection by reviewing documents and records associated with a representative sample of S3000 (homogeneous solids) and S5000 (heterogeneous debris) waste. Inspection details and specific documents and records evaluated for each Item summarized below are recorded in the AK checklist that is included in Attachment C. The EPA did not evaluate any AK documentation related to S4000 (soil) waste streams; however, the EPA determined that the AK process for characterization of S4000 would be the same as the process evaluated during this inspection. Completion of documentation associated with the creation and characterization of an S4000 waste stream by the AMWTP is a Tier 2 reporting requirement, as described below (see Table 1).
Technical Evaluation
The EPA examined personnel training and qualifications and found them to be adequate.
The AMWTP provided qualification cards for all Acceptable Knowledge Experts and Site Project Managers that actively work with the AMWTP waste characterization program. The EPA reviewed example qualification cards and screenshots of the qualifications/certifications database showing the qualification dates and expiration dates for all AMWTP AK Experts and Site Project Managers. The EPA also interviewed a portion of the listed AK Experts and Site Project Managers and one Waste Certification Official. The EPA has no issues with AMWTP personnel qualifications for AK Experts, Waste Certification Officials, or Site Project Managers.
Submission to the EPA of a list of AK Experts and Site Project Managers who performed work in these roles for the AMWTP waste characterization program in the previous quarter is a Tier 2 reporting requirement (see Table 1).
The EPA assessed nonconformance and discrepancy resolution documentation and found it to be adequate. 
The EPA evaluated sample AK resolution checklists, discrepancy resolution reports and nonconformance reporting and found that the discrepancies were adequately documented and resolved. The EPA also observed use of the AK Resolution Ledger to track AK resolution checklists and associated action items. The AMWTP AK process includes reviewing the AK Resolution Ledger for open action items periodically and any time an AK summary report or generator-site-specific AK document is being revised. 
The EPA assessed documentation of waste stream definitions and waste traceability and found that the definitions are adequately supported and waste containers are adequately traceable.
The EPA evaluated waste stream definitions documented in two AK summary reports and supported by various source documents, AK documents and topic-specific reference documents (i.e., RPT-TRUW-05, RPT-TRUW-07 and RPT-TRUW-12). During this evaluation, the EPA verified:
 All waste within a waste stream was generated from a single process or activity.
 All waste within a waste stream is similar in material and physical form, and the expected physical parameters are adequately described.
 The expected radiological parameters are adequately documented.
 Any use of AK (and associated limitations) in NDA is clearly documented and communicated between AK and NDA personnel.
 Waste containers assigned to specific waste streams are traceable from generation through characterization and have documentation supporting inclusion in the waste stream.
Notification to the EPA upon completion of or substantive modification to all AK summary reports, AK documents and the three topic-specific reference reports RPT-TRUW-05, RPT-TRUW-07 and RPT-TRUW-12 are T2 changes (see Table 1).
The EPA evaluated implementation of the Enhanced Acceptable Knowledge process and found it to be adequate.
The Enhanced AK process is intended to document (1) evaluation of container-specific AK to provide reasonable assurance that the waste container management and packaging activities are bounded by the applicable AK and (2) evaluation of waste-stream-specific AK to provide reasonable assurance that all potential chemical incompatibilities have been identified and evaluated for impact to long-term isolation of TRU waste.
The AMWTP currently has two ways of documenting the container-specific evaluation: (1) the Interface Waste Management Documents List (IWMDL; FRM-2274) form documenting the waste-stream-generating process for containers generated using current/present-day procedures or (2) an AK assessment memorandum for existing waste streams with unshipped containers. The AMWTP does not consider an IWMDL form complete and available for demonstrating container-specific evaluations until all the procedures listed in an IWMDL form have been evaluated. The AMWTP is still in the process of conducting walk-down evaluations of each of the procedures listed on their first IWMDL form. The EPA reviewed the signed IWMDL form and an example completed checklist for one of the procedures and interviewed the AK Expert responsible for conducting the walk-downs. The process is reasonable, and the EPA will continue to review the process during future evaluations. 
The AMWTP will document using AK assessment memoranda that the AK associated with each container has been reviewed and all waste handling procedures and waste management documents have been accurately and completely accounted for. When completing the AK assessment memorandum for the Waste Stream BNINW216 containers at the WIPP Waste Handling Building, AMWTP AK experts evaluated the Rocky Flats (where the waste was originally generated prior to 1980 and buried at the Idaho National Laboratory) procedures and controlled documents that were already in the AMWTP record but did not attempt to fill in any holes between revisions. This approach is reasonable for waste streams from facilities such as Rocky Flats where operations varied little over the years, but it may not be appropriate for other waste streams. The EPA will continue to review the process during future evaluations.
The waste-stream-specific evaluation for chemical compatibilities is currently being documented on a chemical compatibility evaluation (CCE) memorandum. In general, the AMWTP intends to generate one chemical compatability evaluation memorandum for each waste stream that has containers yet to be emplaced at the WIPP. The primary source of information for the chemical compatability evaluation memorandum is the AK summary report, but the AK expert also reviews relevant source documents to identify additional chemicals not deemed necessary for inclusion in the AK summary report. An additional chemist and transportation personnel are involved in decisions about quantity and reaction potential. The EPA reviewed the only draft (yet to-be-CBFO-approved) AMWTP chemical compatability evaluation memorandum available during the inspection and found that the assumptions that form the bases of the chemical compatability evaluation memorandum's conclusions are clearly documented to support the DOE's chemical compatibility determination. In this case, submission of the final chemical compatability evaluation memorandum is a Tier 2 reporting requirement. 
As part of the corrective actions resulting from the February 2014 event at the WIPP, CBFO "established criteria [in the Basis of Knowledge (BoK)] that must be used by the WIPP Certified Programs to evaluate TRU waste containing one or more oxidizing chemicals to determine acceptability at the WIPP as-is and to identify when additional evaluation or treatment is required." As in the AK assessment process, the AMWTP documents this evaluation for each container destined for emplacement at the WIPP. The primary sources of information for the evaluation are the AK assessment and chemical compatability evaluation memoranda. The AK assessment for the Waste Stream BNINW216 containers at the WIPP Waste Handling Building identified the quantities of liquid absorbed in each container. For the Basis of Knowledge analysis, the AK expert completed bounding calculations to show that appropriate quantities of absorbent were used during packaging. The technical assumptions used to evaluate the subject containers against the specified criteria of the Basis of Knowledge for the treatment and management of oxidizing materials are clearly documented in the example Basis of Knowledge memorandum the EPA reviewed.
The sample IWMDL form and AK assessment, chemical compatability evaluation and Basis of Knowledge memoranda that the EPA reviewed adequately demonstrate implementation of the Enhanced AK process. However, as a result of the AK assessment, chemical compatability evaluation and Basis of Knowledge memoranda are being considered as "memoranda" instead of "reports". As a result, currently, the AMWTP does not have a strong system in place to control the review and revision processes for these documents. The AMWTP was aware of this weakness and indicated that they are "working on it." Submission of theses documents upon completion is a Tier 2 change reporting requirement. The EPA will continue to evaluate the Enhanced AK process during future evaluations. 
Notification to the EPA upon completion of or substantive modification to Enhanced AK documentation, including IWMDL forms and AK assessment, chemical compatability evaluation and Basis of Knowledge memoranda, are Tier 2 changes (see Table 1). Note that this Tier 2 requirement applies to all substantive modifications and reissuances of these documents, not just those modifications that are considered "revisions."
The EPA evaluated the waste stream certification process and found it to be adequate.
The EPA evaluated samples of the documents commonly associated with Site Project Manager certification of the waste streams, including Reconciliation with Data Quality Objectives forms, characterization information summaries, waste stream profile form packages and AK accuracy reports. The EPA found that the AMWTP's certification process is adequate and appropriately documented.
Notification to the EPA upon completion of or substantive modification to all waste stream profile forms and any associated change notices is a Tier 2 reporting requirement (see Table 1).
Notification to the EPA upon completion of or substantive modification to AK accuracy reports (annually, at a minimum) is also a Tier 2 reporting requirement (see Table 1).
The EPA evaluated the AMWTP's overall system of controls and found them to be adequate.
The EPA evaluated the AMWTP's completeness of the sampled AK summary reports and AK documents and general compliance with the AK procedure as evidenced by successful completion of the required forms and found the documents to be complete. The applicable waste stream documentation includes estimates of the total waste volume and the percentage of the waste volume that is above and below 100 nanocuries per gram (nCi/g).
The WIPP Land Withdrawal Act (Public Law 102-579) as amended by Public Law 104-201 states that waste identified for emplacement at the WIPP must be defense in origin, must not be spent nuclear fuel and must not be high-level waste. The EPA received sample AK summary reports and AK documents. In these documents, the DOE states that the waste has a defense origin and does not contain spent nuclear fuel or high-level waste. (For more details, see references C191A, TRUW-09 and TRUW-83 for AKSRs, as well as TRUW-56, TRUW-06 and TRUW-XX.)
The overall system of controls also includes the NDA, RTR and VE controls described in sections 6.3 through 6.5 of this report. The EPA finds that the system of controls in place at the time of this baseline inspection are adequate for ensuring the long-term isolation of TRU waste.
Any change to the payload management status of approved waste streams by the AMWTP is a Tier 2 reporting requirement (see Table 1). Changes to AMWTP procedures impacting the processes described in this report and requiring CBFO approval are also to be reported as Tier 2 changes (see Table 1).
Acceptable Knowledge Conclusion
Changes to Tiering
The EPA did not identify any Tier 1 changes relative to the AK process at the AMWTP. The EPA identified several Tier 2 changes, as described throughout section 6.2 and summarized in Table 1. The Tier 2 reporting requirements for AK are:
 Submission of a list of active AMWTP CH AK Experts and Site Project Managers who performed work during the previous quarter
 Notification to the EPA upon completion of or substantive modification to:
 RPT-TRUW-05, RPT-TRUW-07 and RPT-TRUW-12 
 AK accuracy reports (annually, at a minimum)
 Waste stream profile forms and any associated change notices
 AK summary reports and generator-site-specific AK documents
 Site procedures requiring CBFO approval
 The payload management status of approved waste streams
 Enhanced AK documents such as Interface Waste Management Documents List forms and AK assessment, chemical compatability evaluation and Basis of Knowledge memoranda
The language in Table 1 regarding AK documentation applies to all AMWTP CH waste streams, unless specifically stated otherwise.
The Enhanced AK process, as implemented, provides extensive documentation of generator-site and AMWTP waste treatment and packaging practices and can support the AMWTP's assessment that the WIPP-bound AMWTP TRU waste containers as processed do not exhibit characteristics of ignitability and reactivity, the main causes of the February 2014 WIPP radiation release.
Summary of Acceptable Knowledge Findings and Concerns
The EPA did not identify any AK-related findings or concerns. No open issues related to AK result from this inspection.
Proposed Acceptable Knowledge Baseline Approval
The EPA is proposing to approve the AK process, as observed during this inspection and in the context of the limitations described in this report. See Table 1 for AMWTP CH AK Tier 1 and Tier 2 changes resulting from this baseline inspection. 
Nondestructive Assay (NDA)
Waste Characterization Element Description 
The EPA evaluates several characteristics of an NDA measurement system during a technical inspection, including the range of conditions for which the instrument is capable of producing technically defensible data with regard to two aspects:
 Activity -- The nuclear disintegration rate of specific radiation types (neutron or gamma), typically special nuclear material or TRU radionuclides. Units of activity and mass are interchangeable by applying a conversion based on a radionuclide's specific activity.
 Physical characteristics -- The physical attributes of waste matrices as they relate to a radiometric system, i.e., how the matrix's physical properties interact with the radiations that originate within the sample and affect the system's ability to detect them. Examples include attenuation of photons and moderation and absorption of neutrons.
The AMWTP performs NDA on CH TRU wastes using the following seven NDA systems: 
 IWAS units Z-211-102 and Z-211-103, located in Building WMF-634
 IWAS units Z-390-100 and Z-390-101, located in Building WMF-676 
 WAGS, located in the SWEPP
 SGRS, located in the SWEPP 
 RBAS, located in Building WMF-634
The AMWTP uses these systems to identify and quantify the activities of the 10 WIPP-tracked radionuclides americium-241 ([241]Am), cesium-137 ([137]Cs), [238]Pu, [239]Pu, [240]Pu, [242]Pu, strontium-90 ([90]Sr), uranium-233 ([233]U), [234]U and [238]U and their uncertainties. Measurement data support a determination regarding the TRU alpha activity concentration of CH TRU waste containers. During this baseline inspection, the EPA inspected these seven AMWTP NDA systems, all of which had been evaluated and approved for characterizing TRU wastes at the AMWTP previously. The sections that follow describe all systems in detail.
The design and performance specifications of the four IWAS units are identical, although there are operational distinctions between the Z-211 and the Z-390 systems. As discussed in section 6.1, the SGRS and WAGS units were previously operated by INL-CCP and were transitioned to the AMWTP in 2015 (EPA Air e-Docket No. EPA-HQ-OAR-2001-0012-0466; April 4, 2016). The RBAS is a relatively new unit for CH TRU assays at the AMWTP, and EPA initially approved it in 2015 (EPA Air e-Docket No. EPA-HQ-OAR-2001-0012-0459; October 19, 2015). Specifically, the EPA reviewed the following elements of the NDA process for all seven AMWTP NDA systems:
 Capability of the measurement hardware and software to perform the required analyses for the radionuclides of interest, including their uncertainties, in the waste matrices of interest
 Technical adequacy of the NDA documents, procedures and controls
 Knowledge, understanding and training of NDA personnel at the AMWTP
Batch Data Reports Reviewed
During this inspection, the EPA evaluated batch data reports for all seven NDA systems. The specific batch data reports are listed below by assay system, including their AMWTP identifier and the types of containers that were assayed. As with all AMWTP records, the NDA batch data reports exist in electronic format only.
Table 2. Evaluated BDRs by Assay System
                               Instrument Number
                                  BDR Number	
                                Container Type
                                    in BDR
                                   Z-212-105
                                  BSY16-00110
                              Standard Waste Box
                                   Z-212-105
                                  BSY17-00036
                                   55-Gallon
                                   SGRS-610
                                  ASY16-02439
                                   55-Gallon
                                   SGRS-610
                                  ASY16-03128
                                   55-Gallon
                                   WAGS-610
                                  ASY16-04097
                                   55-Gallon
                                   WAGS-610
                                  ASY16-03498
                                   55-Gallon
                                   Z-211-102
                                  ASY16-02166
                             83/85-Gallon Overpack
                                   Z-211-102
                                  ASY17-01161
                                   55-Gallon
                                   Z-211-103
                                  ASY16-03800
                             83/85-Gallon Overpack
                                   Z-211-103
                                  ASY17-01299
                                   55-Gallon
                                   Z-390-100
                                  ASY16-02155
                                   55-Gallon
                                   Z-390-100
                                  ASY17-02468
                                   55-Gallon
                                   Z-390-101
                                  ASY16-02214
                                   55-Gallon
                                   Z-390-101
                                  ASY17-02152
                                   55-Gallon
Technical Evaluation
Integrated Waste Assay System Units Z-211-102, Z-211-103, Z-390-100 and Z-390-101
The Z-211-102 and Z-211-103 IWAS units are located in Building WMF-634. The Z-390-100 and Z-390-101 IWAS units are located in the processing facility, Building WMF-676; they are also referred to as the in-plant systems by virtue of their location within the waste processing facility at the AMWTP. The following sections describe all four units; any differences are noted. 
 The EPA verified that the designs and essential functions of the four Integrated Waste Assay System units were technically adequate and essentially the same.
The Z-211 and Z-390 IWAS units are identically designed NDA systems that combine active neutron and passive neutron assays with gamma spectrometry in a single system. All four IWAS units quantify TRU radionuclides in 55-gallon drums; however, the Z-211 systems also assay 55-gallon overpacks (83- or 85-gallon). All four systems can assay a variety of waste matrices, including combustibles, glass, organic and inorganic sludge, and metals. However, the Z-390 systems are limited to assaying only debris wastes, while the Z-211 systems assay debris and solids. During the period from June 1, 2016, through August 9, 2017, the Z-390-100 unit assayed 7,121 drums, the Z-390-101 unit assayed 5,205 drums, the Z-211-102 unit assayed 4,463 drums and the Z-211-103 unit assayed 4,216 drums. Not all these assays are germane to this inspection, because assay results of containers that show less than 100 nCi/g of TRU radionuclides indicate that the containers are not WIPP eligible (i.e., are not TRU waste).
IWAS passive neutron assays use more than 100 helium-3 ([3]He) proportional counters, arranged in a 4Π geometry to detect the neutrons emitted from spontaneous fission, typically associated with [240]Pu or other even-numbered Pu isotopes. The IWAS estimates the quantity of [240]Pu (referred to as the [240]Pu effective or [240]PuEFF) based on the measured neutron flux. Other radionuclides are quantified by combining the observed [240]Pu value with isotopic ratios that are measured using two broad-energy germanium (BEGe) detectors, described below, or are based on approved AK isotopics. The system uses an Add-A-Source technique to correct for the effects of the waste matrix on the container's neutron emission by introducing a californium-252 ([252]Cf) source into the measurement chamber. The system's response to the [252]Cf source with the waste present is compared to the response without waste to provide a container-specific matrix correction.
In the active neutron mode, a pulsed source of 14 mega-electron volt neutrons is thermalized by the high-density polyethylene walls of the measurement chamber, and potentially the waste matrix itself, and induces fission in fissionable radionuclides, most notably [239]Pu. The IWAS detects the fission-induced neutrons in one of four Fast Neutron Detector Packs located in the walls of each of the drum measurement chamber. Each Fast Neutron Detector Pack consists of several [3]He proportional counters surrounded by high density polyethylene walls and wrapped in a thin layer of cadmium. Using a differential die-away analysis, the [239]Pu content is quantified, referred to as the [239]Pu effective or [239]PuEFF. Other radionuclides are quantified by combining the observed [239]PuEFF with isotopic ratios from the broad-energy germanium detectors or AK, in the same manner as with the [240]PuEFF for passive neutron assays.
In the gamma-ray assay mode, the two broad-energy germanium detectors located in the chamber walls determine radionuclide ratios and the absolute quantity of gamma-emitting radionuclides. The broad-energy germanium detectors are withdrawn from the chamber to prevent neutron damage from active neutron assays and they are reinserted post-active neutron assay. Gamma spectra from the broad-energy germanium detectors are analyzed with Canberra's NDA-2000 software and Multi-Group Analysis, which estimates the radionuclide ratios based on the relative heights of specific gamma energy peaks. When Multi-Group Analysis fails to provide a valid result, NDA-2000 uses default isotopics based on previous assays of either weapons-grade Pu, if [239]Pu is the dominant Pu isotope, or an isotopic mix consistent with heat-source Pu, if [238]Pu is the dominant Pu isotope. In some cases, TRU radionuclides are not detected but there may be significant quantities of depleted uranium. The Multi-Group Analysis-Uranium software package analyzes spectra from predominantly uranium-bearing wastes. Of course, drums containing only U with no measurable TRU signal are not eligible for shipment to the WIPP. The decision to use measured or default isotopic ratios is an automated function of the NDA software. There are no operator inputs or selections, and the NDA system does not use information directly from AK or the Waste Tracking System in making this determination.
The EPA had no concerns regarding the designs and essential functions of the four Integrated Waste Assay System units.
New equipment or substantive physical modifications to approved equipment is a T1 change (see Table 1). Notification to the EPA upon substantive modification to software for approved NDA equipment is a T2 change (see Table 1).
The EPA verified that the calibration of the Integrated Waste Assay Systems was adequate and noted that there were no major system changes apart from routine maintenance.
Canberra Industries calibrated all four IWAS units at its factory in Meriden, Connecticut, before shipment to the AMWTP. The calibration of each system was verified and documented in site acceptance reports CI-IDA-NDA-0051 through CI-IDA-NDA-0054.
The BEGe detectors are calibrated for gamma energies between 59 and 1,408 kiloelectron volts (keV). The active neutron calibrations are valid for absorber-moderator indices between 1.0 and 2.7, and the passive neutron for moderator indices between 1.0 and 3.0. This calibration is appropriate for a variety of waste matrices, including glass, combustibles, metal and sludge. The applicable waste sludge waste codes are 001, 002, 003 and 004; debris waste codes are 320, 330, 336, 339, 371, 374, 393, 432, 440, 441, 442, 480 and 481. The system has a stated upper limit of 12 grams (g) for [240]Pu mass, which correlates to approximately 200 g weapons grade Pu. The administrative control limit on the overall matrix correction factor is less than 6.0. The gamma calibration is applicable for low atomic number (low Z) materials (Z < 15) with densities up to 1.6 grams per cubic centimeter (g/cm[3]) and uses a matrix correction factor (which accounts for waste matrix effects) generated by a multi-energy matrix correction factor curve. To determine a drum's appropriate gamma measurement range, the system generates a bulk density, assuming that the drum is 100% full. 
The AMWTP presents the gamma operating range of the instruments as 0.010 to 200 g of weapons-grade Pu, although it is not a mass calibration in the strict sense. In theory, there is no mass limit, provided that the photon energy is between 59 and 1,480 keV and all operational and spectral parameters are acceptable. The software automatically selects the operational mode (i.e., gamma, active neutron or passive neutron) that is reported for each assay event based on the results that have the smallest total measurement uncertainty (TMU). Conceptually, the active neutron mode is selected for a weapons grade Pu content between 0.010 and 0.250 g, while the passive neutron mode is appropriate for measurements between 0.100 and 200 g weapons-grade Pu. Initially, the system was configured to automatically perform the active neutron assay first, but operational experience has shown that this mode was rarely used as the assay of record and its automatic use has been deactivated. It can still be used, but the operator must initiate it deliberately, which would typically happen if the passive neutron and gamma data indicated it was needed. The gamma-ray mode is most likely to be chosen to assay waste matrices with low-Z materials or low Pu content.
The EPA had no concerns regarding the technical adequacy of the IWAS NDA systems.
Extension of or changes to approved calibration ranges for approved equipment is a Tier 1 change (see Table 1). Notification to the EPA upon changes to the approved operating ranges of approved NDA systems upon CBFO approval is a Tier 2 change (see Table 1).
Notification to the EPA upon changes to IWAS procedures that require CBFO approval is a Tier 2 change (see Table 1).
The EPA verified that determination and documentation for the total measurement uncertainty (TMU) for the Integrated Waste Assay Systems are adequate.
The determination of TMU for all four IWAS units is documented in one document, CI-IDA-NDA-0055, "Total Measurement Uncertainty for the AMWTP Integrated Waste Assay Systems," Revision 1, July 30, 2003. The EPA evaluated this document and found that it addresses all major components of TMU. Uncertainty sources for the passive neutron mode included calibration, counting statistics, matrix/source distribution effects and elevated backgrounds due to high Z matrices. The active neutron mode TMU determination also includes contributions of calibration, counting statistics, matrix/source distribution effects, neutron multiplication and self-shielding. The gamma based TMU determination includes contributions from calibration, counting statistics, self-absorption, matrix and source heterogeneity and measurement of isotopic ratios.
The EPA had no concerns regarding the technical adequacy of the TMU determination and its documentation for the four IWAS units.
The EPA confirmed that the AMWTP's determination and documentation of the lower limit of detection, including the minimum detectable concentration, of the Integrated Waste Assay Systems was technically adequate.
The lower limit of detection (LLD) is defined as that level of radioactivity that, if present, yields a measured value greater than the critical level with a 95% probability, where the critical level is defined as that value measurements of the background will exceed with 5% probability. The LLD is a strong function of both the ambient background and the system's detection efficiency. NDA-2000 calculates the LLD and the minimum detectable concentration for each assay event based on the background and efficiency associated with that particular measurement.
The AMWTP determined nominal LLDs and minimum detectable concentrations for a variety of matrices for the active neutron, passive neutron and gamma modes by assaying surrogate drums of those matrices without radioactive sources. Matrices used for active neutron and passive neutron assays included combustibles, metals, glass and inorganic and organic sludge. For the gamma mode, the AMWTP estimated the LLD and minimum detectable concentration values for four matrices that varied in density from 0.0284 to 1.58 g/cm[3]. The nominal values were reported in CI-IDA-NDA-0053 through CI-IDA-NDA-0054, which the EPA Inspection Team reviewed and deemed to be adequate.
The EPA had no concerns regarding the determination and documentation of the LLD for the IWAS NDA systems.
The EPA assessed training of all Integrated Waste Assay Systems personnel and found it to be adequate.
All AMWTP personnel associated with the calibration, operation, data review and approval of the four IWAS units had current training, as evidenced by the screenshot of the qualifications/certifications database dated July 24, 2017, that the AMWTP provided before the inspection. The EPA has no concerns regarding the training of AMWTP IWAS NDA personnel.
Submission to the EPA of a list of all NDA personnel who performed work during the previous quarter remains an NDA Tier 2 change (see Table 1). Specifically, the list must include all IWAS operators, Expert Analysts and Independent Technical Reviewers.
The EPA established that the Integrated Waste Assay Systems successfully participated in the Carlsbad Field Office-sponsored Performance Demonstration Program.
All four IWAS units successfully participated in the CBFO-sponsored Performance Demonstration Program (PDP) Cycle 24A, as documented in the CBFO memorandum dated June 29, 2017. The systems met all PDP performance criteria and were approved for use without restriction. The four IWAS units are scheduled to participate in the CBFO-sponsored PDP annually. The EPA has no concerns regarding the AMWTP's participation in the CBFO-sponsored PDP.
The EPA confirmed that the AMWTP performed replicate testing of the Integrated Waste Assay Systems, and that all assays complied with the criteria for the U.S. Environmental Protection Agency Replicate Testing Protocol.
The purpose of the replicate testing performed as part of this inspection is to provide the EPA with an independent means to verify that the IWAS units can provide reproducible results for the determination of the quantity of 10 WIPP-tracked radionuclides ([241]Am, [137]Cs, [238]Pu, [239]Pu, [240]Pu, [242]Pu, [90]Sr, [233]U, [234]U and [238]U) and the TRU alpha activity concentration. This is accomplished by having the IWAS units reassay drums they previously measured to demonstrate each system's ability to do the following:
 Produce results consistent with the reported TMU by comparing the sample standard deviation for a number of replicate measurements taken over several hours or days to the reported TMU.
 Provide reproducible results over longer periods of time, such as weeks or months, by comparing the results of the replicate measurements to the original reported values.
As part of this inspection, the EPA requested that the AMWTP reassay five drums that the EPA selected from a list of drums previously assayed on the Z-211-102 and Z-211-103 units. Container Nos. 10597312 and 10612378 were chosen for the Z-211-102 unit, and Container Nos. 10596959, 10597411 and 10610103 were chosen for the Z-211-103 unit. The AMWTP reassayed all chosen containers five times, and EPA compared the results to the original assay data. Two statistical tests, a χ[2] test and a t-test, were performed, and the raw data and results of the statistical analysis are included in Attachments D.1 through D.5. The χ[2] test, which is also known as the goodness-of-fit test or the chi-squared test for independence, is used to show how observed data compare with data we would expect to obtain according to a specific hypothesis. The EPA applied it in this instance to show whether the replicate measurements differed from the expected original measurement. The t-test is a statistical tool that is used to tell if two sets of data are statistically different from one another. The EPA applied it to the replicate data to see if there were statistically significant differences between the original assay values and the average of the five replicate measurements.
The χ[2] test for all replicate analyses showed that the observed variances in the replicate measurements are less than or equal to the reported uncertainties within the statistical limits of the test. The t-test for all replicate analyses also showed no statistically significant differences between the original assay values and the average of the five replicate measurements. The EPA had no issues relative to replicate testing for the Z-211-102 and Z-211-103 IWAS units performed for this inspection at the AMWTP.
The AMWTP was not able to adjust the drum-handling protocols for the Z-390 IWAS units because the AMWTP WMF-636 process involves crushing all drums post-assay, rendering them unavailable for reassay. Accordingly, the EPA chose to forego replicate testing for the Z-390-100 and Z-390-101 IWAS units.
Summary of Evaluation of Integrated Waste Assay System Units Z-211-102, Z-211-103, Z-390-100 and Z-390-101
Based on the results of this evaluation, the EPA has no technical issues or concerns with the four IWAS units for assaying CH TRU waste.
Retrieval Box Assay System
 The EPA assessed the design and operational history of the Retrieval Box Assay System and determined they were adequate.
The Pajarito Scientific Company RBAS is designated as AMWTP Instrument No. Z-212-105 and is located in Building WMF-639 at the AMWTP, the same building that houses the Z-211-102 and Z-211-103 IWAS units. The RBAS is also used to certify low-level radioactive waste and for "safety significant" assays, i.e., assays to determine the fissile gram equivalent content of containers before bringing them into Building WMF-676 for processing as facility feed. The RBAS has been operational at the AMWTP to certify low-level radioactive waste and determine fissile gram equivalent since 2004. The EPA originally approved the RBAS for CH TRU assays in 2015 (see EPA Air e-Docket No. EPA-HQ-OAR-2001-0012-0459; October 19, 2015).
The RBAS is an imaging passive neutron/active neutron measurement system supplemented by a high-purity germanium gamma detection system. The passive neutron and active neutron data are used in conjunction with gamma-based isotopic determinations using Fixed-Energy Response Function Analysis with Multiple Efficiencies to quantify specific radionuclides and/or determine an item's fissile gram equivalent. Isotopic information can also be provided by approved AK. Integration of the neutron and isotopic data for each item is performed off line by the RBAS WIPP Analysis Reporting Software for Expert Analysis. Neutron measurements are matrix sensitive, particularly with respect to an item's hydrogen content. Accordingly, active neutron and passive neutron assays are typically discussed in terms of absorber indices for active neutron and moderator index for passive neutron. These indices represent the RBAS's response to specific matrices and nuclear material loadings and are combined into an absorber-moderator index for active neutron assays, while the moderator index is used for passive neutron assays, as discussed in section 6.3.1. 
The EPA has no concerns regarding the description, history or proposed application of the RBAS at the AMWTP for assaying CH TRU wastes.
New equipment or substantive physical modifications to approved equipment remains a Tier 1 change (see Table 1). Notification to the EPA upon substantive modification to software for approved NDA equipment remains a Tier 2 change (see Table 1).
The EPA verified that system calibrations for the Retrieval Box Assay System have been performed as required and are appropriate for the waste matrices the system will measure.
The RBAS had been calibrated initially at the Pajarito Scientific Company factory in Nashville, Tennessee, in 2001, as documented in the RBAS calibration test report/site acceptance test report PSC-5431-CRR-001. The AMWTP used [252]Cf sources for the passive neutron mode calibration and depleted uranium sources for the active neutron calibration, in conjunction with surrogate matrices in a fiberglass reinforced plastic (FRP) box. Certificates for the [252]Cf and depleted uranium sources are provided in Appendix 7 to PSC-5431-CRR-001. The [252]Cf sources were commercially available from Frontier Technology Corporation and were traceable to the national standards base [i.e., the National Institute of Standards and Technology (NIST)]. Robert Marshall's group at Los Alamos National Laboratory certified the fourteen depleted uranium sources for radionuclide content and traceability in 1991. The [252]Cf sources for passive neutron calibration represent a [240]PuEFF mass of approximately 11.55 g, equivalent to 194.05 g WG Pu. The [240]PuEFF provides a basis for comparing passive neutron measurements because it includes all even-numbered Pu isotopes. 
The depleted uranium sources used for active neutron calibration represented 0.862 g [239]PuEFF, a useful basis for comparing active neutron measurements because it includes all fissile radionuclides (i.e., [239]Pu, [233]U and [235]U). Each [252]Cf and depleted uranium source was measured twice at 42 reference points in a fiberglass reinforced plastic box for a total of 84 measurements. All radionuclide sources were appropriately documented and are appropriate for calibration of a passive and active neutron system.
Before beginning WIPP assays, the AMWTP amended the original RBAS calibration by adding metals and mixed debris (organic/inorganics), both of which required new absorber-moderator index values, as described in PSC-5431-CCR-001. This addition required adjusting the active neutron assay configuration for debris in Standard Waste Boxes to better match the matrix and absorber-moderator index values. Specifically, a manual override for active neutron assays for box size is recommended, while passive neutron assays are still selected automatically. A specific matrix selection has also been identified for sludge waste in 55-gallon drums inside a Standard Waste Box. Additionally, the active neutron threshold for [239]PuEFF was set such that any measured value greater than 8 g [240]PuEFF would be based on the passive neutron response. Both changes were technically adequate and appropriately documented in PSC-5431-CCR-001.
Fixed-Energy Response Function Analysis with Multiple Efficiencies typically provides statistically valid isotopic data for mass loadings above approximately 10 g total Pu. The RBAS WIPP Analysis Reporting Software for Expert Analysis software usually selects AK-based isotopics for values below 10 g of total Pu. Specific AK default parameter sets in the RBAS library provide values for [238]Pu, [239]Pu, [24][0]Pu, [241]Pu, [242]Pu and [241]Am for weapons grade and heat source Pu. The AMWTP evaluated the accuracy of Fixed-Energy Response Function Analysis with Multiple Efficiencies gamma data for three Pu standards at 8.9, 74.7 and 157.1 g of total Pu. Results of the analysis are shown in PSC-5431-CCR-001, Table 10.25. All results were acceptable.
The EPA has no concerns regarding the technical adequacy and documentation of the RBAS passive and active mode calibrations.
Extension of or changes to approved calibration ranges for approved equipment is a T1 change (see Table 1). Notification to the EPA upon changes to the approved operating ranges of approved NDA systems upon CBFO approval is a T2 change (see Table 1).
Notification to the EPA upon changes to RBAS procedures that require CBFO approval is a T2 change (see Table 1).
The EPA verified that determination and documentation for the total measurement uncertainty of assays performed by the Retrieval Box Assay System are adequate.
The AMWTP determined the TMU for the RBAS initially in 2002 and modified it most recently in 2004, as documented in BII-5112-TMU-001, Revision 2. The determination used NIST-traceable Pu sources assayed in a fiberglass reinforced plastic box and included the contributions of the following components for passive neutron and active neutron assays:
 Random error
 Background effects
 Matrix effects (heterogeneous and homogeneous)
 Neutron or gamma interferences
 Source distribution
 Box size effects
 Self-shielding, absorption and neutron multiplication
 Calibration uncertainties
The contributions of these components were added in quadrature, based on the assumption that all sources of error are independent. 
The AMWTP's determination of TMU for the RBAS was technically adequate and appropriately documented. The EPA has no concerns regarding the TMU determination for assaying CH TRU waste.
The EPA confirmed that the AMWTP's determination and documentation of the lower limit of detection, including the minimum detectable concentration, of the Retrieval Box Assay System was technically adequate.
The LLD for the RBAS is a function of the item's weight and the absorber-moderator index for absorber-moderator index active neutron assays and the moderator index for passive neutron assays; as such, it is complex. However, the criterion of interest is whether the RBAS has adequate sensitivity to support a TRU determination at the 100 nCi/g criterion. The AMWTP performed a series of replicate measurements with a variety of surrogate matrices in Standard Waste Boxes, fiberglass reinforced plastic and shredder boxes for both active neutron and passive neutron assays to establish and document that the RBAS had the required sensitivity.
The AMWTP determined the LLD for [238]Pu, [239]Pu, [240]Pu, [241]Pu, [242]Pu and [241]Am for both active neutron and passive neutron assays, for all measurement configurations, as shown in PSC-5431-CRR-001, Figure 8.2 and Figure 8.3. For the other WIPP-tracked or significant radionuclides, the AMWTP developed minimum detectable activity equivalent values (ratios) relative to Pu; minimum detectable activity values of zero will be reported for [234]U and [90]Sr.
The EPA has no concerns regarding the ability of the RBAS to sort TRU and non-TRU waste at the 100 nCi/g criterion.
The EPA assessed personnel training and found it to be adequate.
All AMWTP personnel associated with the calibration, operation, data review and approval of the RBAS had current training, as evidenced by the screenshot of the qualifications/certifications database dated July 24, 2017, that the AMWTP provided to the EPA before the inspection. The EPA has no concerns regarding the training of AMWTP RBAS NDA personnel.
Submission to the EPA of a list of all NDA personnel who performed work during the previous quarter remains an NDA Tier 2 change (see Table 1). Specifically, the list must include all RBAS operators, Expert Analysts and Independent Technical Reviewers.
The EPA established that the RBAS successfully participated in the Carlsbad Field Office-sponsored Performance Demonstration Program.
The RBAS successfully participated in the CBFO-sponsored PDP Cycle B16A, as documented in the CBFO memorandum dated October 20, 2016. The system met all performance criteria and was approved for use without restriction. The RBAS is scheduled to participate in the CBFO-sponsored PDP annually. The EPA has no concerns regarding the AMWTP RBAS's participation in the CBFO-sponsored PDP.
EPA replicate testing of the Retrieval Box Assay System was not performed. 
The EPA determined that replicates were not required as part of this inspection, based on the limited use of the RBAS for WIPP-certified assays. The EPA may request replicate analyses for the RBAS at a future inspection.
Summary of Evaluation of the Retrieval Box Assay System 
Based on the results of this evaluation, the EPA has no technical issues or concerns with the RBAS for assaying CH TRU wastes.
SWEPP Gamma-Ray Spectrometer
 The EPA verified that the design and essential functions SWEPP Gamma-Ray Spectrometer were adequate and that neither had changed for several years.
The SGRS was initially operated under the INL-CCP waste characterization program, and was transitioned to the AMWTP in October 2015. At that time, the EPA inspected the AMWTP TRU waste characterization program with the newly-acquired characterization equipment and processes, including the SGRS, and approved the program for characterizing CH TRU wastes for WIPP. Documentation for the SGRS's design, initial calibration and performance testing is provided by INL-CCP records, and these serve as the system's calibration of record. Accordingly, the EPA's technical evaluation of the system's design, initial calibration and performance testing occurred during the 2015 continued compliance inspection (see EPA E-DOCKET NO. EPA-HQ-OAR-2001-0012-0466). 
Between June 1, 2016, and August 11, 2017, the SGRS assayed 7,395 drums. The EPA inspectors observed the assay of Drum No. 10568514, which was one of the replicates selected by the EPA. For this baseline inspection, the EPA technical personnel reviewed the more recent INL-CCP records that reflected the system's design and performance history and indicate its continued adequacy for assaying CH TRU wastes. The EPA determined that the design and essential functions of the SGRS were technically adequate and appropriately documented in AMWTP documents.
New equipment or substantive physical modifications to approved equipment remains a Tier 1 change (see Table 1). Notification to the EPA upon substantive modification to software for approved NDA equipment remains a Tier 2 change (see Table 1).
The EPA verified that the calibration of the SWEPP Gamma-Ray Spectrometer was adequate for the wastes that the AMWTP currently assays and noted that the system has had no major changes apart from routine maintenance.
The EPA verified that the system's calibration was unchanged since the last inspection. The AMWTP performed a calibration verification in the last year after replacing Detector 4, documented in Work Order 510249. All aspects of the calibration verification were technically acceptable and appropriately documented.
The EPA has no concerns regarding the calibration of the SGRS NDA system.
Extension of or changes to approved calibration ranges for approved equipment is a Tier 1 change (see Table 1). Notification to the EPA upon changes to the approved operating ranges of approved NDA systems upon CBFO approval is a Tier 2 change (see Table 1).
Notification to the EPA upon changes to SGRS procedures that require CBFO approval is a Tier 2 change (see Table 1).
The EPA verified that determination and documentation for the total measurement uncertainty for the SWEPP Gamma-Ray Spectrometer are adequate.
The AMWTP documented the technical basis and derivation of TMU for assays performed on the SGRS in CCP-INL-SGRS-002, as required. The EPA Inspection Team verified that this document was technically adequate, addressed all appropriate contributors to the system's TMU and that it was unchanged since its initial publication in 2005.
The EPA has no concerns regarding TMU for the SGRS NDA system.
The EPA confirmed that the AMWTP's determination and documentation of the lower limit of detection, including the minimum detectable concentration, of the SWEPP Gamma-Ray Spectrometer was technically adequate.
Instruments performing TRU/non-TRU waste discrimination must have a minimum detectable concentration of less than 100 nCi/g of TRU radionuclides. Minimum detectable activities are instrument specific and depend on measurement conditions such as background rate and matrix. CCP-INL-SGRS-001, Revision 1, April 2008, adequately documents the technical basis for the system's LLD, including reporting thresholds for specific non-measured radionuclides [242]Pu and [90]Sr. The EPA Inspection Team verified that this document is applicable under the AMWTP waste characterization program and that the SGRS has adequate sensitivity to sort TRU/non-TRU wastes at 100 nCi/g.
The EPA has no concerns regarding the determination of the LLD for the SGRS NDA system.
The EPA assessed personnel training and found it to be adequate.
All AMWTP personnel associated with the calibration, operation, data review and approval of the SGRS had current training, as evidenced by the screenshot of the qualifications/certifications database dated July 24, 2017, that was provided prior to the inspection. There were no concerns regarding the training of AMWTP SGRS personnel.
Submission to the EPA of a list of all NDA personnel who performed work during the previous quarter remains an NDA Tier 2 change (see Table 1). Specifically, the list must include all SGRS operators, Expert Analysts and Independent Technical Reviewers.
The EPA established that the SWEPP Gamma-Ray Spectrometer successfully participated in the Carlsbad Field Office-sponsored Performance Demonstration Program.
The SGRS successfully participated in the CBFO-sponsored PDP, Cycle 24A. The system met all performance criteria and was approved for use without restriction. The SGRS is scheduled to participate in the CBFO-sponsored PDP annually. The EPA has no concerns regarding the AMWTP SGRS participation in the CBFO-sponsored PDP.
The EPA verified that the replicate testing of the SWEPP Gamma-Ray Spectrometer, complied with the criteria for the U.S. Environmental Protection Agency Replicate Testing Protocol.
The purpose of the replicate testing performed as part of this inspection is to provide the EPA with an independent means to verify that the SGRS can provide reproducible results for the determination of the quantity of 10 WIPP-tracked radionuclides ([241]Am, [137]Cs, [238]Pu, [239]Pu, [240]Pu, [242]Pu, [90]Sr, [233]U, [234]U and [238]U) and the TRU alpha concentration. This is accomplished by the SGRS reassaying drums it previously measured to demonstrate the system's ability to do the following:
 Produce results consistent with the reported TMU by comparing the sample standard deviation for a number of replicate measurements taken over several hours or days to the reported TMU.
 Provide reproducible results over longer periods of time, such as weeks or months, by comparing the results of the replicate measurements to the original reported values.
As part of this inspection, the EPA requested that the AMWTP reassay three drums that the EPA randomly selected from a list of drums previously assayed on the SGRS. Drum Nos. 10568514, 10565693 and 10566849 were reassayed five times, and the results were compared to the original assay data. Two statistical tests, a χ[2] test and a t-test as described in section 6.3.1, were performed. Data and results of the statistical analysis are included in Attachments H.1 through H.3.
For Drum Nos. 10565693 and 10566849, the χ[2] test showed that the observed variances in the replicate measurements are less than or equal to the reported uncertainties within the statistical limits of the test. The t-test for Drum Nos. 10565693 and 10566849 also showed no statistically significant differences between the original assay values and the average of the five replicate measurements.
All χ[2] values for the replicate measurements of Drum No. 10568514 were not significant. However, the t-test for [238]Pu was highly significant, while the remaining values were not significant. The primary isotope measured by direct gamma was [239]Pu. Measured isotopic ratios were used to calculate activities for [238]Pu, [240]Pu, [241]Pu and [242]Pu. There was variability in the Multi-Group Analysis results between the original and the average of the replicate measurements. The original measurement had a measured isotopic ratio for [238]Pu that was less than the values for all replicate measurements, which resulted in a highly significant t-test for [238]Pu. This is more an artifact of the statistical evaluation and does not represent a true measurement issue. The overall assay results are acceptable.
Summary of Evaluation of the SWEPP Gamma Ray Spectrometer 
Based on the results of this evaluation, the EPA has no technical issues or concerns with the SGRS for assaying CH TRU wastes.
Waste Assay Gamma System
 The EPA verified that the design and essential functions of the Waste Assay Gamma System were technically adequate and that neither had changed for several years.
 The WAGS was initially operated under the INL-CCP waste characterization program, and was transitioned to the AMWTP in October 2015. At that time, the EPA inspected the AMWTP TRU waste characterization program with the newly-acquired characterization equipment and processes, including the WAGS, and approved the program for characterizing CH TRU wastes for WIPP. Documentation for the WAGS's design, initial calibration and performance testing is provided by INL-CCP records, and these serve as the system's calibration of record. Accordingly, the EPA's technical evaluation of the system's design, initial calibration and performance testing occurred during the 2015 continued compliance inspection (see EPA DOCKET NO. A-98-49; II-A4-206 or EPA E-DOCKET NO. EPA-HQ-OAR-2001-0012-0466). 
Between June 1, 2016, and August 9, 2017, the WAGS assayed 3,651 containers. The instrument was idle on the day of inspection due to a lack of containers to assay; however, the system's status was operable, and the EPA was able to evaluate its performance.
The EPA reviewed the electronic WAGS logbook and batch data report Nos. ASY16-04097 and ASY16-03498 and found them to adequately document drum assays. The EPA observed objective evidence that WAGS operators appropriately recorded all daily performance measurements and that all checks were within acceptance criteria. Specifically, WAGS operators evaluated background, daily performance check, full width at half maximum, energy calibration (gain) and [133]Ba transmission source checks. The AMWTP had established and documented warning and control limits, 2 and 3 sigma (σ) limits, respectively, for all parameters, as appropriate, and boundary limits for full spectrum background of ~40 counts per second, full width at half maximum and amplifier gain.
Due to the approximately 10-year half-life of [133]Ba, the software decay corrects the [133]Ba transmission to adjust the count rate boundary limits throughout their operational lives. The EPA observed WAGS personnel using the current revisions of the WAGS operating procedure. All operational aspects of the WAGS operation were acceptable. The EPA verified that the operational range of the WAGS was adequate for the wastes that the AMWTP currently assays.
New equipment or substantive physical modifications to approved equipment remains a Tier 1 change (see Table 1). Notification to the EPA upon substantive modification to software for approved NDA equipment remains a Tier 2 change (see Table 1).
The EPA verified that the calibration of the Waste Assay Gamma System was adequate and noted that there were no major system changes apart from routine maintenance.
The EPA verified that the system's calibration was adequate for the type of CH TRU wastes that the AMWTP assays with the WAGS, and that the calibration had not been changed for several years. The AMWTP did perform one calibration verification in the last year after replacing BEGe detectors Nos. 2 and 5, which was documented in an AMWTP Work Order, which did confirm the existing calibration. All aspects of the WAGS calibration verification were technically acceptable and appropriate documented. 
The EPA has no concerns regarding the calibration of the WAGS NDA system.
Extension of or changes to approved calibration ranges for approved equipment is a Tier 1 change (see Table 1). Notification to the EPA upon changes to the approved operating ranges of approved NDA systems upon CBFO approval is a Tier 2 change (see Table 1).
Notification to the EPA upon changes to WAGS procedures that require CBFO approval is a Tier 2 change (see Table 1).
The EPA verified that the AMWTP documented the total measurement uncertainty of assays performed on the Waste Assay Gamma System, and that they were technically adequate and appropriately documented. 
The AMWTP documented the technical derivation for TMU of assays performed on the WAGS in CCP-WAGS-002, and the EPA verified that the TMU document was technically adequate, included all appropriate contributors to uncertainty and was unchanged since its initial publication in 2005. The EPA reviewed WAGS batch data report Nos. ASY16-04097 and ASY16-03498 and found the TMU values consistent with CCP-WAGS-002 and adequate for CH TRU wastes.
The EPA has no concerns regarding the technical adequacy or documentation of TMU of the AMWTP WAGS NDA system.
The EPA confirmed that the AMWTP's determination and documentation of the lower limit of detection, including the minimum detectable concentration, of the Waste Assay Gamma System was technically adequate.
The EPA Inspection Team verified that CCP-INL-WAGS-001, Revision 1, April 2008, adequately documents the technical basis for the system's LLD, including reporting thresholds for the specific non-measured radionuclides [242]Pu, [234]U and [90]Sr.
The EPA has no concerns regarding the AMWTP's determination and documentation of the LLD for the WAGS NDA system.
The EPA assessed personnel training and found it to be adequate.
All AMWTP NDA personnel associated with the calibration, operation, data review and approval of the WAGS had current training, as evidenced by the list of employees by qualifications/certifications dated July 24, 2017, that the AMWTP provided before the inspection. The EPA has no concerns regarding the training of AMWTP personnel.
Submission to the EPA of a list of all NDA personnel who performed work during the previous quarter remains an NDA Tier 2 change (see Table 1). Specifically, the list must include all NDA operators, Expert Analysts and Independent Technical Reviewers.
The EPA established that the Waste Assay Gamma System successfully participated in the Carlsbad Field Office-sponsored Performance Demonstration Program.
 The WAGS successfully participated in the CBFO-sponsored PDP, Cycle 24A, as documented in the CBFO memorandum dated June 29, 2017. The system met all performance criteria and was approved for use without restriction. The WAGS is scheduled to participate in the CBFO-sponsored PDP annually. The EPA has no concerns regarding participation of the AMWTP WAGS in the CBFO-sponsored PDP.
EPA replicate testing of the Waste Assay Gamma System was not performed. 
For logistical reasons, the EPA determined that replicates were not required as part of this inspection. The EPA may request replicate analyses for the WAGS at a future inspection.
Summary of Evaluation of the Waste Assay Gamma System 
Based on the results of this evaluation, the EPA has no technical issues or concerns with the WAGS for assaying CH TRU wastes
Nondestructive Assay Conclusion
Changes to Tiering
During an inspection, the EPA evaluates an NDA system's technical capabilities, and these define the operational envelope in which WIPP measurements will occur. Changes to a system's operation with respect to its ability to measure activity and/or waste matrices may represent a different set of conditions from those that EPA evaluated and approved during the inspection. For this reason, certain system changes are Tier 1 changes. Other less significant but still important changes are designated as Tier 2 changes.
Based on the NDA inspection and the results discussed above, the EPA assigns the following AMWTP items or actions as Tier 1 changes that will require EPA review and approval prior to implementation:
 New NDA equipment: A system or component not previously evaluated by the EPA. Specifically, this is defined as a physically distinct or different system or apparatus. An assay system that is reported to be the equivalent of or identical to a previously approved system but that has not been formally inspected and approved by the EPA is a new system and must be approved by the EPA prior to implementation to characterize WIPP wastes.

 Physical modifications to approved equipment: Changes to existing NDA equipment include all changes and/or modifications to approved equipment that have the potential to affect the quality of NDA data used for the purposes of waste characterization and/or waste isolation. This does not include minor or safety-related changes (e.g., addition of hand rails) that do not have the potential to affect waste characterization data.

 Extension or changes to an approved calibration range for approved equipment: Those changes that affect the determination of activity or matrix of any of the seven NDA systems proposed for approval during this inspection. Examples of changes in this category include changing a system's operating system (e.g., first use of Canberra NDA 2000), identification of a systematic problem with a software package and subsequent modifications to address the problem (e.g., use of an incorrect value for a radionuclide's transition probability in NDA 2000), and introduction of a new version of an existing software package beyond what is in current use. 

T2 NDA changes that do not require EPA approval prior to implementation but require reporting and submission of documentation discussing changes by the AMWTP include the following:
 Changes to software for approved equipment that do not affect the determination of activity or matrix by an NDA system
 Changes to the approved operating ranges of approved NDA systems upon CBFO approval
 Changes to procedures that require CBFO approval
Summary of Nondestructive Assay Findings and Concerns
The EPA did not identify any findings or concerns for any of the seven NDA units at the AMWTP. 
Proposed Nondestructive Assay Baseline Approval
The NDA baseline conditions that the EPA Inspection Team evaluated consist of the seven NDA systems described in this report.
The EPA is proposing to approve each NDA system, along with its range of applicability for activity and matrix, and any limitations, as described in this report and detailed in the NDA checklists (Attachments D, E, F, G and H). The EPA has found the NDA procedures, personnel and equipment evaluated at the AMWTP during this inspection to be acceptable for this waste characterization element.
Real-Time Radiography (RTR)
Waste Characterization Element Description
The EPA evaluated the documentation that the AMWTP prepared to support the RTR process to characterize CH TRU wastes using three RTR units, RTR Unit Nos. Z-213-101, Z-213-106 and 1001. The EPA had previously approved these RTR units for SCG S5000 and S3000 wastes. The Z-213-101 and Z-213-106 RTR units were approved under the AMWTP's TRU characterization program, and the No. 1001 RTR unit was approved under the INL-CCP TRU characterization program. 
This baseline inspection consisted of reviewing technical records and batch data reports, which, as with all AMWTP records, exist in electronic format only. The EPA Inspection Team prepared an inspection checklist (see Attachment I) that included the aspects of the RTR systems described below. This was followed by an onsite inspection of the RTR units, including observation of the RTR process for the 1001 RTR unit and one of the WMF-634 units, Z-213-106, focusing on the following: 
       Capability of the RTR hardware and software to perform the required analyses
       Technical adequacy of the NDE documents and procedures to support the AMWTP's RTR operation to characterize CH TRU wastes
       Knowledge, understanding and training of the personnel involved in the AMWTP program 
The EPA evaluation included the aspects listed below.
 The EPA evaluated the operation of the AMWTP real-time radiography units and established that they are technically adequate for nondestructive examination of CH TRU wastes, and that they are the same units that the EPA had approved previously.
The Z-213-101 and Z-213-106 RTR units are co-located located in Building WMF-634 at the AMWTP, the same building as the IWAS and RBAS NDA systems described in sections 6.3.1 and 6.3.2 of this report. The No. 1001 RTR Unit is located in the SWEPP at INL, in the same building as the WAGS and SGRS NDA systems described in sections 6.3.3 and 6.3.4 of this report. EPA technical personnel confirmed that the EPA had approved these RTR units previously, as discussed in sections 6.3.3.and 6.3.4 of this report, and that none of them had been moved or substantially modified since their previous EPA evaluations. 
The EPA evaluated the technical specifications of the units and the detailed instruction for performing RTR, as documented in AMWTP Procedure TPR-8089, and for data validation, documented in AMWTP Procedures MCP-4005 and MCP-4006. The EPA determined that the Z-213-101, Z-213-106 and 1001 RTR units were technically adequate for x-ray radiographic examination of the CH TRU wastes that the AMWTP intends to characterize and ship to the WIPP. The EPA also determined that the operating and data validation procedures were adequate. The EPA had no concerns regarding the operation of the AMWTP RTR units.
New RTR equipment or substantive physical modifications to approved RTR equipment are new Tier 1 changes (see Table 1). Submission to the EPA of a list of AMWTP RTR operators and Independent Technical Reviewers that performed work during the previous quarter and notification to the EPA upon substantive modification to site procedures requiring CBFO approval are new Tier 2 changes (see Table 1).
 The EPA observed the examined real-time radiography process and determined it was adequate.
The EPA observed AMWTP personnel execute the RTR process using two of the three RTR units, as described below. The AMWTP considers the Z-213-101 and Z-213-106 RTR units to be equivalent, and they perform the majority of the RTR events used for WIPP certification. The EPA chose to observe the RTR process using the Z-213-106 RTR unit, because it was operational at the time of this inspection. The 1001 RTR unit is older and is used less frequently for WIPP certification; the EPA also observed the operation of this RTR unit.
RTR Unit Z-213-106
The EPA observed AMWTP personnel operate the Z-213-106 RTR unit using AMWTP Procedures TPR-8089 and TPR-8086 on Container No. 10624612, a 55-gallon drum in an 85-gallon overpack, from RTR Batch No. RTR17-00136. The Z-213-101 RTR unit can accept up to four containers; this container was in position No. 2. The RTR operator performed Image Quality Indicator No. 080912IQI1010 before examining drums after system startup and provided documentation that an independent replicate scan had been performed for this batch. The Image Quality Indicator contained all pertinent information and was reviewed and approved by the Shift Supervisor on AMWTP Form No. 1578. A second AMWTP RTR operator reviewed the replicate scan and found it to be acceptable. The audiovisual record of this scan is stored in RTR File Number 1RTR17-00206.
Using the controls, the RTR operator manipulated the drum and examined its contents, noted that the container had a fill factor of 80% and initiated two nonconformance reports (NCRs) for this container. NCR No. 113071 was initiated for the presence of a prohibited item, an aerosol can. NCR No. 113073 was initiated for liquid observed in two places in the drum, at the bottom of the drum and in a plastic bag at mid-height in the drum. AMWTP personnel changed monitor screens to initiate the NCRs, attached the appropriate forms to the container's record and physically affixed a tag to the container upon completion of the RTR event.
RTR Unit 1001
The EPA observed AMWTP personnel operate the RTR-1001 unit for Container No. 10624626, which had a previous RTR examination, documented in batch data report No. RTR-17-00002. The AMWTP performed this RTR event during this inspection for demonstration purposes; this was not intended to be used for WIPP certification. The RTR operator used AMWTP Procedures TPR-8089 and TPR-8120 and performed an Image Quality Indicator and replicate scan before beginning the RTR event. Using the controls, the RTR operator manipulated the drum, examined its contents and determined that the drum's contents were impenetrable, which was consistent with the previous RTR event, requiring the initiation of an NCR to change the container's waste matrix code assignment to 5490, as detailed in RPT-TRUW-05. The AMWTP RTR operator determined and recorded the drum's fill height and recorded all pertinent RTR characterization data electronically.
The EPA determined that the AMWTP RTR process was technically adequate and appropriately documented. The EPA had no concerns regarding the AMWTP's execution of the RTR process.
 The EPA examined real-time radiography batch data reports and found they were adequate.
The AMWTP provided documentation for four RTR batch data reports to support the EPA's review for this baseline inspection. This included the completed batch data report Nos. RTR-17-00111, RTR-16-00176, RTR-17-00009 and RTR-17-00140, and the audiovisual copy of each examination. The batch data reports contained all required elements; a list of these items is provided with the RTR checklist (see Attachment I).
The EPA determined that the records for RTR at the AMWTP were acceptable and that they appropriately documented the RTR process for CH TRU waste that the AMWTP intends to ship to the WIPP. The EPA had no concerns regarding the AMWTP's documentation of the RTR process.
 The EPA examined real-time radiography training records and found them to be adequate.
The AMWTP provided a list of all AMWTP personnel trained for RTR, including 22 RTR Operators and nine Level 1 Independent Technical Reviewers, all of whom were qualified in accordance with MCP-4026. The EPA reviewed the written and audiovisual training records for selected AMWTP RTR personnel. The training records included:
 NDE training container inventory sheets for RTR training drums
 Training container evaluation data sheets
 Audiovisual recordings of training/test examinations
 RTR Qualification Package No. QPOT03A0
 AMWTP training records for dates covering the time period when AMWTP batch data report Nos. RTR-17-00111, RTR-16-00176, RTR-17-00009 and RTR-17-00140 were generated.
The EPA determined that operators were trained appropriately and that all RTR personnel were included on the list that the AMWTP provided during this baseline inspection. All hard-copy and electronic training records were readily available for the EPA's review. The EPA had no concerns regarding training for AMWTP RTR personnel.
Submission to the EPA of a list of all RTR personnel who performed work during the previous quarter is a new RTR Tier 2 change (see Table 1). Specifically, the list must include all RTR operators and Independent Technical Reviewers. This requirement ensures that the EPA has a complete picture of ongoing AMWTP RTR waste characterization activities, which will inform the scope of future EPA RTR evaluations.
Real-Time Radiography Conclusion
Changes to Tiering
The EPA identified the following changes as RTR T1 changes at the AMWTP:
 New equipment or substantive physical modifications to approved equipment
 Implementation of any new real-time radiography process 
The EPA identified the following changes as RTR T2 changes at the AMWTP:
 Submission of a list of AMWTP RTR operators and Independent Technical Reviewers who performed work during the previous quarter
 Notification to the EPA upon substantive modification to site procedures requiring CBFO approval
These tiering changes are described throughout section 6.4 and listed in Table 1.
Summary of Real-Time Radiography Findings and Concerns
The EPA did not identify any findings or concerns related to RTR as a result of this baseline inspection.
Proposed Real-Time Radiography Baseline Approval
The EPA is proposing to approve the AMWTP RTR process using RTR units Z-213-101, Z-213-106 and 1001 for characterizing CH TRU waste as described in this report.
Visual Examination (VE)
Waste Characterization Element Description
The AMWTP has three types of VE to support the characterization of WIPP CH TRU wastes. They are essentially the same process with respect to the procedural controls and types of documentation each requires; they differ only in the site where the examinations occur.
The AMWTP conducts VE inside the waste treatment building, Building WMF-676, covered under Procedure TPR-8041. The AMWTP refers to this as Facility VE, performed according to Procedure TPR-8041. It is conducted concurrently with AMWTP assembling waste containers in a separate area using remote equipment. Wastes in boxes or other containers are brought into the enclosed processing area in WMF-676, where they are emptied, sorted and placed in new 55-gallon drums using remote-handling equipment. AMWTP VE personnel conduct VE while the drums are being compiled. There were two AMWTP VE Experts for Facility VE, Lawrence J. Walker and Ron Grise.
The AMWTP also conducts VE at the Accelerated Retrieval Project (ARP) and Sludge Repackaging Project (SRP), which the AMWTP refers to as Visual Examination Activities at Radioactive Waste Management Complex, covered under AMWTP Procedure TPR-7997. The ARP and SRP are both areas of active waste removal within the Subsurface Disposal Area at the AMWTP, where personnel excavate wastes from essentially shallow land burial. All work occurs within enclosures (glovebox-like areas), in which wastes are removed, examined and loaded into new 55-gallon drums. AMWTP personnel conduct the VE of record as the wastes are examined and loaded into drums. There were two AMWTP Visual Examination Experts for ARP/SRP VE, Luke Grover and Matt Hudson.
The AMWTP refers to the third type as Non-Facility VE Operations, covered in AMWTP Procedure TPR-8103. This VE can occur anywhere onsite at the AMWTP, but the AMWTP typically conducts this type of VE in conjunction with Facility VE, described above. While conducting Facility VE, operators encounter items that must be removed and set aside. The usual AMWTP practice is to begin accumulating these items in a new 55-gallon drum, which remains open in the processing building (WMF-634) facility, until sufficient items have been accumulated to fill the drum. Upon closure, the drum is processed as newly-generated waste. Typically, this type of VE is performed under the direction of the Facility Visual Examination Experts, Lawrence J. Walker and Ron Grise.
All AMWTP VE procedures contain complete and detailed instructions for performing VE and require the operators to (1) document the waste's waste material parameters and the presence or absence of prohibited items and (2) verify the waste matrix code and waste item description code. All AMWTP VE data are electronically recorded in accordance with the instructions in the VE procedures.
The EPA evaluated the documentation that the AMWTP prepared to support the VE process to characterize CH TRU wastes, which the EPA had previously approved for SCG 3000, 4000 and 5000 wastes. This baseline inspection consisted of reviewing technical records and batch data reports, which, as with all AMWTP records, exist in electronic format only. The EPA Inspection Team members prepared a VE inspection checklist (see Attachment J), that included the aspects of VE described below. This was followed by an onsite inspection of facility VE and VE at the SRP, focusing on the following:
 Capability of the VE process to confirm the waste's waste material parameters, waste matrix code and item description code and document the presence or absence of prohibited items
       Technical adequacy of AMWTP documents and procedures to support VE operations to characterize CH TRU wastes
       Knowledge, understanding and training of AMWTP personnel performing VE for CH TRU wastes
The EPA T1 evaluation included the aspects listed below.
 The EPA observed the contact-handled visual examination process and found it to be technically adequate for visual examination of AMWTP contact-handled transuranic wastes.
The EPA observed VE operations in Room 231, north box-line, of Building WMF-676. Two VE operators sorted waste from Box No. 10623990, from AMWTP CH TRU Waste Stream BN-510, for packaging in 55-gallon Drum No. 1045147. The AMWTP performed VE in accordance with AMWTP Procedure TPR-8103, "Non-Facility Visual Examination Operations." From the facility control room, one operator manipulated the waste with a remote-control arm, while the other operator electronically entered data in an electric format. At the end of packaging, both operators verified the data entry and electronically signed off the data sheet. A Visual Examination Expert was present during the VE event, and all VE operations were technically adequate and appropriately documented.
The EPA also observed the AMWTP VE process at the SRP (also called ARP-5), in accordance with AMWTP Procedure TPR-7997, on Container No. 1617, an SCG S3100 inorganic sludge with an item description code of CW-126 and a net weight of 116.5 kilograms (~239 pounds). The process that the EPA observed consisted of the following steps:
 Unloading material removed from the disposal area into a large, sliding tray
 Sorting the sludge material to remove prohibited or nonconforming items
 Confirming the waste matrix code, waste material parameters and item description code
 Entering VE data electronically, including confirmation by a second AMWTP VE operator
 Radiation surveys conducted by AMWTP Health Physics staff
 Closing drum and tightening with a calibrated torque wrench
 Affixing the appropriate labels
 Weighing the drum on a precalibrated scale
Two AMWTP VE Operators and an AMWTP Visual Examination Expert were present at the VE event. All data were entered by one operator and confirmed by the second operator. The EPA technical inspectors had access to observe all aspects of the VE process at the SRP and viewed all data entry by AMWTP VE personnel.
The EPA had no concerns regarding the CH TRU VE characterization process for the AMWTP.
 The EPA examined visual examination characterization records and found them to be adequate.
The EPA reviewed the following VE batch data reports from VE activities at SRP, ARP and WMF-676:
 SRP batch data report Nos. VEAB-16-00159, VEAB-16-00016
 ARP batch data report Nos. ARP-15-00023, ARP-15-00028
 WMF-676 batch data report No. VNC-16-00019
The EPA determined that the VE batch data reports were complete, were technically adequate and contained all appropriate information to support VE for CH TRU wastes.
The EPA had no concerns regarding the CH TRU VE characterization records for the AMWTP.
 The EPA examined contact-handled visual examination training records and found them to be adequate.
Training for all AMWTP VE personnel was current, including readings/indoctrination and On-the-Job-Training practical requirements (Tailgate Briefings), based on qualification packages that the AMWTP provided for review during this baseline inspection. All VE operators and Independent Technical Reviewers were included on the formal AMWTP training/qualification listing. The EPA reviewed training records in detail for selected operators. The AMWTP provided a complete list of all VE operators, Visual Examination Experts and Independent Technical Reviewers that were qualified at the time of the baseline inspection. All AMWTP Visual Examination Experts had formal Visual Examination Expert appointment letters. The EPA determined that CH TRU VE personnel had adequate training and that their training records were complete and readily available for EPA inspection. 
Submission to the EPA of a list of all VE personnel who performed work during the previous quarter remains a VE T2 requirement (see Table 1). Specifically, the list must include all VE operators, Independent Technical Reviewers and Visual Examination Experts to ensure that the EPA has a complete picture of AMWTP waste characterization activities and potentially inform the scope of future EPA evaluations.
The EPA had no concerns regarding the CH TRU VE training records for AMWTP personnel.
Visual Examination Conclusion
Changes to Tiering
The EPA identified notification to the EPA upon substantive modification to site procedures requiring CBFO approval as a Tier 1 change.
The EPA identified submission of a list of AMWTP VE operators, Visual Examination Experts and Independent Technical Reviewers that performed work during the previous quarter as a Tier 2 change.
These tiering changes are described throughout section 6.5 and listed in Table 1.
Summary of Visual Examination Findings and Concerns
The EPA did not identify any findings or concerns related to VE as a result of this baseline inspection.
Proposed Visual Examination Baseline Approval
The EPA is proposing to approve the AMWTP VE process for characterizing CH TRU waste as described in this report.
Response to Comments
This section is reserved for responses to public comments.
Summary of Results 
Environmental Protection Agency Findings and Concerns
The EPA did not identify any findings or concerns during this inspection. 
Conclusions
This proposed approval is based on the EPA's baseline inspection conducted on August 8 - 10, 2017, in and near Idaho Falls, Idaho. The EPA evaluated the AMWTP's CH TRU waste characterization program and determined it to be technically adequate. The proposed approval includes:
       The AK process for AMWTP CH TRU waste, including the Enhanced AK process
       Four IWAS, the RBAS, the WAGS and the SGRS NDA systems for characterizing CH TRU waste
       The RTR process using three RTR units to identify waste material parameters and the physical form of CH TRU waste
       The VE process to identify waste material parameters and the physical form of CH TRU waste.
Any changes to the waste characterization activities from the date of the baseline inspection must be reported to and, if applicable, approved by the EPA, according to Table 1. All Tier 1 changes must be submitted for approval before their implementation and will be evaluated by the EPA. Upon approval, the EPA will post the results of the evaluations through the EPA website and the WIPPNEWS list. The AMWTP must submit Tier 2 changes that have been implemented four times a year, at the end of each fiscal quarter.

Approval Summary for the AMWTP's Contact-Handled Waste Characterization Program
                               Approved Activity
                     EPA Inspection Number, Approval Dates
                               EPA Docket Number
AMWTP CH Baseline Approval
                               EPA-AMWTP-03.06-8
                                October 3, 2006
                               A-98-49; II-A4-66
T1 Change  -  Addition of Four Hanford Legacy Debris Waste Streams to the BN510 Super-Compacted Debris Waste Stream
                                 June 10, 2010
                              A-98-49; II-A4-127
Unannounced Continued Compliance Inspection 
                                March 16, 2011
                              A-98-49; II-A4-143
T1 Change  -  Addition of ANLE-generated SCG S3000 and S5000 CH Waste and MFC-generated SCG S5000 CH Waste
                               January 29, 2013
                              A-98-49; II-A4-169
Continued Compliance Inspection
                                April 25, 2013
                              A-98-49; II-A4-173
T1 Change  -  Addition of Pre-1980 INL-Exhumed SDA SCG S3000 and S5000 CH Waste
                                 July 9, 2013
                              A-98-49; II-A4-174
T1 Change  -  Addition of Los Alamos National Laboratory Debris CH Waste
                              September 16, 2013
                              A-98-49; II-A4-178
T1 Change  -  Addition of Idaho National Laboratory SCG S3000 and S5000 CH Waste
                               February 11, 2014
                              A-98-49; II-A4-180
T1 Change  -  Addition of Retrieval Box Assay System Nondestructive Assay System
                               October 19, 2015
                              A-98-49; II-A4-200
Continued Compliance Inspection
                                 April 4, 2016
                              A-98-49; II-A4-206
                                       
                                       

BASELINE INSPECTION PERSONNEL LIST
                                Personnel Name
                                 Organization
                               Entrance Meeting
                                  Interviewed
                                 Exit Meeting
Ed Feltcorn
                                    EPA HQ
                                       
                                       
                                       
Jerry Ellis
                                    EPA HQ
                                       
                                       
                                       
Patrick Kelly
                                 SC&A/EPA
                                       
                                       
                                       
Kira Darlow
                                 SC&A/EPA
                                       
                                       
                                       
Rose Gogliotti
                                 SC&A/EPA
                                       
                                       
                                       
John McCoy
                           Fluor ID  -  TRU Prog Mgr
                                       
                                       
                                       
Gina Tedford
                         Fluor ID  -  TRU Program-SPM
                                       
                                       
                                       
L. J. Walker
                               Fluor ID  -  VEE
                                       
                                       
                                       
Ron Grise
                               Fluor ID  -  VEE
                                       
                                       
                                       
Matt Hutson
                               Fluor ID  -  VEE
                                       
                                       
                                       
Steve Carpenter
                               Fluor ID  -  AKE
                                       
                                       
                                       
Roger Vawter
                               CTAC  -  Observer
                                       
                                       
                                       
Doug Pruitt
                             DOE-ID  -  Oversight
                                       
                                       
                                       
Herb Cruickshank
                            DOE-CBFO  -  Oversight
                                       
                                       
                                       
Jim Van Vliet
                         DOE-ID  -  Waste Disposition
                                       
                                       
                                       
Ed Gulbransen
                          Fluor ID  -  Deputy Manager
                                       
                                       
                                       
Preston Abbott
                             Fluor ID  -  NDA SME
                                       
                                       
                                       
James Seamans
                             Fluor ID  -  NDA SME
                                       
                                       
                                       
Steve Tallman
                             Fluor ID  -  RTR SME
                                       
                                       
                                       
George Byram
                            Fluor ID  -  CH TRU Mgr
                                       
                                       
                                       
Roe Thompson
                             Fluor ID  -  RTR/ITR
                                       
                                       
                                       
Elvin Dumas
                            Fluor ID  -  QA Manager
                                       
                                       
                                       
Mindy Giles
                               Fluor ID  -  AKE
                                       
                                       
                                       
Nancy Kirk
                               Fluor ID  -  AKE
                                       
                                       
                                       
Brian Martinson
                               Fluor ID  -  AKE
                                       
                                       
                                       
Stormie Winterbottom
                               Fluor ID  -  WCO
                                       
                                       
                                       
Wesley Skaar
                               Fluor ID  -  SPM
                                       
                                       
                                       
Clay Dennert
                               Fluor ID  -  AKE
                                       
                                       
                                       


Acceptable Knowledge Baseline Inspection Checklist
EPA Inspection No: AMWTP-Fluor 08.17-8 	Inspection Date: August 8 - 10, 2017
Does the waste characterization program adequately define, describe, address or satisfy the following:
                                  Yes, No, NA
                        Objective Evidence and Comments
 Personnel 


 Are all AKEs and SPMs performing work for the AMWTP trained and qualified?
                                      Yes
Screenshot of database showing Qual Date and Expire Date for all AKEs, 6/29/17
Screenshot of database showing SPM Qual Dates and Expire Dates, 7/12/17
AKE Initial Qualification Checklists: Dennert, Giles, Kirk, Martinson
AKE Requalification Checklists: Carpenter, Morris
SPM Requalification Checklists: Tedford, Byram, Skaar
WCO Requalification Checklist: Winterbottom
 Acceptable Knowledge Nonconformances and Discrepancies
                                       

 Are AK-affecting nonconformances documented appropriately such that adequate resolution is attained prior to continued container characterization and/or shipment?
                                      Yes
NCR No. 103740 with AKR-16-910 R1
NCR No. 102733 with AKR-15-906 R5
AMWTP AKEs generate NCRs when the discrepancy needs to be resolved before the drum/container can proceed through characterization.
 When appropriate, is AK reevaluation adequately completed and documented? This may be documented on a Form 1070 Acceptable Knowledge Resolution (AKR) Checklist.
                                      Yes
MCP-4010, Appendix E
AKR-16-910 R1
AKR-15-906 R5
AK Resolution Ledger, demonstrated 8/9/2017
AKRs are generated to document resolution of AK-NDE or AK-NDA discrepancies. 
 Are discrepancies between AK source documents and/or between AK and characterization data documented and resolved? This may be documented on a Form 1784, Acceptable Knowledge Discrepancy Report.
                                      Yes
D120A, D130S
Discrepancy reports are generated to document resolution of AK-AK discrepancies (usually conflicts between source documents).
 Waste Stream Definition and Waste Identification
                                       

 Is all waste within a waste stream generated from a single process/activity and does the AK adequately describe the single process/activity?
                                      Yes
BNINW216: RPT-TRUW-09, Rev. 9; RPT-TRUW-56, Rev. 7; P217A, P219A, P368A
BN510.4: RPT-TRUW-83, Rev. 12; RPT-TRUW-06, Rev.18
J.C. Haynes: RPT-TRUW-XX, draft
The AMWTP documents waste stream-specific information in the AKSR. Generator site processes are described in detail in the AKD, which is referenced as a source document in the AKSR.
 Is all waste within a waste stream similar in material and physical form and are the expected physical parameters adequately described? The expected physical parameters may be documented in RPT-TRUW-05 and/or on a Waste Material Parameters memorandum.
                                      Yes
RPT-TRUW-05, Rev. 41, draft Rev. 42
BNINW216: RPT-TRUW-09, Rev. 9; RPT-TRUW-56, Rev. 7; C534A
BN510.4: RPT-TRUW-83, Rev. 12; RPT-TRUW-06, Rev.18; C1381A
J.C. Haynes: RPT-TRUW-XX, draft
TPR-8165, Rev. 0
RPT-TRUW-05 lists all IDCs that have ever been part of the AMWTP inventory. Each waste container is assigned an IDC based on generator site, generating process, and waste type. RPT-TRUW-05 is used to verify assigned IDCs and/or suggest precise IDCs if the container is assigned a generic IDC.
 Are the expected radiological characteristics for each waste stream adequately described in the AK and are the limitations of AK for use in radiological characterization or assay adequately communicated? The radiological characteristics and AK limitations may be documented in RPT-TRUW-07. 
                                      Yes
RPT-TRUW-07, Rev. 22; DCR No. 9419
BNINW216: RPT-TRUW-09, Rev. 9; RPT-TRUW-56, Rev. 7
BN510.4: RPT-TRUW-83, Rev. 12; RPT-TRUW-06, Rev.18
J.C. Haynes: RPT-TRUW-XX, draft
RPT-TRUW-07 summarizes radiological information associated with waste from each generator site. One or more NDA EAs review the report for each revision.
 Are waste containers traceable from retrieval or generation through the AMWTP's WIPP characterization process? Traceability records may include add-container memoranda, drum-specific paperwork from the generator site, IWMDL forms, characterization BDRs, WTS screenshots or demonstrations.
                                      Yes
WTS demonstration and screenshots for BN510.4 Drum No. BN10500841 and source containers 10213527 and 10497417
WTS demonstration and screenshots for BNINW216 Drum Nos. 10335453 and 10305406
 Enhanced Acceptable Knowledge
                                       

 Has review of the AK associated with certifiable payload containers generated since August 25, 2016, been conducted and documented to provide reasonable assurance that management and packaging of the containers is bounded by the applicable AKSRs? This may be documented on an IWMDL form and/or in a new revision of the AKSR.
                                      Yes
BNINW216 IWMDL, signed 7/5/17, procedures not yet verified; no containers yet associated with IWMDL
Procedure verification checklist for MCP-4006, Rev. 1
Discussion with AKE regarding process
 Has review of the AK associated with certifiable payload containers generated prior to August 25, 2016, been conducted and documented to provide reasonable assurance that management and packaging of the containers is bounded by the applicable AKSRs? This may be documented in an AKA memorandum; there may be more than one AKA memorandum per waste stream.
                                      Yes
AKA memorandum with Attachment 1, BNINW216 in WHB, Rev. 1, 7/19/17; Rev. 2, 10/18/17
Discussion with AKE regarding process
Documentation of review process
 Are the technical assumptions used to evaluate the chemical compatibilities within a waste stream clearly documented and reasonable and/or justified? Is the overall evaluation sufficient to identify any potential impacts to the long-term isolation of TRU waste?
                                      Yes
CCE memorandum for BNINW216 in WHB, 7/20/17
CBFO concurrence and approval memorandum, 11/15/17 
Discussion with AKE regarding process
DRRs and SPM concurrence during revision and review process
 Are the technical assumptions used to evaluate the subject containers against the specified criteria of the BoK for the treatment and management of oxidizing materials clearly documented and reasonable and/or justified?
                                      Yes
BoK Assessment for BNINW216 in WHB, draft provided 8/10/17
Discussion with AKE regarding process
 Waste Stream Certification
                                       

 Is the CBFO-approved waste stream profile package  -  including the WSPF, most recent AKSR, Lot 1 DQO Reconciliation and Characterization Information Summary, and all change notices  -  complete and accurate? 
                                      Yes
P402A (BNINW216 WSPF package)
P2076A (BN510.4 WSPF package)
 Has each characterization lot been reconciled against DQOs and verified to be associated with any open NCRs? This may be documented on FRM-1999, Reconciliation with Data Quality Objectives.
                                      Yes
BN510.4.0070, BN510.4.0155, BN510.4.0156
BNINW216.0107, BNINW216.0108
BN004.0013
 Has each payload container been evaluated for compliance with WIPP certification criteria?
                                      Yes
BN510.4.0070 (BN10554633)
BN004.0013 (10305150)
 Has an AK accuracy report been completed for each active waste stream at least annually and is the report complete and technically adequate?
                                      Yes
Memorandum to G. Byrum from R C Morris, Acceptable Knowledge Accuracy Assessment for July 1, 2014 to June 30, 2015 - RCM-008-15, October 8, 2015
Memorandum to G. Byrum from R C Morris, Acceptable Knowledge Accuracy Assessment for July 1, 2015 to June 30, 2016 - CCN319947, November 2, 2016
 System of Controls
                                       

 Are AKSRs and AKDs complete and do they contain sufficient detail to delineate each included waste stream?
                                      Yes
BNINW216: RPT-TRUW-09, Rev. 9; RPT-TRUW-56, Rev. 7
BN510.4: RPT-TRUW-83, Rev. 12; RPT-TRUW-06, Rev.18
J.C. Haynes: RPT-TRUW-XX, draft
 Are controls in place to ensure that only approved feedstock enters the AMWTP treatment processes?
                                      Yes
RPT-TRUW-83, Rev. 12; MCP-4085, Rev. 0; TPR-8151, Rev. 0; MCP-4003, Rev. 1;
 Is the defense determination for all WIPP-bound waste documented?
                                      Yes
BNINW216: RPT-TRUW-09, Rev. 9; RPT-TRUW-56, Rev. 7
BN510.4: RPT-TRUW-83, Rev. 12; RPT-TRUW-06, Rev.18
J.C. Haynes: RPT-TRUW-XX, draft
 Is there documentation that none of the waste in the waste stream is HLW or SNF?
                                      Yes
BNINW216: RPT-TRUW-09, Rev. 9; RPT-TRUW-56, Rev. 7
BN510.4: RPT-TRUW-83, Rev. 12; RPT-TRUW-06, Rev.18
J.C. Haynes: RPT-TRUW-XX, draft
 If payload management of TRU alpha activity concentration of waste containers selected for overpacking is being conducted for any AMWTP waste stream, does the applicable waste stream documentation include an estimate of the total waste volume and the percentage of the waste volume that is above and below 100 nCi/g?
                                      Yes
BNINW216: RPT-TRUW-09, Rev. 9
RPT-TRUW-07, Rev. 22
Estimated percentages above and below 100 nCi/g are documented in AKSR and RPT-TRUW-07 for direct ship waste streams. Estimated percentages for supercompaction feedstock are documented in RPT-TRUW-07.
 Is the AK collection process adequately documented? Documentation may include FRM-2182, TRU Waste Management AK Checklist; FRM-2457, TRU Waste Stream AK Document Checklist; FRM-2059, AK Source Document Review Summary; FRM-2185, AK Source Document Reference List.
                                      Yes
J.C. Haynes: Form-1084
AMWTP (BN) waste: Form-1066
BNINW216: Form-1067
BN510.4: Form-1067
FRM-2059 or Form-1068 provided with each Source Document cited in this table.
 If applicable, are the data and information shared between related waste streams adequately documented?
                                      Yes
BNINW216: RPT-TRUW-09, Rev. 9; RPT-TRUW-56, Rev. 7
BN510.4: RPT-TRUW-83, Rev. 12; RPT-TRUW-06, Rev.18


Nondestructive Assay Baseline Inspection Checklist:
Z-211 Integrated Waste Assay System (IWAS) Z-211-102 and Z-211-103 
EPA Inspection No.: AMWTP-Fluor 08.17-8	Inspection Date: August 8 - 10, 2017
                           Technical Element/Aspect
                                  Yes, No, NA
                        Comments and Objective Evidence
 General System Attributes
   
   
 Is the NDA system the Integrated Waste Assay System Z-211-102 and Z-211-103? Where is it located?
                                       Y
The IWAS Z-211-102 and Z-211-103 units are in WMF Building 634 at the AMWTP located on DOE's INL site. Confirmed by direct observation during the inspection.
 Describe the Integrated Waste Assay System Z-211-102 and Z-211-103. 
                                       Y
The Z-211-102 and Z-211-103 IWAS units assay CH retrievably-stored or newly-generated wastes in 55- and 85-gallon containers. For PN assays, each IWAS unit uses [3]He proportional counters in a 4Π geometry to detect [240]Pu or other spontaneous fission neutrons. The IWAS estimates the [240]PuEFF based on direct neutron measurement. Individual radionuclides can be estimated by combining the measured [240]PuEFF with ratios of other radionuclides measured with two BEGe gamma detectors. An AAS matrix-correction technique is correct for matrix effects. During the AAS measurement, a [252]Cf source is introduced into the drum measurement chamber. The response of the system to the [252]Cf source with the waste matrix present is compared with the recorded response of the system to the same source when no waste matrix is present, and a correction factor is derived from that ratio.
 System Performance
   
   
 Are the container types, types of TRU waste, and the operational parameters for the Integrated Waste Assay System Z-211-102 and Z-211-103 defined and reasonable? 
                                       Y
The Integrated Waste Assay System Z-211-102 and Z-211-103 IWAS units assay CH TRU waste in 55-gallon drums and 55-gallon/83-gallon overpacks. Both are capable of assaying a variety of waste matrices, including combustibles, glass, organic and inorganic sludge, and metals. Both systems are limited to assaying only debris, and debris and solids. Because of the multi-modal system design and the ability to correct for matrix effects on both the gamma and neutron measurement elements independently, the systems are essentially matrix-independent within the range of demonstrated applicability for each measurement technique.
 How many waste containers were assayed by the Integrated Waste Assay System Z-211-102 and Z-211-103?
                                       Y
The Z-211-102 assayed 4,463 and the Z-211-103 assayed 4,216 waste containers. At the time of assay, all containers were believed to be TRU; however, many drums do not meet the TRU waste criteria and fall out as LLW. Exact numbers were not provided by AMWTP personnel.
 Are the Integrated Waste Assay System Z-211-102 and Z-211-103 able to report quantitative values and uncertainties for the WIPP-tracked radionuclides?
                                       Y
Direct Measurements: [239]Pu, [238]Pu, [240]Pu, [241]Am, [233]U, [238]U and [137]Cs.
In the absence of sufficient gamma signal or other interference that prohibits the use of MGA, NDA 2000 uses default values for WG Pu or HS Pu as a function of the main radionuclide detected, i.e., [239]Pu or [238]Pu. Other gamma emitters may be measured directly and reported, when applicable.
[242]Pu is determined by correlation; [90]Sr and [234]U are scaled to [137]Cs and [235]U and/or [238]U, respectively.
Confirmed with NDA personnel during inspection.
 Have background measurements been taken each operational day? Have any instances of problematic background radiation been documented?
                                       Y
NDA BDRs that were evaluated contain evidence of the background performance for both systems.
 Have system performance checks been completed at least once per operational day? Are the procedures for the performance checks technically adequate for the Integrated Waste Assay System Z-211-102 and Z-211-103, including gamma matrix correction checks, and gamma peak position and resolution checks?
                                       Y
This was confirmed in the electronic logbook and with personnel in the operations area.
 System Calibration & Calibration Verifications
   
   
 Do the Integrated Waste Assay System Z-211-102 and Z-211-103 have a calibration of record? Were consensus standards used in the initial calibration? If so, which standards?
                                       Y
Both IWAS units were calibrated in Meriden, CT, prior to their shipment to the AMWTP. Upon receipt/installation at the AMWTP, calibrations were verified as documented in SATR CI-IDA-NDA-0051 and CI-IDA-NDA-0052. Calibrations for both IWAS units were done in accordance with CI-IDA-NDA-0031. AMWTP-RPT-TRUW-03, Revision 5, references consensus standards ASTM C1030, ASTM C1207 and ASTM C1316.
 Are the calibration, execution of performance checks and operation of the Integrated Waste Assay System Z-211-102 and Z-211-103, the calculation of radionuclide values and the review/validation of Integrated Waste Assay System Z-211-102 and Z-211-103 data governed by controlled-copy (formal) procedures?
                                       
Verification of the instruments' calibration has been performed many times, as documented on the summary provided by J. Seamans, including routine maintenance and replacement of the gamma detector(s).
 Are the current revisions of procedures in use for the Integrated Waste Assay System Z-211-102 and Z-211-103?
                                       
Operations procedures are available as hard copies in the control room. All other procedures were available digitally to the operators, all procedures are current and copies of each were found and easily accessible in the control room for the Z-211-102 and Z-211-103 systems.
 Are the isotopic contributions of unmeasured radionuclides derived using a certain method?
                                       
[241]Am and Pu isotopics are determined by FRAM software; site-approved AK is used for default isotopics. Confirmed with AMWTP NDA personnel during evaluation.
 Were traceable radionuclide sources used for calibration confirmation and/or verifications?
                                       
As verified in Work Order dated June 21, 2017
 Have the operational ranges with respect to matrix (density) and activity been determined for the Integrated Waste Assay System Z-211-102 and Z-211-103? 
                                       
Operating ranges are specified in SATRs CI-IDA-NDA-0051 and CI-IDA-NDA-0052. The IWAS calibrations are not mass calibrations in a strict sense, although the AMWTP expresses the operating range as 0.010 g - 200 g WG Pu. In theory, any assay within energy range for gamma or AAS range for PN that meets measurement criteria is acceptable.
Matrices used for AN and PN calibration include combustibles, glass, organic and inorganic sludges (solids), and metals. For gamma mode, matrices with densities up to 1.6 g/cm[3] were used. Matrices for all operational modes are representative with respect to physical form and activity.
 Have calibration verifications been completed for the Integrated Waste Assay System Z-211-102 and Z-211-103? If so, what is the date of the last calibration verification? Have any others been completed in the last year?
                                       
As verified in Work Order associated with system Z-211-102 dated June 21, 2017. Both BEGe detectors replaced.
 Do the Integrated Waste Assay System Z-211-102 and Z-211-103 meet the requirements for accuracy and precision as specified in DOE/WIPP-02-3122, Appendix A, Table A-2 for calibration verifications?
                                       
SATRs CI-IDA-NDA-0051 and CI-IDA-NDA-0052
 Have any NCRs related to the Integrated Waste Assay System Z-211-102 or Z-211-103 been issued since the last EPA Continued Compliance inspection?
                                       
There have been no system NCRs on the IWAS Z-211-102 and Z-211-103 units since the last inspection. Confirmed during interviews with AMWTP personnel during inspection.
 Do the BDRs contain:
 Testing facility name, testing batch number, container numbers and signature of the SPM or designee?
 Table of contents?
 Background and performance check data or control charts for the relevant time period?
 Separate testing report sheets for each container?
                                       
The EPA reviewed the following BDRs: 
                               Instrument Number
                                  BDR Number	
                                Container Type
                                    in BDR
                                   Z-211-102
                                  ASY16-02166
                             83/85-gallon overpack
                                   Z-211-102
                                  ASY17-01161
                                   55-gallon
                                   Z-211-103
                                  ASY16-03800
                             83/85-gallon overpack
                                   Z-211-103
                                  ASY17-01299
                                   55-gallon

 Do the RDSs include:
 Title "Radioassay Data Sheet"?
 Method/procedure used?
 Date of radioassay?
 Activities and associated TMU for individual radionuclides?
 TRU alpha concentration and its associated TMU?
 Operator and reviewer signatures?
                                       
The EPA reviewed IWAS Z-211-102 and Z-211-103 BDRs to confirm they contain appropriate information. All necessary information is provided.
 Total Measurement Uncertainty
   
   
 Is the magnitude of the TMU values observed in the Integrated Waste Assay System Z-211-102 and Z-211-103 BDRs examined during the inspection within the expected range?
                                       
Confirmed TMU determination is the same for both Z-211 IWAS units, and both are documented in CI-IDA-NDA-0055, TMU for the AMWTP Integrated Waste Assay System, Revision 1, July 30, 2003.
 Lower Limit of Detection
   
   
 Has the LLD for the Integrated Waste Assay System Z-211-102 and Z-211-103 been determined? Is the LLD determination appropriate for the types of TRU waste the AMWTP expects to assay on the Integrated Waste Assay System Z-211-102 and Z-211-103? Is the technical basis for the LLD determination documented?
                                       
LLDs are determined for each assay modality measurement. Nominal values are reported in the Site Acceptance Test Reports CI-IDA-NDA-0051 and CI-IDA-NDA-0052 for Z-211-102 and Z-211-103, respectively.
 Are the Integrated Waste Assay System Z-211-102 and Z-211-103 used to discriminate TRU/Non-TRU wastes at the 100 nCi/g criterion? If so, do the Integrated Waste Assay System Z-211-102 and Z-211-103 have the required sensitivity? 
                                       
SATRs CI-IDA-NDA-0051 and CI-IDA-NDA-0052 for Z-211-102 and Z-211-103, respectively.
 Are there any instances where an LLD value for a non-measured radionuclide is not provided based on a lack of technical feasibility?
                                       
Several BDRs show concentrations near the LLD however this is associated with LLW drums.
 PDP Participation
   

 Have the Integrated Waste Assay System Z-211-102 and Z-211-103 participated successfully in the CBFO NDA PDP? If so, identify the last cycle.
                                       
Both instruments successfully participated in PDP drum Cycle 24A as reported in a June 29, 2017 Memorandum.
 Training


 Do all operators have current CCP training as verified on an LOQI?
                                       
The AMWTP provided a list of employees by qualifications/certifications. All operators were listed as current.
 Are Integrated Waste Assay System Z-211-102 AND Z-211-103 data reviewed and approved by qualified personnel? If so, identify the name of the individuals performing technical review and approval of Integrated Waste Assay System Z-211-102 and Z-211-103 BDRs.
                                       
NDA BDRs that were evaluated contain evidence of appropriate data validation as evidenced by signatures.
In the BDRs reviewed by the EPA, data review was performed by S. Cummins.
 Replicate Testing


 Have replicate testing of the Integrated Waste Assay System Z-211-102 and Z-211-103 been performed, and does it meet the EPA Replicate Testing Protocol?
                                       
Replicate testing is performed in the same manner as routine assays in accordance with INST-OI-11. PDP-type drums with non-interfering matrices were used for all replicate testing.


Replicate Testing Data for Container No. 10597312  - 
IWAS Z-211-102
Quantity of Interest
                             Original Measurement
                                 Replicate #1
                                 Replicate #2

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[235]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[237]Np Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[238]Pu Activity (Ci)
                                                                       3.22E-05
                                                                       1.41E-05
                                                                          43.7%
                                                                       2.77E-05
                                                                       1.23E-05
                                                                          44.5%
                                                                       3.35E-05
                                                                       1.46E-05
                                                                          43.7%
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       1.20E-03
                                                                       2.36E-04
                                                                          19.7%
                                                                       1.04E-03
                                                                       2.20E-04
                                                                          21.2%
                                                                       1.25E-03
                                                                       2.45E-04
                                                                          19.6%
[240]Pu Activity (Ci)
                                                                       2.66E-04
                                                                       5.69E-05
                                                                          21.4%
                                                                       2.31E-04
                                                                       5.29E-05
                                                                          22.9%
                                                                       2.79E-04
                                                                       5.94E-05
                                                                          21.3%
[241]Am Activity (Ci)
                                                                       2.38E-04
                                                                       4.86E-05
                                                                          20.4%
                                                                       2.07E-04
                                                                       4.53E-05
                                                                          21.9%
                                                                       2.51E-04
                                                                       5.10E-05
                                                                          20.3%
[241]Pu Activity (Ci)
                                                                       1.58E-03
                                                                       4.27E-04
                                                                          27.0%
                                                                       1.33E-03
                                                                       3.75E-04
                                                                          28.2%
                                                                       1.60E-03
                                                                       4.30E-04
                                                                          26.9%
[242]Pu Activity (Ci)
                                                                       3.49E-08
                                                                       1.91E-08
                                                                          54.8%
                                                                       3.02E-08
                                                                       1.67E-08
                                                                          55.4%
                                                                       3.65E-08
                                                                       2.00E-08
                                                                          54.8%
TRU Alpha Conc. (nCi/g)
                                                                            362
                                                                              5
                                                                           1.4%
                                                                             31
                                                                              5
                                                                          15.5%
                                                                             38
                                                                              5
                                                                          14.2%

Quantity of Interest
                                 Replicate #3
                                 Replicate #4
                                 Replicate #5

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[235]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[237]Np Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[238]Pu Activity (Ci)
                                                                       3.12E-05
                                                                       1.37E-05
                                                                          44.0%
                                                                       3.19E-05
                                                                       1.40E-05
                                                                          43.9%
                                                                       3.09E-05
                                                                       1.36E-05
                                                                          43.9%
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       1.17E-03
                                                                       2.36E-04
                                                                          20.2%
                                                                       1.19E-03
                                                                       2.38E-04
                                                                          20.0%
                                                                       1.16E-03
                                                                       2.33E-04
                                                                          20.1%
[240]Pu Activity (Ci)
                                                                       2.60E-04
                                                                       5.69E-05
                                                                          21.9%
                                                                       2.66E-04
                                                                       5.77E-05
                                                                          21.7%
                                                                       2.57E-04
                                                                       5.60E-05
                                                                          21.8%
[241]Am Activity (Ci)
                                                                       2.33E-04
                                                                       4.87E-05
                                                                          20.9%
                                                                       2.39E-04
                                                                       4.95E-05
                                                                          20.7%
                                                                       2.31E-04
                                                                       4.80E-05
                                                                          20.8%
[241]Pu Activity (Ci)
                                                                       1.49E-03
                                                                       4.08E-04
                                                                          27.4%
                                                                       1.52E-03
                                                                       4.13E-04
                                                                          27.2%
                                                                       1.48E-03
                                                                       4.04E-04
                                                                          27.3%
[242]Pu Activity (Ci)
                                                                       3.40E-08
                                                                       1.87E-08
                                                                          55.0%
                                                                       3.48E-08
                                                                       1.91E-08
                                                                          54.9%
                                                                       3.37E-08
                                                                       1.85E-08
                                                                          55.0%
TRU Alpha Conc. (nCi/g)
                                                                             35
                                                                              5
                                                                          14.7%
                                                                             36
                                                                              5
                                                                          14.5%
                                                                             35
                                                                              5
                                                                          14.5%

Quantity of Interest
                             Original Measurement
                                  Sample Mean
                           Sample Standard Deviation
                          Relative Standard Deviation
                                      [2]
                                Pr(x <|[2]|)
                                       t
                                 Pr(x <|t|)

                                Reported Value
                             Absolute Uncertainty
                                       
                                       
                                       
                                       
                                       
                                       
                                       
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[234]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[235]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[237]Np Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[238]Pu Activity (Ci)
                                                                       3.22E-05
                                                                       1.41E-05
                                                                       3.10E-05
                                                                       2.12E-06
                                                                           6.8%
                                                                          0.091
                                                                          0.999
                                                                          0.499
                                                                          0.644
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       1.20E-03
                                                                       2.36E-04
                                                                       1.16E-03
                                                                       7.66E-05
                                                                           6.6%
                                                                          0.420
                                                                          0.981
                                                                          0.453
                                                                          0.674
[240]Pu Activity (Ci)
                                                                       2.66E-04
                                                                       5.69E-05
                                                                       2.59E-04
                                                                       1.76E-05
                                                                           6.8%
                                                                          0.382
                                                                          0.984
                                                                          0.384
                                                                          0.720
[241]Am Activity (Ci)
                                                                       2.38E-04
                                                                       4.86E-05
                                                                       2.32E-04
                                                                       1.61E-05
                                                                           6.9%
                                                                          0.440
                                                                          0.979
                                                                          0.329
                                                                          0.759
[241]Pu Activity (Ci)
                                                                       1.58E-03
                                                                       4.27E-04
                                                                       1.48E-03
                                                                       9.81E-05
                                                                           6.6%
                                                                          0.212
                                                                          0.995
                                                                          0.893
                                                                          0.422
[242]Pu Activity (Ci)
                                                                       3.49E-08
                                                                       1.91E-08
                                                                       3.38E-08
                                                                       2.31E-09
                                                                           6.8%
                                                                          0.058
                                                                          1.000
                                                                          0.419
                                                                          0.696
TRU Alpha Conc. (nCi/g)
                                                                             36
                                                                              5
                                                                             35
                                                                              2
                                                                           7.0%
                                                                          0.950
                                                                          0.917
                                                                          0.348
                                                                          0.746

Quantity of Interest
                                   [2] Test
                                    t-Test

                                       
                                       

                                       
                                       
[90]Sr Activity (Ci)
                                Not Applicable
                                Not Applicable
[137]Cs Activity (Ci)
                                Not Applicable
                                Not Applicable
[233]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[234]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[235]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[237]Np Activity (Ci)
                                Not Applicable
                                Not Applicable
[238]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[238]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[239]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[240]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[241]Am Activity (Ci)
                                Not Significant
                                Not Significant
[241]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[242]Pu Activity (Ci)
                                Not Significant
                                Not Significant
TRU Alpha Conc. (nCi/g)
                                Not Significant
                                Not Significant


Replicate Testing Data for Container No. 10612378  - 
IWAS Z-211-102
Quantity of Interest
                             Original Measurement
                                 Replicate #1
                                 Replicate #2

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       3.57E-06
                                                                       1.97E-06
                                                                          55.1%
                                                                       3.40E-06
                                                                       1.87E-06
                                                                          55.1%
                                                                       3.20E-06
                                                                       1.76E-06
                                                                          55.1%
[235]U Activity (Ci)
                                                                       1.15E-06
                                                                       3.42E-07
                                                                          29.7%
                                                                       1.10E-06
                                                                       3.45E-07
                                                                          31.4%
                                                                       1.03E-06
                                                                       3.13E-07
                                                                          30.4%
[237]Np Activity (Ci)
                                                                       3.80E-06
                                                                       9.01E-07
                                                                          23.7%
                                                                       3.84E-06
                                                                       8.99E-07
                                                                          23.4%
                                                                       4.16E-06
                                                                       9.86E-07
                                                                          23.7%
[238]Pu Activity (Ci)
                                                                       3.64E-04
                                                                       1.69E-04
                                                                          46.3%
                                                                       3.90E-04
                                                                       1.80E-04
                                                                          46.1%
                                                                       3.53E-04
                                                                       1.64E-04
                                                                          46.5%
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       1.36E-02
                                                                       3.39E-03
                                                                          24.9%
                                                                       1.46E-02
                                                                       3.56E-03
                                                                          24.4%
                                                                       1.32E-02
                                                                       3.34E-03
                                                                          25.3%
[240]Pu Activity (Ci)
                                                                       3.02E-03
                                                                       7.94E-04
                                                                          26.3%
                                                                       3.25E-03
                                                                       8.38E-04
                                                                          25.8%
                                                                       2.94E-03
                                                                       7.82E-04
                                                                          26.6%
[241]Am Activity (Ci)
                                                                       2.30E-01
                                                                       5.45E-02
                                                                          23.7%
                                                                       2.35E-01
                                                                       5.55E-02
                                                                          23.6%
                                                                       2.23E-01
                                                                       5.33E-02
                                                                          23.9%
[241]Pu Activity (Ci)
                                                                       1.76E-02
                                                                       5.47E-03
                                                                          31.1%
                                                                       1.87E-02
                                                                       5.72E-03
                                                                          30.6%
                                                                       1.69E-02
                                                                       5.29E-03
                                                                          31.3%
[242]Pu Activity (Ci)
                                                                       3.96E-07
                                                                       2.25E-07
                                                                          56.9%
                                                                       4.25E-07
                                                                       2.41E-07
                                                                          56.7%
                                                                       3.85E-07
                                                                       2.20E-07
                                                                          57.1%
TRU Alpha Conc. (nCi/g)
                                                                          1,010
                                                                            245
                                                                          24.3%
                                                                          1,141
                                                                            250
                                                                          21.9%
                                                                          1,078
                                                                            240
                                                                          22.3%

Quantity of Interest
                                 Replicate #3
                                 Replicate #4
                                 Replicate #5

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       2.35E-06
                                                                       1.29E-06
                                                                          55.1%
                                                                       3.22E-06
                                                                       1.77E-06
                                                                          55.1%
                                                                       2.40E-06
                                                                       1.32E-06
                                                                          55.1%
[235]U Activity (Ci)
                                                                       7.60E-07
                                                                       1.94E-07
                                                                          25.5%
                                                                       1.04E-06
                                                                       2.98E-07
                                                                          28.7%
                                                                       7.75E-07
                                                                       1.98E-07
                                                                          25.5%
[237]Np Activity (Ci)
                                                                       3.75E-06
                                                                       8.92E-07
                                                                          23.8%
                                                                       3.77E-06
                                                                       8.93E-07
                                                                          23.7%
                                                                       3.64E-06
                                                                       8.66E-07
                                                                          23.8%
[238]Pu Activity (Ci)
                                                                       4.05E-04
                                                                       1.86E-04
                                                                          46.0%
                                                                       3.68E-04
                                                                       1.70E-04
                                                                          46.2%
                                                                       3.82E-04
                                                                       1.76E-04
                                                                          46.1%
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       1.51E-02
                                                                       3.68E-03
                                                                          24.4%
                                                                       1.38E-02
                                                                       3.39E-03
                                                                          24.6%
                                                                       1.43E-02
                                                                       3.50E-03
                                                                          24.5%
[240]Pu Activity (Ci)
                                                                       3.37E-03
                                                                       8.69E-04
                                                                          25.8%
                                                                       3.06E-03
                                                                       7.96E-04
                                                                          26.0%
                                                                       3.18E-03
                                                                       8.24E-04
                                                                          25.9%
[241]Am Activity (Ci)
                                                                       2.16E-01
                                                                       5.18E-02
                                                                          24.0%
                                                                       2.21E-01
                                                                       5.22E-02
                                                                          23.6%
                                                                       2.42E-01
                                                                       5.71E-02
                                                                          23.6%
[241]Pu Activity (Ci)
                                                                       1.93E-02
                                                                       5.91E-03
                                                                          30.6%
                                                                       1.76E-02
                                                                       5.42E-03
                                                                          30.8%
                                                                       1.82E-02
                                                                       5.59E-03
                                                                          30.7%
[242]Pu Activity (Ci)
                                                                       4.41E-07
                                                                       2.50E-07
                                                                          56.7%
                                                                       4.02E-07
                                                                       2.28E-07
                                                                          56.8%
                                                                       4.16E-07
                                                                       2.36E-07
                                                                          56.7%
TRU Alpha Conc. (nCi/g)
                                                                          1,056
                                                                            233
                                                                          22.1%
                                                                          1,069
                                                                            235
                                                                          22.0%
                                                                          1,168
                                                                            258
                                                                          22.1%

Quantity of Interest
                             Original Measurement
                                  Sample Mean
                           Sample Standard Deviation
                          Relative Standard Deviation
                                      [2]
                                Pr(x <|[2]|)
                                       t
                                 Pr(x <|t|)

                                Reported Value
                             Absolute Uncertainty
                                       
                                       
                                       
                                       
                                       
                                       
                                       
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[234]U Activity (Ci)
                                                                       3.57E-06
                                                                       1.97E-06
                                                                       2.91E-06
                                                                       4.98E-07
                                                                          17.1%
                                                                          0.257
                                                                          0.992
                                                                          1.201
                                                                          0.296
[235]U Activity (Ci)
                                                                       1.15E-06
                                                                       3.42E-07
                                                                       9.41E-07
                                                                       1.61E-07
                                                                          17.1%
                                                                          0.886
                                                                          0.927
                                                                          1.187
                                                                          0.301
[237]Np Activity (Ci)
                                                                       3.80E-06
                                                                       9.01E-07
                                                                       3.83E-06
                                                                       1.97E-07
                                                                           5.1%
                                                                          0.191
                                                                          0.996
                                                                         -0.148
                                                                          0.889
[238]Pu Activity (Ci)
                                                                       3.64E-04
                                                                       1.69E-04
                                                                       3.80E-04
                                                                       2.00E-05
                                                                           5.3%
                                                                          0.056
                                                                          1.000
                                                                         -0.712
                                                                          0.516
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       1.36E-02
                                                                       3.39E-03
                                                                       1.42E-02
                                                                       7.31E-04
                                                                           5.2%
                                                                          0.187
                                                                          0.996
                                                                         -0.749
                                                                          0.496
[240]Pu Activity (Ci)
                                                                       3.02E-03
                                                                       7.94E-04
                                                                       3.16E-03
                                                                       1.67E-04
                                                                           5.3%
                                                                          0.176
                                                                          0.996
                                                                         -0.767
                                                                          0.486
[241]Am Activity (Ci)
                                                                       2.30E-01
                                                                       5.45E-02
                                                                       2.27E-01
                                                                       1.07E-02
                                                                           4.7%
                                                                          0.155
                                                                          0.997
                                                                          0.221
                                                                          0.836
[241]Pu Activity (Ci)
                                                                       1.76E-02
                                                                       5.47E-03
                                                                       1.81E-02
                                                                       9.34E-04
                                                                           5.2%
                                                                          0.117
                                                                          0.998
                                                                         -0.528
                                                                          0.626
[242]Pu Activity (Ci)
                                                                       3.96E-07
                                                                       2.25E-07
                                                                       4.14E-07
                                                                       2.14E-08
                                                                           5.2%
                                                                          0.036
                                                                          1.000
                                                                         -0.758
                                                                          0.491
TRU Alpha Conc. (nCi/g)
                                                                          1,010
                                                                            245
                                                                          1,102
                                                                             49
                                                                           4.5%
                                                                          0.161
                                                                          0.997
                                                                         -1.717
                                                                          0.161

Quantity of Interest
                                   [2] Test
                                    t-Test
[90]Sr Activity (Ci)
                                Not Applicable
                                Not Applicable
[137]Cs Activity (Ci)
                                Not Applicable
                                Not Applicable
[233]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[234]U Activity (Ci)
                                Not Significant
                                Not Significant
[235]U Activity (Ci)
                                Not Significant
                                Not Significant
[237]Np Activity (Ci)
                                Not Significant
                                Not Significant
[238]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[238]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[239]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[240]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[241]Am Activity (Ci)
                                Not Significant
                                Not Significant
[241]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[242]Pu Activity (Ci)
                                Not Significant
                                Not Significant
TRU Alpha Conc. (nCi/g)
                                Not Significant
                                Not Significant


Replicate Testing Data for Container No. 10596959  - 
IWAS Z-211-103
Quantity of Interest
                             Original Measurement
                                 Replicate #1
                                 Replicate #2

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       6.16E-06
                                                                       3.20E-06
                                                                          51.9%
                                                                       6.18E-06
                                                                       3.21E-06
                                                                          51.9%
                                                                       6.22E-06
                                                                       3.23E-06
                                                                          51.9%
[235]U Activity (Ci)
                                                                       1.99E-06
                                                                       2.87E-07
                                                                          14.4%
                                                                       2.00E-06
                                                                       2.88E-07
                                                                          14.4%
                                                                       2.01E-06
                                                                       2.91E-07
                                                                          14.5%
[237]Np Activity (Ci)
                                                                       6.70E-08
                                                                       1.59E-08
                                                                          23.7%
                                                                       7.30E-08
                                                                       1.45E-08
                                                                          19.9%
                                                                       6.86E-08
                                                                       1.37E-08
                                                                          19.9%
[238]Pu Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[240]Pu Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[241]Am Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[241]Pu Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[242]Pu Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
TRU Alpha Conc. (nCi/g)
                                                                       3.62E-03
                                                                       8.58E-04
                                                                          23.7%
                                                                       3.94E-03
                                                                       7.85E-04
                                                                          19.9%
                                                                       3.71E-03
                                                                       7.37E-04
                                                                          19.9%

Quantity of Interest
                                 Replicate #3
                                 Replicate #4
                                 Replicate #5

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       6.20E-06
                                                                       3.22E-06
                                                                          51.9%
                                                                       6.34E-06
                                                                       3.29E-06
                                                                          51.9%
                                                                       6.31E-06
                                                                       3.27E-06
                                                                          51.9%
[235]U Activity (Ci)
                                                                       2.00E-06
                                                                       2.90E-07
                                                                          14.5%
                                                                       2.05E-06
                                                                       2.95E-07
                                                                          14.4%
                                                                       2.04E-06
                                                                       2.96E-07
                                                                          14.5%
[237]Np Activity (Ci)
                                                                       7.40E-08
                                                                       1.47E-08
                                                                          19.8%
                                                                       6.31E-08
                                                                       1.31E-08
                                                                          20.8%
                                                                       7.13E-08
                                                                       1.46E-08
                                                                          20.5%
[238]Pu Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[240]Pu Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[241]Am Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[241]Pu Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[242]Pu Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
TRU Alpha Conc. (nCi/g)
                                                                       4.00E-03
                                                                       7.92E-04
                                                                          19.8%
                                                                       3.41E-03
                                                                       7.09E-04
                                                                          20.8%
                                                                       3.85E-03
                                                                       7.90E-04
                                                                          20.5%

Quantity of Interest
                             Original Measurement
                                  Sample Mean
                           Sample Standard Deviation
                          Relative Standard Deviation
                                      [2]
                                Pr(x <|[2]|)
                                       t
                                 Pr(x <|t|)

                                Reported Value
                             Absolute Uncertainty
                                       
                                       
                                       
                                       
                                       
                                       
                                       
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[234]U Activity (Ci)
                                                                       6.16E-06
                                                                       3.20E-06
                                                                       6.25E-06
                                                                       7.07E-08
                                                                           1.1%
                                                                          0.002
                                                                          1.000
                                                                         -1.162
                                                                          0.310
[235]U Activity (Ci)
                                                                       1.99E-06
                                                                       2.87E-07
                                                                       2.02E-06
                                                                       2.35E-08
                                                                           1.2%
                                                                          0.027
                                                                          1.000
                                                                         -1.168
                                                                          0.308
[237]Np Activity (Ci)
                                                                       6.70E-08
                                                                       1.59E-08
                                                                       7.00E-08
                                                                       4.37E-09
                                                                           6.2%
                                                                          0.302
                                                                          0.990
                                                                         -0.627
                                                                          0.565
[238]Pu Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[240]Pu Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[241]Am Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[241]Pu Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[242]Pu Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
TRU Alpha Conc. (nCi/g)
                                                                       3.62E-03
                                                                       8.58E-04
                                                                              0
                                                                              0
                                                                           6.2%
                                                                          0.300
                                                                          0.990
                                                                         -0.630
                                                                          0.563

Quantity of Interest
                                   [2] Test
                                    t-Test
[90]Sr Activity (Ci)
                                Not Applicable
                                Not Applicable
[137]Cs Activity (Ci)
                                Not Applicable
                                Not Applicable
[233]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[234]U Activity (Ci)
                                Not Significant
                                Not Significant
[235]U Activity (Ci)
                                Not Significant
                                Not Significant
[237]Np Activity (Ci)
                                Not Significant
                                Not Significant
[238]Pu Activity (Ci)
                                Not Applicable
                                Not Applicable
[238]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[239]Pu Activity (Ci)
                                Not Applicable
                                Not Applicable
[240]Pu Activity (Ci)
                                Not Applicable
                                Not Applicable
[241]Am Activity (Ci)
                                Not Applicable
                                Not Applicable
[241]Pu Activity (Ci)
                                Not Applicable
                                Not Applicable
[242]Pu Activity (Ci)
                                Not Applicable
                                Not Applicable
TRU Alpha Conc. (nCi/g)
                                Not Significant
                                Not Significant


Replicate Testing Data for Container No. 10597411  - 
IWAS Z-211-103
Quantity of Interest
                             Original Measurement
                                 Replicate #1
                                 Replicate #2

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[235]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[237]Np Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[238]Pu Activity (Ci)
                                                                       8.03E-05
                                                                       3.59E-05
                                                                          44.7%
                                                                       9.12E-05
                                                                       4.07E-05
                                                                          44.6%
                                                                       8.95E-05
                                                                       3.99E-05
                                                                          44.6%
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       2.99E-03
                                                                       6.49E-04
                                                                          21.7%
                                                                       3.41E-03
                                                                       7.33E-04
                                                                          21.5%
                                                                       3.35E-03
                                                                       7.24E-04
                                                                          21.6%
[240]Pu Activity (Ci)
                                                                       6.64E-04
                                                                       1.54E-04
                                                                          23.2%
                                                                       7.58E-04
                                                                       1.75E-04
                                                                          23.1%
                                                                       7.45E-04
                                                                       1.73E-04
                                                                          23.2%
[241]Am Activity (Ci)
                                                                       5.93E-04
                                                                       1.32E-04
                                                                          22.3%
                                                                       6.81E-04
                                                                       1.51E-04
                                                                          22.2%
                                                                       6.69E-04
                                                                       1.49E-04
                                                                          22.3%
[241]Pu Activity (Ci)
                                                                       3.94E-03
                                                                       1.12E-03
                                                                          28.5%
                                                                       4.36E-03
                                                                       1.24E-03
                                                                          28.4%
                                                                       4.28E-03
                                                                       1.22E-03
                                                                          28.4%
[242]Pu Activity (Ci)
                                                                       8.70E-08
                                                                       4.84E-08
                                                                          55.6%
                                                                       9.94E-08
                                                                       5.52E-08
                                                                          55.5%
                                                                       9.76E-08
                                                                       5.42E-08
                                                                          55.5%
TRU Alpha Conc. (nCi/g)
                                                                             69
                                                                             11
                                                                          15.9%
                                                                             79
                                                                             12
                                                                          15.2%
                                                                             78
                                                                             12
                                                                          15.4%

Quantity of Interest
                                 Replicate #3
                                 Replicate #4
                                 Replicate #5

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[235]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[237]Np Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[238]Pu Activity (Ci)
                                                                       7.51E-05
                                                                       3.48E-05
                                                                          46.4%
                                                                       8.43E-05
                                                                       3.91E-05
                                                                          46.4%
                                                                       7.96E-05
                                                                       3.56E-05
                                                                          44.7%
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       2.81E-03
                                                                       7.05E-04
                                                                          25.1%
                                                                       3.16E-03
                                                                       7.90E-04
                                                                          25.0%
                                                                       2.98E-03
                                                                       6.50E-04
                                                                          21.8%
[240]Pu Activity (Ci)
                                                                       6.25E-04
                                                                       1.65E-04
                                                                          26.4%
                                                                       7.02E-04
                                                                       1.85E-04
                                                                          26.4%
                                                                       6.62E-04
                                                                       1.55E-04
                                                                          23.4%
[241]Am Activity (Ci)
                                                                       5.62E-04
                                                                       1.44E-04
                                                                          25.7%
                                                                       6.31E-04
                                                                       1.62E-04
                                                                          25.6%
                                                                       5.95E-04
                                                                       1.34E-04
                                                                          22.5%
[241]Pu Activity (Ci)
                                                                       3.59E-03
                                                                       1.12E-03
                                                                          31.2%
                                                                       4.03E-03
                                                                       1.25E-03
                                                                          31.1%
                                                                       3.80E-03
                                                                       1.09E-03
                                                                          28.6%
[242]Pu Activity (Ci)
                                                                       8.19E-08
                                                                       4.67E-08
                                                                          57.0%
                                                                       9.19E-08
                                                                       5.24E-08
                                                                          57.0%
                                                                       8.68E-08
                                                                       4.83E-08
                                                                          55.6%
TRU Alpha Conc. (nCi/g)
                                                                             65
                                                                             12
                                                                          18.5%
                                                                             73
                                                                             13
                                                                          17.8%
                                                                             69
                                                                             11
                                                                          15.9%

                                       
Quantity of Interest
                             Original Measurement
                                  Sample Mean
                           Sample Standard Deviation
                          Relative Standard Deviation
                                      [2]
                                Pr(x <|[2]|)
                                       t
                                 Pr(x <|t|)

                                Reported Value
                             Absolute Uncertainty
                                       
                                       
                                       
                                       
                                       
                                       
                                       
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[234]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[235]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[237]Np Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[238]Pu Activity (Ci)
                                                                       8.03E-05
                                                                       3.59E-05
                                                                       8.39E-05
                                                                       6.72E-06
                                                                           8.0%
                                                                          0.140
                                                                          0.998
                                                                         -0.494
                                                                          0.647
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       2.99E-03
                                                                       6.49E-04
                                                                       3.14E-03
                                                                       2.51E-04
                                                                           8.0%
                                                                          0.598
                                                                          0.963
                                                                         -0.553
                                                                          0.610
[240]Pu Activity (Ci)
                                                                       6.64E-04
                                                                       1.54E-04
                                                                       6.98E-04
                                                                       5.58E-05
                                                                           8.0%
                                                                          0.525
                                                                          0.971
                                                                         -0.563
                                                                          0.604
[241]Am Activity (Ci)
                                                                       5.93E-04
                                                                       1.32E-04
                                                                       6.28E-04
                                                                       4.99E-05
                                                                           7.9%
                                                                          0.569
                                                                          0.966
                                                                         -0.634
                                                                          0.561
[241]Pu Activity (Ci)
                                                                       3.94E-03
                                                                       1.12E-03
                                                                       4.01E-03
                                                                       3.23E-04
                                                                           8.0%
                                                                          0.330
                                                                          0.988
                                                                         -0.204
                                                                          0.849
[242]Pu Activity (Ci)
                                                                       8.70E-08
                                                                       4.84E-08
                                                                       9.15E-08
                                                                       7.31E-09
                                                                           8.0%
                                                                          0.091
                                                                          0.999
                                                                         -0.564
                                                                          0.603
TRU Alpha Conc. (nCi/g)
                                                                             69
                                                                             11
                                                                             73
                                                                              6
                                                                           8.1%
                                                                          1.164
                                                                          0.884
                                                                         -0.585
                                                                          0.590

Quantity of Interest
                                   [2] Test
                                    t-Test
[90]Sr Activity (Ci)
                                Not Applicable
                                Not Applicable
[137]Cs Activity (Ci)
                                Not Applicable
                                Not Applicable
[233]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[234]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[235]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[237]Np Activity (Ci)
                                Not Applicable
                                Not Applicable
[238]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[238]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[239]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[240]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[241]Am Activity (Ci)
                                Not Significant
                                Not Significant
[241]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[242]Pu Activity (Ci)
                                Not Significant
                                Not Significant
TRU Alpha Conc. (nCi/g)
                                Not Significant
                                Not Significant


Replicate Testing Data for Container No. 10610103  - 
IWAS Z-211-103
Quantity of Interest
                             Original Measurement
                                 Replicate #1
                                 Replicate #2

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       5.43E-05
                                                                       3.17E-05
                                                                          58.3%
                                                                       5.21E-05
                                                                       3.04E-05
                                                                          58.3%
                                                                       5.28E-05
                                                                       3.08E-05
                                                                          58.3%
[235]U Activity (Ci)
                                                                       1.75E-05
                                                                       5.27E-06
                                                                          30.1%
                                                                       1.68E-05
                                                                       5.06E-06
                                                                          30.1%
                                                                       1.70E-05
                                                                       5.12E-06
                                                                          30.1%
[237]Np Activity (Ci)
                                                                       7.14E-07
                                                                       2.20E-07
                                                                          30.8%
                                                                       8.18E-07
                                                                       2.57E-07
                                                                          31.4%
                                                                       8.46E-07
                                                                       2.58E-07
                                                                          30.5%
[238]Pu Activity (Ci)
                                                                       3.96E-04
                                                                       2.01E-04
                                                                          50.8%
                                                                       3.65E-04
                                                                       1.85E-04
                                                                          50.7%
                                                                       3.36E-04
                                                                       1.66E-04
                                                                          49.5%
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       1.48E-02
                                                                       4.81E-03
                                                                          32.5%
                                                                       1.37E-02
                                                                       4.44E-03
                                                                          32.4%
                                                                       1.26E-02
                                                                       3.83E-03
                                                                          30.4%
[240]Pu Activity (Ci)
                                                                       3.29E-03
                                                                       1.10E-03
                                                                          33.5%
                                                                       3.04E-03
                                                                       1.02E-03
                                                                          33.4%
                                                                       2.80E-03
                                                                       8.82E-04
                                                                          31.5%
[241]Am Activity (Ci)
                                                                       6.75E-02
                                                                       2.09E-02
                                                                          31.0%
                                                                       5.74E-02
                                                                       1.79E-02
                                                                          31.1%
                                                                       5.07E-02
                                                                       1.57E-02
                                                                          31.0%
[241]Pu Activity (Ci)
                                                                       1.92E-02
                                                                       7.18E-03
                                                                          37.4%
                                                                       1.75E-02
                                                                       6.53E-03
                                                                          37.3%
                                                                       1.61E-02
                                                                       5.73E-03
                                                                          35.6%
[242]Pu Activity (Ci)
                                                                       4.31E-07
                                                                       2.61E-07
                                                                          60.6%
                                                                       3.98E-07
                                                                       2.41E-07
                                                                          60.5%
                                                                       3.67E-07
                                                                       2.18E-07
                                                                          59.5%
TRU Alpha Conc. (nCi/g)
                                                                          1,010
                                                                            245
                                                                          24.3%
                                                                          1,141
                                                                            250
                                                                          21.9%
                                                                          1,078
                                                                            240
                                                                          22.3%

Quantity of Interest
                                 Replicate #3
                                 Replicate #4
                                 Replicate #5

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       5.36E-05
                                                                       3.12E-05
                                                                          58.3%
                                                                       5.30E-05
                                                                       3.09E-05
                                                                          58.3%
                                                                       5.31E-05
                                                                       3.10E-05
                                                                          58.3%
[235]U Activity (Ci)
                                                                       1.73E-05
                                                                       5.21E-06
                                                                          30.1%
                                                                       1.71E-05
                                                                       5.15E-06
                                                                          30.1%
                                                                       1.71E-05
                                                                       5.15E-06
                                                                          30.1%
[237]Np Activity (Ci)
                                                                       7.37E-07
                                                                       2.26E-07
                                                                          30.7%
                                                                       8.33E-07
                                                                       2.55E-07
                                                                          30.6%
                                                                       8.10E-07
                                                                       2.48E-07
                                                                          30.6%
[238]Pu Activity (Ci)
                                                                       2.83E-04
                                                                       1.40E-04
                                                                          49.6%
                                                                       3.53E-04
                                                                       1.81E-04
                                                                          51.4%
                                                                       3.43E-04
                                                                       2.09E-04
                                                                          60.9%
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       1.06E-02
                                                                       3.23E-03
                                                                          30.5%
                                                                       1.32E-02
                                                                       4.41E-03
                                                                          33.4%
                                                                       1.28E-02
                                                                       5.99E-03
                                                                          46.8%
[240]Pu Activity (Ci)
                                                                       2.36E-03
                                                                       7.48E-04
                                                                          31.7%
                                                                       2.94E-03
                                                                       1.01E-03
                                                                          34.5%
                                                                       2.85E-03
                                                                       1.35E-03
                                                                          47.5%
[241]Am Activity (Ci)
                                                                       6.15E-02
                                                                       1.90E-02
                                                                          30.9%
                                                                       6.91E-02
                                                                       2.65E-02
                                                                          38.3%
                                                                       6.30E-02
                                                                       1.96E-02
                                                                          31.1%
[241]Pu Activity (Ci)
                                                                       1.35E-02
                                                                       4.82E-03
                                                                          35.7%
                                                                       1.69E-02
                                                                       6.46E-03
                                                                          38.2%
                                                                       1.64E-02
                                                                       8.25E-03
                                                                          50.3%
[242]Pu Activity (Ci)
                                                                       3.09E-07
                                                                       1.84E-07
                                                                          59.6%
                                                                       3.85E-07
                                                                       2.35E-07
                                                                          61.1%
                                                                       3.74E-07
                                                                       2.59E-07
                                                                          69.3%
TRU Alpha Conc. (nCi/g)
                                                                          1,056
                                                                            233
                                                                          22.1%
                                                                          1,069
                                                                            235
                                                                          22.0%
                                                                          1,168
                                                                            258
                                                                          22.1%

Quantity of Interest
                             Original Measurement
                                  Sample Mean
                           Sample Standard Deviation
                          Relative Standard Deviation
                                      [2]
                                Pr(x <|[2]|)
                                       t
                                 Pr(x <|t|)

                                Reported Value
                             Absolute Uncertainty
                                       
                                       
                                       
                                       
                                       
                                       
                                       
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[234]U Activity (Ci)
                                                                       5.43E-05
                                                                       3.17E-05
                                                                       5.29E-05
                                                                       5.45E-07
                                                                           1.0%
                                                                          0.001
                                                                          1.000
                                                                          2.312
                                                                          0.082
[235]U Activity (Ci)
                                                                       1.75E-05
                                                                       5.27E-06
                                                                       1.71E-05
                                                                       1.82E-07
                                                                           1.1%
                                                                          0.005
                                                                          1.000
                                                                          2.211
                                                                          0.092
[237]Np Activity (Ci)
                                                                       7.14E-07
                                                                       2.20E-07
                                                                       8.09E-07
                                                                       4.25E-08
                                                                           5.2%
                                                                          0.149
                                                                          0.997
                                                                         -2.038
                                                                          0.111
[238]Pu Activity (Ci)
                                                                       3.96E-04
                                                                       2.01E-04
                                                                       3.36E-04
                                                                       3.16E-05
                                                                           9.4%
                                                                          0.099
                                                                          0.999
                                                                          1.735
                                                                          0.158
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       1.48E-02
                                                                       4.81E-03
                                                                       1.26E-02
                                                                       1.18E-03
                                                                           9.4%
                                                                          0.242
                                                                          0.993
                                                                          1.712
                                                                          0.162
[240]Pu Activity (Ci)
                                                                       3.29E-03
                                                                       1.10E-03
                                                                       2.80E-03
                                                                       2.61E-04
                                                                           9.3%
                                                                          0.225
                                                                          0.994
                                                                          1.718
                                                                          0.161
[241]Am Activity (Ci)
                                                                       6.75E-02
                                                                       2.09E-02
                                                                       6.03E-02
                                                                       6.83E-03
                                                                          11.3%
                                                                          0.426
                                                                          0.980
                                                                          0.957
                                                                          0.393
[241]Pu Activity (Ci)
                                                                       1.92E-02
                                                                       7.18E-03
                                                                       1.61E-02
                                                                       1.54E-03
                                                                           9.6%
                                                                          0.183
                                                                          0.996
                                                                          1.853
                                                                          0.137
[242]Pu Activity (Ci)
                                                                       4.31E-07
                                                                       2.61E-07
                                                                       3.67E-07
                                                                       3.43E-08
                                                                           9.3%
                                                                          0.069
                                                                          0.999
                                                                          1.716
                                                                          0.161
TRU Alpha Conc. (nCi/g)
                                                                          1,010
                                                                            245
                                                                          1,102
                                                                             49
                                                                           4.5%
                                                                          0.161
                                                                          0.997
                                                                         -1.717
                                                                          0.161

Quantity of Interest
                                   [2] Test
                                    t-Test
[90]Sr Activity (Ci)
                                Not Applicable
                                Not Applicable
[137]Cs Activity (Ci)
                                Not Applicable
                                Not Applicable
[233]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[234]U Activity (Ci)
                                Not Significant
                                Not Significant
[235]U Activity (Ci)
                                Not Significant
                                Not Significant
[237]Np Activity (Ci)
                                Not Significant
                                Not Significant
[238]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[238]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[239]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[240]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[241]Am Activity (Ci)
                                Not Significant
                                Not Significant
[241]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[242]Pu Activity (Ci)
                                Not Significant
                                Not Significant
TRU Alpha Conc. (nCi/g)
                                Not Significant
                                Not Significant


Nondestructive Assay Baseline Inspection Checklist:
Z-390 Integrated Waste Assay System (IWAS) Z-390-100 and Z-390-101
EPA Inspection No.: AMWTP-Fluor 08.17-8	Inspection Date: August 8 - 10, 2017
                           Technical Element/Aspect
                                  Yes, No, NA
                        Comments and Objective Evidence
 General System Attributes
   
   
 Is the NDA system the Integrated Waste Assay System Z-390-100 and Z-390-101? Where is it located?
                                       Y
EPA inspectors found the IWAS Z-390-100 and Z-390-101 units are located in Building 676 at the AMWTP at DOE's Idaho National Laboratory site. Confirmed during inspection.
 Describe the Integrated Waste Assay System Z-390-100 and Z-390-101. 
                                       Y
The Z-390-100 and Z-390-101 IWAS units assay CH retrievably-stored or newly-generated wastes in 55- and 85-gallon containers. For PN assays, each IWAS unit uses [3]He proportional counters in a 4Π geometry to detect [240]Pu or other spontaneous fission neutrons. The IWAS estimates the [240]PuEFF based on direct neutron measurement. Individual radionuclides can be estimated by combining the measured [240]PuEFF with ratios of other radionuclides measured with two BEGe gamma detectors. An AAS matrix-correction technique is correct for matrix effects. During the AAS measurement, a [252]Cf source is introduced into the drum measurement chamber. The response of the system to the [252]Cf source with the waste matrix present is compared with the recorded response of the system to the same source when no waste matrix is present, and a correction factor is derived from that ratio.
 System Performance
   
   
 Are the container types, types of TRU waste and the operational parameters for the Integrated Waste Assay System Z-390-100 and Z-390-101 defined and reasonable? 
                                       Y
The IWAS Z-390-100 and Z-390-101 units are capable of assaying the radiological components of TRU waste in 55-gallon drums. Both are capable of assaying a variety of waste matrices, including combustibles, glass, organic and inorganic sludge, and metals. Both systems are limited to assaying only debris wastes. Because of the multi-modal system design and the ability to correct for matrix effects on both the gamma and neutron measurement elements independently, the systems are essentially matrix-independent within the range of demonstrated applicability for each measurement technique.
 How many waste containers were assayed by the Integrated Waste Assay System Z-390-100 and Z-390-101?
                                       Y
Z-390-100 assayed 7,121 drums, and Z-390-101 assayed 5,205 drums since June 1, 2016. Z-390-101 had less use because the conveyer that feeds the system was broken for approximately a month.
	
 Are the Integrated Waste Assay System Z-390-100 and Z-390-101 able to report quantitative values and uncertainties for the WIPP-tracked radionuclides?
                                       Y
The Z-390 systems provide quantitative values and uncertainties for [238]Pu, [239]Pu, [240]Pu, [242]Pu, [241]Am, [233]U, [234]U, [238]U, [90]Sr and [137]Cs.
Site Acceptance Test Reports CI-IDA-NDA-0053 and CI-NIDA-NDA-0054 for Z-390-100 and Z-390-101, respectively.
Confirmed with NDA personnel during inspection.
 Have background measurements been taken each operational day? Have any instances of problematic background radiation been documented?
                                       Y
Background measurements are taken between each assay. The EPA witnessed this during the inspection
 Have system performance checks been completed at least once per operational day? Are the procedures for the performance checks technically adequate for the Integrated Waste Assay System Z-390-100 and Z-390-101, including gamma matrix correction checks, and gamma peak position and resolution checks?
                                       Y
Performance measurements are taken daily, as confirmed in the electronic logbook. The procedures for the performance checks are technically adequate for the IWAS Z-390-100 and Z-390-101 units.
 System Calibration & Calibration Verifications
   
   
 Do the Integrated Waste Assay System Z-390-100 and Z-390-101 have a calibration of record? Were consensus standards used in the initial calibration? If so, which standards?
                                       Y
Both IWAS units were calibrated at the Canberra factory prior to their shipment to the AMWTP. Upon installation at the AMWTP, factory calibrations were verified as documented in SATR CI-IDA-NDA-0053 and CI-IDA-NDA-0054. Calibration activities for both IWAS units were done in accordance with CI-IDA-NDA-0031. AMWTP-RPT-TRUW-03, Revision 5, references consensus standards ASTM C1030, ASTM C1207 and ASTM C1316.
 Are the calibration, execution of performance checks and operation of the Integrated Waste Assay System Z-390-100 and Z-390-101, the calculation of radionuclide values and the review/validation of Integrated Waste Assay System Z-390-100 and Z-390-101 data governed by controlled-copy (formal) procedures?
                                       Y
Verification of the instruments' calibration has been performed many times, as documented on summary forms provided by the AMWTP, including routine maintenance and replacement of the gamma detector(s).
 Are the current revisions of procedures in use for the Integrated Waste Assay System Z-390-100 and Z-390-101?
                                       Y
These procedures are current, and copies of each were found and easily accessible in the IWAS control rooms for the Z-390-100 and Z-390-101 IWAS units.
 Are the isotopic contributions of unmeasured radionuclides derived using a certain method?
                                       Y
[241]Am and Pu isotopics are determined by FRAM software; site-approved AK is used for default isotopics. Confirmed with AMWTP NDA personnel during evaluation.
 Were traceable radionuclide sources used for calibration confirmation and/or verifications? 
                                       Y
Traceable standards were used, as verified by inspector.
 Have the operational ranges with respect to matrix (density) and activity been determined for the Integrated Waste Assay System Z-390-100 and Z-390-101? 
                                       Y
Operating ranges are specified in SATRs CI-IDA-NDA-0053 and CI-IDA-NDA-0054. The IWAS calibrations are not mass calibrations in a strict sense, although the operating range is expressed in 0.010 g - 200 g WG Pu. In theory, any assay within energy range for gamma or AAS range for PN that meets measurement criteria is acceptable.
Matrices used for AN and PN calibrations include combustibles, glass, organic and inorganic sludges (solids), and metals. For gamma mode, matrices with densities up to 1.6 g/cm[3] were used. Matrices for all operational modes are representative with respect to physical form and activity.
 Have calibration verifications been completed for the Integrated Waste Assay System Z-390-100 and Z-390-101? 
                                       Y
Calibration verifications are documented in work orders at the AMWTP; none have been performed since Fluor took over operations on the systems.
 Do the Integrated Waste Assay System Z-390-100 and Z-390-101 meet the requirements for accuracy and precision as specified in DOE/WIPP-02-3122, Appendix A, Table A-2 for calibration verifications?
                                       Y
The requirements for accuracy and precision specified in DOE/WIPP-02-3122, Appendix A, are met as specified in Site Acceptance Test Reports CI-IDA-NDA-0053 and CI-IDA-NDA-0054.
 Have any NCRs related to the Integrated Waste Assay System Z-390-100 or Z-390-101 been issued since the last EPA Continued Compliance inspection?
                                       Y
There have been no system NCRs on the Integrated Waste Assay System Z-390-100 and Z-390-101 since the last inspection. Confirmed during interviews with AMWTP personnel during inspection. A list of assay-specific NCRs was provided to the EPA.
 Do the BDRs contain:
 Testing facility name, testing batch number, container numbers, and signature of the SPM or designee?
 Table of contents?
 Background and performance check data or control charts for the relevant time period?
 Separate testing report sheets for each container?
                                       Y
The EPA reviewed Integrated Waste Assay System BDRs:
                               Instrument Number
                                  BDR Number	
                                Container Type
                                    in BDR
                                   Z-390-100
                                  ASY16-02155
                                   55-gallon
                                   Z-390-100
                                  ASY17-02468
                                   55-gallon
                                   Z-390-101
                                  ASY16-02214
                                   55-gallon
                                   Z-390-101
                                  ASY17-02152
                                   55-gallon

 Do the RDSs include:
 Method/procedure used
 Date of radioassay
 Activities and associated TMU for individual radionuclides
 TRU alpha concentration and its associated TMU
 Operator and reviewer signatures
                                       Y
The EPA reviewed BDRs from the IWAS Z-390-100 and Z-390-101 units to confirm they contain appropriate information. All signatures are electronically signed. 
 Total Measurement Uncertainty
   
   
 Is the magnitude of the TMU values observed in the Integrated Waste Assay System Z-390-100 AND Z-390-101 BDRs examined during the inspection within the expected range?
                                       Y
Confirmed TMU determination is the same for the IWAS Z-390-100 and Z-390-101 units, and both are documented in CI-IDA-NDA-0055, TMU for the AMWTP Integrated Waste Assay System, Revision. 1, July 30, 2003. CTAC NDA Technical Specialist reviewed and documented approval of TMU for these systems in 2005.
 Lower Limit of Detection
   
   
 Has the LLD for the Integrated Waste Assay System Z-390-100 and Z-390-101 been determined? Is the LLD determination appropriate for the types of TRU waste the AMWTP expects to assay on the Integrated Waste Assay System Z-390-100 and Z-390-101? Is the technical basis for the LLD determination documented?
                                       Y
LLDs are determined for each assay modality measurement. Nominal values are reported in the SATRs CI-IDA-NDA-0053 and CI-IDA-NDA-0054 for Z-390-100 and Z-390-101, respectively.
 Are the Integrated Waste Assay System Z-390-100 and Z-390-101 used to discriminate TRU/Non-TRU wastes at the 100 nCi/g criterion? If so, do the Integrated Waste Assay System Z-390-100 and Z-390-101 have the required sensitivity? 
                                       Y
Both Z-390 systems are used to perform TRU/Non-TRU waste discrimination, and both have an LLD no greater than 100 nCi/g. SATRs CI-IDA-NDA-0053 and CI-IDA-NDA-0054 for Z-390-100 and Z-390-101, respectively.
 Are there any instances where an LLD value for a non-measured radionuclide is not provided based on a lack of technical feasibility?
                                      NA
Not applicable
 PDP Participation
   

 Have the Integrated Waste Assay System Z-390-100 and Z-390-101 participated successfully in the CBFO NDA PDP? If so, identify the last cycle.
                                       Y
The AMWTP successfully participated in drum Cycle 24A. This was confirmed in a June and September 2017 memo from CBFO.
 Training


 Do all operators have current CCP training as verified on an LOQI?
                                       Y
The electronic LOQI equivalent was provided to the EPA. All operators have current training.
 Are Integrated Waste Assay System Z-390-100 and Z-390-101 data reviewed and approved by qualified personnel? If so, identify the name of the individuals performing technical review and approval of Integrated Waste Assay System Z-390-100 and Z-390-101 BDRs.
                                       Y
NDA BDRs that were evaluated contain evidence of appropriate data validation as evidenced by signatures.
In the BDRs reviewed by the EPA, data review was performed by R. Hammon and M. Woodbury.
 Replicate Testing


 Have replicate testing of the Integrated Waste Assay System Z-390-100 and Z-390-101 been performed, and does it meet the EPA Replicate Testing Protocol?
                                       Y
Replicate testing was not done on the in-plant systems due to the process differences that involve compacting drums post-assay.


Nondestructive Assay Baseline Inspection Checklist:
Retrieval Box Assay System (RBAS)
EPA Inspection No.: AMWTP-Fluor 08.17-8	Inspection Date: August 8 - 10, 2017
                           Technical Element/Aspect
                                  Yes, No, NA
                        Comments and Objective Evidence
 General System Attributes
   
   
 Is the NDA system the Retrieval Box Assay System? Where is it located?
                                       Y
EPA inspectors confirmed that the RBAS is located at the AMWTP in Building WMF-634, and is designated as Instrument No. Z-212-105. It has been operational for Non-WIPP assays since 2004 and began WIPP assays in April 2015.
 Describe the Retrieval Box Assay System. 
                                       Y
The RBAS is an imaging PN-AN measurement system supplemented by an HPGe gamma detection system. The passive and/or active neutron data are used in conjunction with gamma-based isotopic determinations using PC-FRAM to quantify specific radionuclides and/or determine an item's FGE. Isotopic information can also be provided by approved AK. Integration of the neutron and isotopic data for each item is performed off line by the RBAS WIPP Analysis Reporting Software for Expert Analysis (RWARS-EA).
 System Performance
   
   
 Are the container types, types of TRU waste, and the operational parameters for the Retrieval Box Assay System defined and reasonable? 
                                       Y
The RBAS can assay all matrices within the system's MOD and ABSMOD ranges, including debris, soils and gravel, and homogeneous solid wastes in SWBs, FRP and shredder boxes. SWBs containing four 55-gallon drums of sludge are also acceptable
 How many waste containers were assayed at-risk by the Retrieval Box Assay System?
                                       Y
The RBAS assayed 246 containers since June 2016, only 8 of which were WIPP assays.
 Is the Retrieval Box Assay System able to report quantitative values and uncertainties for the WIPP-tracked radionuclides?
                                       Y
Direct Measurements: [239]Pu, [238]Pu, [237]Np, [241]Am, [233]U, [235]U, [238]U and [137]Cs.
Nuclides by Scaling: [90]Sr, [234]U, [242]Pu and other isotopic ratios are determined using FRAM software, or approved AK, with active or passive neutron measurements.
Confirmed with NDA personnel during inspection.
 Have background measurements been taken each operational day? Have any instances of problematic background radiation been documented?
                                       Y
Background measurements are required in TPR-8095, Revision 4. Evidence of daily background measurements was seen in RBAS BDRs and in the electronic operational log observed in the RBAS control room. Background does fluctuate due to storage of drums and boxes of nuclear material in Building WMF-634. This expected due to movement of containers in and out of WMF-634. 
 Have system performance checks been completed at least once per operational day? Are the procedures for the performance checks technically adequate for the Retrieval Box Assay System, including gamma matrix correction checks, and gamma peak position and resolution checks?
                                       Y
Performance measurements are required in CCP-TP-107. Evidence of daily performance checks was seen in the RBAS BDRs reviewed and in the electronic operational log observed in the RBAS control room. The EPA reviewed electronic entries from the RBAS operational logbook, and all entries showed that performance checks had been performed and were acceptable.
 System Calibration & Calibration Verifications
   
   
 Does the Retrieval Box Assay System have a calibration of record? Were consensus standards used in the initial calibration? If so, which standards?
                                       Y
The RBAS was initially calibrated at BII Offices in Nashville, TN, in 2001, for AN and PN assay modes. FRAM does not require an efficiency calibration.
 Are the calibration, execution of performance checks and operation of the Retrieval Box Assay System, the calculation of radionuclide values and the review/validation of Retrieval Box Assay System data governed by controlled-copy (formal) procedures?
                                       Y
The EPA reviewed all source certificates found in Calibration Confirmation Report, PSC-5431-CRR-001, AMWTP Retrieval Box Assay System. All standards are traceable to the national standards base and are acceptable to use for the RBAS calibration and calibration confirmation. All Pu, DU and [252]Cf standards are adequate and appropriately documented.
 Are the current revisions of procedures in use for the Retrieval Box Assay System?
                                       Y
AMWTP Procedure Box Assay Post-Maintenance Calibration and Verification, INST-TRUW-8.1.3; AMWTP Procedure Box Assay Operations, INST-OI-15. 
These procedures are current, and copies of each were found and easily accessible in the RBAS control room or accessible electronically.
 Are the isotopic contributions of unmeasured radionuclides derived using a certain method?
                                       Y
[241]Am and Pu isotopics are determined by FRAM software or site-approved AK for default isotopics. Confirmed with AMWTP NDA personnel during evaluation.
 Were traceable radionuclide sources used for calibration confirmation and/or verifications? If so, list or reference all standards used.
                                       Y
The EPA reviewer verified the traceability of all sources listed in the calibration confirmation report.
 Have the operational ranges with respect to matrix (density) and activity been determined for the Retrieval Box Assay System? 
                                       Y
Calibration Confirmation Report, PSC-5431-CRR-001, AMWTP Retrieval Box Assay System 
Passive Mode: SWBs, FRPs and shredder boxes  -  1.07 <= MOD <= 12.48 
Active Mode: SWBS  -  0.91 <= ABSMOD <= 9.53 
Active Mode: FRPs and shredder boxes  -  1.82 <= ABSMOD <= 19.06
 Has a calibration verification been completed for the Retrieval Box Assay System? 
                                       Y
There have been no major component changes since the date of the last EPA inspection.
 Does the Retrieval Box Assay System meet the requirements for accuracy and precision as specified in DOE/WIPP-02-3122, Appendix A, Table A-2 for calibration verifications?
                                       Y
Calibration Confirmation Report, PSC-5431-CRR-001, AMWTP Retrieval Box Assay System. All criteria for accuracy and precision were met for active and passive neutron calibration confirmations.
 Have any NCRs related to the Retrieval Box Assay System been issued since the last EPA Continued Compliance inspection?
                                       Y
There have been no system NCRs pertinent to WIPP assays.
 Do the BDRs contain:
 Testing facility name, testing batch number, container numbers, and signature of the SPM or designee?
 Table of contents?
 Background and performance check data or control charts for the relevant time period?
 Separate testing report sheets for each container?
                                       Y
The EPA reviewed Retrieval Box Assay System BDR No. BSY17-00036 and found it to contain all appropriate information.
 Do the RDSs include:
 Method/procedure used?
 Date of radioassay?
 Activities and associated TMU for individual radionuclides?
 TRU alpha concentration and its associated TMU?
 Operator and reviewer signatures?
                                       Y
The RDSs in RBAS BDR No. BSY17-00036 that EPA reviewed contained all appropriate information.
 Total Measurement Uncertainty
   
   
 Is the magnitude of the TMU values observed in the Retrieval Box Assay System BDRs examined during the inspection within the expected range?
                                       Y
The TMU for the RBAS is documented in BII-5112-TMU-001, Revision 2. The EPA evaluated TMU values in RBAS BDR No. BSY17-00036, and the TMU values were within the expected range in all instances.
 Lower Limit of Detection
   
   
 Has the LLD for the Retrieval Box Assay System has been determined? Is the LLD determination appropriate for the types of TRU waste the AMWTP expects to assay on the Retrieval Box Assay System? Is the technical basis for the LLD determination documented?
                                       Y
Calibration Confirmation Report, PSC-5431-CRR-001, AMWTP Retrieval Box Assay System; Calibration Confirmation Plan, PSC-5431-CP-001, AMWTP Retrieval Box Assay System. MDAs are variable and depend on background, matrix and container type. The AMWTP provided example neutron MDCs for a variety of matrices covered by MOD and ABSMOD ranges.
 Is the Retrieval Box Assay System used to discriminate TRU/Non-TRU wastes at the 100 nCi/g criterion? If so, does the Retrieval Box Assay System have the required sensitivity? 
                                       Y
Calibration Confirmation Report, PSC-5431-CRR-001, AMWTP Retrieval Box Assay System; Calibration Confirmation Plan, PSC-5431-CP-001, AMWTP Retrieval Box Assay System
 Are there any instances where an LLD value for a non-measured radionuclide is not provided based on a lack of technical feasibility?
                                       Y
Calibration Confirmation Report, PSC-5431-CRR-001, AMWTP Retrieval Box Assay System; Calibration Confirmation Plan, PSC-5431-CP-001, AMWTP Retrieval Box Assay System
LLDs for non-measured radionuclides are ratioed to Pu or Am via approved AK.
 PDP Participation
   

 Has the Retrieval Box Assay System participated successfully in the CBFO NDA PDP? If so, identify the last cycle.
                                       Y
The RBAS successfully participated in the October 6, 2016, box Cycle B16A, as documented in the CBFO memo dated October 20, 2016.
 Training


 Do all operators have current CCP training as verified on an LOQI?
                                       Y
All operators have current training as verified on the out-of-plant LOQI equivalent.
 Are Retrieval Box Assay System data reviewed and approved by qualified personnel? If so, identify the name of the individuals performing technical review and approval of Retrieval Box Assay System BDRs.
                                       Y
In the BDRs reviewed by EPA, data review was performed by N. Stoner and S. Boudreau.
 Replicate Testing


 Has replicate testing of the Retrieval Box Assay System been performed, and does it meet the EPA Replicate Testing Protocol?
                                      NA
No replicates were selected for assay on the RBAS for this baseline inspection.


Nondestructive Assay Baseline Inspection Checklist:
Waste Assay Gamma Spectrometer (WAGS)
EPA Inspection No.: AMWTP-Fluor 08.17-8	Inspection Date: August 8 - 10, 2017
                           Technical Element/Aspect
                                  Yes, No, NA
                        Comments and Objective Evidence
 General System Attributes
   
   
 Is the NDA system the Waste Assay Gamma System? Where is it located?
                                       
The WAGS is located in Building WMF-610 at the Radioactive Waste Management Complex at INL, in the same location as when it was evaluated during previous EPA inspections.
 Describe the Waste Assay Gamma System. 
                                       
The WAGS is a standard Canberra IQ3 Assay System gamma system and consists of six high-resolution BEGe gamma detectors, a drum turntable, shielded enclosure, and supporting electronics. The six gamma detectors are arranged in two groups of three, the North bank and the West bank; the detectors in each group are aligned vertically (i.e., aligned to one central vertical axis). The North bank detectors (North top, North middle and North bottom) acquire spectra for quantitative analyses. Under the supplemental calibration, each of the North bank detectors is fitted with a removable filter made of 3 mm Pb, 3 mm Cd, and a thin layer of Cu with the Cu layer closest to the detector. These filters reduce dead time. The North bank detectors are positioned 180 degrees from a set of three [1][33]Ba sources that are used for matrix density corrections. Spectra are acquired simultaneously and represent the upper, middle and lower segments of the drum volume. Data may be individually transmission-corrected to compensate for density, or they may be summed and analyzed against a multi-curve efficiency when the density prohibits sufficient transmission of the [133]Ba photons. The West bank detectors (West top, West middle and West bottom) acquire spectra for isotopic analyses and are positioned 90 degrees relative to the North bank. Under the supplemental calibration, each of the West bank detectors has been fitted with a 32 mm Cd filter.
 System Performance
   
   
 Are the container types, types of TRU waste and the operational parameters for the Waste Assay Gamma System defined and reasonable? 
                                       
The WAGS is capable of assaying all matrices within the system's ranges. 
 How many waste containers (and number of BDRs) were assayed at-risk by the Waste Assay Gamma System?
                                       
The Waste Assay Gamma System assayed 3,651 containers between June 1, 2016, and the inspection date. These containers all are assayed under the presumption that they are TRU wastes; however, some containers do not meet the TRU criteria. 
 Is the Waste Assay Gamma System able to report quantitative values and uncertainties for the WIPP-tracked radionuclides?
                                       
Direct Measurements: [239]Pu, [238]Pu, [240]Pu, [241]Am, [237]Np, [233]U, [235]U, [238]U and [137]Cs.
The [242]Pu content is determined using the correlation technique of Gunnik that has been evaluated previously on NDA systems at INL and other TRU waste characterization facilities. Radionuclides by Scaling: [90]Sr and [234]U. Confirmed with NDA personnel during inspection.
 Have background measurements been taken each operational day? Have any instances of problematic background radiation been documented?
                                       
Evidence of daily background measurements was seen in WAGS BDRs and in the electronic operational log observed in the WAGS control room.
 Have system performance checks been completed at least once per operational day? Are the procedures for the performance checks technically adequate for the Waste Assay Gamma System, including gamma matrix correction checks and gamma peak position and resolution checks?
                                       
System performance checks are completed between each assay, as witnessed during the inspection.
 System Calibration & Calibration Verifications
   
   
 Does the Waste Assay Gamma System have a calibration of record? Were consensus standards used in the initial calibration? If so, which standards?
                                       
The calibration is documented in CCP-INL-WAGS-001 and its attachments. Consensus standards ASTM C-1030, C-1133, C-1215 and E-181 pertain to the WAGS.
 Are the calibration, execution of performance checks and operation of the Waste Assay Gamma System, the calculation of radionuclide values and the review/validation of Waste Assay Gamma System data governed by controlled-copy (formal) procedures?
                                       
The EPA reviewed all source certificates. All standards are traceable to the national standards base and are acceptable to use for the WAGS calibration and calibration confirmation. All standards are technically adequate and appropriately documented.
 Are the current revisions of procedures in use for the Waste Assay Gamma System?
                                       
CCP-TP-019, CCP Waste Assay Gamma Spectrometer (WAGS) Operating Procedure. 
The operating procedure is current, and a copy was found and easily accessible at the Waste Assay Gamma System control room.
 Have the operational ranges with respect to matrix (density) and activity been determined for the Waste Assay Gamma System? 
                                       
Density range 0.02 to 2.1 g/cm[3]; energy range 59 - 1,408 keV.
For North detectors: density range 0.02 to 0.66 g/cm[3]; energy range 122 - 1,408 keV
 Has a calibration verification been completed for the Waste Assay Gamma System? If so, what is the date of the last calibration verification? Have any others been completed in the last year?
                                       Y
A calibration versification was completed in August 2016 following the replacement of two detectors. This is documented appropriately in an AMWTP Work Order.
 Does the Waste Assay Gamma System meet the requirements for accuracy and precision as specified in DOE/WIPP-02-3122, Appendix A, Table A-2 for calibration verifications?
                                       Y
All criteria for accuracy and precision were met.
 Have any NCRs related to the Waste Assay Gamma System been issued since the last EPA Continued Compliance inspection?
                                       Y
No system-wide NRCs have been issued for the WAGS since 2016.
 Do the BDRs contain:
 Testing facility name, testing batch number, container numbers, and signature of the SPM or designee?
 Table of contents?
 Background and performance check data or control charts for the relevant time period?
 Separate testing report sheets for each container?
                                       Y
The EPA reviewed WAGS BDRs to verify that they contain all appropriate information.
 Do the RDSs include:
 Method/procedure used?
 Date of radioassay?
 Activities and associated TMU for individual radionuclides?
 TRU alpha concentration and its associated TMU?
 Operator and reviewer signatures?
                                       Y
The EPA reviewed several WAGS BDRs and found that their RDSs contain appropriate information.
 Total Measurement Uncertainty
   
   
 Is the magnitude of the TMU values observed in the Waste Assay Gamma System BDRs examined during the inspection within the expected range?
                                       
WAGS TMU determination is documented in CCP-INL-WAGS-0024, Total Measurement Uncertainty for the Waste Assay Gamma System, April 20, 2005. This document does not have a revision number, EPA determined that there were no changes to the WAGS TMU as a result of this supplemental calibration.
 Lower Limit of Detection
   
   
 Has the LLD for the Waste Assay Gamma System has been determined? Is the LLD determination appropriate for the types of TRU waste the AMWTP expects to assay on the Waste Assay Gamma System? Is the technical basis for the LLD determination documented?
                                       
LLD values for the 10 WIPP-tracked radionuclides and [235]U were calculated, and each result was divided by the net matrix weight to derive an MDC in nCi/g. LLD results in CCP-INL-WAGS-002, Tables 8a, 8b, 8c, 9a, 9b and 9c for the three matrix types. Typical reporting thresholds for radionuclides not directly measured are shown in CCP-INL-WAGS-08-003, Table 8.
 Is the Waste Assay Gamma System used to discriminate TRU/Non-TRU wastes at the 100 nCi/g criterion? If so, does the Waste Assay Gamma System have the required sensitivity? 
                                       
The WAGS is used to discriminate TRU and non-TRU wastes, which requires a system LLD to be 100 nanocuries of TRU alpha activity per gram (nCi/g) of waste.
 Are there any instances where an LLD value for a non-measured radionuclide is not provided based on a lack of technical feasibility?
                                       
[234]U is derived from measured values [235]U and [238]U, and AMWTP states it is not technically feasible to determine a unique reporting threshold.
CCP-INL-WAGS-001, Revision 1, WAGS Calibration, Conformation, and Verification Report; CCP-INL-08-002, Revision 0, Wags Multi-Curve Efficiency Calibration Extension Addendum; CCP-INL-WAGS-003, Revision 0, WAGS Calibration, Confirmation, & Verification Report
 PDP Participation
   

 Has the Waste Assay Gamma System participated successfully in the CBFO NDA PDP? If so, identify the last cycle.
                                       
The WAGS successfully participated in CBFO PDP drum Cycle 24A, as documented in the CCP memo provided by AMWTP personnel. 
 Training


 Do all operators have current CCP training as verified on an LOQI?
                                       Y
All operators have current training as versified in the LOQI-equivalent document provided by AMWTP personnel.
 Are Waste Assay Gamma System data reviewed and approved by qualified personnel? If so, identify the name of the individuals performing technical review and approval of Waste Assay Gamma System BDRs.
                                       Y
In the BDRs reviewed by EPA, data review was performed by J. Law and W. Davis.
 Replicate Testing


 Has replicate testing of the Waste Assay Gamma System been performed, and does it meet the EPA Replicate Testing Protocol?
                                      NA
For logistical reasons the EPA elected not to require replicates from the WAGS during this inspection.


Nondestructive Assay Baseline Inspection Checklist:
SWEPP Gamma-Ray Spectrometer
EPA Inspection No.: AMWTP-Fluor 08.17-8	Inspection Date: August 8 - 10, 2017
                           Technical Element/Aspect
                                  Yes, No, NA
                        Comments and Objective Evidence
 General System Attributes
   
   
 Is the NDA system the SWEPP Gamma-Ray Spectrometer? Where is it located?
                                       Y
EPA inspectors confirmed that the SWEPP Gamma-Ray Spectrometer is located at Building WMF-610 at the INL Radioactive Waste Management Complex.
 Describe the SWEPP Gamma-Ray Spectrometer. 
                                       Y
SWEPP Gamma-Ray Spectrometer uses four high-resolution BEGe gamma detectors for quantitative gamma analysis. Gamma spectra are acquired; the peaks are summed and corrected for attenuation using a multi-curve calibration that computes efficiency as a function of waste density and gamma energy. A pulser performs live time corrections.
 System Performance
   
   
 Are the container types, types of TRU waste and the operational parameters for the SWEPP Gamma-Ray Spectrometer defined and reasonable? 
                                       Y
The SWEPP Gamma-Ray Spectrometer is capable of assaying all matrices within the system's ranges, i.e., debris, soil/gravel and solids.
 How many waste containers (and number of BDRs) were assayed at-risk by the SWEPP Gamma-Ray Spectrometer?
                                       Y
The SGRS has assayed 7,395 containers since June 2016. All containers were assumed to be TRU, some fell out as non-TRU post-assay. Exact numbers were not easily available at the time of inspection.
 Is the SWEPP Gamma-Ray Spectrometer able to report quantitative values and uncertainties for the WIPP-tracked radionuclides?
                                       Y
Direct Measurements: [239]Pu, [241]Am, [233]U, [235]U, [238]U and [137]Cs.
Isotopic Fractions: [238]Pu, [240]Pu, [241]Pu, [242]Pu by correlation and [241]Am relative to Pu.
Nuclides by Scaling: [90]Sr and [234]U.
Confirmed with SGRS NDA personnel during inspection.
 Have background measurements been taken each operational day? Have any instances of problematic background radiation been documented?
                                       Y
Background measurements are required in TPR-8092, Revision 3. Evidence of daily background measurements was seen in SGRS BDRs and electronic operational log observed in the SGRS control room.
 Have system performance checks been completed at least once per operational day? Are the procedures for the performance checks technically adequate for the SWEPP Gamma-Ray Spectrometer, including gamma matrix correction checks and gamma peak position and resolution checks?
                                       Y
The SGRS is standardized between each assay, as witnessed during inspection.
 System Calibration & Calibration Verifications
   
   
 Does the SWEPP Gamma-Ray Spectrometer have a calibration of record? Were consensus standards used in the initial calibration? If so, which standards?
                                       Y
The SWEPP Gamma-Ray Spectrometer was last recalibrated following the replacement of Detector No. 4, as documented in AMWTP work order. Consensus standards ASTM C-1030, C-1133, C-1215 and E-181 pertain to the SGRS calibration, documented in CCP-INL-SGRS-001, SWEPP Gamma-Ray Spectrometer (SGRS) Calibration, Confirmation and Verification Report.
 Are the calibration, execution of performance checks and operation of the SWEPP Gamma-Ray Spectrometer, the calculation of radionuclide values and the review/validation of SWEPP Gamma-Ray Spectrometer data governed by controlled-copy (formal) procedures?
                                       Y
The EPA reviewed all source certificates in TPR-7996. All standards are traceable to the national standards base and are acceptable to use for the SGRS calibration and calibration confirmation. All standards are technically adequate and appropriately documented.
 Are the current revisions of procedures in use for the SWEPP Gamma-Ray Spectrometer?
                                       Y
Operating Procedure, Calibration Procedure, and Data Validation Procedure. All changes are documented in CCP-INL-SGRS-001, SWEPP Gamma-Ray Spectrometer (SGRS) Calibration, Confirmation and Verification Report. Procedures are current and copies of each were found in the SGRS control room.
 Were traceable radionuclide sources used for calibration confirmation and/or verifications? If so, list or reference all standards used.
                                       Y
CCP-INL-SGRS-001, SWEPP Gamma-Ray Spectrometer (SGRS) Calibration, Confirmation and Verification Report, Revision 2, November 14, 2012.
 Have the operational ranges with respect to matrix (density) and activity been determined for the SWEPP Gamma-Ray Spectrometer? 
                                       Y
Range ~0.010 g to 200 g Total Pu (calibration-based and administrative). Limited by LLD and system dead-time. Calibration assumes that the matrices are mainly Z < 15, which includes debris, soil/gravel and solids. Waste matrices outside range and/or presence of denser materials (Z>15) require expert review.
 Has a calibration verification been completed for the SWEPP Gamma-Ray Spectrometer? If so, what is the date of the last calibration verification? Have any others been completed in the last year?
                                       Y
A calibration verification was completed following the replacement of detector 4. The AMWTP work order associated with this verification was provided to the EPA reviewers.
 Does the SWEPP Gamma-Ray Spectrometer meet the requirements for accuracy and precision as specified in DOE/WIPP-02-3122, Appendix A, Table A-2 for calibration verifications?
                                       Y
As documented in CCP-INL-SGRS-001, Revision 2, SWEPP Gamma-Ray Spectrometer (SGRS) Calibration, Confirmation, and Verification Report, Revision 2, dated November 14, 2012; and INST-TRUW-8.1.4, Waste Assay Gamma Spectrometer/SWEPP Gamma-Ray Spectrometer Post-Maintenance Calibration and Verification.
 Have any NCRs related to the SWEPP Gamma-Ray Spectrometer been issued since the last EPA Continued Compliance inspection?
                                       Y
A list of Type 1 NCRs was provided to the EPA during the inspection.
 Do the BDRs contain:
 Testing facility name, testing batch number, container numbers, and signature of the SPM or designee?
 Table of contents?
 Background and performance check data or control charts for the relevant time period?
 Separate testing report sheets for each container?
                                       Y
The EPA reviewed SGRS BDRs to confirm they contain all appropriate information.
 Do the RDSs include:
 Method/procedure used?
 Date of radioassay?
 Activities and associated TMU for individual radionuclides?
 TRU alpha concentration and its associated TMU?
 Operator and reviewer signatures?
                                       Y
The EPA reviewed SWEPP Gamma-Ray Spectrometer BDRs to confirm they contain RDSs with all appropriate information.
 Total Measurement Uncertainty
   
   
 Is the magnitude of the TMU values observed in the SWEPP Gamma-Ray Spectrometer BDRs examined during the inspection within the expected range?
                                       Y
The TMU for the SGRS is documented in CCP-INL-SGRS-002, Total Measurement Uncertainty for the SGRS Assay System, dated April 21, 2005.
 Lower Limit of Detection
   
   
 Has the LLD for the SWEPP Gamma-Ray Spectrometer has been determined? Is the LLD determination appropriate for the types of TRU waste the AMWTP expects to assay on the SWEPP Gamma-Ray Spectrometer? Is the technical basis for the LLD determination documented?
                                       Y
Reporting thresholds for [90]Sr and other radionuclides are determined and documented appropriately. 
 Is the SWEPP Gamma-Ray Spectrometer used to discriminate TRU/Non-TRU wastes at the 100 nCi/g criterion? If so, does the SWEPP Gamma-Ray Spectrometer have the required sensitivity? 
                                       Y
TRU discrimination is regularly done on the instrument, as evidenced by the large number of drums that fall out as non-TRU (typically these are LLW).
 Are there any instances where an LLD value for a non-measured radionuclide is not provided based on a lack of technical feasibility?
                                       Y
A reporting threshold for [234]U is not determined, based on the AMWTP's statement that it "is not technically feasible to determine a unique reporting threshold for [234]U," a technical position supported by DOE/WIPP-02-31224.
 PDP Participation
   

 Has the SWEPP Gamma-Ray Spectrometer participated successfully in the CBFO NDA PDP? If so, identify the last cycle.
                                       Y
The SGRS last successfully participated in the CBFO PDP drum Cycle 24A. Evidence of this was provided to EPA inspectors.
 Training


 Do all operators have current CCP training as verified on an LOQI?
                                       Y
All operators have current training as verified in the out-of-plant LOQI-equivalent document.
 Are SWEPP Gamma-Ray Spectrometer data reviewed and approved by qualified personnel? If so, identify the name of the individuals performing technical review and approval of SWEPP Gamma-Ray Spectrometer BDRs.
                                       Y
In the BDRs reviewed by the EPA, data review was performed by J. Law and B. Dial.
 Replicate Testing


 Has replicate testing of the SWEPP Gamma-Ray Spectrometer been performed, and does it meet the EPA Replicate Testing Protocol?
                                       Y
EPA inspectors selected Drum Nos. 10566849, 10565693 and 10568514.


Replicate Testing Data for Container No. 10565693  - 
SWEPP Gamma-Ray Spectrometer
Quantity of Interest
                             Original Measurement
                                 Replicate #1
                                 Replicate #2

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       1.19E-05
                                                                       7.46E-06
                                                                          62.7%
                                                                       9.62E-06
                                                                       6.01E-06
                                                                          62.5%
                                                                       8.54E-06
                                                                       5.34E-06
                                                                          62.5%
[235]U Activity (Ci)
                                                                       3.77E-07
                                                                       1.59E-07
                                                                          42.1%
                                                                       3.05E-07
                                                                       1.31E-07
                                                                          42.8%
                                                                       2.71E-07
                                                                       1.20E-07
                                                                          44.1%
[237]Np Activity (Ci)
                                                                       1.70E-06
                                                                       6.48E-07
                                                                          38.1%
                                                                       1.57E-06
                                                                       5.93E-07
                                                                          37.8%
                                                                       1.62E-06
                                                                       6.12E-07
                                                                          37.8%
[238]Pu Activity (Ci)
                                                                       1.03E-03
                                                                       5.53E-04
                                                                          53.7%
                                                                       1.11E-03
                                                                       5.95E-04
                                                                          53.6%
                                                                       1.08E-03
                                                                       5.78E-04
                                                                          53.5%
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       3.82E-02
                                                                       1.45E-02
                                                                          37.9%
                                                                       4.14E-02
                                                                       1.56E-02
                                                                          37.7%
                                                                       4.03E-02
                                                                       1.51E-02
                                                                          37.5%
[240]Pu Activity (Ci)
                                                                       8.50E-03
                                                                       3.30E-03
                                                                          38.8%
                                                                       9.20E-03
                                                                       3.55E-03
                                                                          38.6%
                                                                       8.96E-03
                                                                       3.45E-03
                                                                          38.5%
[241]Am Activity (Ci)
                                                                       6.62E-02
                                                                       2.56E-02
                                                                          38.6%
                                                                       6.81E-02
                                                                       2.59E-02
                                                                          38.0%
                                                                       6.47E-02
                                                                       2.45E-02
                                                                          37.9%
[241]Pu Activity (Ci)
                                                                       5.11E-02
                                                                       2.15E-02
                                                                          42.1%
                                                                       5.30E-02
                                                                       2.23E-02
                                                                          42.0%
                                                                       5.17E-02
                                                                       2.16E-02
                                                                          41.8%
[242]Pu Activity (Ci)
                                                                       1.11E-06
                                                                       7.06E-07
                                                                          63.6%
                                                                       1.21E-06
                                                                       7.68E-07
                                                                          63.5%
                                                                       1.17E-06
                                                                       7.42E-07
                                                                          63.4%
TRU Alpha Conc. (nCi/g)
                                                                          1,012
                                                                            263
                                                                          26.0%
                                                                          1,066
                                                                            270
                                                                          25.3%
                                                                          1,021
                                                                            258
                                                                          25.3%

Quantity of Interest
                                 Replicate #3
                                 Replicate #4
                                 Replicate #5

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       1.41E-06
                                                                       8.81E-07
                                                                          62.5%
                                                                       1.03E-05
                                                                       6.44E-06
                                                                          62.5%
                                                                       8.53E-06
                                                                       5.33E-06
                                                                          62.5%
[235]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       3.27E-07
                                                                       1.35E-07
                                                                          41.3%
                                                                       2.71E-07
                                                                       1.18E-07
                                                                          43.5%
[237]Np Activity (Ci)
                                                                       1.62E-06
                                                                       6.12E-07
                                                                          37.8%
                                                                       1.54E-06
                                                                       5.84E-07
                                                                          37.9%
                                                                       1.62E-06
                                                                       6.12E-07
                                                                          37.8%
[238]Pu Activity (Ci)
                                                                       1.11E-03
                                                                       5.94E-04
                                                                          53.5%
                                                                       1.09E-03
                                                                       5.83E-04
                                                                          53.5%
                                                                       1.05E-03
                                                                       5.62E-04
                                                                          53.5%
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       4.16E-02
                                                                       1.56E-02
                                                                          37.5%
                                                                       4.08E-02
                                                                       1.53E-02
                                                                          37.5%
                                                                       3.93E-02
                                                                       1.47E-02
                                                                          37.5%
[240]Pu Activity (Ci)
                                                                       9.24E-03
                                                                       3.55E-03
                                                                          38.4%
                                                                       9.07E-03
                                                                       3.49E-03
                                                                          38.5%
                                                                       8.74E-03
                                                                       3.36E-03
                                                                          38.5%
[241]Am Activity (Ci)
                                                                       6.37E-02
                                                                       2.43E-02
                                                                          38.2%
                                                                       7.06E-02
                                                                       2.68E-02
                                                                          37.9%
                                                                       6.66E-02
                                                                       2.53E-02
                                                                          38.0%
[241]Pu Activity (Ci)
                                                                       5.33E-02
                                                                       2.23E-02
                                                                          41.8%
                                                                       5.23E-02
                                                                       2.19E-02
                                                                          41.8%
                                                                       5.04E-02
                                                                       2.11E-02
                                                                          41.9%
[242]Pu Activity (Ci)
                                                                       1.21E-06
                                                                       7.67E-07
                                                                          63.4%
                                                                       1.19E-06
                                                                       7.54E-07
                                                                          63.4%
                                                                       1.15E-06
                                                                       7.30E-07
                                                                          63.5%
TRU Alpha Conc. (nCi/g)
                                                                          1,030
                                                                            258
                                                                          25.0%
                                                                          1,084
                                                                            275
                                                                          25.4%
                                                                          1,030
                                                                            262
                                                                          25.4%

Quantity of Interest
                             Original Measurement
                                  Sample Mean
                           Sample Standard Deviation
                          Relative Standard Deviation
                                      [2]
                                Pr(x <|[2]|)
                                       t
                                 Pr(x <|t|)

                                Reported Value
                             Absolute Uncertainty
                                       
                                       
                                       
                                       
                                       
                                       
                                       
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[234]U Activity (Ci)
                                                                       1.19E-05
                                                                       7.46E-06
                                                                       7.68E-06
                                                                       3.58E-06
                                                                          46.7%
                                                                          0.923
                                                                          0.921
                                                                          1.075
                                                                          0.343
[235]U Activity (Ci)
                                                                       3.77E-07
                                                                       1.59E-07
                                                                       2.35E-07
                                                                       1.33E-07
                                                                          56.8%
                                                                          2.826
                                                                          0.587
                                                                          0.973
                                                                          0.386
[237]Np Activity (Ci)
                                                                       1.70E-06
                                                                       6.48E-07
                                                                       1.59E-06
                                                                       3.71E-08
                                                                           2.3%
                                                                          0.013
                                                                          1.000
                                                                          2.605
                                                                          0.060
[238]Pu Activity (Ci)
                                                                       1.03E-03
                                                                       5.53E-04
                                                                       1.09E-03
                                                                       2.49E-05
                                                                           2.3%
                                                                          0.008
                                                                          1.000
                                                                         -2.126
                                                                          0.101
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       3.82E-02
                                                                       1.45E-02
                                                                       4.07E-02
                                                                       9.26E-04
                                                                           2.3%
                                                                          0.016
                                                                          1.000
                                                                         -2.446
                                                                          0.071
[240]Pu Activity (Ci)
                                                                       8.50E-03
                                                                       3.30E-03
                                                                       9.04E-03
                                                                       2.02E-04
                                                                           2.2%
                                                                          0.015
                                                                          1.000
                                                                         -2.452
                                                                          0.070
[241]Am Activity (Ci)
                                                                       6.62E-02
                                                                       2.56E-02
                                                                       6.67E-02
                                                                       2.75E-03
                                                                           4.1%
                                                                          0.046
                                                                          1.000
                                                                         -0.179
                                                                          0.866
[241]Pu Activity (Ci)
                                                                       5.11E-02
                                                                       2.15E-02
                                                                       5.21E-02
                                                                       1.15E-03
                                                                           2.2%
                                                                          0.012
                                                                          1.000
                                                                         -0.822
                                                                          0.457
[242]Pu Activity (Ci)
                                                                       1.11E-06
                                                                       7.06E-07
                                                                       1.19E-06
                                                                       2.61E-08
                                                                           2.2%
                                                                          0.005
                                                                          1.000
                                                                         -2.661
                                                                          0.056
TRU Alpha Conc. (nCi/g)
                                                                          1,012
                                                                            263
                                                                          1,046
                                                                             27
                                                                           2.6%
                                                                          0.043
                                                                          1.000
                                                                         -1.144
                                                                          0.317

Quantity of Interest
                                   [2] Test
                                    t-Test
[90]Sr Activity (Ci)
                                Not Applicable
                                Not Applicable
[137]Cs Activity (Ci)
                                Not Applicable
                                Not Applicable
[233]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[234]U Activity (Ci)
                                Not Significant
                                Not Significant
[235]U Activity (Ci)
                                Not Significant
                                Not Significant
[237]Np Activity (Ci)
                                Not Significant
                                Not Significant
[238]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[238]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[239]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[240]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[241]Am Activity (Ci)
                                Not Significant
                                Not Significant
[241]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[242]Pu Activity (Ci)
                                Not Significant
                                Not Significant
TRU Alpha Conc. (nCi/g)
                                Not Significant
                                Not Significant


Replicate Testing Data for Container No. 10566849  - 
SWEPP Gamma-Ray Spectrometer
                                       
Quantity of Interest
                             Original Measurement
                                 Replicate #1
                                 Replicate #2

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       1.35E-04
                                                                       8.68E-05
                                                                          64.3%
                                                                       1.45E-04
                                                                       9.29E-05
                                                                          64.1%
                                                                       1.29E-04
                                                                       8.27E-05
                                                                          64.1%
[235]U Activity (Ci)
                                                                       4.29E-06
                                                                       1.74E-06
                                                                          40.6%
                                                                       4.60E-06
                                                                       1.85E-06
                                                                          40.2%
                                                                       4.10E-06
                                                                       1.65E-06
                                                                          40.2%
[237]Np Activity (Ci)
                                                                       5.67E-07
                                                                       2.38E-07
                                                                          42.0%
                                                                       5.48E-07
                                                                       2.28E-07
                                                                          41.6%
                                                                       4.91E-07
                                                                       2.08E-07
                                                                          42.3%
[238]Pu Activity (Ci)
                                                                       1.04E-03
                                                                       5.78E-04
                                                                          55.6%
                                                                       1.06E-03
                                                                       5.87E-04
                                                                          55.4%
                                                                       9.87E-04
                                                                       5.47E-04
                                                                          55.4%
[238]U Activity (Ci)
                                                                       1.66E-05
                                                                       7.01E-06
                                                                          42.2%
                                                                       1.70E-05
                                                                       7.34E-06
                                                                          43.2%
                                                                       1.55E-05
                                                                       6.73E-06
                                                                          43.4%
[239]Pu Activity (Ci)
                                                                       3.85E-02
                                                                       1.56E-02
                                                                          40.5%
                                                                       3.97E-02
                                                                       1.60E-02
                                                                          40.2%
                                                                       3.69E-02
                                                                       1.48E-02
                                                                          40.2%
[240]Pu Activity (Ci)
                                                                       8.57E-03
                                                                       3.55E-03
                                                                          41.4%
                                                                       8.83E-03
                                                                       3.62E-03
                                                                          41.0%
                                                                       8.21E-03
                                                                       3.37E-03
                                                                          41.1%
[241]Am Activity (Ci)
                                                                       2.05E-02
                                                                       8.77E-03
                                                                          42.8%
                                                                       3.16E-02
                                                                       1.31E-02
                                                                          41.5%
                                                                       2.08E-02
                                                                       9.26E-03
                                                                          44.5%
[241]Pu Activity (Ci)
                                                                       5.15E-02
                                                                       2.29E-02
                                                                          44.5%
                                                                       5.09E-02
                                                                       2.25E-02
                                                                          44.2%
                                                                       4.74E-02
                                                                       2.10E-02
                                                                          44.3%
[242]Pu Activity (Ci)
                                                                       1.12E-06
                                                                       7.31E-07
                                                                          65.3%
                                                                       1.16E-06
                                                                       7.54E-07
                                                                          65.0%
                                                                       1.08E-06
                                                                       7.03E-07
                                                                          65.1%
TRU Alpha Conc. (nCi/g)
                                                                            579
                                                                            154
                                                                          26.6%
                                                                            685
                                                                            177
                                                                          25.8%
                                                                            566
                                                                            150
                                                                          26.5%

Quantity of Interest
                                 Replicate #3
                                 Replicate #4
                                 Replicate #5

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       1.41E-04
                                                                       9.04E-05
                                                                          64.1%
                                                                       1.35E-04
                                                                       8.65E-05
                                                                          64.1%
                                                                       1.34E-04
                                                                       8.59E-05
                                                                          64.1%
[235]U Activity (Ci)
                                                                       4.48E-06
                                                                       1.80E-06
                                                                          40.2%
                                                                       4.27E-06
                                                                       1.72E-06
                                                                          40.2%
                                                                       4.24E-06
                                                                       1.71E-06
                                                                          40.3%
[237]Np Activity (Ci)
                                                                       5.03E-07
                                                                       2.12E-07
                                                                          42.2%
                                                                       5.09E-07
                                                                       2.13E-07
                                                                          41.8%
                                                                       5.61E-07
                                                                       2.34E-07
                                                                          41.8%
[238]Pu Activity (Ci)
                                                                       9.99E-04
                                                                       5.53E-04
                                                                          55.4%
                                                                       9.79E-04
                                                                       5.42E-04
                                                                          55.4%
                                                                       9.67E-04
                                                                       5.38E-04
                                                                          55.6%
[238]U Activity (Ci)
                                                                       1.92E-05
                                                                       7.99E-06
                                                                          41.6%
                                                                       1.58E-05
                                                                       6.81E-06
                                                                          43.1%
                                                                       1.72E-05
                                                                       7.24E-06
                                                                          42.1%
[239]Pu Activity (Ci)
                                                                       3.74E-02
                                                                       1.50E-02
                                                                          40.2%
                                                                       3.66E-02
                                                                       1.47E-02
                                                                          40.2%
                                                                       3.62E-02
                                                                       1.47E-02
                                                                          40.5%
[240]Pu Activity (Ci)
                                                                       8.31E-03
                                                                       3.42E-03
                                                                          41.1%
                                                                       8.14E-03
                                                                       3.34E-03
                                                                          41.0%
                                                                       8.05E-03
                                                                       3.33E-03
                                                                          41.4%
[241]Am Activity (Ci)
                                                                       1.78E-02
                                                                       8.15E-03
                                                                          45.8%
                                                                       2.89E-02
                                                                       1.18E-02
                                                                          41.0%
                                                                       2.43E-02
                                                                       1.04E-02
                                                                          42.6%
[241]Pu Activity (Ci)
                                                                       4.79E-02
                                                                       2.12E-02
                                                                          44.2%
                                                                       4.69E-02
                                                                       2.07E-02
                                                                          44.2%
                                                                       4.64E-02
                                                                       2.06E-02
                                                                          44.5%
[242]Pu Activity (Ci)
                                                                       1.09E-06
                                                                       7.10E-07
                                                                          65.1%
                                                                       1.07E-06
                                                                       6.97E-07
                                                                          65.1%
                                                                       1.05E-06
                                                                       6.86E-07
                                                                          65.3%
TRU Alpha Conc. (nCi/g)
                                                                            544
                                                                            148
                                                                          27.2%
                                                                            630
                                                                            162
                                                                          25.7%
                                                                            587
                                                                            154
                                                                          26.2%

Quantity of Interest
                             Original Measurement
                                  Sample Mean
                                       
                           Sample Standard Deviation
                          Relative Standard Deviation
                                      [2]
                                Pr(x <|[2]|)
                                       t
                                 Pr(x <|t|)

                                Reported Value
                             Absolute Uncertainty
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       

                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                               
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                               
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                               
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[234]U Activity (Ci)
                                                                       1.35E-04
                                                                       8.68E-05
                                                                       1.37E-04
                                                                               
                                                                       6.26E-06
                                                                           4.6%
                                                                          0.021
                                                                          1.000
                                                                         -0.262
                                                                          0.806
[235]U Activity (Ci)
                                                                       4.29E-06
                                                                       1.74E-06
                                                                       4.34E-06
                                                                               
                                                                       2.00E-07
                                                                           4.6%
                                                                          0.053
                                                                          1.000
                                                                         -0.219
                                                                          0.837
[237]Np Activity (Ci)
                                                                       5.67E-07
                                                                       2.38E-07
                                                                       5.22E-07
                                                                               
                                                                       3.04E-08
                                                                           5.8%
                                                                          0.065
                                                                          0.999
                                                                          1.341
                                                                          0.251
[238]Pu Activity (Ci)
                                                                       1.04E-03
                                                                       5.78E-04
                                                                       9.98E-04
                                                                               
                                                                       3.64E-05
                                                                           3.6%
                                                                          0.016
                                                                          1.000
                                                                          1.045
                                                                          0.355
[238]U Activity (Ci)
                                                                       1.66E-05
                                                                       7.01E-06
                                                                       1.69E-05
                                                                               
                                                                       1.46E-06
                                                                           8.6%
                                                                          0.174
                                                                          0.996
                                                                         -0.212
                                                                          0.842
[239]Pu Activity (Ci)
                                                                       3.85E-02
                                                                       1.56E-02
                                                                       3.74E-02
                                                                               
                                                                       1.38E-03
                                                                           3.7%
                                                                          0.031
                                                                          1.000
                                                                          0.754
                                                                          0.493
[240]Pu Activity (Ci)
                                                                       8.57E-03
                                                                       3.55E-03
                                                                       8.31E-03
                                                                               
                                                                       3.07E-04
                                                                           3.7%
                                                                          0.030
                                                                          1.000
                                                                          0.779
                                                                          0.479
[241]Am Activity (Ci)
                                                                       2.05E-02
                                                                       8.77E-03
                                                                       2.47E-02
                                                                               
                                                                       5.66E-03
                                                                          22.9%
                                                                          1.666
                                                                          0.797
                                                                         -0.674
                                                                          0.537
[241]Pu Activity (Ci)
                                                                       5.15E-02
                                                                       2.29E-02
                                                                       4.79E-02
                                                                               
                                                                       1.77E-03
                                                                           3.7%
                                                                          0.024
                                                                          1.000
                                                                          1.859
                                                                          0.137
[242]Pu Activity (Ci)
                                                                       1.12E-06
                                                                       7.31E-07
                                                                       1.09E-06
                                                                               
                                                                       4.18E-08
                                                                           3.8%
                                                                          0.013
                                                                          1.000
                                                                          0.655
                                                                          0.548
TRU Alpha Conc. (nCi/g)
                                                                            579
                                                                            154
                                                                            602
                                                                               
                                                                             56
                                                                           9.3%
                                                                          0.529
                                                                          0.971
                                                                         -0.381
                                                                          0.722

Quantity of Interest
                                   [2] Test
                                    t-Test
[90]Sr Activity (Ci)
                                Not Applicable
                                Not Applicable
[137]Cs Activity (Ci)
                                Not Applicable
                                Not Applicable
[233]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[234]U Activity (Ci)
                                Not Significant
                                Not Significant
[235]U Activity (Ci)
                                Not Significant
                                Not Significant
[237]Np Activity (Ci)
                                Not Significant
                                Not Significant
[238]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[238]U Activity (Ci)
                                Not Significant
                                Not Significant
[239]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[240]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[241]Am Activity (Ci)
                                Not Significant
                                Not Significant
[241]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[242]Pu Activity (Ci)
                                Not Significant
                                Not Significant
TRU Alpha Conc. (nCi/g)
                                Not Significant
                                Not Significant


Replicate Testing Data for Container No. 10568514  - 
SWEPP Gamma-Ray Spectrometer
Quantity of Interest
                             Original Measurement
                                 Replicate #1
                                 Replicate #2

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       1.74E-07
                                                                       1.06E-07
                                                                          60.9%
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       1.58E-07
                                                                       9.62E-08
                                                                          60.9%
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[235]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[237]Np Activity (Ci)
                                                                       4.45E-06
                                                                       1.56E-06
                                                                          35.0%
                                                                       4.09E-06
                                                                       1.42E-06
                                                                          34.8%
                                                                       4.31E-06
                                                                       1.50E-06
                                                                          34.7%
[238]Pu Activity (Ci)
                                                                       1.66E-02
                                                                       7.50E-03
                                                                          45.2%
                                                                       3.00E-02
                                                                       1.67E-02
                                                                          55.5%
                                                                       2.85E-02
                                                                       1.09E-02
                                                                          38.2%
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       1.11E+00
                                                                       3.81E-01
                                                                          34.3%
                                                                       1.09E+00
                                                                       3.71E-01
                                                                          34.0%
                                                                       1.08E+00
                                                                       3.67E-01
                                                                          34.0%
[240]Pu Activity (Ci)
                                                                       2.50E-01
                                                                       8.60E-02
                                                                          34.4%
                                                                       1.50E-01
                                                                       5.24E-02
                                                                          34.9%
                                                                       2.44E-01
                                                                       8.32E-02
                                                                          34.1%
[241]Am Activity (Ci)
                                                                       2.85E-01
                                                                       9.80E-02
                                                                          34.4%
                                                                       2.70E-01
                                                                       9.21E-02
                                                                          34.1%
                                                                       2.36E-01
                                                                       8.14E-02
                                                                          34.5%
[241]Pu Activity (Ci)
                                                                       6.32E-01
                                                                       2.21E-01
                                                                          34.9%
                                                                       5.27E-01
                                                                       2.26E-01
                                                                          42.9%
                                                                       7.26E-01
                                                                       2.50E-01
                                                                          34.5%
[242]Pu Activity (Ci)
                                                                       2.06E-05
                                                                       7.35E-06
                                                                          35.7%
                                                                       1.03E-05
                                                                       3.91E-06
                                                                          38.0%
                                                                       2.01E-05
                                                                       7.12E-06
                                                                          35.4%
TRU Alpha Conc. (nCi/g)
                                                                         16,433
                                                                          3,970
                                                                          24.2%
                                                                         15,246
                                                                          3,821
                                                                          25.1%
                                                                         15,741
                                                                          3,821
                                                                          24.3%

Quantity of Interest
                                 Replicate #3
                                 Replicate #4
                                 Replicate #5

                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
                                Reported Value
                             Absolute Uncertainty
                             Relative Uncertainty
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[234]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[235]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[237]Np Activity (Ci)
                                                                       4.58E-06
                                                                       1.58E-06
                                                                          34.6%
                                                                       3.87E-06
                                                                       1.35E-06
                                                                          34.8%
                                                                       4.30E-06
                                                                       1.49E-06
                                                                          34.7%
[238]Pu Activity (Ci)
                                                                       3.29E-02
                                                                       1.23E-02
                                                                          37.3%
                                                                       2.83E-02
                                                                       1.08E-02
                                                                          38.1%
                                                                       2.62E-02
                                                                       1.01E-02
                                                                          38.6%
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       1.10E+00
                                                                       3.74E-01
                                                                          34.0%
                                                                       1.09E+00
                                                                       3.71E-01
                                                                          34.0%
                                                                       1.08E+00
                                                                       3.67E-01
                                                                          34.0%
[240]Pu Activity (Ci)
                                                                       2.43E-01
                                                                       8.29E-02
                                                                          34.1%
                                                                       2.34E-01
                                                                       7.98E-02
                                                                          34.1%
                                                                       2.43E-01
                                                                       8.29E-02
                                                                          34.1%
[241]Am Activity (Ci)
                                                                       2.77E-01
                                                                       9.45E-02
                                                                          34.1%
                                                                       2.70E-01
                                                                       9.18E-02
                                                                          34.0%
                                                                       2.66E-01
                                                                       9.07E-02
                                                                          34.1%
[241]Pu Activity (Ci)
                                                                       5.60E-01
                                                                       2.06E-01
                                                                          36.7%
                                                                       5.93E-01
                                                                       2.05E-01
                                                                          34.6%
                                                                       6.09E-01
                                                                       2.11E-01
                                                                          34.6%
[242]Pu Activity (Ci)
                                                                       2.01E-05
                                                                       7.18E-06
                                                                          35.7%
                                                                       1.94E-05
                                                                       6.87E-06
                                                                          35.4%
                                                                       2.01E-05
                                                                       7.12E-06
                                                                          35.4%
TRU Alpha Conc. (nCi/g)
                                                                         16,334
                                                                          3,900
                                                                          23.9%
                                                                         14,949
                                                                          3,603
                                                                          24.1%
                                                                         16,038
                                                                          3,841
                                                                          23.9%

Quantity of Interest
                             Original Measurement
                                  Sample Mean
                           Sample Standard Deviation
                          Relative Standard Deviation
                                      [2]
                                Pr(x <|[2]|)
                                       t
                                 Pr(x <|t|)

                                Reported Value
                             Absolute Uncertainty
                                       
                                       
                                       
                                       
                                       
                                       
                                       
[90]Sr Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       3.48E-08
                                                                       7.78E-08
                                                                         223.6%
                                                                            N/A
                                                                            N/A
                                                                         -0.408
                                                                          0.704
[137]Cs Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       3.16E-08
                                                                       7.07E-08
                                                                         223.6%
                                                                            N/A
                                                                            N/A
                                                                         -0.408
                                                                          0.704
[233]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[234]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[235]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[237]Np Activity (Ci)
                                                                       4.45E-06
                                                                       1.56E-06
                                                                       4.23E-06
                                                                       2.66E-07
                                                                           6.3%
                                                                          0.117
                                                                          0.998
                                                                          0.755
                                                                          0.492
[238]Pu Activity (Ci)
                                                                       1.66E-02
                                                                       7.50E-03
                                                                       2.92E-02
                                                                       2.48E-03
                                                                           8.5%
                                                                          0.437
                                                                          0.979
                                                                         -4.628
                                                                          0.010
[238]U Activity (Ci)
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                       0.00E+00
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
                                                                            N/A
[239]Pu Activity (Ci)
                                                                       1.11E+00
                                                                       3.81E-01
                                                                       1.09E+00
                                                                       8.37E-03
                                                                           0.8%
                                                                          0.002
                                                                          1.000
                                                                          2.400
                                                                          0.074
[240]Pu Activity (Ci)
                                                                       2.50E-01
                                                                       8.60E-02
                                                                       2.23E-01
                                                                       4.09E-02
                                                                          18.4%
                                                                          0.905
                                                                          0.924
                                                                          0.607
                                                                          0.577
[241]Am Activity (Ci)
                                                                       2.85E-01
                                                                       9.80E-02
                                                                       2.64E-01
                                                                       1.60E-02
                                                                           6.1%
                                                                          0.107
                                                                          0.999
                                                                          1.207
                                                                          0.294
[241]Pu Activity (Ci)
                                                                       6.32E-01
                                                                       2.21E-01
                                                                       6.03E-01
                                                                       7.56E-02
                                                                          12.5%
                                                                          0.471
                                                                          0.976
                                                                          0.350
                                                                          0.744
[242]Pu Activity (Ci)
                                                                       2.06E-05
                                                                       7.35E-06
                                                                       1.80E-05
                                                                       4.32E-06
                                                                          24.0%
                                                                          1.377
                                                                          0.848
                                                                          0.550
                                                                          0.612
TRU Alpha Conc. (nCi/g)
                                                                         16,433
                                                                          3,970
                                                                         15,662
                                                                            566
                                                                           3.6%
                                                                          0.081
                                                                          0.999
                                                                          1.245
                                                                          0.281

Quantity of Interest
                                   [2] Test
                                    t-Test
[90]Sr Activity (Ci)
                                Not Applicable
                                Not Significant
[137]Cs Activity (Ci)
                                Not Applicable
                                Not Significant
[233]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[234]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[235]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[237]Np Activity (Ci)
                                Not Significant
                                Not Significant
[238]Pu Activity (Ci)
                                Not Significant
                              Highly Significant
[238]U Activity (Ci)
                                Not Applicable
                                Not Applicable
[239]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[240]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[241]Am Activity (Ci)
                                Not Significant
                                Not Significant
[241]Pu Activity (Ci)
                                Not Significant
                                Not Significant
[242]Pu Activity (Ci)
                                Not Significant
                                Not Significant
TRU Alpha Conc. (nCi/g)
                                Not Significant
                                Not Significant


Nondestructive Examination Baseline Inspection Checklist:
Real-Time Radiography
EPA Inspection No.: AMWTP-Fluor 08.17-8	Inspection Date: August 8 - 10, 2017
                          Technical Element or Aspect
                                 Yes, No or NA
                        Comments and Objective Evidence
 Real-Time Radiography Process
   
   
 Do AMWTP procedures provide complete instructions for operators to perform the CH RTR examination and complete associated documentation?
                                       Y
The EPA observed the RTR examination of the Z-213-106 and 1001 RTR units. The operator had performed the necessary equipment checks before the EPA's arrival. The EPA observed the entire RTR examination of the Z-213-106 and 1001 drums, including generation of the electronic and audiovisual records. Waste items were identified by the operator on the audiovisual recording and entered electronically into the RTR data sheet; the WMC was verified; and the container's fill height was determined. The operator used the appropriate AMWTP procedures to guide the examination and referenced the waste stream AK summary, as necessary. The RTR procedures for both units include detailed operational instructions and tables for waste item weights and prohibited items. Both operators were able to describe the NCR process and when NCRs are initiated. The EPA reviewed a list of qualified individuals and determined that the RTR operators for both units were properly qualified.
Nonconformance Report NCR No. 113071, Draft, and NCR No. 113073, Draft; BDR Nos. RTR-16-00176, RTR-17-00009, RTR-17-00111 and RTR-17-00140
 Do RTR operators perform image quality checks?
                                       Y
The EPA reviewed AMWTP RTR BDRs to ensure that successful image quality checks were performed before the examination of unknown containers. The EPA did not identify any issues with the quality control check.
BDR Nos. RTR-16-00176, RTR-17-00009, RTR-17-00111 and RTR-17-00140
 Does the RTR operator adjust the RTR as appropriate to accommodate the physical properties of the waste and waste containers likely to be encountered at the site?
                                       Y
The Z-213-106 and 1001 RTR operators were able to adjust the RTR as appropriate to accommodate the physical properties of the waste and waste containers. 
TPR-8089, Revision 3, Real-Time Radiography Examination (Certification Scans); TPR-8086. Real-Time Radiography Unit Operation (WMF-634); TPR-8120, Revision 1, Real-Time Radiography Unit Operation-RTR 1001; BDR Nos. RTR-16-00176, RTR-17-00009, RTR-17-00111 and RTR-17-00140
 Does the RTR operator follow a standard process for determining whether the waste matches the waste stream description and waste matrix code, and for determining waste material parameters and weights?
                                       Y
The EPA reviewed AMWTP RTR procedures and determined that they are adequate for the generation of RTR waste characterization data for WIPP-bound CH TRU waste. The Z-213-106 and 1001 RTR operators were able to assess whether the waste matches the waste stream description and WMC, and to determine WMPs and assign appropriate item weights.
TPR-8089, Revision 3, Real-Time Radiography Examination (Certification Scans); TPR-8086, Real-Time Radiography Unit Operation (WMF-634); TPR-8120, Revision 1, Real-Time Radiography Unit Operation-RTR 1001; BDR Nos. RTR-16-00176, RTR-17-00009, RTR-17-00111 and RTR-17-00140
 Does the RTR operator follow a standard process for identifying prohibited items and for processing drums containing prohibited items?
                                       Y
The EPA observed that the Z-213-106 and 1001 RTR operators followed formal AMWTP procedures for identifying prohibited items and for processing drums containing prohibited items.
TPR-8089, Revision 3, Real-Time Radiography Examination (Certification Scans); TPR-8086, Real-Time Radiography Unit Operation (WMF-634); TPR-8120, Revision 1, Real-Time Radiography Unit Operation-RTR 1001; BDR Nos. RTR-16-00176, RTR-17-00009, RTR-17-00111 and RTR-17-00140
 Does the RTR process include the quality control examinations, evaluation accuracy and reproducibility of the RTR process?
                                       Y
The EPA reviewed RTR BDRs to ensure that required QC examinations were performed and all BDRs reviewed contained an Independent Observation and Replicate Scan.
RTR Qualification Package No. QPOT03A0; MCP-4026, Personnel Qualification and Certification; BDR Nos. RTR-16-00176, RTR-17-00009, RTR-17-00111 and RTR-17-00140
 Real-Time Radiography Records
                                         
   
 Are RTR records of sufficient quality for a complete review?
                                       Y
The EPA inspectors reviewed the electronic and audiovisual records for the RTR BDRs listed below. The waste examined in these BDRs included 55-gallon and 85-gallon drums and had been generated using the Z-213-101, Z-213-106 and 1001 RTR units. A successful image quality check had been performed and recorded for each BDR. The QC examinations for these BDRs were reviewed and determined to be adequate. All BDRs had been reviewed at the data generation and project level. NCRs had been initiated when necessary, and all data forms were completed and signed as required
BDR Nos. RTR-16-00176, RTR-17-00009, RTR-17-00111 and RTR-17-00140
 Are the RTR data recorded on appropriate standardized forms? 
                                       Y
The Z-213-106 and 1001 RTR operators were able to describe the NCR process and when NCRs are initiated. The EPA reviewed a list of qualified individuals and determined that the operators performing the RTR demonstration on both units were properly qualified.
TPR-8089, Revision 3, Real-Time Radiography Examination (Certification Scans); TPR-8086, Real-Time Radiography Unit Operation (WMF-634); TPR-8120, Revision 1, Real-Time Radiography Unit Operation-RTR 1001; BDR Nos. RTR-16-00176, RTR-17-00009, RTR-17-00111 and RTR-17-00140
 Are BDR reviews at the data generation and project levels completed and adequately documented?
                                       Y
The EPA determined that all RTR BDRs had been reviewed at the data generation and project level.
MCP-4005, Revision 0, Level I Data Validation; MCP-4006, Revision 1, Level II Data Validation; BDR Nos. RTR-16-00176, RTR-17-00009, RTR-17-00111 and RTR-17-00140
 Personnel Training
                                         
   
 Are the RTR personnel adequately trained and qualified? 
                                       Y
The EPA inspectors reviewed training records for AMWTP operators. Operators are required to perform an RTR examination of test and training containers as part of their initial and ongoing training requirements. All training records were complete and readily available for review. Review of training records and completed RTR BDRs demonstrated that only qualified personnel were generating and reviewing RTR data.
RTR Qualification Package No. QPOT03A0; MCP-4026, Personnel Qualification and Certification; BDR Nos. RTR-16-00176, RTR-17-00009, RTR-17-00111 and RTR-17-00140

                    Information Included in AMWTP RTR BDRs 
                                       
                            Required Batch Content
                                   Present?
                                    Y or N
                            Required Batch Content
                                   Present?
                                    Y or N
                            Required Batch Content
                                   Present?
                                    Y or N
Batch date
                                       Y
Description of liners
                                       Y
Verification of waste matrix code
                                       Y
Report date
                                       Y
Layers of confinement
                                       Y
Reference to or copies of any NCRs
                                       Y
Waste container number
                                       Y
Indication of vented rigid liners
                                       Y
Operator signature and test date
                                       Y
Waste matrix code
                                       Y
Description of container contents
                                       Y
Data generation checklists
                                       Y
Implementing procedure name or #
                                       Y
Indication of sealed containers >4L
                                       Y
Project-level checklists
                                       Y
Videotape reference
                                       Y
Amount of free liquid
                                       Y

                                       
QC documentation
                                       Y
Container gross weight
                                       Y

                                       
Verification that waste matches waste stream description
                                       Y
Estimated weights for waste material parameters
                                       Y

                                       



Nondestructive Examination Baseline Inspection Checklist:
Visual Examination
EPA Inspection No.: AMWTP-Fluor 08.17-8	Inspection Date: August 8 - 10, 2017
                          Technical Element or Aspect
                                 Yes, No or NA
                        Comments and Objective Evidence
 Visual Examination Process
   
   
 Do AMWTP procedures and technical guidance documents provide complete instructions for performing CH VE?
                                      Yes
AMWTP VE personnel have specific procedures and/or technical guidance in container management, nonconformance reporting, conduct of operations, AK documents and TRUCON codes.
TPR-7997, Revision 2, Visual Examination Activities at RWMC; TPR-8041, Revision 2, Visual Examination Operations. 
 Are corrective actions taken and appropriately documented and closed when necessary?
                                      Yes
Reporting of nonconformances is addressed directly in AMWTP procedures and training. The EPA did not observe any AMWTP VE NCRs during this baseline inspection.
TPR-7997, Revision 2, Visual Examination Activities at RWMC; TPR-8041, Revision 2, Visual Examination Operations; PowerPoint Presentations: Level I and Level II ARP; OAWT3145, Visual Examination (VE) for ARP; OAWT3141, Revision 4, Module B, November 2011; OAWT3143, Revision 3; OAWT3142, Revision 4, Module B, November 2011
 Visual Examination Records
   
   
 Are all appropriate VE records available for review?
                                      Yes
All training records; lists of qualified operators, VEEs and ITRs; list of prohibited items; AK summaries and other records were readily available for review.
List of Qualified Operators: Employees by Qualification/Certifications: Level I Validation ITR for VE; List of Qualified Operators: Employees by Qualification/Certifications: AMWTP Visual Examiner (Facility VE); List of Qualified Operators: Employees by Qualification/Certifications: Visual Exam ARP/SRP
 Are BDR reviews at the data generation and project levels completed and adequately documented?
                                      Yes
All VE BDRs were reviewed and signed as appropriate.
SRP VE BDR Nos. VEAB-16-00159, VEAB-16-00016; ARP VE BDR Nos. ARP-15-00023, ARP-15-00028; VE BDR No. VNC-16-00019; MCP-4005, Revision 0, Level I Data Validation; MCP-4006, Revision 1, Level II Data Validation
 Personnel Training
   
   
 Are the VE personnel adequately trained and qualified?
                                      Yes
AMWTP records indicate that CH TRU VE personnel at all levels were appropriately trained.
List of Qualified Operators: Employees by Qualification/Certifications: Level I Validation ITR for VE; List of Qualified Operators: Employees by Qualification/Certifications: AMWTP Visual Examiner (Facility VE); List of Qualified Operators: Employees by Qualification/Certifications: Visual Exam ARP/SRP; SRP VE BDR Nos. VEAB-16-00159, VEAB-16-00016; ARP VE BDR Nos. ARP-15-00023, ARP-15-00028; VE BDR No. VNC-16-00019
 Are the VE personnel qualification and requalification requirements adequately described?
                                      Yes
Qualification and requalification requirements are addressed in AMWTP documents.
PLN-5198, Certification Plan for INL Transuranic Waste; PLN-5199, Quality Assurance Project Plan; PowerPoint Presentations: Level I and Level II ARP; OAWT3145, Visual Examination (VE) for ARP; OAWT3141, Revision 4, Module B, November 2011; OAWT3143, Revision 3; OAWT3142, Revision 4, Module B, November 2011
 Does the AMWTP have a designated VEE for CH VE?
                                      Yes
The AMWTP had four designated VEEs, as documented by VEE appointment letters.
Advanced Mixed Waste Treatment Project Visual Examination Designees-GTB-006-15, August 15, 2015; SRP VE BDR Nos. VEAB-16-00159, VEAB-16-00016; ARP VE BDR Nos. ARP-15-00023, ARP-15-00028; VE BDR No. VNC-16-00019



Documents Reviewed During the Baseline Inspection
Acceptable Knowledge
AK Resolution Ledger, demonstrated August 9, 2017
AKE Initial Qualification Checklist, QCAKE01A, Brian Martinson, June 8, 2017
AKE Initial Qualification Checklist, QCAKE01A, Clay Dennert, January 25, 2016
AKE Initial Qualification Checklist, QCAKE01A, Mindy Giles, May 8, 2017
AKE Initial Qualification Checklist, QCAKE01A, Nancy Kirk, June 1, 2017
AKE Requalification Checklist, QCAKE01A, Randall C. Morris, June 24, 2015
AKE Requalification Checklist, QCAKE01A, Steve Carpenter, September 14, 2016
AKR-15-906, Revision 5, June 6, 2016
AKR-16-910, Revision 1, August 24, 2016
BNINW216 Interface Waste Management Document List, FRM-2274, July 5, 2017
C1381A, Waste Material Parameter Weight Per Unit of Waste Calculations for the BN510.4 Supercompacted Debris, Randall C Morris, RCM-003-15, Revision 0, April 27, 2015
C191A, Memorandum from DOE CAO to J.M. Roberson, RFFO and J.M. Wilcynski, INEEL, "Identification of Defense Waste Streams Generated at Rocky Flats Environmental Technology Site (RFETS)," George E. Dials, DOE CBFO, Revision 2, May 20, 1997
C534A, Memorandum to File, Waste Material Parameter (WMP) Weight Calculations and Supporting Data to Determine WMP Weight per Unit of Waste, Tim Venneman, TV-001-07, January 19, 2007
CBFO DRRs for CCE Drafts for BNINW216 Waste Handling Building Containers, LANL-CO, Bynum, and Biedscheid
D120A, Discrepancy Resolution: Constituent List Discrepancy between CCP AK for RH waste from RF and AMWTP Generator Report for RF, Revision 0, Randall C. Morris, January 28, 2015
D130S, Discrepancy Resolution: Asphalt/Pond Sludge as a Component of the BNINW216 Waste Stream, Revision 1, D. Arrenholz, September 16, 2015
DCR No. 9419, Document Change Request for RPT-TRUW-07, Revision 15 to Revision 16, August 13, 2010
Form-1066, TRU Waste Management AK Checklist, AMWTP (BN), October 8, 2015
Form-1067, TRU Waste Stream AK Documentation Checklist, BN510.4, November 16, 2016
Form-1067, TRU Waste Stream AK Documentation Checklist, BNINW216, November 29, 2016
Form-1084, AK Source Document Reference List, J.C. Haynes Laboratory Waste, provided August 10, 2017
Interoffice Memorandum, Chemical Compatibility Evaluation for Waste Stream BNINW216, July 20, 2017, with CBFO Concurrence and Approval for the revised Chemical Compatibility Evaluation Memorandum for the AMWTP Waste Stream BNINW216, November 15, 2017
MCP-4003, Production Planning, Advanced Mixed Waste Treatment Project, Revision 1, May 4, 2017
MCP-4010, Collection, Review, and Management of Acceptable Knowledge Documentation, Revision 1, July 25, 2017
MCP-4085, Virtual Overpack Process and Planning, Advanced Mixed Waste Treatment Project, Revision 0, February 16, 2017
Memorandum to File, Acceptable Knowledge Assessment for BNINW216 Waste at Waste Handling Building; AMWTP Closure Dates from April 23, 2008 through March 5, 2010 and AMWTP Repack Dates from July 12, 2013 to October 15, 2013, July 19, 2017, with Attachment 1, Revision 1, July 19, 2017, and Revision 2, October 18, 2017
Memorandum to: George Byram, TRU Programs Manager/Alternate Site Project Manager, Steve Carpenter, Acceptable Knowledge Manager/Alternate Site Project Manager, Gina Tedford, Site Project Manager, From: Randall C. Morris, Ph.D., PMP, Re: Acceptable Knowledge Accuracy Assessment for July 1, 2014 to June 30, 2015  -  RCM-008-15, October 8, 2015
Memorandum to: George Byram, TRU Programs Manager/Alternate Site Project Manager, Gina Tedford, Site Project Manager, Steve Carpenter, Alternate Site Project Manager, From: Randall C. Morris, Acceptable Knowledge Expert, Re: Acceptable Knowledge Accuracy Assessment for July 1, 2015 to June 30, 2016, CCN 319947, November 2, 2016
Nonconformance Report for Container ID: 10576737, NCR No. 103740, August 25, 2016
Nonconformance Report for Container ID: 10581368, NCR No. 102733, June 10, 2016
P2076A, BN510.4 Waste Stream Profile Package for Supercompacted Debris Waste, including CIS and current AKSR, Revision 4, November 15, 2016
P217A, Waste Stream Profile Form INW 216.001 - First/Second Stage Sludge, Transmittal letter (CNN 21151) from Thomas Monk to Jerry Wells, US DOE, dated May 24, 2001, and WSPF Update for WIPP Operating Record, dated February 19, 2003
P219A, Hazardous Waste Code Determination for First/Second Stage Sludge Waste Stream (IDCs 001, 002, 800), R.E. Arbon, INEEL/EXT-01-00015, Bechtel BWXT Idaho, LLC, Revision 2, May 1, 2001
P368A, Acceptable Knowledge Document for INEEL Stored Transuranic Waste - Rocky Flats Plant Waste, INEL-96/0280, Revision 0, October 1996; Revision 1, August 19, 1997; Revision 2, January 23, 1998; Revision 3, February 28, 2003
P402A, BNINW216 First/Second Stage Sludge Waste Stream Profile Package, September 17, 2004; Change Notice No. 1, February 2, 2005; Change Notice No. 2, January 24, 2007; Change Notice No. 3, April 2, 2008; and Change Notice No. 4, August 6, 2010, including CIS and current AKSR, Revision 1, November 29, 2016
Procedure verification checklist for IWMDL - Waste Stream No. BNINW216, Procedure Number: MCP-4006 Rev 1, Level II Data Validation/Assay, Observed implementation for Batch No. ASY17-022936
Reconciliation with Data Quality Objectives, Completed Forms for Reconciliation Lot Nos. BN510.4.0070, BN510.4.0155, BN510.4.0156, BNINW216.0107, BNINW216.0108 and BN004.0013
RPT-TRUW-05, Waste Matrix Code Reference Manual, Advanced Mixed Waste Treatment Project, Revision 41, July 26, 2016, Draft Revision 42, provided August 9, 2017
RPT-TRUW-06, Acceptable Knowledge Document for AMWTP Waste, Advanced Mixed Waste Treatment Project, Revision 18, March 24, 2016
RPT-TRUW-07, Determination of Radioisotopic Content in TRU Waste Based on Acceptable Knowledge, Advanced Mixed Waste Treatment Project, Revision 22, May 27, 2015
RPT-TRUW-09, Acceptable Knowledge Summary for First/Second Stage Sludge (BNINW216), Advanced Mixed Waste Treatment Project, Revision 9, March 27, 2013
RPT-TRUW-12, AMWTP Waste Streams Designations, Advanced Mixed Waste Treatment Project, Revision 24, September 2, 2014
RPT-TRUW-56, Acceptable Knowledge Document for INL Stored Transuranic Waste - Rocky Flats Plant Waste, Advanced Mixed Waste Treatment Project, Revision 7, November 18, 2014
RPT-TRUW-83, Acceptable Knowledge Summary for Supercompacted Debris Waste, Advanced Mixed Waste Treatment Project, Revision 12, July 26, 2016
RPT-TRUW-XX, Acceptable Knowledge Document for J.C. Haynes Laboratory Waste, Advanced Mixed Waste Treatment Project, Draft Revision 0, provided August 9, 2017
RPT-TRUW-XXX, Basis of Knowledge Assessment Report for First and Second Stage Sludge [BNINW216] (Waste Handling Building Containers), Advanced Mixed Waste Treatment Project, Revision X, draft provided August 10, 2017
Screenshot of Employees by Qualifications/Certifications Database, QCAKE01A, June 29, 2017
Screenshot of Employees by Qualifications/Certifications Database, QCSPM01A, July 12, 2017
SPM and Management Concurrence with AKA Drafts for BNINW216 Waste Handling Building Containers, July 20, 2017
SPM Concurrence with CCE Drafts for BNINW216 Waste Handling Building Containers, Gina Tedford, October 26, 2016, June 1, 2017, August 7, 2017
SPM Requalification Checklist, QCSPM01A, Georgy Byram, January 2, 2017
SPM Requalification Checklist, QCSPM01A, Gina Tedford, May 1, 2017
SPM Requalification Checklist, QCSPM01A, Wesley Skaar, January 9, 2017
TPR-8151, TRU Programs Site Project Office Process, Advanced Mixed Waste Treatment Project, Revision 0, May 4, 2017
TPR-8165, TRU Program Acceptable Knowledge Container Evaluation Process, Revision 0, February 13, 2017
WCO Requalification Checklist, QCWWC01A, Stormie Winterbottom, May 18, 2016
WDS Certification Screenshots for Container Nos. BN10554633 (Reconciliation Lot No. BN510.4.0070) and 10305150 (Reconciliation Lot No. BN004.0013)
WTS demonstration and screenshots for BN510.4 Drum No. BN10500841 and source containers 10213527 and 10497417, provided August 9, 2017
WTS demonstration and screenshots for BNINW216 Drum No. 10335453, provided August 9, 2017
Nondestructive Assay
BII-5112-TMU-001, AMWTP Retrieval Box Assay System (RBAS) Total Measurement Uncertainty Report, Revision 2, March 2004
BNFL-5232-INST-OI-14, Drum Assay Operations, Revision 17, February 9, 2006
BNFL-5232-INST-OI-11, Drum Assay Operations, Revision 19, FC-1, August 17, 2004
BNFL-5232-RPT-TRUW-03, Drum Assay Technical Review Report, Revision 5, February 14, 2006
BNFL-5232-RPT-TRUW-06, Determination of Radioisotopic Content in TRU Waste Based on Acceptable Knowledge, Revision 1, November 20, 2003
BNFL-5232-RPT-TRUW-07, Determination of Radioisotopic Content in TRU Waste Based on Acceptable Knowledge, Revision 8, February 9, 2006
CI-IDA-NDA-0035, Calibration Verification & Confirmation Procedure for the Integrated Waste Assay System (IWAS) at AMWTP, Revision 3, May 29, 2003
CI-IDA-NDA-0051, Site Acceptance Test Report (SATR) for the Integrated Waste Assay Systems Unit 1 at AMWTP, Canberra Industries 
CI-IDA-NDA-0052, Site Acceptance Test Report (SATR) for the Integrated Waste Assay Systems Unit 2 at AMWTP, Canberra Industries
CI-IDA-NDA-0053, Site Acceptance Test Report (SATR) for the Integrated Waste Assay Systems Unit 3 at AMWTP, Canberra Industries
CI-IDA-NDA-0054, Site Acceptance Test Report (SATR) for the Integrated Waste Assay Systems Unit 4 at AMWTP, Canberra Industries
CI-IDA-NDA-0055, Total Measurement Uncertainty for the AMWTP Integrated Waste Assay Systems, Revision 1, July 30, 2003
CCP-INL-SGRS-001, SWEPP Gamma-Ray Spectrometer (SGRS) Calibration, Confirmation and Verification Report, Revision 1, November 14, 2012; Revision 3, December 7, 2016
CCP-INL-SGRS-002, Total Measurement Uncertainty for the SGRS Assay System, April 21, 2005 
CCP-INL-SGRS-14-005, October 8, 2014 
CCP-INL-WAGS-001, Waste Assay Gamma Spectrometer (WAGS) Calibration, Confirmation, and Verification Report, Revision 1, April 8, 2008 
CCP-INL-WAGS-002, Total Measurement Uncertainty for the WAGS system, April 20, 2005 
CCP-INL-WAGS-003, Waste Assay Gamma Spectrometer (WAGS) Calibration, Confirmation & Verification Report, Revision 0, May 18, 2011 
CCP-INL-WAGS-08-002, Waste Assay Gamma Spectrometer (WAGS) Multi-Curve Efficiency Calibration Extension Addendum, Revision 0, April 10, 2008 
CCP-INL-WAGS-14-006, August 14, 2014 
CCP-INL-WAGS-15-001, Measurement Control Limits Update, March 30, 2015 
CCP-INL-WAGS-15-003, Measurement Control Limits Update, July 23, 2015 
INST-OI-122, Stored Waste Examination Pilot Gamma-Ray Spectrometer Operations, Advanced Mixed Waste Treatment Project, Revision 0, October 26, 2015 
INST-OI-123, Waste Assay Gamma Spectrometer Operations, Advanced Mixed Waste Treatment Project, Revision 0, October 15, 2015 
INST-TRUW-8.1.4, Waste Assay Gamma Spectrometer/SWEPP Gamma-Ray Spectrometer Post-Maintenance Calibration and Verification, Advanced Mixed Waste Treatment Project, Revision 0, October 27, 2015 
Memorandum to Doug Pruitt, Approval Status Notification for Advanced Mixed Waste Treatment Project in Drum Cycle 24A of the Nondestructive Assay Performance Demonstration Program, June 29, 2017
Memorandum Norma Castaneda to James Malmo, Approval Status Notification for Advanced Mixed Waste Treatment Project in Box Cycle B16A of the Nondestructive Assay Performance Demonstration Program, October 20, 2016
MCP-4005, Level I Data Validation, Advanced Mixed Waste Treatment Project, Revision 0, November 19, 2016
MCP-4006, Level II Data Validation, Advanced Mixed Waste Treatment Project, Revision 1, December 22, 2016
MP-8.1.1, Drum Assay Post-Maintenance Calibration & Verification, Revision 6, November 22, 2004
MP-TRUW-8.1, Certification Plan for INEEL Contact-Handled Transuranic Waste, Appendix A, Revision 10, January 3, 2006
MP-TRUW-8.8, Level I Data Validation, Section 3.4, Revision 14, February 10, 2006
NDA BDR Nos. BSY16-00110, BSY17-00036, ASY16-02439, ASY16-03128, ASY16-04097, ASY16-03498, ASY16-02166, ASY17-01161, ASY16-03800, ASY17-01299, ASY16-02155, ASY16-02214, ASY17-02152 and ASY17-02468 
NDA Drum assay system log entries dated June 20, 2017, July 25, 2016, August 10, 2017, August 20, 2016, and August 11, 2017
PSC-5431-CCR-001, AMWTP RBAS System, Revision 1, April 7, 2015
PSC-5431-CP-001, PSC Calibration Confirmation Plan, Revision 0, January 16, 2015
PSC-5431-CP-001, Calibration Confirmation Plan, Revision 2, April 7, 2015
OAWT3141, Revision 4, Module B, November 2011
OAWT3142, Revision 4, Module B, November 2011
OAWT3143, Revision 3
OAWT3145, Visual Examination (VE) for ARP
RPT-TRUW-03, Drum Assay Technical Report, Advanced Mixed Waste Treatment Project, Revision 11, September 29, 2016
TPR-7994, Drum Assay Post-Maintenance Calibration and Verification, Revision 1, November 19, 2016
TPR-7995, Box Assay Post-Maintenance Calibration and Verification, Revision 1, November 19, 2016
TPR-7996, WAGS SGRS Post-Maintenance Calibration and Verification, Revision 1, November 19, 2016
TPR-8025, In-Plant Drum Assay Operations, Revision 3, June 27, 2017
TPR-8092, Stored Waste Examination Pilot Plant Gamma-Ray Spectrometer Operations, Revision 3, June 9, 2017
TPR-8093, Waste Assay Gamma Spectrometer Operations, Revision 3, June 9, 2017
TPR-8094, Drum Assay Operations, Revision 2, June 9, 2017
TPR-8095, Box Assay Operations, Revision 4, June 21, 2017
Work Order 510249, SGRS, July 18, 2016
Work Order 510379, WAGS, July 25, 2016
Work Order 510912, Z-211-103, August 20, 2016
Work Order 525638, Z-211-102, June 21, 2017
Real-Time Radiography
AMWTP Real Time Radiography Listing: Employees by Qualification/Certifications, screenshot, undated
AMWTP Level I VAL ITR for RTR, Real Time Radiography Independent Technical Reviewer Listing: Employees by Qualification/Certifications, screenshot, undated
AMWTP Form No. 1578, Imaging Quality Indicator Verification Form for RTR, Revision 7, August 14, 2013
Image Quality Indicator No. 080912IQI1010
MCP-4005, Level I Data Validation, Revision 0, November 19, 2016
MCP-4006, Level II Data Validation, Revision 1, December 22, 2016
MCP-4026, Personnel Qualification and Certification, undated
Nonconformance Report NCR No. 113071, Draft, August 9, 2017
Nonconformance Report NCR No. 113073, Draft, August 9, 2017
RPT-TRUW-05, Waste Matrix Code Reference Manual, Revision 41, July 26, 2016
RTR BDR Nos. RTR-17-00111, RTR-16-00176, RTR-17-00009 and RTR-17-00140
RTR BDR No. 17-0002
RTR Qualification Package No. QPOT03A0, Revision 14, March 2016
TPR-8018, Packaging Newly-Generated Waste 
TPR-8086, Real-Time Radiography Unit Operation (WMF-634)
TPR-8089, Real-Time Radiography Examination (Certification Scans), Revision 3, June 8, 2017
TPR-8120, Real-Time Radiography Unit Operation-RTR 1001, Revision 1, June 9, 2017
Visual Examination
Advanced Mixed Waste Treatment Project Visual Examination Designees-GTB-01, August 25, 2015
Advanced Mixed Waste Treatment Project Visual Examination Designees-GTB-006-15, August 15, 2015
ARP VE BDR Nos. ARP-15-00023, ARP-15-00028
Level I and II ARP/SRP Validation, AMWTP NDE PowerPoint Presentation, undated
List of Qualified Operators: Employees by Qualification/Certifications: Level I Validation ITR for VE, July 25, 2017
List of Qualified Operators: Employees by Qualification/Certifications: AMWTP Visual Examiner (Facility VE)
List of Qualified Operators: Employees by Qualification/Certifications: Visual Exam ARP/SRP 
MCP-4005, Level I Data Validation, Revision 0, November 19, 2016
MCP-4006, Level II Data Validation, Revision 1, December 22, 2016
OAWT3141, Visual Examination Indoctrination, Revision 4, Module B, November 2011; PowerPoint Presentation
OAWT3142, Visual Examination Revision 4, Module B, November 2011; PowerPoint Presentation
OAWT3143, Waste Tracking System (WDS) and Data Quality Objectives (DQOs), Revision 3;, undated; PowerPoint Presentation
OAWT3145, Visual Examination (VE) for ARP; PowerPoint Presentation
PLN-5198, Certification Plan for INL Transuranic Waste
PLN-5199, Quality Assurance Project Plan
QPOT03A0; MCP-4026, Personnel Qualification and Certification PowerPoint Presentations
SRP VE BDR Nos. VEAB-16-00159, VEAB-16-00016
TPR-7997, Visual Examination Activities at RWMC, Revision 2, June 21, 2017
TPR-8041, Visual Examination Operations, Revision 2, June 9, 2017
TPR-8103, Non-Facility Visual Examinations, Revision 1, November 1, 2016
VE BDR No. VNC-16-00019
