                                              EPA DOCKET NO. A-98-49, II-A4-195
                                     EPA E-DOCKET NO. EPA-HQ-OAR-2001-0012-XXXX

                      WASTE CHARACTERIZATION INSPECTION
                          CONTINUED COMPLIANCE REPORT

            EPA INSPECTION OF THE CENTRAL CHARACTERIZATION PROJECT
                        WASTE CHARACTERIZATION PROGRAM
                          AT THE SAVANNAH RIVER SITE

                             August 19 - 21, 2014
                               October 15, 2014

                     U.S. Environmental Protection Agency
                      Office of Radiation and Indoor Air
                  Center for Waste Management and Regulations
                         1200 Pennsylvania Avenue, NW
                             Washington, DC 20460

                                 February 2015

                               TABLE OF CONTENTS
1.0	Executive Summary	1
2.0	Purpose of Continued Compliance Inspections	7
3.0	Inspection Personnel	7
4.0	Purpose of This Report	7
5.0	Scope of This Continued Compliance Inspection	8
6.0	Technical Evaluation	8
6.1	Acceptable Knowledge for Contact-Handled and Remote-Handled Waste Characterization	8
6.1.1	Technical Evaluation: Contact-Handled Waste	8
6.1.2	Technical Evaluation: Remote-Handled Waste	14
6.1.3	Acceptable Knowledge Findings and Approval	19
6.2	Nondestructive Assay for Contact-Handled Waste Characterization	19
6.2.1	Technical Evaluation: Nondestructive Assay Box Counter	20
6.2.2	Nondestructive Assay Findings and Approval	23
6.3	Radiological Characterization for Remote-Handled Waste	23
6.3.1	Technical Evaluation: Dose-to-Curie	23
6.3.2	Technical Evaluation: In Situ Object Counting System	24
6.3.3	Radiological Characterization Findings and Approval	25
6.4	Nondestructive Examination for Contact-Handled and Remote-Handled Waste Characterization	25
6.4.1	Technical Evaluation: Real-Time Radiography	25
6.4.2	Real-Time Radiography Findings and Approval	26
7.0	Findings and Concerns	27
8.0	Conclusions	27

                                LIST OF TABLES
Table 1.  Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented by SRS-CCP	3
Table 2.  Tiering of Remote-Handled Transuranic Waste Characterization Processes Implemented by SRS-CCP	5
Table 3. Contact-Handled SRS-CCP Waste Streams Sampled for Review	9
Table 4. Contact-Handled Containers Evaluated for Traceability	10
Table 5. Remote-Handled Containers Evaluated for Traceability	16

                                  ATTACHMENTS
Attachment A.1	Approval Summary for SRS-CCP Contact-Handled Waste Characterization Program
Attachment A.2	Approval Summary for SRS-CCP Remote-Handled Waste Characterization Program
Attachment B	Inspection Personnel
Attachment C	EPA Inspection Issue Tracking Form, Issue No. SRS-CCP-CH-CC-2014-01CR, Final
Attachment D.1	Acceptable Knowledge Continued Compliance Inspection Checklist: Contact-Handled Waste
Attachment D.2	Acceptable Knowledge Continued Compliance Inspection Checklist: Remote-Handled Waste
Attachment E	Nondestructive Assay Box Counter Continued Compliance Inspection Checklist
Attachment F.1	Replicate Testing Data for Drum SR515955  -  Nondestructive Assay Box Counter
Attachment F.2	Replicate Testing Data for Drum SR21524421  -  Nondestructive Assay Box Counter
Attachment G.1	Dose-to-Curie Continued Compliance Inspection Checklist
Attachment G.2	In Situ Object Counting System Continued Compliance Inspection Checklist
Attachment H	Real-Time Radiography Continued Compliance Inspection Checklist
Attachment I	List of Documents Reviewed for this Inspection

ACRONYMS AND ABBREVIATIONS
%R	percent recovery
%RSD	percent relative standard deviation
	sigma
uR/hr	microroentgen per hour
χ[2]	chi-squared
AGNS	Allied-General Nuclear Services
AK 	acceptable knowledge
AKE	Acceptable Knowledge Expert
AKSR	acceptable knowledge summary report
AKTSS	acceptable knowledge tracking spreadsheet
Am	americium
AMWTP	Advanced Mixed Waste Treatment Project
ASTM	American Society for Testing and Materials
Att.	Attachment
Ba	barium
BDR	batch data report
BEGe	broad energy germanium
BeO	beryllium oxide
BGR	burial ground record
BNAS	Box Neutron Assay System
BNFP	Barnwell Nuclear Fuel Plant
BKG	background count rate
BSGS	 Box Segmented Gamma System
CBFO	Carlsbad Field Office
CCP 	Central Characterization Program
CFR	Code of Federal Regulations
CH	contact-handled
Ci	Curie
CIS	characterization information summary
cps	counts per second
CRR	characterization reconciliation report
Cs	cesium
CSSF	correlation and surrogate summary form
CTAC 	Carlsbad Technical Assistance Contractor
CWI	CH2M-WG Idaho, LLC
DEQ	Department of Environmental Quality
DOE 	U.S. Department of Energy
DPS	drum packaging stations
DQO	data quality objective
DR	discrepancy resolution
DSA	digital spectrum analyzer
DTC	dose-to-curie
DU	depleted uranium
DVD	digital video disk
EA	Expert Analyst
EPA 	U.S. Environmental Protection Agency
EU	enriched uranium
FWHM	full width at half maximum
FY	fiscal year
g	gram
HBL	HB-Line
HCLA	Hot and Cold Laboratory Area
HEU	highly enriched uranium
HFEF	Hot Fuel Examination Facility
HLW	high-level waste
HS Pu	heat-source plutonium
HWN	hazardous waste number
ISOCS	In Situ Object Counting System
ITR	Independent Technical Reviewer
keV	kilo electron volt
kg	kilogram
kg/L	kilogram per liter
kV	kilovolt
LLD	lower limit of detection
LLW	low-level waste
LOQI	list of qualified individuals
MCS	Mobile Characterization Services
MGA	multi-group analysis
MGA-U	multi-group analysis-uranium
mR/hr	milliroentgen per hour
NABC	Nondestructive Assay Box Counter
nCi/g	nanocuries per gram
NCR	nonconformance report
NDA	nondestructive assay
NDE	nondestructive evaluation
NWP	Nuclear Waste Partnership, LLC
OJT	on-the-job training
ORIA	Office of Radiation and Indoor Air
PCB	polychlorinated byphenyl
PDP	Performance Demonstration Program
PK	process knowledge
POC	pipe overpack containers
PSAP	Project-specific Sampling and Analysis Plan
Pu	plutonium
QA	quality assurance
QAPD	quality assurance program document
QAPP	Quality Assurance Project Plan
QC	quality control
R	roentgen
R/hr	roentgen per hour
RDS	radioassay data sheet
Rev.	revision
RFP 	Rocky Flats Plant
RH	remote-handled
RTR	real-time radiography
SC&A	S. Cohen and Associates (SC&A, Inc.)
SCG	summary category group
SD	source document
SLI	special legacy items
SME	Subject-Matter Expert
SNF	spent nuclear fuel
SPC	sludge pan container
SPM	Site Project Manager
Sr	strontium
SRP	Sludge Repackage Project
SRS	Savannah River Site
STR	Host Site Subcontract Technical Representative
T1	Tier 1
T2	Tier 2
TAAC	TRU Alpha Activity Concentration
Th	thorium
TMU	total measurement uncertainty
TRU 	transuranic
TSA	Transuranic Storage Area
U	uranium
UREX	Uranium Recovery by Extraction
VE	visual examination
VEE	Visual Examination Expert
VEO	Visual Examination Operator
VHS	Video Home System
VPM	Vendor Project Manager
WAC	waste acceptance criteria
WCPIP	Waste Characterization Program Implementation Plan
WDS	WIPP Waste Data System
WG Pu	weapons-grade plutonium
WIPP 	Waste Isolation Pilot Plant
WMC	waste matrix code
WMO	Waste Management Operations Department
WMP 	waste material parameter
WSPF	waste stream profile form
wt%	weight percent

EXECUTIVE SUMMARY
This report supports the U.S. Environmental Protection Agency's (EPA's) determination that the waste characterization program at the U.S. Department of Energy's (DOE's) Savannah River Site (SRS) continues to be in compliance with federal regulations. In accordance with Title 40 of the Code of Federal Regulations (40 CFR) 194.24(h), EPA can conduct a continued compliance inspection of the EPA-approved transuranic (TRU) waste characterization systems used at the TRU waste sites operated by DOE. Since 2006, the Central Characterization Program (CCP), a mobile waste characterization systems provider, has operated a waste characterization program for contact-handled (CH) and remote-handled (RH) TRU wastes at SRS in Aiken, South Carolina.
EPA conducted a continued compliance inspection of the site's program to characterize CH and RH TRU wastes proposed for disposal at the Waste Isolation Pilot Plant (WIPP). During this inspection, EPA evaluated samples of the following waste characterization activities:
   * Acceptable knowledge (AK) for CH and RH TRU waste streams.
   * One nondestructive assay (NDA) system for characterizing CH TRU waste: the Nondestructive Assay Box Counter (NABC).
   * Dose-to-curie (DTC) and the In Situ Object Counting System (ISOCS) for RH TRU waste.
   * Real-time radiography (RTR) for CH and RH TRU waste.
For logistical reasons, the inspection took place in three segments: AK was evaluated in Denver, Colorado on August 19 - 21, 2014; NDA, DTC and ISOCS were evaluated at SRS on August 20 - 21, 2014; and RTR was evaluated at SRS on October 15, 2014. Based on the results of this continued compliance inspection, EPA confirms that the SRS-CCP CH and RH TRU waste characterization programs in the configuration observed during this inspection are consistent with the limitations described in the baseline inspection reports (see EPA Docket Nos. A-98-49; II-A4-65, dated July 10, 2006, and A-98-49; II-A4-161, dated April 18, 2012) and subsequent EPA Tier 1 (T1) approvals. Attachments A.1 and A.2 summarize all of EPA's approvals of the SRS-CCP CH and RH TRU waste characterization programs.
Based on this inspection, EPA made several changes to the CH and RH tiering designations, as shown in Tables 1 and 2. Any use of VE to characterize CH waste is a new T1 change. During the 2006 baseline inspection, EPA approved SRS-CCP to use VE to characterize CH waste; however, EPA did not include this process in the continued compliance inspection scope because SRS-CCP is not currently prepared to use or demonstrate the CH VE process. Since EPA did not observe and review the CH VE process during the continued compliance inspection, the CH VE process must be approved in the future as a separate T1 evaluation.
EPA also made substantive changes to the AK, NDA, radiological characterization and RTR Tier 2 (T2) designations. These changes require DOE action:
   1. Submission to EPA of a list of all SRS-CCP AK Experts (AKEs) and Site Project Mangers (SPMs) who performed work in these roles during the previous quarter is a new CH and RH AK T2 change (see Tables 1 and 2).
   2. Submission to EPA of a list of all SRS-CCP NDA personnel who performed work during the previous quarter is a new NDA T2 change (see Table 1). Specifically, the list must include all operators, Expert Analysts (EAs) and Independent Technical Reviewers (ITRs).
   3. Submission to EPA of a list of all SRS-CCP DTC and ISOCS personnel who performed work during the previous quarter is a new radiological characterization T2 change (see Table 2). Specifically, the list must include all operators, EAs and ITRs.
   4. Submission to EPA of a list of all RTR personnel who performed work during the previous quarter is a new CH and RH RTR T2 change (see Tables 1 and 2). Specifically, the list must include all RTR operators and ITRs.
These changes to the T2 requirements are necessary to harmonize the SRS-CCP tiering designations consistent with the requirements identified during the baseline inspections and revised as needed as part of Tier 1 approvals and continued compliance evaluations at other CH and RH TRU sites. EPA also revised the tiering tables to remove duplicate entries and ensure completeness and consistency with recent EPA continued compliance and T1 approval reports. As part of the consistency edits, EPA 1) added an RH AK T1 requirement to explicitly state that addition of load management to any RH waste stream is a T1 change and 2) revised the RH AK T2 requirements to clarify the specific CCP-TP-005 Attachments for which EPA expects to receive T2 notification. Tables 1 and 2 show the substantive T1 and T2 changes for CH and RH in bold text. T1 and T2 changes that were initiated during the CH and RH baseline and subsequent T1 approvals remain in effect. The language in Tables 1 and 2 regarding AK documentation applies to all SRS-CCP waste streams.
The harmonization of the site-specific tiering tables serves the following objectives when waste characterization activities at the approved sites resume as waste emplacement at WIPP returns to a pre-February 2014 level:
   * DOE could gain efficiencies when demonstrating regulatory compliance to EPA; and
   * EPA inspects the site-based activities for baseline approval or continued compliance

EPA did not identify any findings during this inspection. EPA identified one concern requiring a response regarding necessary revisions to AK summary report (AKSR) CCP-AK-SRS-022. This concern is documented on the EPA Inspection Issue Tracking Form, Issue No. SRS-CCP-CH-CC-2014-01CR, which is included in Attachment C. SRS-CCP revised several documents during the inspection and provided them to EPA. Attachment I is a list of all documentation reviewed, including batch data reports (BDRs).

This report serves as EPA's public notification of the results of the continued compliance inspection. This information will be provided through the EPA website and by sending emails to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3).

Table 1.  Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented by SRS-CCP
(Based on October 31 - November 3, 2005, Baseline Inspection and Subsequent Tier 1 Evaluations, Updated February 2015)
                               Process Elements
          SRS-CCP CH Waste Characterization Processes  -  T1 Changes
          SRS-CCP CH Waste Characterization Processes  -  T2 Changes*
Acceptable Knowledge, including Load Management
Load management for the S3000 summary category group
Submission of a list of SRS-CCP CH AKEs and SPMs that performed work during the previous quarter
Notification to EPA upon completion of or substantive modification** to:
   * AK accuracy reports (annually, at a minimum)
   * AK-AK and AK-NDA/NDE Discrepancy Resolution Reports
   * WSPFs and AKSRs and related attachments (e.g., CIS) for all new or modified waste streams, including change notices
   * CCP-TP-005, Attachments 4, 6 and 7 and associated memoranda
   * Add Container Memoranda
   * The load management status of approved waste streams
   * Site procedures requiring CBFO approval
   * Any waste identified outside of the waste profiles included in the 2002 Transuranic Waste Baseline Inventory Report
   * Creation of newly generated soil or debris waste streams through remediation or decontamination and decommissioning activities
Nondestructive Assay
New equipment or substantive physical modifications** to approved equipment
Extension of or changes to the approved calibration range for approved equipment
Submission of a list of SRS-CCP NDA operators, EAs and ITRs that performed work during the previous quarter
Notification to EPA upon substantive modification** to:
   * Site procedures requiring CBFO approval
   * Software for approved equipment
   * Operating ranges upon CBFO approval
Real-Time Radiography
None
Submission of a list of SRS-CCP CH RTR operators and ITRs that performed work during the previous quarter
Notification to EPA upon:
   * New equipment or substantive physical modifications** to approved equipment
   * Substantive modification** to site procedures requiring CBFO approval
Visual Examination and Visual Examination Technique
Any use of visual examination
Notification to EPA upon substantive modification** to site procedures requiring CBFO approval
WIPP Waste Data System
Changes to Waste Data System algorithms specific to load management.
Notification to EPA upon substantive modification** to:
   * Site procedures requiring CBFO approval
   * The load management status of approved waste streams
 New T1s, T2s and significant modifications to existing T1s or T2s are in bold text; T1s or T2s that were only revised for style are not shown in bold.
 *	SRS-CCP will report all T2 changes to EPA every three months.
 **	"Substantive modification" refers to a change with the potential to affect SRS-CCP'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. EPA may request copies of new references that DOE adds during a document revision.

Table 2.  Tiering of Remote-Handled Transuranic Waste Characterization Processes Implemented by SRS-CCP
(Based on August 20 - September 1, 2011, and December 6 - 7, 2011, Baseline Inspection, Updated February 2015)
                               Process Elements
           SRS-CCP RH Waste Characterization Process  -  T1 Changes
           SRS-CCP RH Waste Characterization Process  -  T2 Changes*
Acceptable Knowledge

Any new SCG S3000 or S4000 RH waste stream
Any new SCG S5000 RH waste stream that does not have a companion CH waste stream
Load management for any RH waste stream
Substantive modification** to EPA-approved AKSRs and certification confirmation test plans (e.g., CCP-AK-SRS-580, CCP-AK-SRS-582, CCP-CP-SRS-562)
Submission of a list of SRS-CCP RH AKEs and SPMs that performed work during the previous quarter
Notification to EPA upon characterization of any new SCG S5000 RH waste stream that does have a companion CH waste stream
Notification to EPA upon availability of or nonsubstantive modification** to AKSRs and certification confirmation test plans (e.g., CCP-AK-SRS-580, CCP-AK-SRS-582, CCP-CP-SRS-562)
Notification to EPA upon availability of or modification to:
   * Site procedures requiring CBFO approval
   * CCP-TP-005 Attachments 4, 6, 8 and 15, including when Attachment 4 is generated to reflect the updated AKSR Source Document Reference List
   * WSPF, CIS, CRR and related attachments, and any subsequent revisions to these documents
   * AK accuracy reports (annually, at a minimum)
   * Add container memoranda
   * Additional discrepancy resolution reports and nonconformance reports
Radiological Characterization, including Dose-to-Curie
Use of the MCS/ISOCS to provide any information other than the relative determinations of gamma-emitting radionuclides for use as scaling factors
Future use of the ORTEC/ISOCS for any RH TRU waste
Application of new (i.e., not EPA-approved) scaling factor processes for isotopic determination (applies to new RH waste streams and to the addition of containers to an approved waste stream)
Substantive modification** to EPA-approved procedures or radiological characterization technical reports (e.g., CCP-TP-504, CCP-AK-SRS-581, CCP-RC-SRS-561)
Submission of a list of SRS-CCP DTC and ISOCS operators, EAs and ITRs that performed work during the previous quarter
Notification to EPA upon:
   * Characterization of any new RH waste stream using an approved scaling factor process for isotopic determination
   * Modification of the procedures or radiological characterization technical reports (e.g., CCP-TP-504, CCP-AK-SRS-581, CCP-RC-SRS-561) requiring CBFO approval
   * Availability of calculation package CCP-SRS-44 or equivalent records
Visual Examination
Any use of visual examination
N/A
Real-Time Radiography
Real-time radiography by any new process
Submission of a list of SRS-CCP RH RTR operators and ITRs that performed work during the previous quarter
Notification to EPA upon:
   * Substantive modification** to site procedures requiring CBFO approval
   * Characterization of SCG S3000 or S4000 RH waste by an approved process
  New T1s, T2s and significant modifications to existing T1s or T2s are in bold text; T1s or T2s that were only revised for style are not shown in bold.
  * 	SRS-CCP will report all unmarked T2 changes to EPA every three months.
  ** 	"Substantive modification" refers to a change with the potential to affect SRS-CCP's RH 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. EPA may request copies of new references that DOE adds during a document revision.

Purpose of Continued Compliance Inspections
Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, Federal Register notice, EPA must perform a single baseline inspection of a TRU waste generator site's waste characterization program (Vol. 69, No. 136, pages 42571 - 42583, July 16, 2004). The purpose of EPA's baseline inspection is to approve the site's waste characterization program, based on a demonstration that the program's components, with applicable conditions and limitations, can adequately characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes destined for disposal at the WIPP.
Following EPA's baseline approval, EPA has the authority to conduct continued compliance inspections to verify that the site (1) continues to use only the approved waste characterization processes to characterize the waste, and (2) remains in compliance with all the regulatory requirements in 40 CFR 194. EPA is also authorized to evaluate and approve changes (i.e., tiering changes), if necessary, to the site's approved waste characterization program by conducting additional inspections under the authority of 40 CFR 194.24(h).
EPA performs annual continued compliance inspections of each TRU waste characterization program, covering all elements of the programs, including the common elements of waste characterization processes that are not expected to significantly vary by waste stream. Examples of the common characterization elements are personnel training, procedures and equipment capabilities. EPA will consider the results of continued compliance inspections when setting the scope and evaluating site-specific T1 changes.
The results of this continued compliance inspection and the review of quarterly T2 changes submitted since the August 2014 inspection will be the basis for EPA's evaluation of any SRS-CCP T1 change requests submitted before the next EPA continued compliance inspection. Thus, EPA can focus on only those waste characterization components that are critical to the specific T1 change request, evaluation and approval (e.g., waste-stream-specific AK records). In addition, EPA may not revisit the elements discussed in this report until the next continued compliance inspection, at the Agency's discretion.
Inspection Personnel
EPA and its support personnel conducted interviews with SRS-CCP waste characterization personnel in several disciplines. The personnel contacted represented a sample of the CH and RH TRU waste characterization staff. The EPA inspection team and SRS-CCP personnel contacted are listed in Attachment B, with their affiliations and areas of expertise or function.
Purpose of This Report
This report documents the basis for EPA's decision to maintain the approval of the SRS-CCP waste characterization program for CH and RH TRU wastes. Specifically, this report:
      *       Describes the sample of the SRS-CCP waste characterization systems evaluated during this inspection.
      *       Identifies all areas where waste characterization systems have changed relative to what was approved during the baseline inspection and subsequent EPA T1 evaluations and assesses the impact, if any, of those changes.
      *       Provides objective evidence to support the basis for EPA's continued approval of all waste characterization systems.
      *       Describes any tests or demonstrations completed during the course of the inspection and their relevance to EPA's approval decision.
Scope of This Continued Compliance Inspection
The scope of this continued compliance inspection included the evaluation of selected elements of the waste characterization systems in use at SRS-CCP to characterize CH and RH TRU wastes that were approved during the baseline inspection and subsequent T1 evaluations. The waste characterization activities evaluated included AK for a subset of the CH and RH waste streams characterized in the year preceding this continued compliance inspection, the NABC NDA system for CH waste characterization, the DTC and ISOCS systems for RH waste characterization and RTR operations for CH and RH TRU waste.
Technical Evaluation
EPA's technical evaluation is summarized in sections 6.1 - 6.4 of this report. The details of EPA's technical evaluation are located in the completed inspection checklists, which are included in this report as Attachments D.1 - E and G.1 - H.2. When evaluating future T1 change requests and concurring with quarterly T2 change submissions, EPA may use these checklists to supplement their review. Attachments F.1 - F.2 contain the results of SRS-CCP's NDA replicate scanning as discussed in section 6.2.1, Item (8), of this report. The DOE documents that EPA reviewed for this evaluation are cited throughout the report and are listed in Attachment I. Any of these documents can be requested from the following address:
Manager, National TRU Sites and Transportation Division
Carlsbad Field Office
U.S. Department of Energy
P O Box 3090
Carlsbad, NM 88221-3090
Acceptable Knowledge for Contact-Handled and Remote-Handled Waste Characterization
Technical Evaluation: Contact-Handled Waste
EPA evaluated SRS-CCP's continued compliance with EPA-approved AK procedures for CH waste characterization. EPA has approved SRS-CCP's CH AK characterization program for Summary Category Group (SCG) S3000 (homogeneous solids), SCG S4000 (soils) and SCG S5000 (heterogeneous debris) waste. SRS-CCP personnel stated that SRS-CCP performed waste characterization activities for 26 CH Waste Streams in the year prior to this continued compliance inspection. EPA reviewed documents from 16 of these waste streams as representative samples of the SRS-CCP CH AK waste characterization program. The AK checklist used for this inspection is included in Attachment D.1. The 16 waste streams reviewed during this inspection are listed below in Table 3.
Table 3. Contact-Handled SRS-CCP Waste Streams Sampled for Review
Waste Stream
                                     AKSR*

Waste Stream
                                     AKSR*
SR‐W027‐FB‐Pre86‐C
                                      002

SR-AGNS-HOM
                                      011
SR-W026-221F-HET-A
                                      003

SR-SDD-HET-A
                                      013
SR-W027-221H-HET
                                      004

SR-DWPF-HET
                                      015
SR‐W026‐772F‐HET
                                      005

SR-KAC-HET-A
                                      018
SR‐W027‐235F‐HET
                                      006

SR-HBL-235F-HET
                                      020
SR-W027-773A-HOM
                                      007

SR-221H-EUOx
                                      022
SR-MD-SOIL
                                      008

SR-BCLDP.004.004
                                      540
SR-MD-PAD1
                                      009

      *The full AKSR citation for each waste stream is CCP-AK-SRS-XXX, where XXX represents the numbers indicated in the AKSR column. For example, the full citation for AKSR-002 is CCP-AK-SRS-002.
   (1) EPA examined select Central Characterization Program procedures and found them to be adequate.
EPA reviewed select CCP procedures for AK documentation, training of AKEs and disposition of nonconformances for technical sufficiency and scope. Specifically, EPA reviewed:
   * CCP-QP-002, Revisions 37 and 38, "Training and Qualification Plan," August 7, 2014
   * CCP-QP-005, Revision 24, "Nonconforming Item Reporting and Control," June 25, 2013.
   * CCP-TP-002, Revision 26, "Reconciliation of DQOs and Reporting Characterization Data," June 19, 2013.
   * CCP-TP-005, Revision 26, "CCP Acceptable Knowledge Documentation," August 12, 2013.
CCP revised CCP-QP-002 in June 2014 (Revision 37) and August 2014 (Revision 38) to address a Carlsbad Field Office (CBFO) corrective action report (CAR), the resolution of which was to state that the preferred method of determining a subject matter expert's (SME's) on-the-job training (OJT) is to examine his or her resume. The changes also included addition of and subsequent revisions to a template SME appointment letter that documents the SPM's determination that an individual is suitable as an EA, RH technical staff member, SME for a given NDA unit, or Visual Examination Expert. Text was also revised with respect to the qualification process of the RTR Operator/Independent Technical Reviewer.  These are significant procedural changes and EPA has determined that these changes will be examined as part of the T2 change review process because these changes apply to all CCP sites.  The remaining procedures adequately reflect the requirements of 40 CFR 194. Procedure implementation is evidenced by adequate preparation and maintenance of the required documentation, as reviewed below.
Notification to EPA upon completion of or substantive modification to site procedures requiring CBFO approval remains a T2 change (see Table 1).
   (2) EPA verified that SRS-CCP adequately implemented the acceptable knowledge characterization process for containers, including acceptable knowledge assembly, compilation and verification.
EPA evaluated SRS-CCP's completion of each of the 15 attachments associated with CCP procedure CCP-TP-005 (AK documentation) by reviewing samples of each attachment for Waste Streams SR-W027-773A-HOM, SR-MD-PAD1, SR-KAC-HET-A and SR-HBL-235F-HET.
The examined CCP-TP-005 attachments indicate that SRS-CCP is adequately implementing the AK characterization process. EPA identified a few inconsistencies between CCP-TP-005, Attachment 6s, and the associated waste material parameter (WMP) calculation memoranda. During the inspection, SRS-CCP AKEs did pen-and-ink revisions of the two WMP calculation memoranda to correct rounding errors.
Notification to EPA upon completion of or substantive modification to CCP-TP-005, Attachments 4, 6 and 7 and associated memoranda remains a T2 change (see Table 1).
   (3) EPA verified that waste traceability was adequately demonstrated.
EPA randomly selected containers from four of the active waste streams to assess traceability.  Selected waste streams and drums are presented in Table 4. Drums selected could be traced from original SRS packaging documentation including Burial Ground Records, TWCFF, Drum repackaging forms, and site-specific data bases.
Table 4. Contact-Handled Containers Evaluated for Traceability
Drum No.
Waste Stream
SR503072VB
SR-W027-221H-HET
772F000027
SR-W026-772F-HET
SR520533
SR-AGNS-HOM
HBL130022
SR-221H-EUOx
The four Waste Streams containers selected were traceable through original waste generation paperwork through SRS-CCP characterization.
   (4)  EPA assessed the acceptable knowledge summary reports and found them to be adequate.
EPA evaluated five of the AKSRs listed in Table 3 for inclusion of sufficient information, supported by appropriate source documents, to support the following statements:
   *          All waste within the waste stream was generated from a single process/activity.
   *          All waste within the waste stream is similar in material and physical form.
   *          All waste within the waste stream has similar radiological properties.
   *          All of the waste in the waste stream is defense in origin.
   *          None of the waste in the waste stream is high-level waste (HLW).[2]
   *          None of the waste in the waste stream is spent nuclear fuel (SNF).[2]
EPA found that the AKSRs for Waste Streams SR-W027-221H-HET, SR-W026-772F-HET, SR-W027-235F-HET, SR-AGNS-HOM are adequate. EPA found that the AKSR CCP-AK-SRS-22, Waste Stream SR-221H-EUOx, does not adequately address elements of the waste origin, waste generation processes, and the defense determination. EPA issued a concern requiring a response pertinent to these issues, see Attachment C. SRS-CCP provided the freeze file for this revision to EPA during the inspection. The final revised AKSR must be provided to EPA for review prior to resumption of characterization activities for Waste Stream SR-221H-EUOx.
Explanations and source documents supporting each of the above statements are included in the checklist in Attachment D.1.
Notification to EPA upon completion of or revisions to all AKSRs remains a T2 change (see Table 1).
   (5) EPA evaluated waste stream profile form preparation and completeness and found them to be adequate.
EPA reviewed the waste stream profile forms (WSPFs), including the characterization information summaries (CISs) and summations of aspects, and related change notices for Waste Streams SR-MD-SOIL, SR-SDD-HET-A and SR-BCLDP.004.004 and found them to be complete and adequate.
The WSPFs were examined and there were no major inconsistencies between the WSPF and AKSRs primarily because the WSPFs were relatively recent.  However, AKSRs are modified frequently and may contain significant changes to waste volume and composition that CCP's internal procedure does not require to be reflected in the WSPF.  As a result, older WSPFs and recent AKSRs may be inconsistent.  CCP previously had used Change Notices to document these inconsistencies so that anyone using the WSPFs could, in conjunction with the Change Notices, understand the current waste stream.  CCP abandoned using the Change Notices a few years ago, but EPA insists that the change notices and WSPF revision must be reinstated to ensure that up-to-date information is available within the WSPF for the Site and CBFO management. The change notices and WSPF revision is a new T2 change for all active TRU Sites with EPA approval given the February 2014 radiological release in the WIPP.
Notification to EPA upon completion of or revisions to all WSPFs and related attachments, including generation of any Change Notices, remains a T2 change (see Table 1).
   (6) EPA assessed acceptable knowledge personnel training and found it to be adequate.
SRS-CCP provided an extensive list of AKEs and SPMs that previously worked or continue to work in the SRS-CCP CH program. EPA reviewed training records for all of these individuals, including the three who were present or available by telephone during EPA's inspection: Jeff Harrison (AKE), Lisa Watson (AKE) and Beverly Schrock (SPM). SRS-CCP provided completed qualification cards and documentation showing familiarity of the AKEs and SPMs with the current revisions of AK procedures, except in the case of CCP-QP-002, Revision 38, "Training and Qualification Plan," August 7, 2014. For this procedure, SRS-CCP provided documented training to Revision 37.
Training records for the personnel listed above and in Attachment D.1 (checklist item AK-2) are complete and adequate with three exceptions:
   * Barbara Broomfield's SPM qualification card indicated that her qualification is valid for sites with attached site-specific addenda. CCP no longer requires site-specific addenda for SPMs; however, the documentation provided to EPA for Barbara Broomfield does not show this change in policy.
   * David Ams (AKE) and Sherry Auckland (AKE) are not listed on the SRS-CCP CH AKE and SPM Acknowledgement of CCP-TP-005, Revision 26.
EPA will review training records for Ms. Broomfield, Mr. Ams and Ms. Auckland, as well as any additional personnel, if they are indicated as actively supporting CH waste characterization in a future T2 change report.
Submission to EPA of a list of AKEs and SPMs who performed work in these roles for the SRS-CCP CH waste characterization program in the previous quarter is a new T2 change (see Table 1).
   (7) EPA assessed nonconformance and discrepancy resolution documentation and found it to be adequate.
EPA evaluated sample nonconformance and discrepancy resolution (DR) documentation from Waste Streams SR‐W027‐FB‐Pre86‐C, SR-W026-221F-HET-A, SR‐W027‐235F‐HET, SR-MD-PAD1, SR-DWPF-HET, SR-HBL-235F-HET and SR-221H-EUOx	. EPA evaluated sample NCRs, sample CCP-TP-005, Attachment 10s (AK re-evaluation checklists), and sample CCP-TP-005, Attachment 11s (DR reports) and found that SRS-CCP adequately prepared these documents, as necessary.
Notification to EPA upon completion of or substantive modification to AK-AK and AK-NDA/NDE DR reports remains a T2 change (see Table 1).
   (8) EPA assessed acceptable knowledge accuracy and found it to be adequate.
EPA reviewed recent AK accuracy reports for Waste Streams SR-W027-773A-HOM, SR-MD-PAD1 and SR-HBL-235F-HET and found them to be adequate. However, AK accuracy is calculated by comparing AK against measurement data after troublesome containers identified by fast scan and other pre-screening methods have been removed from the waste stream. Containers that were initially included in a waste stream but were removed prior to the WIPP-certifiable characterization do not count against AK accuracy. The AK accuracy report cannot be used to evaluate the accuracy of the original AK or the decision to include or exclude certain containers in the waste stream based on AK alone.
Notification to EPA upon completion of or substantive modification to AK accuracy reports (annually, at a minimum) remains a T2 change (see Table 1).
   (9) EPA assessed communication between acceptable knowledge and nondestructive assay personnel and found it to be adequate.
EPA reviewed the current AK-NDA memoranda for Waste Streams SR-W027-773A-HOM, SR-MD-PAD1, SR-KAC-HET-A and SR-HBL-235F-HET. EPA evaluated the memoranda for completeness, technical adequacy and compared the memoranda with the AKSRs and determined that the reviewed AK-NDA memoranda are adequate.
EPA noted that the expected radionuclides in CCP-TP-005, Attachment 7, for Waste Stream SR-W027-773A-HOM do not match the expected radionuclides in the associated AK-NDA memorandum. The SRS-CCP AKEs explained that they revised the AKSR and Attachment 7 for Waste Stream SR-W027-773A-HOM to replace the AK-expected radionuclides with expected radionuclides based on actual waste stream NDA data. SRS-CCP did not revise the AK-NDA memorandum in this case because there are no additional drums to characterize and therefore no need for the memorandum to be up to date. EPA expects if SRS identifies any additional containers for inclusion in Waste Stream SR-W027-773A-HOM, SRS-CCP will revise the AK-NDA memorandum prior to characterizing the additional containers.
Notification to EPA upon completion of or substantive modification to AK-NDA memoranda remains a T2 change (see Table 1).
   (10) EPA found load management to be adequately implemented.
The WIPP waste acceptance criteria allow that a payload container may include drums that measure less than 100 nanocuries per gram (nCi/g) of TRU radionuclides so long as the TRU Alpha Activity Concentration (TAAC) of the payload in total is greater than 100 nCi/g. The AKSR for each waste stream selected for payload management must include an estimate of the total waste volume and percentage of the waste volume that is above and below100 nCi/g TAAC. Each container selected for payload management must contain at least one TRU radionuclide whose activity exceeds the lower limit of detection (LLD) of the radioassay system used to characterize the waste (i.e., is measureable), and each container may only be overpacked into a payload container with other containers from the same TRU waste stream.
EPA examined the AKSRs for waste streams SR-W027-221H-HET, SR-W026-772F-HET, SR-AGNS-HOM and SR-221H-EUOx and found that three of the AKSRs stated that all payload containers will contain >100 nCi/g TRU isotopes (i.e., load management will not take place). SRS-CCP representatives stated that payload management of the fourth waste stream (Waste Stream SR-221H-EUOx) will not be performed, although the AKSR did not specifically address payload management.
Implementation of load management for the S3000 SCG remains a T1 change. Notification to EPA upon modification to the load management status of approved S5000 waste streams remains a T2 change (see Table 1).
   (11) EPA evaluated compliance with tiering requirements and found it to be adequate.
T2 notification to EPA upon completion of or substantive modification to the waste-stream-specific documents listed in Table 1 is required on a quarterly basis. EPA compared the revision dates of documents provided during this continued compliance inspection with the T2 notification reports provided to EPA by CBFO.
In general, EPA found that SRS-CCP is providing T2 notification as required. However, the 1[st] quarter report for fiscal year (FY) 2014 was incomplete and SRS-CCP has inconsistently notified EPA regarding the availability of CCP-TP-005 attachments (specifically Attachments 4 and 6) and add-container memoranda. EPA discussed these deficiencies with SRS-CCP and determined that the issues with the 1[st] quarter FY 2014 report were a one-time event. SRS-CCP agreed that the CCP-TP-005 attachments and add-container memoranda are being inconsistently included in the T2 notifications and made committed to improving their performance. EPA restated that all CH T2 requirements apply to all SRS-CCP CH waste streams, unless specifically stated otherwise.
The tiering changes identified during the SRS-CCP CH baseline inspection and subsequent T1 inspections remain in effect and are included as Table 1 of this document.
Summary of Acceptable Knowledge for Contact-Handled Waste
EPA did not identify any findings related to AK for CH waste as a result of this continued compliance inspection. EPA identified one concern requiring a response regarding the adequacy of AKSR CCP-AK-SRS-22 (see Concern No. SRS-CCP-CH-CC-2014-01CR in Attachment C). SRS-CCP provided the freeze file for this revision to EPA during the inspection. The final revised AKSR must be provided to EPA for review prior to resumption of characterization activities for Waste Stream SR-221H-EUOx. EPA considers the concern closed.
There are no changes to the T1 designations for CH AK as a result of this continued compliance inspection. Submission to EPA of a list of AKEs and SPMs who performed work in these roles for the SRS-CCP CH waste characterization program in the previous quarter is a new T2 change (see Table 1).
Based on the results of this evaluation and the data examined, EPA determines that SRS-CCP demonstrated continued AK characterization compliance for CH waste streams.
Technical Evaluation: Remote-Handled Waste
EPA evaluated SRS-CCP's continued compliance with EPA-approved AK procedures for RH waste characterization for SCG S5000 (heterogeneous debris) waste. SRS-CCP management stated that SRS-CCP performed waste characterization activities on four waste streams since EPA's 2012 RH baseline approval. SRS-CCP completely characterized Waste Stream SR-RH-SDD.01 prior to EPA's T1 approval; therefore, EPA did not include this waste stream in the scope of this continued compliance inspection. EPA reviewed documents associated with Waste Streams SR-RH-235F.01, SR-RH-FBL.01 and SR-RH-221H.01 as a representative sample of the SRS-CCP RH AK waste characterization program, all of which have companion CH waste streams. EPA reviewed the initial population of Waste Stream SR-RH-FBL.01 during the SRS-CCP RH baseline inspection. EPA has not previously reviewed AK documentation for Waste Streams SR-RH-235F.01 and SR-RH-221H.01. The AK checklist used for this inspection is included in Attachment D.2.
   (1) EPA examined select Central Characterization Program procedures and found them to be adequate.
EPA reviewed several CCP procedures for AK documentation, training of AKEs and disposition of nonconformances for technical sufficiency and scope. In addition to the procedures listed and discussed in section 6.1.1, Item (1), EPA reviewed CCP-TP-506, Revision 5. CCP modified CCP-TP-506, Revision 5, significantly with respect to Revision 4, including changes to attachment format and content, removal of AKE signatory requirements, and other modifications. These are significant procedural changes and EPA has determined that the changes to CCP-TP-506, Revision 5, will be examined as part of the T2 change review process because these changes apply to all CCP sites. The other procedures adequately reflect the requirements of 40 CFR 194. Procedure implementation is evidenced by adequate preparation and maintenance of the required documentation, as reviewed below.
Notification to EPA upon completion of or modification to site procedures requiring CBFO approval remains a T2 change (see Table 2).
   (2) EPA verified that SRS-CCP adequately implemented the acceptable knowledge characterization process for containers, including information assembly, compilation and verification.
EPA evaluated SRS-CCP's completion of the attachments associated with procedure CCP-TP-005 for AK documentation for Waste Streams SR-RH-235F.01, SR-RH-FBL.01, and SR-RH-221H.01. EPA evaluated whether SRS-CCP revised the attachments as necessary to incorporate the ongoing waste characterization and whether SRS-CCP prepared the attachments using forms from the appropriate revisions of CCP-TP-005. EPA found that SRS-CCP should have generated a revised Attachment 4 for Waste Stream SR-RH-FBL.01 at the same time that SRS-CCP revised the AKSR, or at least prior to the EPA continued compliance inspection. Also, the Correlation and Surrogate Summary Form (CSSF), Attachment 15, did not reflect that there are two CH companion streams for Waste Stream SR-RH-FBL.01. SRS-CCP provided revised versions of both the Attachments 4 and 15 in question during the inspection. EPA found that the rest of the attachments had been appropriately revised, as necessary.
Notification to EPA upon availability or modification of CCP-TP-005 attachments remains a T2 change. EPA revised the language in the tiering table to clarify that EPA expects to receive notification upon availability or modification of CCP-TP-005 Attachments 4, 6, 8 and 15, including when Attachment 4 is generated to reflect the updated AKSR Source Document Reference List (see Table 2).
   (3) EPA verified that SRS-CCP adequately demonstrated waste traceability.
EPA examined traceability from waste generation through characterization for newly characterized drums from all three waste streams, as shown in Table 5. EPA examined documentation for initial packaging and final drum identification and characterization. These data show that the final drums can be traced to the original sources.
Table 5. Remote-Handled Containers Evaluated for Traceability
Drum No.
Waste Stream
SR504231
SR-RH-235F.01
SR611464
SR-RH-FBL.01
SR545535
SR-RH-221H.01
SR522596A
SR-RH-221H.01
Traceability for Waste Streams SR-RH-235F.01, SR-RH-FBL.01 and SR-RH-221H.01 was adequately demonstrated.
   (4) EPA assessed the acceptable knowledge summary report and found it to be adequate.
EPA evaluated the AKSR for each sample waste stream to determine whether SRS-CCP appropriately developed or revised the document to account for all waste currently being characterized. EPA reviewed process information, radiological characterization, characterization progression, and other aspects of each waste stream to verify accuracy of the AKSR and adequacy of the waste stream determination. EPA found that SRS-CCP developed and subsequently revised each of the sample AKSRs to adequately document the subject waste.
Notification to EPA upon completion of or non-substantive modification to all AKSRs remains a T2 change; substantive modification to EPA-approved AKSRs remains a T1 change (see Table 2).
   (5) EPA evaluated waste stream profile form preparation and completeness and found them to be adequate.
EPA had not previously reviewed the final WSPF for any of these waste streams. EPA found all three WSPF to be adequate, but also identified room for improvement in all three. The WSPF procedure requires revision of the WSPF only if there are changes to the EPA hazardous waste numbers, content codes, or waste material parameter (WMP) weight estimates per unit of waste. Any other changes in the waste stream (i.e., projected volume of waste, generation dates, generating processes) are not currently reflected in the WSPF. Given the February 2014 radiological release from a nitrate-waste containing container EPA expects CCP to institute a process by which waste stream changes due to identification of additional hazardous waste characteristics must be documented as part of the WSPF record. EPA will continue to monitor the WSPF revision process to ensure that key information is available in the waste stream profile.
Notification to EPA upon availability of or modification to WSPFs, CIS, CRR and related attachments remains a T2 change (see Table 2).
   (6) EPA assessed acceptable knowledge personnel training and found it to be adequate.
SRS-CCP provided an extensive list of AKEs and SPMs that previously worked or continue to work in the SRS-CCP RH program. EPA reviewed training records for all of these individuals, including the four who were present during EPA's inspection: Kevin Peters (AKE), Steve Schafer (AKE), Laura Turner (SPM) and Charlie Turner (SPM). SRS-CCP provided completed qualification cards and documentation showing familiarity of the AKEs and SPMs with the current revisions of AK procedures, except in the case of CCP-QP-002, Revision 38, "Training and Qualification Plan," August 7, 2014. For this procedure, SRS-CCP provided documented training to Revision 37.
Training records for the personnel listed above and in Attachment D.2 (checklist item AK-2) are complete and adequate with one exception: Irene Joo's SPM qualification card indicated that her qualification is valid for sites with attached site-specific addenda. CCP no longer requires site-specific addenda for SPMs; however, the documentation provided to EPA for Ms. Joo does not show this change in policy.
EPA will review training records for Ms. Joo, as well as any additional personnel, if they are indicated as actively supporting RH waste characterization in a future T2 change report.
Submission to EPA of a list of AKEs and SPMs who performed work in these roles for the SRS-CCP RH waste characterization program in the previous quarter is a new T2 change (see Table 2).
   (7) EPA assessed nonconformance and discrepancy resolution documentation and found it to be adequate.
SRS-CCP has not generated any AK-related NCRs or any AK re-evaluation checklists (CCP-TP-005, Attachment 10s) for any of the subject RH waste streams; EPA reviewed DR reports for Waste Streams SR-RH-235F.01 and SR-RH-221H.01. EPA determined that SRS-CCP is adequately preparing the DR reports and that the lack of Attachment 10s is also appropriate.
Notification to EPA upon completion of or modification to DR reports and NCRs for AK nonconformances remains a T2 change (see Table 2).
   (8) EPA assessed acceptable knowledge accuracy and found it to be adequate.
EPA evaluated the most recent AK accuracy reports for Waste Streams SR-RH-235F.01, SR-RH-FBL.01 and SR-RH-221H.01 and found that the reports did not adequately address requirements for comparison of AK and measurement results in the case of significant discrepancies. SRS-CCP provided revised versions of all three AK accuracy reports to EPA during the inspection. The revised AK accuracy reports are technically adequate.
Notification to EPA upon availability of or modification to AK accuracy reports (annually, at a minimum) remains a T2 change (see Table 1).
   (9) EPA evaluated the certification plans and identification of data quality objectives in the certification plan, and found them to be adequate.
EPA reviewed the certification plans for Waste Streams SR-RH-235F.01, SR-RH-FBL.01 and SR-RH-221H.01 and found them to adequately describe the role of AK in waste characterization.  Further, the certification plans also adequately described the data quality objectives related to defense, HLW and SNF determination as well as those related to radioactive properties and physical properties.
Notification to EPA upon availability of or nonsubstantive modifications to certification plans remains a T2 change; substantive modification to certification plans remains a T1 change (see Table 2).
   (10) EPA found load management to not be applicable.
The WIPP waste acceptance criteria allow payload management such that a payload container may include drums that measure less than 100 nCi/g so long as the TAAC of the payload in total is greater than 100 nCi/g. SRS-CCP does not intend to load manage any RH waste streams.
EPA modified the RH tiering table to explicitly state that addition of load management to any RH waste stream is a T1 change (see Table 2). This language is consistent to EPA tiering requirements at other waste characterization sites.
   (11) EPA evaluated compliance with tiering requirements and found it to be adequate.
T2 notification to EPA upon completion of or substantive modification to the waste-stream-specific documents listed in Table 2 is required on a quarterly basis. EPA compared the revision dates of documents provided during this continued compliance inspection with the T2 notification reports provided to EPA by CBFO.
In general, EPA found that SRS-CCP is providing T2 notification, as required. However, SRS-CCP has not notified EPA regarding the availability of any CCP-TP-005 attachments and inconsistently provides notification of add-container memoranda. SRS-CCP also did not notify EPA regarding the availability of the AK accuracy reports, which were completed during the 3[rd] quarter of FY 2014. EPA discussed these deficiencies with SRS-CCP and determined that the RH T2 requirements need to be clarified to identify the specific CCP-TP-005 attachments for which EPA expects to receive notification [see Item (2) of this section].  EPA also restated that all RH T2 requirements apply to all SRS-CCP RH waste streams, unless specifically stated otherwise.
The tiering changes identified during the SRS-CCP RH baseline inspection and subsequent T1 inspections remain in effect and are included as Table 2 of this document.
Summary of Acceptable Knowledge for Remote-Handled Waste
EPA did not identify any findings or concerns related to AK for RH SCG S5000 waste as a result of this continued compliance inspection.
There are no changes to the T1 designations for RH AK as a result of this continued compliance inspection. Submission to EPA of a list of AKEs and SPMs who performed work in these roles for the SRS-CCP RH waste characterization program in the previous quarter is a new T2 change. EPA also revised an existing T2 change to clarify that EPA expects to receive notification upon availability or modification of CCP-TP-005 Attachments 4, 6, 8 and 15, including when Attachment 4 is generated to reflect the updated AKSR Source Document Reference List. The changes are indicated in bold in Table 2. In addition, all RH T2 requirements apply to all SRS-CCP RH waste streams, unless specifically stated otherwise.
Based on the results of this evaluation and the data examined, EPA determines that SRS-CCP demonstrated continued AK characterization compliance for RH SCG S5000 waste streams.
Acceptable Knowledge Findings and Approval
Summary of Acceptable Knowledge Findings and Concerns
EPA did not identify any findings related to AK as a result of this continued compliance inspection. EPA identified one concern requiring a response regarding the adequacy of AKSR CCP-AK-SRS-22 (see Concern No. SRS-CCP-CH-CC-2014-01CR in Attachment C). SRS-CCP provided the freeze file for this revision to EPA during the inspection. The final revised AKSR must be provided to EPA for review prior to resumption of characterization activities for Waste Stream SR-221H-EUOx. EPA considers the concern closed.
Acceptable Knowledge Approval
There are no changes to the T1 designations for CH AK as a result of this continued compliance inspection. EPA modified the RH AK T1 designations to explicitly state that addition of load management to any RH waste stream is a T1 change (see Table 2).
Submission to EPA of a list of AKEs and SPMs who performed work in these roles for the SRS-CCP CH and RH waste characterization programs in the previous quarter is a new T2 change (see Tables 1 and 2). EPA also revised an existing T2 change to clarify that EPA expects to receive notification upon availability or modification of CCP-TP-005 Attachments 4, 6, 8 and 15, including when Attachment 4 is generated to reflect the updated AKSR Source Document Reference List (see Table 2).
Based on the results of this evaluation and the data examined, EPA determines that SRS-CCP demonstrated continued AK characterization compliance.
Nondestructive Assay for Contact-Handled Waste Characterization
SRS-CCP currently has one NDA system approved for WIPP assays of CH TRU wastes: the NABC. EPA approved the NABC initially during a T1 evaluation in August 2009 (EPA Docket No. A-98-49; II-A4-114) and has evaluated its operation in five subsequent T1s, as shown in Attachment A.1. SRS-CCP demonstrated the system's ability to perform the required analyses during the baseline inspection and confirmed it during subsequent T1 evaluations. Accordingly, this inspection focused on the following:
   * Confirmation that the design and technical capabilities of the NABC's hardware and software had not changed since EPA's last inspection.
   * Adequacy of the current revisions of the SRS-CCP NABC procedures and documents.
   * Operational and maintenance history of the NABC since the last EPA inspection.
   * Knowledge, understanding and training status of SRS-CCP NDA personnel.
   * Replicate testing of the NABC as outlined in the EPA Replicate Testing Protocol.
Technical Evaluation: Nondestructive Assay Box Counter
EPA evaluated SRS-CCP's continued compliance with the EPA-approved waste characterization program for CH waste using the NABC NDA system. The checklist used for this inspection is included in Attachment E. EPA evaluated the following aspects of the NABC during this inspection.
   (1) The Nondestructive Assay Box Counter nondestructive assay system is the same system that EPA approved previously, has not been moved or relocated and has essentially the same functions as when first approved.
The NABC is located at SRS, E Area, Building 643-43E, and is operated by SRS-CCP. It is a bimodal system consisting of a Box Segmented Gamma System (BSGS) and a Box Neutron Assay System (BNAS). The NABC is configured for CH TRU wastes in three container types (geometries): 55-gallon (208-liter) drums, standard waste boxes (SWBs) and standard large boxes (SLB-2s). It has two configurations: the near-field and far-field. SRS-CCP documents refer to the far-field configuration as the "stand off geometry" or the "five-foot setback."
This is the same system as EPA inspected and approved previously. The NABC has not been moved since EPA approved it initially in 2009. During this inspection, EPA verified that there have been no substantive changes to this system since EPA's last inspection. There were no concerns regarding these aspects of the NABC at SRS-CCP.
   (2) EPA assessed the design and operational range of the Nondestructive Assay Box Counter and found them to be unchanged from the last inspection and adequate for the radionuclide content and physical composition of the wastes currently being assayed.
Subsequent to EPA's baseline approval of the NABC in 2009, EPA has approved the NABC for assaying 55-gallon drums, SWBs and SLB-2s in both the near-field and far-field geometries. As detailed in EPA's previous T1 reports, all measurement configurations, container sizes and assay modes (filtered or non-filtered) for the NABC were unchanged. The operational ranges for all assay configurations with respect to radionuclide composition (Weapons Grade Pu or [239]Pu and Heat Source Pu or [238]Pu) and concentration, and physical form (matrix) were unchanged.
EPA observed SRS-CCP personnel perform the complete BSGS assay of container No. SR515955, and the startup and daily source checks for the BNAS. There were no concerns regarding the adequacy of the design and operational range of the NABC.
   (3) SRS-CCP performed and documented system calibration and calibration confirmation of the Nondestructive Assay Box Counter as required.
The NABC BSGS calibrations were performed at Canberra's facility in Meriden, Connecticut, for all three geometries and were confirmed by SRS-CCP. The BSGS calibrations had been updated in conjunction with the T1 changes (see Attachment A) and EPA had approved all updated calibrations previously. Calibration of the BNAS was performed at the Canberra facility in Meriden, Connecticut, for all appropriate parameters for all three geometries and these had been verified and documented. EPA established this during the baseline inspection in 2009 and subsequent T1 evaluations, see Attachment A.1. The BNAS calibrations were essentially unchanged for the T1 changes subsequent to the baseline approval. There were no concerns regarding the technical aspects of the NABC calibration or its documentation.
   (4) Determination and documentation for the total measurement uncertainty for the Nondestructive Assay Box Counter are adequate.
The determination of total measurement uncertainty (TMU) for the NABC is addressed in "Savannah River Gamma Box Counter Calibration Report Alternatives for Non-Destructive Assay (NDA) of Large Containers to Allow Shipping in TRUPACT III without Resizing and/or Repackaging," Canberra Document No. 40945. EPA had evaluated this document previously and determined during this evaluation that it was unchanged. There were no concerns regarding the determination and documentation of TMU for the NABC.
   (5) SRS-CCP determined and documented the lower limit of detection, including the minimum detectable concentration of the Nondestructive Assay Box Counter, as required.
The lower limits of detection (LLD) for the NABC had been determined and documented for all near-field assay configurations. The LLDs for far-field configurations are more complex. There are three configurations where SRS-CCP could not demonstrate the NABC's ability to discriminate TRU and non-TRU at 100 nanocurie per gram (nCi/g) in the far-field configuration, specifically:
   * Assaying SLB2s.
   * The attenuated-mode "summed spectrum" configuration for any container, where the actual LLD is on the order of 300 nCi/g.
   * The BNAS component of the NABC for predominantly plutonium-238 ([238]Pu)-bearing wastes.
All containers that the NABC assays in the five-foot setback configuration were previously assayed in the near-field configuration and exhibited high dead-times, often as a result of high concentrations of [238]Pu. Accordingly, these containers are assumed to have TRU concentrations in excess of 100 nCi/g. SRS-CCP expects to use the far-field setback configuration to assay only containers with easily measureable concentrations of TRU radionuclides, making the inability to sort at the TRU/non-TRU criterion not applicable for the far-field configuration. There were no concerns regarding the determination and documentation of the LLD for the NABC.
   (6) The Nondestructive Assay Box Counter had successfully participated in the performance demonstration program, as required.
The NABC successfully completed NDA performance demonstration program (PDP) Cycle B12A for SWBs, and was most recently approved by CBFO on November 1, 2012. The NABC successfully completed NDA PDP Cycle 20B for 55-gallon drums and was most recently approved by CBFO on September 17, 2013. There were no concerns regarding the NABC's participation in the CBFO-sponsored NDA PDP.
   (7) EPA assessed personnel training and found it to be adequate.
The SRS-CCP list of qualified individuals (LOQI) dated June 27, 2014, showed four qualified NABC operators and two EAs. EPA verified the training of the NABC operator who performed the BSGS, Tim Carlton, and the BNAS operator, Tom Shepley, by reviewing their qualification cards. Both individuals were current on all applicable training. There were no concerns regarding training for SRS-CCP NABC personnel.
   (8) SRS-CCP performed replicate testing of the Nondestructive Assay Box Counter unit. EPA evaluated the results and found the testing to comply with the criteria for the Environmental Protection Agency Replicate Testing Protocol.
The purpose of the replicate testing performed as part of this inspection is to provide EPA with an independent means to verify that the NABC can provide reproducible results for the determination of the quantity of 10 WIPP-tracked radionuclides [americium-241 ([241]Am), cesium-137 ([137]Cs), [238]Pu, [239]Pu, [240]Pu, [242]Pu, strontium ([90]Sr), uranium-233 ([233]U), [234]U and [238]U] and the TRU alpha activity concentration.  This is accomplished by re-assaying containers previously measured on the same system, in order 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 EPA's evaluation of the NABC, EPA requested that the NABC re-assay two containers that EPA randomly selected from a list of previously assayed containers: Nos. SR515955 and SR21524421. Both containers were re-assayed on the NABC unit five times, and the data for the five replicates and the original assay were analyzed using two statistical tests, a chi-squared (χ[2]) test, and a t-test. The EPA inspection team observed operation of the NABC as it performed the assay of SLB-2 No. SR515955. Attachments F.1 and F.2 include data and results of the statistical analyses for all assays.
The t-test for both containers assayed on the NABC did not show any statistically significant differences between the original measurement assay values and the average of the five replicate measurements for the activities of any of the target radionuclides or the TRU alpha activity concentration. The χ[2] test for both containers assayed on the NABC 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.  There are no technical issues associated with replicate testing of the NABC.
Nondestructive Assay Findings and Approval
Summary of Nondestructive Assay Findings and Concerns
EPA did not identify any findings or concerns for the NABC NDA system at SRS-CCP.
Nondestructive Assay Approval
There are no changes to the T1 designations for NDA as a result of this continued compliance inspection. Submission to EPA of a list of all NDA personnel who performed work during the previous quarter is a new NDA T2 change (see Table 1). Specifically, the list must include all operators, EAs and ITRs.
Based on the results of this evaluation and the data examined, EPA determines that SRS-CCP demonstrated continued compliance with the EPA-approved waste characterization program for the NABC NDA system.
Radiological Characterization for Remote-Handled Waste
EPA approved the DTC and ISOCS processes at SRS-CCP initially during the RH baseline inspection in April 2012 (EPA Docket No. A-98-49; II-A4-161).
Technical Evaluation: Dose-to-Curie
EPA evaluated SRS-CCP's continued compliance with EPA-approved DTC procedures for RH waste characterization. The checklist used for this inspection is included in Attachment G.1. EPA evaluated the following aspects of DTC during this inspection:
   (1) EPA observed the dose-to-curie technique, including source checks, and confirmed it was consistent with the EPA-approved process.
EPA initially observed the DTC technique at SRS-CCP in the DTC alcove located in Area E, Pad 4, as part of the RH baseline inspection and subsequently for a T1 evaluation (see Attachment A.2). During this inspection, SRS-CCP performed a DTC demonstration on August 21, 2014, using a previously-characterized RH TRU waste drum (No. SR522331) and the EPA-approved equipment and procedures. SRS-CCP personnel performed all appropriate source checks, number of measurements, etc., as if the assay was the measurement of record for the container, as detailed in the DTC checklist (see Attachment G.1). The process was unchanged from the configuration that EPA approved previously. There were no concerns regarding the execution and documentation of the DTC event at SRS-CCP.
   (2) EPA assessed personnel training and found it to be adequate.
The SRS-CCP LOQI dated June 27, 2014, showed three qualified operators and two EAs. EPA verified the training of the DTC operator, Tim Carlton, by reviewing his qualification card, which showed him to be current on all applicable training. There were no concerns regarding training for SRS-CCP DTC personnel.
Summary of Dose-to-Curie for Remote-Handled Waste
EPA did not identify any findings or concerns related to DTC for RH waste as a result of this continued compliance inspection. There are no changes to the T1 designations for radiological characterization as a result of this continued compliance inspection. Submission to EPA of a list of all DTC personnel who performed work during the previous quarter is a new radiological characterization T2 change (see Table 2). Specifically, the list must include all operators, EAs and ITRs. Based on the results of this evaluation and the data examined, EPA determines that SRS-CCP demonstrated continued DTC compliance for RH waste.
Technical Evaluation: In Situ Object Counting System
EPA evaluated SRS-CCP's continued compliance with EPA-approved ISOCS procedures for RH waste characterization. The checklist used for this inspection is included in Attachment G.2. EPA evaluated the following aspects of the ISOCS during this inspection:
   (1) EPA observed operation of the In Situ Object Counting System for a TRU waste container.
The ISOCS is a portable system by design and can easily be relocated to a new area, as needed. EPA observed its operation at SRS in E Area, Building 643-43E, at the other end of the structure housing the NABC, the same location as was observed previously.
The ISOCS provides relative determinations, i.e., ratios of two measured radionuclides, as opposed to absolute determinations. Accordingly, EPA limited its evaluation to observing the ISOCS operation on a RH TRU waste container that was available, since SRS-CCP was not actively using the ISOCS for routine assays, EPA observed its operation on a previously-assayed waste container drum that SRS had available. SRS-CCP personnel made entries in the appropriate ISOCS logbook, successfully performed required source checks and initiated measurement of container No. SR52231. EPA observed the spectrum that ISOCS generated for the RH waste drum, and confirmed that several peaks relating to specific, relevant gamma-emitting radionuclides were visible. There were no concerns regarding SRS-CCP's use of the ISOCS.
   (2) EPA assessed the training of In Situ Object Counting System personnel and found it to be adequate.
The SRS-CCP LOQI dated June 27, 2014, showed three qualified operators, two qualified SMEs and two EAs. EPA verified the training of the ISOCS operator, Tim Carlton, by reviewing his qualification card, which showed him to be current on all applicable ISOCS training. There were no concerns regarding training for SRS-CCP ISOCS personnel.
Summary of In Situ Object Counting System for Remote-Handled Waste
EPA did not identify any findings or concerns related to ISOCS for RH waste as a result of this continued compliance inspection. There are no changes to the T1 designations for radiological characterization as a result of this continued compliance inspection. Submission to EPA of a list of all ISOCS personnel who performed work during the previous quarter is a new radiological characterization T2 change (see Table 2). Specifically, the list must include all operators, EAs and ITRs. Based on the results of this evaluation and the data examined, EPA determines that SRS-CCP demonstrated continued ISOCS compliance for RH waste.
Radiological Characterization Findings and Approval
Summary of Radiological Characterization Findings and Concerns
EPA did not identify any findings or concerns for radiological characterization at SRS-CCP.
Radiological Characterization Approval
There are no changes to the T1 designations for radiological characterization as a result of this continued compliance inspection. Submission to EPA of a list of all DTC and ISOCS personnel who performed work during the previous quarter is a new radiological characterization T2 change (see Table 2). Specifically, the list must include all operators, EAs and ITRs.
Based on the results of this evaluation and the data examined, EPA determines that SRS-CCP demonstrated continued compliance with the EPA-approved waste characterization program for radiological characterization.
Nondestructive Examination for Contact-Handled and Remote-Handled Waste Characterization
EPA evaluated SRS-CCP's continued compliance with EPA-approved RTR procedures for RH and CH waste and found compliance to be adequate. The RTR checklist used for this inspection is included in Attachment H.
Technical Evaluation: Real-Time Radiography
   (1) EPA observed real-time radiography examination of a drum and found it to be adequate.
On October 15, 2014, EPA observed the RTR evolution for container No. 773A120021 from BDR No. SR4RTR0365. This 55-gallon container was a debris drum from Waste Stream SR-W027-773A-HET (SCG S5400). The operator had successfully completed the image quality check prior to EPA's arrival and the demonstration commenced at the start of the examination of the above referenced drum. The operator properly examined the container's contents and entered characterization data into the electronic data sheet. The operator determined that the waste matched the waste stream description and verified the waste matrix code (WMC). The operator used procedure CCP-TP-053, Revision 15, to guide the examination and did not identify any prohibited items in the container.
The EPA inspector determined the procedure and processes used continue to be adequate and effective for generation of compliant RTR data.
   (2) EPA examined real-time radiography characterization records and found them to be adequate.
EPA reviewed the audio/visual (A/V) and written records for selected containers from CH BDR Nos. SRLBR0115 and SR4RTR0271 and from RH BDR Nos. SRLBR0098, SRLBR0120, SR4RTR0248, SR4RTR0363 and SR4RTR0364 and determined that the records were complete and generated in accordance with CCP procedures. An image quality check had been performed prior to each RTR event for the BDRs examined and the required quality control (QC) examinations had been performed. TRT operators had properly examined and identified each container's contents and entered characterization data into an electronic data sheet. The containers reviewed include SCG S5000 (debris) and S3000 (sludge) wastes. RTR operators determined if the waste matched the waste stream description and verified the WMC.
The operators had initiated NCRs as needed for multiple containers in some of the reviewed BDRs. NCR Nos. NCR-SRS-0623-13 and NCR-SRS-0624-13 were generated for containers in BDR No. SRLBR0115. NCR Nos. NCR-RHSRS-0687-13 and NCR-RHSRS-0689-13 were generated for containers in BDR No. SRLBR0098. All reviewed NCRs had been processed and dispositioned in accordance with SRS-CCP procedures.
The SRS-CCP RTR BDRs had been reviewed at the data generation and SPM levels; the reviews were recorded on the appropriate forms from CCP-TP-053 and CCP-TP-001.
   (3) EPA examined real-time radiography training records and found them to be adequate.
The EPA inspectors reviewed training records, including Qualification Cards and Test and Training container examination records, for selected RTR operators. EPA determined that RTR operators continue to be trained in accordance with CCP procedures and that training records were readily available for review. EPA reviewed a list of qualified individuals and determined that the operator performing the on-site RTR demonstration was properly trained and qualified.
Real-Time Radiography Findings and Approval
Summary of Real-Time Radiography Findings and Concerns
EPA did not identify any findings or concerns related to RTR for CH and RH wastes as a result of this continued compliance inspection.
Real-Time Radiography Approval
Submission to EPA of a list of all RTR personnel who performed work during the previous quarter is a new RTR T2 change (see Tables 1 and 2). Specifically, the list must include all operators and ITRs.
Based on the results of this evaluation and the data examined, EPA determines that SRS-CCP demonstrated continued RTR compliance for CH and RH waste.
EPA expects SRS-CCP to continue to maintain RTR proficiency particularly now when most legacy waste has been packaged, characterized and shipped or readied for shipment to WIPP.

Findings and Concerns
EPA did not identify any findings during this continued compliance inspection. EPA identified one concern requiring a response regarding necessary revisions to AKSR CCP-AK-SRS-022. This concern is documented on the EPA Inspection Issue Tracking Form, Issue No. SRS-CCP-CH-CC-2014-01CR, which is included in Attachment C. The concern is closed and there are no open concerns as a result of this continued compliance inspection.
Conclusions
Changes to Tiering
EPA made several changes to the CH and RH tiering designations, as shown in Tables 1 and 2. Any use of VE to characterize CH waste is a new T1 change. During the 2006 baseline inspection, EPA approved SRS-CCP to use VE to characterize CH waste; however, EPA did not include this process in the continued compliance inspection scope because SRS-CCP is not currently prepared to use or demonstrate the CH VE process. Since EPA did not observe and review the CH VE process during the continued compliance inspection, the CH VE process must be approved in the future as a separate T1 evaluation.
EPA also made substantive changes to the AK, NDA, radiological characterization and RTR T2 designations. These changes require DOE action:
   1. Submission to EPA of a list of all SRS-CCP AKEs and SPMs who performed work in these roles during the previous quarter is a new CH and RH AK T2 change (see Tables 1 and 2).
   2. Submission to EPA of a list of all SRS-CCP NDA personnel who performed work during the previous quarter is a new NDA T2 change (see Table 1). Specifically, the list must include all operators, EAs and ITRs.
   3. Submission to EPA of a list of all SRS-CCP DTC and ISOCS personnel who performed work during the previous quarter is a new radiological characterization T2 change (see Table 2). Specifically, the list must include all operators, EAs and ITRs.
   4. Submission to EPA of a list of all RTR personnel who performed work during the previous quarter is a new CH and RH RTR T2 change (see Tables 1 and 2). Specifically, the list must include all RTR operators and ITRs.
These changes to the T2 requirements are necessary to make the SRS-CCP tiering designations consistent with the requirements at other CH and RH TRU sites and to support EPA's process for conducting T1 evaluations. EPA also revised the tiering tables to remove duplicate entries and ensure completeness and consistency with recent EPA continued compliance and T1 approval reports. As part of the consistency edits, EPA 1) added an RH AK T1 requirement to explicitly state that addition of load management to any RH waste stream is a T1 change and 2) revised the RH AK T2 requirements to clarify the specific CCP-TP-005 Attachments for which EPA expects to receive T2 notification. Tables 1 and 2 show the substantive T1 and T2 changes for CH and RH in bold text. T1 and T2 changes that were initiated during the CH and RH baseline and subsequent T1 approvals remain in effect. The language in Tables 1 and 2 regarding AK documentation applies to all SRS-CCP waste streams.
Approval
EPA determined that the SRS-CCP waste characterization program activities continue to be technically adequate. The scope of the compliance decision is based on EPA's inspection completed August 19 - 21 and October 15, 2014.

ATTACHMENT A.1: APPROVAL SUMMARY FOR SRS-CCP CONTACT-HANDLED WASTE CHARACTERIZATION PROGRAM
                               Approved Activity
                     EPA Inspection Number, Approval Dates
                               EPA Docket Number
   SRS-CCP CH Baseline Approval
                        EPA-SRS-10.05-8
July 10, 2006
                               A-98-49; II-A4-65
   T1 Change  -  Approval of Segmented Gamma Scanner, Nondestructive Assay System
                                August 29, 2007
                               A-98-49; II-A4-90
   T1 Change  -  Approval of Nondestructive Assay Box Counter, Nondestructive Assay System
                                August 4, 2009
                              A-98-49; II-A4-114
   T1 Change  -  Addition of S3000 Solids
                                March 23, 2010
                              A-98-49; II-A4-123
   T1 Change  -  Extension of the Calibrated Range of the NABC BSGS to 7.18 g 238Pu Using a 20-Minute Counting Time
                              September 14, 2010
                              A-98-49; II-A4-133
   T1 Change  -  Changing to an Efficiency-based Calibration for NABC BSGS
                                 May 31, 2011
                              A-98-49; II-A4-148
   T1 Change  -  NABC BSGS 5-ft Setback for 55-gallon drums
                              September 11, 2012
                              A-98-49; II-A4-166
   T1 Change  -  NABC BSGS 5-ft Setback for SWBs
                               February 21, 2013
                              A-98-49; II-A4-171
   T1 Change  -  NABC BSGS 5-ft Setback for SLB-2s
                                March 24, 2014
                              A-98-49; II-A4-182

ATTACHMENT A.2: APPROVAL SUMMARY FOR SRS-CCP REMOTE-HANDLED WASTE CHARACTERIZATION PROGRAM
                               Approved Activity
                     EPA Inspection Number, Approval Dates
                               EPA Docket Number
SRS RH Baseline Approval
                    EPA-SRS-CCP-RH-08.11-8, April 18, 2012
                              A-98-49; II-A4-161
T1 Change  -  Addition of Waste Stream SR-RH-235F.01
                               February 11, 2013
                              A-98-49; II-A4-170
T1 Change  -  Addition of Waste Stream SR-RH-221H.01
                                August 20, 2013
                              A-98-49; II-A4-177
T1 Change  -  Addition of Waste Stream SR-RH-SDD.01
                                 May 22, 2014
                              A-98-49; II-A4-184

ATTACHMENT B: INSPECTION PERSONNEL
                                   Personnel
                                  Affiliation
                          AREA OF EXPERTISE/FUNCTION
                               Entrance Meeting
                                  Interviewed
                                     Exit
                                    Meeting
Rajani Joglekar
                                 U.S. EPA ORIA
                          EPA Inspector - Team Leader

Ed Feltcorn
                                 U.S. EPA ORIA
                                 EPA Inspector

Dorothy Gill
                                SC&A, Inc.
                               RTR/VE Inspector

Connie Walker
                                SC&A, Inc.
                                 AK Inspector

Kira Darlow
                                SC&A, Inc.
                                 AK Inspector

Patrick Kelly
                                SC&A, Inc.
                  NDA/Radiological Characterization Inspector

Beverly Schrock
                                      CCP
                                    CH SPM

Byron Gelderman
                                    SRS-CCP
                                 RTR Operator

Charles Turner
                                      CCP
                                    RH SPM

Dale Bignell
CBFO/CTAC
                                   Observer

Dan Remington
                                    MCS/NDA
                             NDA Senior Scientist

Ed Gulbransen
                                    NWP/CCP
                                  CCP Manager

Erin Pennala
                                      MCS
                                General manager

Georgia Kareis
                                    SRS-CCP
                            RTR Lead Operator, SME

Irene Joo
NWP/CCP
                                  RH Manager

Jake Knox
                                    NWP/CCP
                             Site Project Manager

Jeff Harrison
                                    SRS-CCP
                                      AKE

Joe Harvill
                                    NWP/CCP
                                  NDA Support

Kevin Peters
                                    SRS-CCP
                                      AKE

Laura Turner
                                      CCP
                                    RH SPM

Lee Fox
                                     SRNS
                         Site Technical Representative

Lisa Watson
                                    SRS-CCP
                                      AKE

Pat Tilman
                                    CCP/NWP
                         SRS Characterization Manager

Ronnie Lee
                                      CCP
                              SRS Project Manager

Steve Schafer
                                    SRS-CCP
                                      AKE

Tim Carlton
                                    MCS/NDA
                            NABC & DTC Operator

Todd Shepley
                                    MCS/NDA
                               NDA Lead Operator

Tom Morgan
                                     CBFO

              ATTACHMENT C: EPA INSPECTION ISSUE TRACKING FORM,
                   ISSUE NO. SRS-CCP-CH-CC-2014-01CR, FINAL
Inspection No. SRS-CC-2014
Issue Number:  SRS-CCP-CH-CC-2014-01CR
Date: August 21, 2014, Final
Inspector: C. Walker
Attachments?   YES     NO
Sample Size: 1 AKSR
Population size (if known):
Description of Issue: The AK Summary Report (AKSR) CCP-AK-SRS-22, Waste Stream SR-221H-EUOx, does not adequately address elements of the waste origin, waste generation processes, and the defense determination.  To address these issues, AKSR CCP-AK-SRS-22 will be revised to address the following:

a. Indicate that the entire waste stream will be blended or remove reference to only 30 containers being blended.
b. Better address the general process origin of the uranium oxides for each of the three oxide sources to indicate material origin, general (few sentences or small paragraph) process information, material management/transfer information, etc.  This discussion does not need to detail accountable material generation but should provide enough information to define this component of the waste. Include citations to additional source documents (e.g., LANL), as necessary.
c. Better describe the blending material with respect to how addition of this material does not modify the debris status of the waste stream.
d. Revise the AKSR to more completely address the defense determination.

SRS-CCP provided the freeze file for this revision to EPA during the inspection. The final revised AKSR must be provided to EPA for review prior to start of the characterization program, expected in the Spring of 2015.
B.     Regulatory Reference: 40 CFR 194.24(c)
C.     Site requirement(s): Not applicable
D.     Discussed with: Jeff Harrison, Steve Shafer
E.     Additional Comments: None
F.     Site Response Information:

   Site Response Required?  YES   NO
   Site Response Due Date: Final Revised AKSR CCP-AK-SRS-22, prior to resumption of characterization activities at SRS, expected to be Spring of 2015
Notes: Is there a different final version? What is the Sept due date that Rajani referenced in her email? At minimum, need to revise response due date text to specify that we are referring to resumption of characterization of Waste Stream SR-221H-EUOx since we are not explaining about them suspending characterization activities.
Attachment 1 of 2 to Concern No. SRS-CCP-CH-CC-2014-01CR

Attachment 2 of 2 to Concern No. SRS-CCP-CH-CC-2014-01CR