WACC-WTG Review Comment Sheets Page: 2 of 10
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example, the laboratory analyzing a gas sample would be clearly alerted about a sample
which the samplers believed would have a high alpha internal surface contamination and
might therefore required extra monitoring. DOE could have required that this information
be passed on the chain-of-custody form. Our experience at Savannah River has shown that
it is critical to safe handling of WIPP waste analyses to pass safety information between
groups. This information is usually part of the process history records for the waste
Second, the DOE Plan appears to be inconsistent in the quality of calibrations required to
meet the measurement objectives, especially if one contrasts the DOE nuclear analyses with
the chemical calibrations required by the EPA methods. For example the DOE Plan for
radio-assay (RA) allows a single point calibration of a non-matrix matched standard to be
used for the Passive-Active Neutron assay (PAN). The "Pink Drum" is a Cf-252 source.
Savannah River experience with assay of TRU wastes indicates that a multiple method
assay is needed for some waste types to adjust for sources of neutrons generated by
(alpha,neutron) reactions. Other corrections are needed for waste containing neutron
absorbers. At Savannah River these factors if not corrected would cause a high
uncertainty in the neutron measurement of the waste even though the assay of the "Pink
Drum" falls within the required precision and accuracy. I am not familiar with the INEL
waste and DOE may have supporting data to indicate that the simple calibration is not a
problem with these wastes. But I saw no requirement in the DOE Plan which would
account for matrix issues on the neutron assay.
In contrast to the RA, the organic measurements require multiple five level calibration
curves with internal spiked standards. I suggest that DOE require that a matrix matched set
of standards be used periodically to independently check the alpha activities for the primary
types of waste forms.
The DOE QA Program Plan requires that a high resolution gas mass spectrometer be used
for the assay of hydrogen and atmospheric and radiolysis gases. The Plan requires that the
mass spectrometer resolve common mass interferences at mass 28. The DOE Plan did not
appear to allow for alternative methods for making the same determinations. For example,
the same measurement can be made using a GC coupled to a lower resolution quadrupole
residual gas mass spectrometer. This latter option would be much cheaper (>$600K vs
<$200K for instrumentation.) I assume that all of the sites that will need to follow the plan
already have access to the high resolution gas mass spectrometer?
The plan should have options to reduce the amount of hazardous sampling as process
knowledge develops. If a site determines that a certain type of waste is well characterized
from process knowledge or RTR examination why is 100 percent sampling required. For
example a quick screen for hydrogen and methane could quickly indicate if a radiolysis
problem exists with a particular waste container, The present plan appears to require full
The DOE Plan does not formalize exchanges between sites of waste samples fog perfor-
mance evaluation. I suspect that a requirement to analyze a common and easily obtainable
gas, inorganic, organic standard would improve the data transferability between laborato-
ries. I suggest contacting the DOE EM-532 Laboratory Management Branch to coordinate
a program of this type.
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Spencer, W.A. WACC-WTG Review Comment Sheets, report, April 2, 1991; Aiken, South Carolina. (https://digital.library.unt.edu/ark:/67531/metadc1059830/m1/2/: accessed March 22, 2019), University of North Texas Libraries, Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.