**DOCKET NO: A-98-49, II-A4-99**

**WASTE CHARACTERIZATION INSPECTION REPORT**

**PROPOSED APPROVAL**

**EPA BASELINE INSPECTION NO. EPA-SRS-CCP-RH-07.07-8**

**OF THE CENTRAL CHARACTERIZATION PROJECT**

**REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION**

**PROGRAM FOR BATTELLE COLUMBUS LABORATORIES DECOMMISSIONING PROJECT
WASTES STORED AT THE SAVANNAH RIVER SITE**

**July 17 -- 19, July 31 -- August 2, and December 4 -- 5, 2007**

**U.S. Environmental Protection Agency**

**Office of Radiation and Indoor Air**

**Center for Waste Management and Regulations**

**1200 Pennsylvania Avenue, NW**

**Washington, DC 20460**

**May 2008**

**TABLE OF CONTENTS**

[Section]{.underline} [Page]{.underline}

[1.0 Executive Summary 1](#executive-summary)

[2.0 Purpose of Inspection 3](#purpose-of-inspection)

[3.0 Purpose of This Report 5](#purpose-of-this-report)

[4.0 Scope of Inspection 5](#scope-of-inspection)

[5.0 Inspection-Related Definitions 6](#inspection-related-definitions)

[6.0 Personnel 6](#personnel)

[6.1 EPA Inspection Team 6](#epa-inspection-team)

[6.2 Personnel Contacted 7](#personnel-contacted)

[7.0 Performance of the Inspection 8](#performance-of-the-inspection)

[8.0 Technical Evaluation 9](#technical-evaluation)

[8.1 Acceptable Knowledge Process Overview and Analysis
21](#acceptable-knowledge-process-overview-and-analysis)

[8.2 Radiological Characterization 33](#radiological-characterization)

[8.3 Physical Form and Prohibited Item Characterization -- Visual
Examination
46](#physical-form-and-prohibited-item-characterization-visual-examination)

[8.4 WIPP Waste Information System 48](#wipp-waste-information-system)

[8.5 Attainment of Data Quality Objectives
49](#attainment-of-data-quality-objectives)

[9.0 Response to Comments 50](#response-to-comments)

[10.0 Summary of Results 50](#summary-of-results)

[10.1 EPA Findings and Concerns 50](#epa-findings-and-concerns)

[10.2 Conclusions 50](#conclusions)

[10.3 Baseline Approval 50](#baseline-approval)

[11.0 References 52](#references)

**ATTACHMENTS**

Attachment A EPA Inspection Issue Tracking Form, EPA Issue No.
SRS‑CCP‑RH‑AK‑07‑001F

**ACRONYMS**

AK acceptable knowledge

AKE acceptable knowledge expert

Am americium

ANLE Argonne National Laboratory-East

ANSI American National Standards Institute

Ba barium

BC Battelle Columbus

BCL Battelle Columbus Laboratory

BCLDP Battelle Columbus Laboratory Decommissioning Project

BDR batch data report

BMI Battelle Memorial Institute

CAR Corrective Action Report

CBFO Carlsbad Area Field Office

CCP Central Characterization Project

CFR *Code of Federal Regulations*

CH contact-handled

CH-TRAMPAC Contact-Handled Transuranic Waste Authorized Methods for
Payload Control

Ci curie

Ci/Ci curies per curie

Ci/L curies per liter

Cm curium

Co cobalt

CPR cellulose, plastic, and rubber

CRR Characterization Reconciliation Report

Cs cesium

CTAC Carlsbad Technical Assistance Contractor

CTP Confirmatory Test Plan

D&D decontamination and decommissioning

DOE U.S. Department of Energy

DQO data quality objective

DR discrepancy resolution

DTC dose-to-curie

EPA U.S. Environmental Protection Agency

FGE fissile gram equivalent

FR *Federal Register*

Eu europium

g gram

g/cm^3^ grams per cubic centimeter

HCL Hot Cell Laboratory

HEU highly enriched uranium

HLW high-level waste

INL Idaho National Laboratory

kg kilogram

LANL Los Alamos National Laboratory

LLD lower limit of detection

LWA *Land Withdrawal Act*

LWR light-water reactor

m^3^ cubic meter

MDA minimum detectable activity

mR/hr milli Roentgen per hour

mrem/hr millirem per hour

MSDS material safety data sheets

N/A not applicable

nCi/g nanocurie per gram

NCR non-conformance report

NDE non-destructive examination

Np neptunium

ORIA Office of Radiation and Indoor Air

PE Ci plutonium equivalent curie

PTS Project Tracking System

Pu plutonium

QA quality assurance

QAO quality assurance objective

QAPD quality assurance program description

R/hr/Ci Roentgen per hour per curie

RCRA Resource Conservation and Recovery Act

RH remote-handled

RIDS Record Inventory and Disposition System

RTR real-time radiography

Sb antimony

SCG Summary Category Group

SNF spent nuclear fuel

SPM Site Project Manager

Sr strontium

SRS Savannah River Site

Th thorium

T1 Tier 1

T2 Tier 2

TBD to be determined

TMU total measurement uncertainty

TRU transuranic

U uranium

VE visual examination

VEE visual examination expert

WAC waste acceptance criteria

WC waste characterization

WCO Waste Certification Official

WCPIP Waste Characterization Program Implementation Program

WIPP Waste Isolation Pilot Plant

WMC waste matrix code

WMP waste material parameter

WSPF Waste Stream Profile Form

WWIS WIPP Waste Information System

Y yttrium

# Executive Summary

In accordance with 40 CFR 194.8(b), the U.S. Environmental Protection
Agency (EPA or the Agency) conducted Baseline Inspection
No. EPA-SRS-CCP-RH-07.07-8 of the Central Characterization Project's
(CCP) waste characterization (WC) program for remote-handled (RH)
transuranic (TRU) waste at the U.S. Department of Energy's (DOE)
Savannah River Site (SRS) located in Aiken, South Carolina. The waste
characterized by the SRS-CCP is RH debris waste from the decommissioning
of a hot cell laboratory at the Battelle Columbus Laboratory (BCL) that
was shipped to SRS for characterization and disposal at the Waste
Isolation Pilot Plant (WIPP). EPA conducted a baseline inspection of
SRS-CCP's program to characterize this waste in the Washington Group's
office in Denver, Colorado, on July 17-19, 2007 and at the DOE's
Carlsbad Area Field Office (CBFO) in Carlsbad, New Mexico, on July 31 -
August 2, 2007 and December 4 - 5, 2007.

Presently, SRS-CCP stores RH waste from Battelle Columbus Laboratory
Decommissioning Project (BCLDP) at SRS, and the WC activities discussed
in this report occurred at the Battelle Columbus Laboratory prior to
shipment of the BCLDP RH waste to SRS for interim storage. SRS-CCP is
responsible for characterizing this waste for its disposal at WIPP. The
SRS-CCP TRU WC personnel are located all over the country and SRS-CCP
maintains files for TRU waste information for all CCP TRU waste sites
including this waste at CCP headquarters in Carlsbad, New Mexico. For
this inspection SRS-CCP was not performing any actual radiological
measurements or physical contents determination but was using the
historical BCLDP-generated data to develop acceptable knowledge (AK)
records, thus negating any need to conduct this baseline inspection at
SRS. As a practical matter EPA opted to conduct AK record review and
discussions with SRS-CCP's AK and radiological characterization staff in
Denver, Colorado. Additionally, EPA decided to evaluate the remaining WC
components, namely, non-destructive examination (NDE) and waste database
in CCP's Carlsbad office. EPA may continue this inspection approach for
other CCP RH sites, as necessary.

This inspection's sole focus was to evaluate the records that had been
assembled to document RH TRU WC activities, including recently performed
modeling, interpretation, and additional calculations based on
previously generated measurement data for Battelle Columbus Laboratory
Demolition Project (BCLDP) RH debris Waste Stream SR‑RL‑BCLDP.001. Like
the RH debris waste in 16 canisters from the Los Alamos National
Laboratory (LANL) that EPA approved in February 2008 (see Air Docket No.
A-98-49, II‑A4‑89), this is a discrete waste stream. There will be no
further waste generation and characterization activities relative to
this waste. This proposed approval, hence, is directed to a discrete set
of 87 drum liners within this RH debris waste stream that are currently
stored at SRS, as supported by the documentation the EPA inspection team
evaluated during this inspection.

Although these wastes are currently stored at SRS, the waste generation
and characterization activities covered by this proposed approval were
performed at the BCLDP, as stated previously. This proposed approval is
limited to RH debris waste from BCLDP only. Note that this is a
retrospective approval of the RH debris waste from BCLDP, and no
additional RH debris waste from BCLDP remains to be characterized for
WIPP disposal. Any BCLDP-related RH waste that SRS-CCP may characterize
upon the approval of WC activities discussed in this report will require
EPA approval as a Tier 1 (T1) change. Upon approval of the RH TRU WC
processes discussed in this report, if SRS-CCP embarks on characterizing
RH waste other than that generated at BCLDP for WIPP disposal, a
separate baseline inspection and approval will be necessary. That is,
any SRS RH waste destined for WIPP disposal characterized by SRS-CCP or
another program remains subject to EPA's baseline inspection and
approval.

EPA must verify compliance with 40 CFR 194.24 before waste may be
disposed of at the WIPP, as specified in Condition 3 of the Agency's
certification of the WIPP's compliance with disposal regulations for TRU
radioactive waste (63 *Federal Register* (FR) 27354 and 27405, May 18,
1998). EPA Baseline Inspection No. EPA-SRS-CCP-RH-07.07-8 was performed
in accordance with the provisions of 40 CFR 194.8(b), as issued in a
July 16, 2004, FR notice (Vol. 69, No. 136, pp. 42571--42583). The
purpose of the SRS-CCP RH WC inspection was to evaluate the adequacy of
the site's WC programs for 87 drum liners[^1] in a single RH debris
waste stream for disposal at the WIPP. The 87 drum liners of RH debris
in this waste stream were generated from the decontamination and
decommissioning (D&D) of the Building JN-1 Hot Cell Laboratory (HCL) at
the Jefferson North facility, which operated from 1955 until D&D began
in 1988, under the BCLDP. (See page 8 for additional details of the
waste generation in Section 8.0 of this report.)

The EPA inspection team identified one finding during the July 2007
inspection (see Attachment A). SRS-CCP revised specific documents to
address the finding and submitted them for EPA review following the
initial July 2007 inspection. The EPA inspection team reviewed the
revised documents and subsequently met with SRS-CCP personnel in
December 2007 to discuss the changes to WC documents addressing the EPA
finding and examine additional objective evidence. Upon completing their
reviews, the EPA inspection team determined that the revised documents
adequately addressed all aspects of the EPA finding. Accordingly, EPA
has determined that the records documenting SRS-CCP's RH WC program
represented activities that were technically adequate and the finding
has been resolved. EPA, therefore, is proposing to approve the SRS-CCP
RH WC program for the 87 RH TRU drum liners in SRS RH Waste Stream
SR-RL-BCLDP.001 evaluated during this baseline inspection that is
described and documented in this report. The proposed approval includes
the following:

(1) The AK process for the 87 drum liners of RH retrievably-stored TRU
    debris in the waste stream designated as Waste Stream
    SRS-RL-BCLDP.001 currently stored at the TRU storage pads in the E
    Area of SRS

(2) The radiological characterization process using dose-to-curie (DTC)
    and modeling-derived scaling factors, supported by radionuclide data
    from the analysis of 69 swipe samples, for assigning radionuclide
    values to 87 drum liners of RH retrievably-stored TRU debris in one
    waste stream, designated as SRS-RL-BCLDP.001, that is documented in
    CCP‑AK‑LANL‑501, Revision 2, and detailed in this report.

(3) The visual examination (VE) process to identify waste material
    parameters and the physical form of the waste

(4) The WIPP Waste Information System (WWIS) to submit data for both
    characterization and certification to WWIS for RH TRU waste

(5) The attainment of pertinent data quality objectives (DQOs)

Since no additional WC activities are expected to occur relative to the
87 drum liners of RH debris waste, no changes to the WC activities
evaluated during the baseline inspection are anticipated. EPA,
therefore, does not expect SRS-CCP to make additional revisions to the
documents that were reviewed as part of this inspection and proposed
approval limited to the WC processes specific to the 87 drum liners
evaluated during the July, August and December 2007 inspections. In the
event that SRS-CCP makes changes to the WC components proposed for
approval or implements them to characterize additional waste from the
BCLDP activity (e.g., solids or soil/gravel) associated with D&D
activities at Building JN-1 at the BCL, EPA will consider changes that
have the potential to affect WC activities to be T1 changes, as stated
above.

This report does not list specific T1 or Tier 2 (T2) designations
relative to these 87 waste liners and the WC components proposed for the
approval at this time.

# Purpose of Inspection

On May 18, 1998, EPA certified that the WIPP will comply with the
radioactive waste disposal regulations in 40 CFR Part 191. In this
certification, EPA also included Condition 3, which states that "the
Secretary shall not allow shipment of any waste from...any waste
generator site other than LANL for disposal at the WIPP until the Agency
has approved the processes for characterizing those waste streams for
shipment using the process set forth in §194.8." The approval process
described in 40 CFR 194.8 requires DOE to (1) provide EPA with
information on AK[^2] for waste streams proposed for disposal at the
WIPP, and (2) implement a system of controls used to confirm that the
total amount of each waste component that will be emplaced in the WIPP
will not exceed limits identified in the WIPP Compliance Certification
Application.

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, FR
notice, EPA must perform a baseline inspection of a TRU waste generator
site's WC program. The purpose of the baseline inspection is to approve
the site's WC program based on the demonstration that the program's
components, with applicable conditions and limitations, can adequately
characterize TRU wastes and comply with the regulatory requirements
imposed on TRU wastes destined for disposal at the WIPP. An EPA
inspection team conducts an on-site inspection to verify that the site's
system of controls is technically adequate and properly implemented.
Specifically, EPA's inspection team verifies compliance with
40 CFR 194.24(c)(4), which states the following:

> *Any compliance application shall: . . . Provide information which
> demonstrates that a system of controls has been and will continue to
> be implemented to confirm that the total amount of each waste
> component that will be emplaced in the disposal system will not exceed
> the upper limiting value or fall below the lower limiting value
> described in the introductory text of paragraph of this section.*[^3]
> *The system of controls shall include, but shall not be limited to:
> measurement; sampling; chain of custody records; record keeping
> systems; waste loading schemes used; and other documentation.*

In other words, the purpose of the baseline inspection is to implement
the requirements of\
40 CFR 194 by assessing whether DOE sites that characterize TRU waste
prior to disposal at the WIPP are capable of characterizing and tracking
the waste. EPA may also conduct follow-up inspections to address issues
remaining from the baseline inspection or to seek further
clarification/discussion related to WC processes evaluated during a
baseline inspection. By approving the WC systems and processes at
SRS-CCP that were applied to the 87 drum liners of retrievably-stored RH
debris waste, EPA confirms that the Agency has evaluated the
capabilities of systems and processes implemented by the site to
accomplish two tasks: (1) the identification and measurement of waste
components such as plutonium that must be tracked for compliance,[^4]
and (2) the confirmation that the waste in any given container has been
properly identified as belonging to the group of approved waste streams.

Based on the adequacies of the WC processes demonstrated during the
baseline inspection, including all conditions and limitations, EPA
usually specifies which subsequent WC program changes or modifications
must undergo further EPA inspection or approval under 40 CFR 194.24.
This is accomplished by assigning a tier level to each aspect of the
characterization program, i.e., T1 and T2 activities. However, the
nature of the WC activities at SRS-CCP is such that no additional
characterization activities are anticipated, making a prospectively
orientated T1 or T2 assignment not relevant. Accordingly, no formal
tiering is proposed for the SRS-CCP RH WC program at this time. As
stated previously, EPA's proposed approval is limited to the 87 drum
liners of RH TRU wastes whose characterization is documented in the
records evaluated during the inspection, as detailed in this report. The
rule applying to this baseline inspection can be found in the FR (Vol.
69, No. 136, pp. 42571--42583, July 16, 2004). EPA doesn't expect to
conduct additional SRS-CCP RH waste inspections specific to this waste
stream in the future. If, for DOE, SRS-CCP characterizes RH waste not
originating at BCLDP for WIPP disposal, a new EPA baseline inspection
and approval will be necessary under the authority of 40 CFR 194.8.

# Purpose of This Report

This report documents the basis for EPA's approval decision and explains
the results of Baseline Inspection No. EPA-SRS-CCP-RH-07.07-8 in terms
of findings or concerns. Specifically, this report does the following:

-   Describes the characterization systems proposed for approval

-   Delineates a specific set of RH wastes proposed for approval

-   Provides objective evidence of the proposed approval basis for all
    WC systems and/or waste containers

-   Identifies all relevant limitations and or conditions for each WC
    system and/or waste container

-   Provides objective evidence of outstanding findings or concerns in
    the form of documentation, as applicable

-   Describes any tests or demonstrations completed during the course of
    the inspection and their relevance to EPA's proposed approval
    decision

The listings in each section reference the documents that the EPA
inspection team members reviewed in support of the technical
determination. To see or obtain copies of any items identified in the
attached checklists, write to the following address:

> Quality Assurance Manager
>
> USDOE/Carlsbad Field Office

P.O. Box 3090

> Carlsbad, NM 88221

EPA's final approval decision regarding the SRS-CCP RH WC program is
conveyed to DOE separately by letter. In accordance with 40 CFR
194.8(b)(3), this information is also available on EPA's Web site at
<http://www.epa.gov/radiation/WIPP>.

# Scope of Inspection

The scope of Baseline Inspection No. EPA-SRS-CCP-RH-07.07-8 included the
technical adequacy of the WC systems used by SRS-CCP to characterize 87
drum liners of RH TRU wastes in SRS RH Waste Stream SR-RL-BCLDP.001. At
the start of the inspection, SRS-CCP presented the number of drums in
Waste Stream SRS-RL-BCLDP.001 as 88. However, SRS-CCP determined that
one of these drums did not meet the definition of TRU waste and it was
removed from the waste stream directly prior to the inspection, leaving
a total of 87 drums within the inspection's scope. The basis for all
radiological and physical waste characterization of these 87 drums was
AK and included the identification and quantification of the 10
WIPP-tracked radionuclides (^241^Am, ^137^Cs, ^238^Pu, ^239^Pu, ^240^Pu,
^242^Pu, ^90^Sr, ^233^U, ^234^U, and ^238^U). Accordingly, the
inspection's scope consisted of reviewing records of WC activities that
had been performed previously in conjunction with the BCLDP,
supplemented by data interpretation and manipulation, and the
development and application of conceptual models related to WC that were
performed by SRS-CCP more recently.

During an inspection, EPA does not approve characterization data; that
function is the sole responsibility of the site being evaluated during
the inspection, in this case SRS-CCP. EPA evaluated records that
documented the technical aspects of the WC processes implemented by
SRS-CCP to characterize 87 drum liners of RH retrievably-stored debris
waste that were conducted during the BCLDP. These records included more
recent compilations of older information, as well as newer
interpretations of, and additional calculations to, older measurement
data. The evaluation consisted of interviewing personnel and inspecting
records related to the WC processes within the inspection's scope. An
important aspect of this evaluation is the objective evidence that
documents the effectiveness of the WC processes. Objective evidence
typically takes the form of BDRs for radiological characterization and
AK accuracy reports. EPA typically selects samples of each of these
items based on the number and variety of items that were completed and
available for inspecting each WC process, consistent with standard
sampling techniques. However, because the WC activities for these BCLDP
RH wastes are not ongoing, BDRs were not prepared. Accordingly, EPA
evaluated records associated with the characterization of an appropriate
sample of the 87 drum liners. EPA examined WC information that was
provided within specific SRS-CCP reports that was the equivalent of what
is typically contained in BDRs. Based on an evaluation of the WC
processes documented in the SRS RH records, EPA determined the technical
adequacy of the WC processes within the inspection's scope.

# Inspection-Related Definitions

During the course of an inspection, EPA inspectors may encounter items
or activities that require further inquiry for their potential to
adversely affect WC and/or isolation within the repository. The two main
categories relevant to WC inspections are identified below:

*Finding*: A determination that a specific item or activity does not
conform to 40 CFR 194.24(c)(4). A finding requires a response from CBFO.

*Concern*: A judgment that a specific item or activity may or may not
have a negative effect on compliance and, depending on the magnitude of
the issue, may or may not require a response. (Concerns not requiring a
response do not have to be addressed prior to program approval.)

# Personnel

## EPA Inspection Team

The members of the EPA WC inspection team are identified in Table 1.

+----------------------+---------------------+------------------------+
| ####### Table 1.     |                     |                        |
|  EPA Inspection Team |                     |                        |
|  Members {#table-1.- |                     |                        |
| epa-inspection-team- |                     |                        |
| members .unnumbered} |                     |                        |
+----------------------+---------------------+------------------------+
| **Inspection Team    | ##                  | **Affiliation**        |
| Member**             | ##### Position {#po |                        |
|                      | sition .unnumbered} |                        |
+----------------------+---------------------+------------------------+
| Ms. Rajani Joglekar  | Inspection Team     | U.S. EPA ORIA          |
|                      | Leader              |                        |
+----------------------+---------------------+------------------------+
| Mr. Ed Feltcorn      | Inspector           | U.S. EPA ORIA          |
+----------------------+---------------------+------------------------+
| Ms. Connie Walker    | Inspector           | S. Cohen & Associates, |
|                      |                     | Inc.                   |
+----------------------+---------------------+------------------------+
| Ms. Dorothy Gill     | Inspector           | S. Cohen & Associates, |
|                      |                     | Inc.                   |
+----------------------+---------------------+------------------------+
| Mr. Patrick Kelly    | Inspector           | S. Cohen & Associates, |
|                      |                     | Inc.                   |
+----------------------+---------------------+------------------------+

##  {#section .unnumbered}

## Personnel Contacted 

EPA and its support personnel conducted interviews with SRS-CCP
personnel in several disciplines on several occasions. The personnel
contacted represented a sample of the SRS-CCP WC staff, and they are
listed in Table 2, along with their affiliation and technical area. This
listing is comprehensive and includes personnel present at all meetings
conducted as part of this baseline inspection.

+--------------------+----------------+-------------------------------+
| #######            |                |                               |
| Table 2. Personnel |                |                               |
|  Contacted During  |                |                               |
| Inspection {#table |                |                               |
| -2.-personnel-cont |                |                               |
| acted-during-inspe |                |                               |
| ction .unnumbered} |                |                               |
+====================+================+===============================+
| ######             | *              | **Area of Expertise**         |
| Personnel {#person | *Affiliation** |                               |
| nel-1 .unnumbered} |                |                               |
+--------------------+----------------+-------------------------------+
| Rob Tayloe         | CCP            | AK/DTC; Scaling Factors       |
+--------------------+----------------+-------------------------------+
| Jene Vance         | CCP            | AK/DTC; Scaling Factors       |
+--------------------+----------------+-------------------------------+
| Keith Meger        | CCP            | AK/DTC; Scaling Factors       |
+--------------------+----------------+-------------------------------+
| Eric D'Amico       | CCP            | RH SPM                        |
+--------------------+----------------+-------------------------------+
| Larry Porter       | CCP            | AK, RH SPM; Scaling Factors   |
+--------------------+----------------+-------------------------------+
| Steve Schafer      | CCP            | AK, AKE                       |
+--------------------+----------------+-------------------------------+
| Kevin Peters       | CCP            | AK, AKE                       |
+--------------------+----------------+-------------------------------+
| Mark Doherty       | CCP            | DTC & Scaling Factors-MS Data |
+--------------------+----------------+-------------------------------+
| J.R. Stroble       | DOE/CBFO       | RH TRU Waste Certification    |
|                    |                | Manager                       |
+--------------------+----------------+-------------------------------+
| Irene Quintana     | CCP            | RH SPM                        |
+--------------------+----------------+-------------------------------+
| Charlie Riggs      | CTAC           | Observer                      |
+--------------------+----------------+-------------------------------+
| Porf Martinez      | CTAC           | Observer                      |
+--------------------+----------------+-------------------------------+

# Performance of the Inspection

**[Background and History: Battelle Columbus and Savannah River
Site]{.underline}**

The RH debris waste that is the focus of this inspection came from the
West Jefferson North Site, which is part of Battelle Memorial Institute
(BMI), located near West Jefferson, Ohio, approximately 15 miles west of
the main BMI King Avenue facility in Columbus, Ohio. BMI had supported
the first large-scale military application of nuclear power through
development of fuel element/assemblies design and materials. The West
Jefferson North Site's focus was research in the areas of reactor fuel,
control rod, and structural material studies. Since operations began in
the JN-1 HCL in 1955, a variety of studies relating to the radiation
performance of materials were conducted in the remote-handling
facilities in Building JN-1. Experiments in the JN-1 HCL consisted
primarily of: reactor fuel studies that evaluated uranium, thorium, and
plutonium alloys and compounds; control rod material studies of
rare-earth absorbers; and evaluations of structural and cladding
material. Remedial D&D activities of the West Jefferson North facilities
began in 1988 under the BCLDP, whose objective was to decontaminate the
West Jefferson buildings and associated grounds such that they suitable
for unrestricted use, i.e., use without radiological restrictions.
Battelle completed the BCLDP D&D program with the final shipments of
these RH TRU waste to SRS in December 2005 where they are currently
stored on the TRU Pad in E Area of SRS. SRS-CCP did not perform any
actual characterizations relative to these wastes, but instead but was
using the BCLDP-generated data to develop AK records that support the WC
activities for these 87 RH drums. Accordingly, it was not necessary to
conduct this baseline inspection at SRS and EPA conducted the review of
AK records and discussions with SRS-CCP personnel in Denver, CO.
Additionally, EPA decided to evaluate the non-destructive examination
(NDE) and the WWIS in CCP's Carlsbad office.

####  {#section-1 .unnumbered}

#### Inspection Process Overview {#inspection-process-overview .unnumbered}

EPA Inspection No. EPA-SRS-CCP-RH-07.07-8 had the scope described in
Section 4.0, above, for the purpose of determining the site's compliance
with 40 CFR 194.24. The inspection was conducted in the following steps:

(1) Obtaining and reviewing site procedures, reports, and other
    technical information related to RH WC activities used to
    characterize these wastes at BCLDP previously

(2) Preparing technical questions specific to the various aspects of AK
    prior to the inspection based on the activities cited in the
    previous bullet

(3) Interacting with CBFO and SRS-CCP personnel to arrange inspection
    logistics

(4) Evaluating SRS-CCP's implementation of WC processes for adequacy and
    demonstrating compliance with 40 CFR 194.24 requirements, as
    evidenced by the records of the WC activities conducted at BCLDP
    previously

(5) Conducting the baseline inspection in Denver to verify the technical
    adequacy and/or qualifications of RH WC personnel, procedures,
    processes, and equipment, as evidenced by the records of the WC
    activities conducted at BCLDP previously

(6) Recording one finding on an EPA Inspection Issue Tracking Form,
    which was completed and provided to CBFO and SRS-CCP personnel as it
    was generated (see Attachment A for a copy of this form)

(7) Communicating all pertinent information with CBFO and SRS-CCP
    personnel

(8) Pursuing resolution of all identified issues prior to completion of
    the inspection, when feasible

(9) Conducting entrance, exit, and daily briefings for CBFO and SRS-CCP
    management personnel

(10) Obtaining and reviewing SRS-CCP documents that were revised in
     response to the EPA finding after the inspection

(11) Conducting additional meetings with SRS-CCP personnel to discuss
     the revised documents and examine objective evidence for the
     purpose of addressing the technical issues identified in the
     finding

(12) Issuing the inspection report and proposed approval

# Technical Evaluation

##  {#section-2 .unnumbered}

EPA examined the AK process and associated information to determine
whether the SRS-CCP RH program for characterizing Waste Stream
SR-RL-BCLDP.001 from the BCLDP demonstrated compliance with the
requirements of 40 CFR 194.8. Due to the approach taken by SRS-CCP
BCLDP, all WC activities relative to the 87 drum liners in this waste
stream fall under the general heading of AK. In this report, AK is
divided into five sections:

-   8.1, Acceptable Knowledge Overview and Process Analysis

-   8.2, Radiological Characterization

-   8.3, Physical Form and Prohibited Item Characterization, Visual
    Examination

-   8.4, WIPP Waste Information System

-   8.5, Attainment of Data Quality Objectives

This report format differs from the format that EPA generally uses where
there are multiple sections named for each WC process, i.e., AK, NDA,
NDE, and WWIS that can be found in other EPA baseline inspection
reports. Such a format reflects that the WC activities evaluated during
the inspection are ongoing and are expected to continue upon approval of
the site's WC program. The nature of the SRS-CCP program is different in
that all WC activities have occurred and there are no further ongoing WC
activities upon approval. The basis for all WC activities consists of
records of previously conducted activities, and accordingly all this
information is considered AK. However, the actual information may
consist of examinations of the waste using both NDA and NDE, in addition
to historical information regarding the waste's nature and origin.

#### Waste Containers {#waste-containers .unnumbered}

All BCLDP wastes were loaded into 55-gallon steel drum liners (a rigid
liner that essentially fits within a 55-gallon drum which acts as
overpack). Once the liners were full, lids were installed, and the
liners were transferred into U.S. Department of Transportation (DOT)
approved containers. This report uses the term *RH drum liner* or *waste
liner*, which requires clarification. Any use of the term *liner* in
this report means a steel container that fits inside a standard
55‑gallon drum. Each liner has the following dimensions: 0.105 inch
thick, 32.250\" high, with an outer diameter of 22\" and an inner
diameter of 19.5\", as shown in Figure 1. Each liner was sealed once it
was full of waste, and 82 of the sealed liners were transferred to DOT
approved, UN/1A2/X400/S/99 55‑gallon drums equipped with Nucfil-013
filters (vented). Five additional steel liners were loaded directly into
two 72-B RH TRU canisters, three in one canister and two in the other
canister. The total waste stream population consists of these 87 drum
liners referred to throughout this report. In some cases this report
cites objective evidence (i.e., BCLDP or SRS-CCP reports) that uses the
terms *waste container* or *waste drum*, both of which are synonymous
with the term *liner*.

[Waste Origin and Generation]{.underline}

The RH debris in this waste stream was generated from the D&D of
Building JN-1 in the West Jefferson North Site of BCL in Columbus,
Ohio[^5]. The JN-1 HCL was dedicated to reactor fuel research and
material evaluation in support of DOE and other federal agencies.
Remedial activities of the West Jefferson North facilities began in 1988
under the BCLDP and continued until the final shipment of BCLDP D&D
wastes to SRS was made in December 2005. The BCLDP generated a total of
135 55-gallon drums \[approximately 29 cubic meters (m^3^)\] of RH
wastes, 48 of which are not within the scope of this inspection and are
currently stored at DOE's Hanford Site in Richland, Washington[^6]. The
remaining 87 drums of waste that are subject of this inspection are
composed of 82 individual 55-gallon drums and five additional 55-gallon
drums that are contained in two 72B RH Casks, three drums in one cask
and two drums in the other cask, all of which are currently stored at
the TRU Storage Pad in E Area of SRS. The waste components include
cellulosics, plastic, rubber, glass and metal, and less than 50 percent
by volume in any one container consists of homogeneous organic and
inorganic materials. Radionuclide components of the waste include
^241^Am, ^238^Pu, ^239^Pu, ^240^Pu, ^241^Pu, ^242^Pu, ^234^U, ^235^U,
^238^U, ^137^Cs and ^60^Co. The scope of this inspection was the 87 drum
liners of RH wastes currently stored at SRS and does not include the 47
additional 55-gallon drums of BCLDP wastes that are in storage at
Hanford.

![](media/image1.wmf){width="5.825in" height="7.504166666666666in"}

####### Figure 1. Configuration and Dimensions of a 55-Gallon Drum TRU RH Liner {#figure-1.-configuration-and-dimensions-of-a-55-gallon-drum-tru-rh-liner .unnumbered}

The approval of additional BCLDP drum liners at Hanford or any other
location will require a separate baseline inspection as such time that
the site decides to characterize these wastes for disposal at WIPP. The
wastes to which this proposed approval applies are discussed in this
report and were generated by the BCLDP. The fact that these wastes are
stored at SRS has no bearing on characterization activities performed on
any other CH or RH TRU materials at SRS or any other DOE site. Should
DOE notify EPA that there are additional containers of RH TRU wastes
from the BCLDP proposed for disposal at WIPP apart from the 87 liners
discussed in this report, EPA would address the situation as a T1
change, as discussed previously. However, such an option would apply
only to BCLDP wastes (such as solids or soil/gravel) that have waste
generation and WC elements in common with the 87 liners described in
this report.

#### Waste Characterization Overview {#waste-characterization-overview .unnumbered}

AK provides the basis for all radiological and physical WC information.
In the case of this specific SRS RH waste stream, wastes were grouped
using AK into a debris waste stream of 87 drum-liners generated through
D&D of the JN-1 HCL. As part of the inspection, EPA reviewed the
following with respect to the use of AK for WC:

-   Waste stream definition and identification, including radiological
    content

-   Identification of TRU versus non-TRU wastes, i.e., high-level waste
    (HLW) and spent nuclear fuel (SNF)

-   Identification and quantification of the waste's radionuclide
    content including uncertainty

-   Defense waste status

-   Waste Material Parameters (WMP)

-   Assignment of waste matrix codes (WMC)

-   Role of AK in the characterization methodology, with the
    determination of quality assurance (QA) equivalency (addressed
    outside of this report), peer review, or confirmation via modeling
    used as verification techniques

-   Compilation of AK documentation and assembly of required information

-   Adequacy of the Waste Characterization Program Implementation Plan
    (WCPIP) AK process implementation and AK summary report

-   AK data traceability for all drums and containers used in the
    process from data assembly through confirmatory modeling

-   AK source document sufficiency

-   WCPIP interpretation with respect to AK qualification

-   Confirmatory Test Plan (CTP) preparation and plan adequacy

-   Characterization Reconciliation Report (CRR) preparation and report
    adequacy

-   Correlation and Surrogate Summary Form and CH-RH correlation

-   Personnel training

-   AK discrepancy resolution (DR)

-   AK accuracy

-   Implementation of load management

-   Physical form and prohibited item characterization using VE

-   WWIS

-   Identification of the method for determining DQOs, including those
    to be attained by AK qualification

Waste Stream SR-RL-BCLDP.001 has been characterized by AK that was
qualified through a determination of QA equivalency (not addressed in
this report). Because the characterization process is based solely on AK
records and the various methods used to verify AK exclusive of
confirmatory testing, the entire inspection was based on reviewing
documents of activities that had been completed prior to the inspection.
BDRs were not prepared to meet WCPIP requirements, and observations of
procedural implementation could not be made because all characterization
activities had been completed prior to the inspection. No further
testing or characterization of the 87 drum liners will be performed.

Radiological information available for this waste stream includes the
radiochemical analytical results of 69 swipe[^7] samples taken at
various locations within JN-1, as well as a memorandum presenting ^235^U
enrichment, burn-up, and decay for light-water reactor (LWR) fuel pins.
External exposure rate (dose rate)[^8] measurements were taken at the
time of packaging for all drum liners. The determination of several DQOs
was achieved through use of radionuclide-specific scaling factors and
isotopic distributions that were applied to dose rate data derived by
applying the DTC technique for each drum liner. The scaling factors were
derived using ORIGEN2.2[^9] modeling with input based on attributes of
LWR fuels that were assumed to contribute the majority of the waste
stream's radionuclide content. Radionuclide data from the analysis of
swipe samples taken throughout the JN-1 facility were used to support
the scaling factors derived with ORIGEN2.2 for plutonium and americium
isotopes and specific fission products.

#### Documents Reviewed {#documents-reviewed .unnumbered}

The list of documents provided below includes all documents related to
the SRS-CCP RH radiological characterization program that were evaluated
to support this inspection:

-   C001, Interview Record: Eugene Sands, Master Research Technician;
    Larry Stickel, Master Technician; Harley Toy, Manager of Regulatory
    Compliance and Technical Services; Max Berchtold, JN-1 Lab
    Technician; George Kirsch, Health Physicist; K.J. Peters and J.
    Harrison, May 1, 1998

-   C002, Packet of Letters Concerning Destruction/Immobilization of
    Toxic Substances by Intense Gamma Irradiation, L. M. Lowry, H. L.
    Toy, E. W. Ungar, R. DiSalvo, November 8, 1982, December 13, 1982,
    December 15, 1982, January 27, 1983

-   C003, Letter to Louis B. Myers, re: Characterization of the JN-1 Hot
    Cell Waste Drums, M. P. Failey, May 1, 1997

-   C004, Interview Record: Harley Toy, Manager of Regulatory Compliance
    and Technical Services; George Kirsch, Health Physicist, Historical
    Operations in JN-1, K.J. Peters, July 12, 1998

-   C005, Interview Record: Scott Kitts, Manager Special Waste Projects,
    Hanford N-Reactor Process Tube in JN-1, K.J. Peters, July 16, 1998

-   C006, Interview Record: Max Berchtold, JN-1 Lab Technician,
    Historical Operations in JN-1 and Hydraulic Oil Composition
    (including MSDS), K.J. Peters, July 15, 1998

-   C007, Interview Record: Scott Kitts, Manager Special Waste Projects,
    Separation of Hot Cell Waste from Wastes from Supporting Areas, K.J.
    Peters, July 22, 1998

-   C008, Memorandum to Mike Brown, re: Certification Strategy for
    Transuranic Waste Generated from the Battelle Columbus Laboratories
    Decommissioning Project, C98-065, Various, June 25, 1998

-   C021, Letter to AK Record, re: Estimates of Waste Stream Generation
    Volumes and Waste Material Parameter Categories for Building JN-1
    Repackaged Waste, K.J. Peters, May 7, 1999

-   C033, Letter to Contractors, Richland, Washington; Director, Pacific
    Northwest Laboratory; President, Westinghouse Hanford Company, re:
    Spent Nuclear Fuel Records, 96-SFD-059, E.D. Sellers, March 14, 1996

-   C034, Memorandum to Elizabeth D. Sellers, re: National Spent Nuclear
    Fuel Program Evaluation of Hanford Building 327 Material for
    Applicability of RH-TRU Waste Criteria for Disposal at WIPP,
    OPE-SFP-081, J. Boyd, March 24, 1997

-   C035, Letter to H. J. Hatch, re: Contract No. DE-AC05-96RL13200 -
    Classification of Nuclear Materials in the 327 Building, 97-SFD-074,
    E.D. Sellers, April 21, 1997

-   C047, Letter to Pete Erickson, re: Findings on the Result of
    Pressure Wash Decontamination on the JN Waste Matrix, C. Jensen
    and J. Sarge, July 25, 2000

-   C501, Battelle Defense Determination Approval, E. Rose, July 15,
    2005

-   C502, Surveillance (S-01-37) of the Battelle Columbus Laboratories
    Decommissioning Project (BCLDP) Remote Handled Waste
    Characterization, CBFO:QA:TJR:VW:01-1451:UFC:2300, T. Baillieul,
    September 17, 2001

-   C504, Waste Material Parameter Weight Evaluation for Waste Stream
    SR-RL-BCLDP.001, K.J. Peters, April 11, 2007

-   C505, U.S. DOE CAO Audit Report of the Battelle Columbus
    Laboratories Decommissioning Project, TRU Waste Characterization
    Activities Related to Acceptable Knowledge, May 7, 1999, Audit
    Number A-99-15, M.A. Italiano, June 4, 1999

-   DR002, Interview Record for Discrepancy Report of George Kirsch, re:
    Date of the Beginning of Operations of the HEC and Pool, K.J.
    Peters, July 28, 1998

-   DR004, Interview Record of Cidney Voth, re: Evaporation of the JN-1
    Transfer/Storage Pool Water, K.J. Peters, April 27, 1999

-   DR005, Letter to AK Record, re: Discrepancy Report Relating to Lead
    Detected in Sample of Pool Water, K.J. Peters, May 12, 1999

-   DR006, Letter to AK Record, re: Discrepancy Report Relating to RCRA
    Metals Detected in Samples Pool Resins and Filters, K.J. Peters,
    June 29, 1999

-   DR009, Letter to AK Record, re: Discrepancy Report Regarding
    Generation of Four Debris Waste Streams, 5190-01, 5190-02, 5390-01,
    and 5390-02, K.J. Peters, May 25, 2001

-   DR010, Letter to AK Record, re: Discrepancy Report Relating to RCRA
    Metals Detected in Pool Resins and Filters Samples, and TRU Resin
    Volume Estimation, S.M. Smith, May 25, 2001

-   DR011, RCRA Hazardous Waste Number Assignment Discrepancy Report,
    K.J. Peters, Date TBD

-   P002, Fuel Storage Pool, Pump Room, and Washdown Room JN-1B.
    Decontamination and Decommissioning Operations, L.B. Myers, M.B.
    Berchtold, and J.L. Stickel, July 1, 1995

-   P003, High Energy Cell, Mezzanine, and Top of HEC JN-1B.
    Decontamination and Decommissioning Operations, L.B. Myers, M.B.
    Berchtold, P.D. Faust, and P.A. Tomlin, December 1, 1994

-   P004, Waste Storage Shed JN-1A. Decontamination and Decommissioning
    Operations, L.B. Myers and M.B. Berchtold, June 1, 1995

-   P005, Hot Cell Purposes and Activities. Decontamination and
    Decommissioning Operations, Battelle Columbus Laboratories,
    September 22, 1997

-   P006, Contents of the West Jefferson North Hot Cells and Storage
    Areas, L.B. Myers, M.B. Berchtold, and E.H. Sands, May 1, 1995

-   P008, West Jefferson North Hopper Location and Contents, L.B. Myers
    and M.B. Berchtold, June 1, 1995

-   P009, Chemistry Laboratory, Counting Room and Microprobe Room, L.B.
    Myers, M.B. Berchtold, P.A. Tomlin, and M.P. Failey, December 1,
    1994

-   P010, Evaporator Room JN-1A, Louis B. Myers, M.B. Berchtold, and
    P.A. Tomlin, November 1, 1994

-   P011, Controlled Access Area Storage Rooms JN-1A, L.B. Myers, M.B.
    Berchtold, P.D. Faust, and P.A. Tomlin, October 1, 1994

-   P012, Controlled Access Area JN-1A, L.B. Myers, M.B. Berchtold, P.D.
    Faust, and P.A. Tomlin, September 1, 1994

-   P013, Mezzanines JN-1A, L.B. Myers and M.B. Berchtold, September 1,
    1994

-   P014, Mechanical Test Cell JN-1A, L.B. Myers, C.A. Redd, Sr., and
    M.B. Berchtold, July 1, 1994

-   P015, High Level Cell and Low Level Cell Hydraulic Doors and
    Hydraulic Door Room JN-1A, L.B. Myers and M.B. Berchtold, September
    1, 1994

-   P016, Subcells of the High Level and Low Level Cells in JN-1A, L.B.
    Myers, M.B. Berchtold, and P.A. Tomlin, November 1, 1994

-   P017, Low Level Cell JN-1A, L.B. Myers, M.B. Berchtold, T.A.
    Beddick, P.D. Faust, and P.A. Tomlin, August 1, 1994

-   P018, High Level Cell JN-1A, L.B. Myers, M.B. Berchtold, P.D. Faust,
    and P.A. Tomlin, August 1, 1994

-   P019, Charpy Room JN-1A, Louis B. Myers, C.A. Redd, Sr., M.B.
    Berchtold, June 1, 1994

-   P023, Course 7: Metals for Nuclear Power, Lesson Ten: Structural
    Materials, Metals Engineering Institute, 1958

-   P025, Miscellaneous Material Safety Data Sheets (MSDS), Various

-   P026, The U.S. Government and Battelle: Partners in Nuclear
    Research, 1943 - Present, Various, Not Given

-   P028, Battelle Columbus Laboratory Hot Cell Facility, Radioactive
    Material Receipt Record and Survey, Project G-7656-3, T.R. Emswiler,
    October 24, 1967

-   P029, Battelle Memorial Institute - Columbus Laboratory, Radioactive
    Shipment and Receipt Form, Project 227566, T. R. Emswiler, December
    24, 1970

-   P032, Procedures Manual for Battelle's Radioisotope, Gamma, and
    Hot-Cell Laboratories, BMI-PM-662, D.N. Sunderman and R.F.
    Dickerson, February 20, 1962

-   P034, Finding of No Significant Impact and Environmental Assessment,
    Battelle Columbus Laboratories Decommissioning Project, U.S. DOE
    Chicago Operations Office, June 1, 1990

-   P037, Decontamination Work Plan for Building JN-1, Battelle Columbus
    Division, November 1, 1990

-   P041, Interim Guidance on Ensuring that Waste Qualifies for Disposal
    at the Waste Isolation Pilot Plant, U.S. DOE CBFO, December 13, 1997

-   P076, Acceptable Knowledge Summary, Pool Water Prefilter and Debris,
    Revision 1, WASTREN, Inc., January 19, 2001

-   P077, Waste Management Operating Procedure: Operation and
    Maintenance of the Alkota Pressure Washer, WA-OP-061, Revision 3,
    Battelle Columbus Laboratories, March 6, 2001

-   P078, Work Instruction: Operation of CAA Pressure Wash System,
    WI-976, Revision 2, Battelle Columbus Laboratories, November 30,
    2000

-   P079, Work Instruction: Material Removal from the High Level Cell,
    WI-1021, Revision 0, BCL, February 2, 2001

-   P501, Building JN-1 Hot Cell Laboratory Acceptable Knowledge
    Document, TCP-98-03, Revision 2, K. J. Peters, August 2001

-   P503, Waste Characterization Classification, and Shipping Support
    Technical Basis Document for BCLDP West Jefferson North Facility,
    DD-98-04, Revision 4, C. W. Skapik, November 2002

-   P505, Segregation and Packaging of TRU Waste, TC-OP-01.4, Revision
    2, P. Erickson, Date TBD

-   P506, Packaging Video Documentation, TC-OP-01.5, Revision 2, D.
    Garber, Date TBD

-   P511, Technical Basis Document, Acceptable Knowledge Process
    Description, Repackaging of Building JN-1 Clean-Up Waste Containers,
    TCP-98-03.1.2, Revision 2, K.J. Peters, WASTREN, Inc., July 2001

-   P512, Technical Basis Document, Acceptable Knowledge Process
    Description, TRU Waste Laundry Decontamination, TCP-98-03.1.3,
    Revision 1, K.J. Peters, WASTREN, Inc., June 2001

-   P514, Identification, Segregation, Separation, and Documentation of
    Low Level and Radioactive Mixed Waste, WA-OP-020, Revision 7, P.
    Erickson, Date TBD

-   P518, Lessons Learned Report for the BCLDP Transuranic Waste
    Shipments to Hanford and the Savannah River Site for Interim Storage
    and Final Characterization, N/A, P. Weaver, November 2006

-   P704, Characterization of Remote-Handled Transuranic Waste for the
    Waste Isolation Pilot Plant -- Final Report, National Academy of
    Sciences, 2002

-   P727, CCP Calculation Cover Sheet: SRS TRU Radiological
    Characterizations, SRS-RH-01, Revision 0, R. Tayloe, June 26, 2007

-   P729, Swipe Sample Data Analysis Calculation Package, SRS-RH-03,
    Revision 0, J. Vance, May 16, 2007

-   P735, Fuel Type Evaluation, SRS-RH-09, Revision 0, J. Vance, May 16,
    2007

-   P737, Calc Package for Determination of Reportable Isotopes,
    SRS-RH-11, Revision 0, J. Vance, May 16, 2007

-   U001, Miscellaneous Maps of Battelle Columbus West Jefferson
    Facility, Battelle Columbus Laboratories, Date Not Given

-   U002, Description of the Battelle Hot Cell Laboratory, Battelle
    Columbus Laboratories, Date Not Given

-   U003, Battelle-Columbus Hot Cell Laboratory - Capability Summary,
    Battelle Columbus Laboratories, Date Not Given

-   U004, Buildings JN-1, JN-2, and JN-3 Summaries, Battelle Columbus
    Laboratories, Date Not Given

-   U006, ENG-92 Contract Projects Database 1 Printout, Query Dated May
    20, 1985

-   U008, Nuclear Fuel Inventory at West Jefferson North, Battelle
    Columbus Laboratories, Date Not Given

-   U009, Miscellaneous JN-1 Waste Inventory Data, Battelle Columbus
    Laboratories, 1988−1997

-   U014, ENG-92 Contract Projects Database 2 Printout, Battelle
    Columbus Laboratories, Query, October 17, 1986

-   U016, Nuclear Materials Questionnaires, Battelle Columbus
    Laboratories, 1985

-   U025, Actinide Screen Data for Radionuclides Contained in Strippable
    Paint from JN-1 Charpy Cell, Battelle Columbus Laboratories, July
    17, 2000

-   U026, 69 Sample Basis of DD-98-04 Technical Basis Document, Battelle
    Columbus Laboratories, May 25, 2001

-   U509, Waste Management 2000 Presentation and Paper -- RH-TRU Waste
    Packaging Visual Confirmation Using a Dual-Camera Video Security and
    Documentation System, D. Garber, J. Eide, and K. Peters, Not Dated

-   U513, Miscellaneous Inventory Spreadsheets, K.J. Peters, BCLDP, SRS,
    Hanford, Various

-   U516, Waste Management 2002 Paper, Adequacy of a Small Quantity Site
    RH-TRU Waste Programs in Meeting Proposed WIPP Characterization
    Objectives, J. Biedscheid, M. Devarakonda, S. Stahl, K. Peters,
    and J. Eide, 2002

-   U734, Review of Spreadsheet WJ_samp.xls "69 Swipes from
    Battelle", R. Tayloe, August 7, 2001

-   CCP-AK-SRS-500: Central Characterization Project Acceptable
    Knowledge Report for Battelle Columbus Laboratory's Decontamination
    Project (BCLDP) Remote Handled Transuranic Debris Waste from the
    Building JN-1 Hot Cell Laboratory, Waste Stream: SR-BL-BCLDP.001,
    Revision 0, May 17, 2007 and Revision 1, August 27, 2007

-   CCP-AK-SRS-501: Central Characterization Project Remote Handled
    Transuranic Radiological Characterization Technical Report for
    Remote Handled Transuranic Debris Waste from Battelle Columbus
    Laboratory's Decontamination Project at the West Jefferson Facility,
    Revision 0, June 14, 2007 and Revision 2, November 28, 2007

-   CCP-AK-SRS-502: Central Characterization Project RH TRU Waste
    Certification Plan for 40 CFR Part 194 Compliance and Confirmation
    Test Plan for BCLDP Waste Stream SR-RL-BCLDP.001, Revision 0, June
    11, 2007

-   CCP-AK-SRS-503: Central Characterization Project Battelle Columbus
    Laboratory Decommissioning Project Quality Assurance Equivalency
    Report and Procedure Matrix for Remote--Handled Transuranic Debris
    Waste, Revision 0, June 13, 2007

-   CCP-TP-506, CCP Preparation of the Remote-Handled Transuranic Waste
    Acceptable Knowledge Characterization Reconciliation Report,
    Revision 2

-   Characterization Reconciliation Report, BC SRS Waste Stream -
    SR-RL-BCLDP.001, Attachment 5 and related required documents,
    prepared July 17, 2007 (Waste Stream Profile Form, Draft, also
    provided)

-   TRU Waste Package Loading Record, BC0048, February 24, 2003

-   Qualification Cards for S. Nance, AK Expert (AKE) and R. Tayloe (DTC
    Technical Specialist), provided July 19, 2007

-   Project Office Data Tracking System (PTS), CTS Corrective Action Non
    Conformance Reporting, provided July 19, 2007

-   Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot
    Plant, DOE/WIPP- 02-3122**,** Revision 6, November 16, 2006

-   Remote-Handled TRU Waste Characterization Program Implementation
    Plan, DOE/WIPP -02-3214, Revision 0D

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-   Scaling Factor Development, Calculation Package No. SRS-RH-01
    Revision 0, June 26, 2007 and Revision 2, November 6, 2007

-   Dose-to-Curie Correlation for Cs-137 and Co-60, Calculation Package
    No. SRS-RH-02, Revision 0, June 26, 2007 and Revision 1, November 5,
    2007

-   Evaluation of Swipe Sample Data, Calculation Package No. SRS-RH-03,
    Revision 0, June 26, 2007 and Revision 1, October 26, 2007

-   Source Uncertainty Using MCNP5, Calculation Package No. RSR-RH-04,
    Revision 0, May 16, 2007 and Revision 1, November 7, 2007

-   Dose-to-Curie Spreadsheet, Calculation Package No. SRS-RH-05,
    Revision 0, May 16, 2007 and Revision 1, November 7, 2007

-   Uncertainty Analysis, Calculation Package No. SRS-RH-06, Revision 0,
    May 16, 2007 and Revision 1, November 7, 2007

-   ORIGEN2.2 Benchmarking for LWR Fuel, Calculation Package No.
    SRS-RH-07, Revision 0, May 16, 2007

-   Evaluation of Different Fuel Type, Calculation Package No.
    SRS-RH-09, Revision 0, May 16, 2007 and Revision 1, November 5, 2007

-   Evaluation of Different Fuel Type, Calculation Package No.
    SRS-RH-09,

-   Swipe Sample Data Decay Correction, Calculation Package No.
    SRS-RH-10, Revision 0, June 26, 2007 and Revision 1, November 5,
    2007

-   Determination of Reportable Isotopes, Calculation Package No.
    SRS-RH-11, Revision 0, May 16, 2007 and Revision 1, November 6, 2007

-   Swipe Sample Data Input Check, Calculation Package No. SRS-RH-12,
    Revision 0, May 25, 2007

-   Fission Product Contribution to Dose Rate, Calculation Package No.
    SRS-RH-13, Revision 0, May 25, 2007 and Revision 1, November 5, 2007

-   ORIGEN2.2 Date Extraction Program (OriOout01), Calculation Package
    No. SRS-RH-14, Revision 0, May 29, 2007

-   TC-OP-01.4, Revisions 1 and 2

-   TCP-98-05, Revision 3, Training Plan for the Battelle Columbus
    Laboratories Decommissioning Project (BCLDP) TRU WCP, March 3, 2003

-   Training Program, TRU 100, WIPP Indoctrination for the BCLDP TRU WCP
    Training Program Record, Revision 2, June 15, 2000

-   Work Instruction WI-958, Set Up and Packaging of Transuranic Waste
    in the High Energy Cell, Revision 2, April 1, 2000

-   Work Instruction 956, Packaging of Transuranic Waste in the
    Mechanical Test Cell Addendum 1, March 1,1999

-   List of Containers in Waste Stream SR-RL-BCLDP.001

-   TRU Waste Packaging Loading Record Itemized Data, Container No.
    BC0090

-   TRU Waste Packaging Loading Record Itemized Data and Audio/Visual
    recording, Container No. BC0070

-   TRU Waste Packaging Loading Record Itemized Data and Audio/Visual
    recording, Container No. BC0035

-   TRU Waste Packaging Loading Record Itemized Data and Audio/Visual
    recording, Container No. BC0051

-   TRU Waste Packaging Loading Record Itemized Data and Audio/Visual
    recording, Container No. BC0120

-   Training Record for VE Operator for Procedure TC-OP-01.4, Revision 2

-   Record Inventory and Disposition System (RIDS) for BCLDP from
    PR-AP-17.1, Revision 5

-   WIPP Waste Container Report for Canister ID0051 Housing Container
    Nos. 001131, 001141, and 001143

-   WIPP Waste Container Report, Container No. 001131

-   WIPP Waste Container Report, Container No. 001141

-   WIPP Waste Container Report, Container No. 001143

-   WWIS Data Entry Summary Spreadsheet, Container No. 001131

-   RTR Data Sheet, Container No. 001131

-   Dose-to-Curie Data sheet, Container No. 001131

-   CAR/NCR Email for INL RH Lot 9

-   Waste Container Data, Container No. 001117

## Acceptable Knowledge Process Overview and Analysis

(1) Waste stream definition for SRS-CCP BCLDP waste stream
    SR‑RL‑BCLDP.001 was examined and found to be adequate following
    incorporation of additional information.

The WCPIP defines *waste stream* as "waste material generated from a
single process or activity, or as waste with similar physical, chemical,
and radiological properties." Waste Stream SR‑RL‑BCLDP.001 is a debris
waste stream generated in the JN-1 HCL facility during D&D activities
performed from May 1999 through August 2004, and was packaged in June,
consisting of 87 drum liners.

The EPA inspection team evaluated the physical and radiological
compositions of the waste with respect to waste stream definition to
ensure they were appropriate. Several references were examined to
understand the historical AK assessment of the stream, including but not
limited to, P501, C001, P023, P026, P511, P514, and U513. It was noted
that the waste stream was generated solely through D&D of the JN-1 HCL,
which included several areas such as the Mechanical Test Cell,
High-Energy Cell, Low-Energy Cell, Alpha-Gamma Cells, Controlled Access
Area, and Charpy Room. Wastes generated included the spectrum of D&D-
related debris materials. Reference C504 summarized the WMP content
within each drum liner. All waste in the drum liners had been
mechanically compacted during loading to reduce void space and maximize
waste packaging using a 5,000-pound weight.

It was also noted that this waste stream includes four liners that
contained mop heads, as well as residual solidified materials
representative of small fines or the solidification of liquids
associated with mop heads and other clean-up materials. While the WMPs
in these four liners are distinguishable from the remaining D&D waste
population, EPA concluded that the four drums containing mop heads and
related materials were generated by the same process and should contain
the same general material and radiological parameters, so inclusion of
the drums in the stream was appropriate. The AKEs interviewed stated
that no individual drum liner contained greater that 50% solidified
material, so the waste summary category group (SCG) was consistent
within the waste stream, as presented in reference C504.

The EPA inspection team determined that the AK record for this waste
stream was initiated years prior to completion of waste packaging. For
example, AK document P501 was prepared in 2001 and described at least
nine separate waste types based on physical form. The EPA inspection
team also found that while SRS-CCP considered the debris in this stream
to have originated from a single process similar in material, chemical
and radiological properties, BCL representatives packaging the waste
during the clean-up process segregated the waste into four separate
groupings: hazardous combustibles; non-hazardous combustibles; hazardous
non-combustibles; and non-hazardous non-combustibles. The EPA inspection
team determined that additional justification and information pertinent
to waste stream packaging and waste stream determination were required
to better support CCP's conclusion to combine the 87 drum liners into a
single waste stream.

As part of EPA's assessment of the waste stream determination, the EPA
inspection team tracked and verified several elements of the AK summary
(CCP-AK-SRS-500) and its references to ensure that radiological
characterization performed was technically supported, with particular
emphasis on AK parameters used to develop the JN-1 Standard Isotopic Mix
and scaling factors. CCP-AK-SRS-500 presents the JN-1 Standard Isotopic
Mix, citing P503 and U516 as among the primary references supporting the
determination of this mix. However, P503 has only a general discussion
of the isotopic mix determination and does not provide detailed
supporting information, and U516 has the proceeding from a presentation
given at a Waste Management conference in 2002. The EPA inspection team
found that the memorandum documenting ^235^U enrichment, burn-up, and
decay was not verified through supporting references or other
information. The SRS-CCP AKE stated that some of the original BCL
information was not available and that they could not produce a historic
database that cataloged the radiological experiments and parameters
relative to the activities within JN-1.

Some references such as U014 contain worthwhile information. The EPA
inspection team also determined that the representativeness of the 69
swipe samples used to generate the radionuclide scaling factors was not
adequately supported in the AK record. The EPA inspection team
determined that it was necessary to better document the origin of ^235^U
enrichment, and the burn-up and decay values used as input to ORIGEN2.2
modeling in SRS-CCP documents. EPA discussed the need for better
documentation of the origin of ^235^U enrichment with AKEs and also
issued EPA Finding No. SRS-RH-AK-07-001F, that included a number of
technical elements. This was the single finding of the inspection and it
is discussed in Sections 8.1 and 8.2 of this report. The aspects that
pertain to waste stream determination and radiological characterization
are presented below.

**EPA Finding No. SRS-RH-AK-07-001F**: This finding covers four issues
and Table 3, below, indicates where each issue is addressed, the
information provided by SRS-CCP for their resolution is discussed, and
the status of the issue. For a full description of this finding see
Attachment A to this report.

+---------------+--------------------------+---------------+----------+
| **Table 3.    |                          |               |          |
| Details of    |                          |               |          |
| EPA Finding   |                          |               |          |
| No.           |                          |               |          |
| SRS-R         |                          |               |          |
| H-K-07-001F** |                          |               |          |
+===============+==========================+===============+==========+
| **EPA Finding | **Issue Summary**        | **Report      | **Issue  |
| No.**         |                          | Section Where | Status** |
|               |                          | Issue is      |          |
| **SRS-R       |                          | Discussed**   |          |
| H-AK-07-00F** |                          |               |          |
+---------------+--------------------------+---------------+----------+
| Issue (a)     | Completeness and         | Section 8.1   | Resolved |
|               | adequacy of              | (1), page 23  |          |
|               | documentation for AK and |               |          |
|               | radiological             |               |          |
|               | characterization         |               |          |
+---------------+--------------------------+---------------+----------+
| Issue (b),    | Limit waste stream       | Section 8.1   | Resolved |
| 1^st^ bullet  | documentation to 87 drum | (3), page 26  |          |
|               | liners at SRS            |               |          |
+---------------+--------------------------+---------------+----------+
| Issue (b),    | Clarify isotopic         | Section 8.1   | Resolved |
| 2^nd^ bullet  | distributions            | (3), page 26  |          |
+---------------+--------------------------+---------------+----------+
| Issue (b),    | Expand discussion of     | Section 8.1   | Resolved |
| 3^rd^ bullet  | radiological             | (3), page 26  |          |
|               | characteristics of waste |               |          |
|               | stream                   |               |          |
+---------------+--------------------------+---------------+----------+
| Issue (c)     | Delineation of waste     | Section 8.1   | Resolved |
|               | stream                   | (1), page 23  |          |
+---------------+--------------------------+---------------+----------+
| Issue (d)     | Documentation of TMU and | Section 8.2   | Resolved |
|               | radionuclide scaling     | (6), page 43  |          |
|               | factors                  |               |          |
|               |                          | Section 8.2   |          |
|               |                          | (7), page 45  |          |
+---------------+--------------------------+---------------+----------+

**EPA Finding No. SRS-RH-AK-07-001F, Issues (a) and (c):** In August
2001, EPA conducted a surveillance of the BCL RH WC program. In the
report sent to DOE (EPA's Technical and Regulatory Support Document for
RH Waste Determination, February 2004 transmitted by EPA to DOE by Frank
Marcinowski, March 26, 2004), EPA stated that: "BC's RH Program could be
improved through more diligent acquisition and integration of AK-based
radionuclide information to determine isotopic distributions." EPA also
questioned the representativeness of swipe samples collected that were
later used as part of scaling factor/JN-1 isotopic mix development. EPA
concluded that the "AK program data assembly/compilation elements were
not complete". EPA concluded that while the radioassay approach had
merit, characterization activities performed to support the approach at
the time of the 2001 surveillance "were not technically adequate."

EPA's current inspection identifies the following issues related to AK
and radiological characterization documentation completeness and
adequacy, many of which are related to issues identified in our August
2001 surveillance:

**Issue (a)**: Isotopic ratio/composition information from two primary
sources was used to develop scaling factors (also the JN-1 Standard
Isotopic Mix). The factors were derived from a combination of swipe
sample and modeling results, using input data to the model (ORIGEN2.2)
that originated in a memorandum from a 1999 meeting. As an auditable
record, additional information and rationale supporting the approach is
required both for the isotopic distributions based on the swipe data and
the recommended burn-up, enrichment, and decay data from the 1991
memorandum. Documentation of the references and data sources that were
reviewed and evaluated during the 1999 meeting is necessary to support
the conclusions used by SRS-CCP. With regard to the swipe data, the
sampling plan and collection, the sample numbers, sampling results, and
other relevant information must be summarized to show that the sample
data are sufficiently representative of the wastes within Waste Stream
SR-RL-BCLDP.001.

> **Issue (c):** Through the course of the AK information acquisition
> and interpretation process, the number of waste streams identified in
> JN-1 has changed over time. Specifically, the current designation of
> Waste Stream SR-RL-BCLDP.001 stream was originally identified as four
> separate waste streams. There is no information given to show these
> waste streams were combined into a single stream.

**EPA Finding No. SRS-RH-AK-07-001F, Issues (a) and (c) Resolution:** In
response to Issues (a) and (c), SRS-CCP provided a formal resolution
letter describing their approach, as well as References C510, C511, 513,
and C520, three of which contain additional information pertaining to
the 1999 memorandum. While the source of information for the parameter
ranges in the 1999 memorandum was not cited in C511 other than to cite
general text references, C520 indicates that these ranges agree with the
fuel libraries associated with ORIGEN 2.2, the sources of which are
documented. Reference C513 provides additional information concerning
waste origin and distribution.

Reference C510 states that while a sampling plan was not found, SRS-CCP
interviewed the individuals that performed the sampling and analysis,
and these individuals indicated that the sampling was *authoritative* in
nature. SRS-CCP representatives indicated that the samples were selected
to include the widest variety of surfaces within JN-1 to ensure that all
possible contaminated surfaces were tested. SRS-CCP did not provide
additional information to document that this approach was compliant with
the WCPIP requirements for representativeness, with the understanding
that the WCPIP was not in place at the time of sample collection.
Accordingly, SRS-CCP could not demonstrate representativeness of the 69
swipe samples through a statistical analysis. It is evident from the
available information that these wastes were transferred and packaged
without regard to the generation location within the JN-1 complex (i.e.,
wastes from different areas were packaged together), and thus
potentially contaminating surfaces throughout the JN-1 area.
Accordingly, the JN-1 sample collection locations and number of samples
taken should result in a reasonable portrayal of the potential
contamination of the wastes generated within the JN-1 complex.

EPA's conclusions are based upon interviews with SRS-CCP personnel, as
there is no sampling plan or other documentation from the individuals
who performed the sampling. To support both SRS-CCP's assessment and
EPA's inspection, EPA required that SRS-CCP provide a Memorandum
documenting the sampling approach prepared by BCL staff familiar with
the swipe sampling at various JN-1 locations where RH debris waste was
handled. EPA specifically required that this memorandum address the
sampling procedure and rationale that was followed, with emphasis on the
following:

1)  Guidance that was followed to develop and execute the sample
    collection, e.g., DOE Order, CBFO Procedure or other guidance

2)  Sample protocols (reference the procedure(s) followed)

3)  Reason for initial sample collection and the use of 69 samples to
    characterize the waste, i.e., why 69 samples were considered
    sufficient

4)  Rationale why the selected samples were considered representative,
    i.e., selected from a variety of surfaces, certain number from each
    area, anticipated contamination in the areas

5)  Indicate if the sampling was performed prior to approval of the
    WCPIP, if this is the case

6)  Specify timing of sampling and the selection of the 69 sample subset

EPA determined that the lack of this information prevents EPA from
independently verifying that the data from 69 swipe samples was
representative on the basis of the objective evidence presented. Also,
EPA considered it necessary to have this information to support DOE's
contention that 69 swipe samples are indeed representative, as discussed
in Section 8.2 (2).

SRS-CCP prepared Reference C509, which documented why BCLDP personnel
performed the initial waste subdivisions, and why combining four
different waste categories into a single stream is appropriate and
compliant with WCPIP and requirements.

The CCP responded to EPA's request in April 2008, preparing a memorandum
titled "Response to EPA SRS RH Additional Information Request". In
response to EPA Items 1 and 2, the memorandum stated that "The sampling
protocol used to collect the smears was the routine health physics
survey procedure HP-OP-019, *Radiation and Contamination Survey
Techniques* (AK source document number P751). This procedure, coupled
with waste instructions, provided the documentation used by BCLDP to
collect the samples. The BCLDP staff considered this procedure as
equivalent to the sampling plan at the time. Waste Instruction WI-956
(AK source document number P707), is an example of a waste instruction
from the 1999 time frame." Review of these references indicates that
while HO-OP-019 (P751) certainly contains descriptions of smear survey
protocols and other procedures that could also be used in
characterization surveys, the document also states in Section 4.2 "This
procedure does not apply to characterization surveys, nor is it intended
to alter current or future characterization surveys". Reference P707
describes waste packaging protocols for pool filters and resins that are
outside of the current waste stream. The Memorandum also relies heavily
on expert judgment and personnel expertise to support appropriate sample
collection. In response to EPA Item 3, the Memorandum states that
surveyed material, surveyed locations, and statistical analysis (Central
Limit Theorum) indicate that 69 swipe samples are "reasonable and
adequate". EPA agrees that the number of samples collected should be
sufficient if the initial population selected for sampling adequately
captures the variability of the waste population as a whole. In response
to EPA Item 4, the Memorandum reiterates information obtained by EPA
during the inspection: samples were collected randomly from a variety of
surfaces to capture the maximum potential isotopic distribution that may
be present in the waste. The Memorandum, however, makes no statement
regarding collection of samples prior to approval of the WCPIP (EPA Item
5).

EPA recognizes that smear/swipe sampling was performed during the
pre-2000 time period (EPA Item 6), while EPA approved the WCPIP
addressing RH waste characterization activities in 2003. The WCPIP
explicitly *requires* the preparation of a sampling and analysis plan
when sampling is performed (Section 4.8.1): e.g.: "...A sampling plan
shall be developed and documented for each RH TRU waste stream....the
burden of responsibility for developing a technically sound sampling
plan rests with the TRU waste generator". Since the smear samples were
taken prior to the sampling and analysis (S&A) plan requirement of the
WCPIP, EPA understands that compliance with all WCPIP requirements may
not be possible for this waste stream.

In future, EPA, however, expects that the CCP will provide rigorous and
detailed information as part of the AK Record to document as much
information about waste sampling as possible (such as that provided to
resolve this EPA Finding) to meet the WCPIP-based sampling requirements
initially for EPA evaluation. When proposing as a T1 change another
BCLDP RH waste stream (e.g., BCLDP solids and soil/gravel) for EPA
evaluation and approval, the CCP must provide rigorous and detailed
sampling and analysis information when CCP cannot fulfill the S&A plan
requirement of the WCPIP for EPA evaluation. Based on the information
provided by CCP prior to, during and since the inspection, EPA concludes
that the samples collected, together with Fuel Type Scaling Factor
comparisons (discussed in Section 8.2 of this report), results in a
reasonable description of the isotopic distribution sufficient to verify
acceptable knowledge.

[]{.mark}

**EPA Finding No. SRS-RH-AK-07-001F, Issues (a) and (c) Status:** Based
on the information examined, as discussed here and in Section 8.2 (7),
the EPA inspection team determined that the use of the 69 swipe sample
data in the manner employed by SRS-CCP resulted in sufficient
information to verify isotopic distributions presented in the AK Summary
and assumptions discussed later in Section 8.2 of this report. EPA
considers both Issues (a) and (c) to be closed.

\(2\) The identification of these wastes as defense-related, TRU versus
HLW, low-level waste, and SNF was examined and accepted.

CCP-AK-SRS-500 stated that the waste met the definition of defense
waste, even though the vast majority of radiological material managed in
JN-1 was non-defense related. DOE agrees with SRS-CCP's justification as
to the defense determination. DOE is solely responsible for the
determination. EPA does not evaluate the defense determination that DOE
performs for TRU waste destined for disposal at WIPP. The AK Summary
stated that the waste met the definition of defense waste because
defense-related naval reactor material was managed in the complex, and
defense-related research and development activities took place in JN-1.
The occurrence of both activities would cause the defense and
non-defense material to be commingled, thus imparting a defense
determination to the waste. This is also documented in Reference C501.
The AK Summary indicated that the waste did not contain wastes derived
from the separation or reprocessing of constituent elements from reactor
fuel and the waste stream did not contain irradiated fuel elements
withdrawn from a reactor. SRS‑CCP BCLDP representatives stated that HLW
is not included in this waste stream by definition. Similar to the LANL
debris waste that lacked an explicit SNF pedigree (see Air Docket No.
A-98-49, II‑A4‑89), the RH debris waste from BCLDP does not have an
explicit SNF pedigree.

\(3\) Sufficiency of the AK summary and implementation of AK as required
in Attachment A of the WCPIP were evaluated and found to be adequate
upon revision of key documents.

Attachment A of the WCPIP specifies that the following be included in AK
summaries:

-   Executive summary

-   Waste stream identification summary

-   AK data and information description

-   Program information

-   Waste stream information

-   Qualification of AK information

-   Container-specific information

Attachment A of the WCPIP mandates that the data collection and analysis
process should be similar to the process that is used for CH wastes.
Both the content of the AK summary and sufficiency of AK implementation
were assessed, and EPA determined that the AK Summary adequately
addressed the main required elements of the WCPIP. The EPA inspection
team, however, found discussion of additional separate waste streams
within the text of the AK summary, which implies that SRS-CCP may have
been seeking a broader scope of approval than what EPA determined
through interview of the AKEs. EPA focused only on Waste Stream
SR‑RL‑BCLDP.001 and limits its evaluation to that waste stream. The EPA
inspection team also found the discussion in CCP‑AK‑SRS‑500 concerning
the "standard" versus "non-standard" radiological mixes and differing
characterization processes confusing. The AKE indicated that this waste
stream was only characterized using the JN-1 Standard Isotopic Mix and
no other sampling or analysis approach was apparently used to
characterize waste outside of this stream. The text of CCP‑AK‑SRS‑500
did not include information pertaining to general radiological content
of materials managed in the JN-1 HCL, including the number of
experiments associated with LWR and other reactors or related isotopic
information. While the AKE indicated upon interview that only material
originating from within JN-1 HCL was present in waste, AK data provided
as references and in the CRR were confusing because it was unclear how
radiological data from the JN-2, JN-3 and JN-4 areas pertain to JN-1.
This was discussed with SRS-CCP personnel during the inspection and EPA
included this issue as a finding on the EPA Inspection Issue Tracking
Form that was discussed throughout this report (see Attachment A of this
report for a copy of this form). The aspects of the finding that pertain
to the content of the AK Summary are presented below:

**EPA Finding No. SRS-RH-AK-07-001F, Issue (b):** EPA's current
inspection identifies the following issues related to AK and
radiological characterization documentation completeness and adequacy,
many of which are related to issues identified in our August 2001
surveillance:

CCP-AK-SRS-500 must be revised to address the following:

-   Only describe the SRS waste stream of 87 drum liners subject to this
    inspection.

-   The document states that there are wastes in this stream that
    exhibit both "standard" and "non-standard" isotopic distributions
    and that non-standard waste will undergo separate sampling and
    analysis. However, the AKE indicated that only "standard" isotopic
    mix wastes are included in the stream, and there are no wastes that
    underwent the alternative sampling and analysis approach discussed
    in the text.

-   Include a thorough presentation of general radiological
    characteristics of wastes. Information such as types of
    radionuclides handled in JN-1 in the various cells/areas, origin of
    radionuclides (e.g., LWR), outliers, and any other information
    necessary to provide a general overview of the radionuclides handled
    through the course of JN-1 operations is necessary.

**EPA Finding No. SRS-RH-AK-07-001F, Issue (b) Resolution:** SRS-CCP
revised CCP‑AK‑SRS‑500, noting that the number of drum liners within the
most recent version was correctly reduced to 87. SRS-CCP removed the
88^th^ drum liner from consideration as it did not meet the definition
of TRU waste and hence, not eligible for WIPP disposal. Also, while
additional process information and the CCP radiological characterization
approach were included in Revision 1 of CCP-AK-SRS-500, the radiological
data cited in the EPA finding was included in Revision 2 of
CCP-AK-SRS-501. Therefore, the radiological characteristics of waste are
adequately defined in the combination of the information presented in
the revised CCP-AK-SRS-500 and CCP-AK-SRS-501 reports, as well as
supporting references.

**EPA Finding No. SRS-RH-AK-07-001F, Issue (b) Status:** Based on the
information examined, the EPA inspection team determined that the AK
Summary had been adequately revised to address the above issues. EPA
considers this aspect of the finding to be closed.

\(4\) Data traceability was examined and found to be adequate upon
incorporation of additional information.

Data traceability was assessed to understand the hierarchy of
information that was ultimately used by AK personnel to identify the
physical and radiological parameters associated with this waste stream.
SRS-CCP-BCLDP personnel provided the following information pertaining to
data traceability:

-   Waste Packaging Records for Liners BC0127 (Pressure Wash Filters),
    BC0075, and BC003 (Liner in Canister)

-   Certification Paperwork for Liners BC0127 (Pressure Wash Filters),
    BC0075, and BC003 (Liner in Canister)

-   HP Survey Report for Liners BC0127 (Pressure Wash Filters), BC0075,
    and BC003 (Liner in Canister)

-   CCP-AK-SRS-501, Appendix 3, Waste Container Dose to Curie Conversion
    Records (All 87 Drum Liners)

-   Calculation Packages P729, P7353, P737

This waste stream did not have individual records pertaining to isotopic
characteristics of individual containers (i.e., data that associated the
69 swipe samples with specific containers or campaigns were not
available, and individual drum data except for drum loading travelers
were not available). The AKE stated that the liners were not typically
packaged in the same room or cell where the wastes were generated, so
there could be no correlation between wastes and their generation point.
However, VE records document the origin of individual waste items within
the liners and shows that multiple areas may have contributed to the
waste in an individual drum liner. Typically for CH TRU wastes, EPA
evaluates traceability of radiological measurements of waste containers
(drums) during the on-site inspection. In the case of this RH waste
stream, the measurements used to support the WC are historical which
complicates the data traceability evaluation. Assessing data
traceability is necessary to understand the origin and hierarchy of
radionuclide and physical data associated with each canister. See AK
Sections (1) and (2), above, regarding deficiencies with respect to
radionuclide data traceability and supportability.

\(5\) Sufficiency of AK support documents and related document tracking
was evaluated and was found to be adequate.

A list of AK source document references was prepared using unique
identifiers for the different document types following the format used
by SRS-CCP for CH wastes. The listing is based on CCP-TP-005 Revision
18, Attachment 4. The listing was complete, and was easy to understand
because it followed the same format used for CH waste streams. Several
AK support documents were referenced in the text and the references
examined to date address the element or issue that is referenced with
the AK summary, although applicability does vary. EPA only examines
support documentation specific to the technical element referenced in
the AK summary that caused that support reference to be selected for
examination.

(6) Interpretation of WCPIP was evaluated with respect to contents of
    the Certification Plan, the CTP and the proposed characterization
    process and was found to be adequate.

EPA's RH WCPIP framework approval letter dated March 26, 2004, indicated
that sites must generate a Certification Plan that explains how RH waste
characterization will take place at each site, as well as a CTP. Based
on the previous RH inspection experience, EPA determined that combining
the Certification Plan and CTP in a single document that described the
proposed characterization process would satisfy the EPA requirements. In
this instance however, EPA observed that language within the CTP is
sometimes confusing, as indicated in Item 7, below.

\(7\) Content and technical adequacy of the CTP was evaluated and found
to be adequate.

The WCPIP requires a description of the following items to be included
in the CTP:

-   The waste stream or waste stream lots to which the plan applies

-   The confirmatory testing proposed, including the percentage of waste
    containers that will be subject to confirmatory testing

-   The WC DQOs and quality assurance objectives (QAOs) that will be
    satisfied with the data being qualified

-   The DQOs and QAOs that will not be confirmed with the data being
    qualified and an explanation of how compliance with those DQOs and
    QAOs will be demonstrated

-   How the tested subpopulation is representative of the waste stream
    or waste stream lot

The required bullets listed above are addressed in the CTP. In the case
of this waste stream, the CTP also includes a discussion pertaining to
AK accuracy and related DQOs. Because this specific waste stream deals
solely with AK-based WC, an evaluation of AK accuracy is not applicable
(other than to document this statement in an AK accuracy memorandum and
within the CTP). Also, EPA has noted that the use of the term
*confirmation* is sometimes confusing in that EPA regards confirmation
to mean actual radiological measurement data or estimation of physical
contents of a waste container to confirm AK information, but CCP has
sometimes used the term in a broader sense when verification activities
take place. EPA understands that the form and substance of the CTP is
designed to meeting the requirements stated in the WCPIP, but care
should be exercised in the future RH site documentations with regard to
the use of the term *confirmation*.

\(8\) Content and technical adequacy of the CRR was evaluated and the
process was found to be adequate as using example data.

The EPA inspection team evaluated the CRR against requirements in
CCP‑TP‑506, Revision 1, for Waste Stream SR-RL-BCLDP.001 to evaluate if
this report reflected the requirements of CCP-TP-506, and to ensure that
the CRR addressed requirement elements as specified in the WCPIP,
including:

-   Specification of applicable site and waste stream

-   A listing of each DQO

-   Data from the AK record that addresses each DQO

-   AK source document references that support/provide the data

-   A listing of AK record DRs, if any, relevant to each DQO

-   Documentation, including specific references, of how the AK data for
    each DQO were qualified, such as batch data reports, corroborative
    data, proceedings of a peer review, etc.

-   Real Time Radiography (RTR) and/or VE summary to document that
    liquids greater than 1 percent are absent from the waste and to
    confirm AK concerning the physical properties of the waste

-   A summary presentation of radiological measurement data used to meet
    the DQOs and to confirm AK

-   A complete AK summary

-   A complete listing of all container identification numbers used to
    generate the WSPF, cross-referenced to each BDR

-   A listing of AK discrepancies generated by an AK qualification
    process and the corresponding resolutions

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-   Signature of the Site Project Manager (SPM)

The example CRR that the EPA inspection team examined included all of
the above WCPIP requirements. As had been observed previously for the RH
WC programs at INL and Argonne National Laboratory-East (ANLE) (see
Docket Nos. A-98-49, II-A4-72 and A-98-49, II-A4-73, respectively), the
CRR DQO worksheet (Attachment 3 of CCP-TP-506) for this RH waste stream
did not include a listing of the 10 WIPP-tracked radionuclides as part
of the DQO assessment process. These radionuclides need to be specified,
quantified, and assessed as part of the CRR. In the past, site
representatives declined to specifically address these because it is not
required by the WCPIP. However, EPA requires information for the 10
WIPP-tracked radionuclides and the CRR generated at other CCP RH TRU
sites must include the ten radionuclides. The reason being that for the
WIPP Performance Assessment performed in conjunction with the WIPP
Repository Recertifcation every five years, identification and
quantification of the 10 WIPP-tracked radionuclides is essential.

Radiological characterization BDRs are not prepared because the
characterization is performed based solely on AK. However, SRS-CCP
documents the compliance of each container with DQOs and other SPM
approvals (signatures) on Attachments 1 and 2 of CCP-TP-506, and the
results of this analysis are rolled up into Attachments 3 and 4 of
CCP-TP-506. The EPA inspection team usually examines these individual
attachments to ensure that complete, drum-specific documentation is kept
for each container throughout the process, and to ensure that this
information is adequately "rolled up." During this inspection only the
single example draft attachment was available. SRS-CCP personnel stated
that data will be manually downloaded from CCP-AK-SRS-501 into a WWIS
controlled spreadsheet. When such data are entered manually, DOE needs
to provide to EPA for review a copy of the WWIS spreadsheet showing
manual data entries.

\(9\) Use of a Correlation and Surrogate Summary Form was evaluated and
was found to be adequate.

Completion of a Correlation and Surrogate Summary Form is required when
AK information from a related CH waste stream is used in the RH WC. The
CCP AKE stated that to date, no CH surrogate container has been
identified pertinent to this waste stream.

\(10\) Personnel training was evaluated and was found to be adequate.

Training records for Sherri Nance and Rob Tayloe were examined. Ms.
Nance's training was evaluated with respect to: training to the RH TRU
WCPIP; non-conformance and corrective action processes; the AK procedure
presented in Attachment A of the WCPIP; site-specific training relative
to the contents of the subject waste stream(s); and determination of
radiological contents of individual drums. The Qualification Card
examined demonstrated training in each area except for non-conformances
(which should be not applicable for this waste stream) and the
determination of the radiological contents of each drum. Where detailed
radiological analysis and expertise are required, Messrs. Jene Vance and
Rob Tayloe performed those tasks. The expertise of Messrs. Vance and
Tayloe was examined, and Mr. Tayloe's resume was reviewed since he was
the CCP technical expert for radiological characterization. Although Mr.
Tayloe did not show direct training with respect to this area, his
resume showed considerable expertise suitable to demonstrating
proficiency. In summary, the evaluated AKE and the radiological Subject
Matter Expert demonstrated the necessary level of knowledge in the area
of radiological assessment through on the job training.

\(11\) Discrepancy Resolution (DR) Forms were examined and found to be
adequate.

Because measurement data were not collected for this waste stream and
all characterization is based on AK, Non Conformance Reports (NCRs) were
not created. Instead, issues identified were AK-AK in nature, so DR
forms were created. DR numbers DR001 through DR0010 were provided within
the CRR. The forms provided detail AK-AK discrepancies dealing with
radiological data in JN-4, transfer pool construction dates, WMP
percentage recalculation, evaporation of JN-1 pool water, analytical
data pertaining to the JN-1 pool (not included in this waste stream),
Resource Conservation and Recovery Act (RCRA) code assignment, waste
generation parameter discrepancies, and JN-1 pool water prefilter
radiological data (not included in this waste stream). Most of these
documents were prepared prior to the current SRS-CCP documentation
process, and the documents adequately address the DR process. When
SRS-CCP addresses items 1 and 3 above, discrepant data may be identified
that require resolution or at least documentation. When this occurs, EPA
expects that all discrepancies identified will be documented on DR forms
with the appropriate supporting documents, and that this information (if
generated) will be placed in the AK record and provided to EPA for
review.

\(12\) A WSPF was examined and was found to be adequate.

An example WSPF was examined for Waste Stream SR‑RL‑BCLDP.001. The form
included the required items as presented in the WCPIP, Attachment 4; the
CRR and RH AK summary are also required for submission to CBFO to allow
assessment of the WSPF. EPA understands that this form was abbreviated
because it was provided for inspection purposes only, and expects that
the completed form will include more AK data, checklists (as
applicable), etc., to better present the required information. EPA
expects to receive the completed WSPF when available for review.

\(13\) AK accuracy was assessed for applicability and was adequately
addressed in the context of this waste stream.

The WCPIP requires determination of AK Accuracy in three areas:
reassignment of the waste to a different SCG; reassignment of the waste
to a different waste stream; and stream-specific assessment of
radiological parameter accuracy. In the case of Waste Stream
SR-RL-BCLDP.001, all characterization was based on AK alone, so an
accuracy determination based on measurement versus AK comparisons cannot
be performed. SRS-CCP included a discussion of AK Accuracy in the CTP
and an AK Accuracy Memorandum. In this document, SRS-CCP cites
comparisons of the modeling/sampling and AK data with respect to TRU
waste determination qualification. CCP‑AK‑SRS‑502 states that TRU waste
determination qualification is accomplished through comparison of AK and
drum liner (also AK) measurement results, while activity determination
qualification was accomplished through AK-based modeling and AK sampling
results. CCP‑AK‑SRS‑502 also states that AK Accuracy DQOs for residual
liquid and physical form are demonstrated through packaging records.
While the comparisons do show that AK data are in agreement in the cited
examples, the information does not address AK Accuracy, which addresses
the comparison of confirmatory measurement data and the AK record.
Therefore, EPA concludes that AK Accuracy cannot be assigned for this
waste stream because confirmatory sampling and analysis information were
not obtained and therefore there is no information on which to base an
assessment of AK Accuracy.

\(14\) The use of load management for this waste stream was assessed and
was determined to be not applicable at this time.

The possibility that containers have TRU concentrations less than 100
nCi/g was evaluated. None of the drum liners were reported to have TRU
concentrations less than 100 nCi/g. The SRS-CCP SPM stated that this
waste stream will not undergo load management, so approval of a load
management by EPA is not requested. Since these drum liners are not
likely to be opened for repackaging or adding other TRU waste, EPA
expects load management not to occur. In a highly unlikely event SRS-CCP
considers load management, compliance with Appendix E of the TRU Waste
Acceptance Criteria (WAC) is necessary.

[]{.mark}

[]{.mark}

## Radiological Characterization

EPA evaluated the method by which the required radiological constituents
for each waste container were determined. The nature of RH TRU wastes
presents some difficulty with respect to obtaining meaningful
measurement data, as is routinely done with CH TRU. Apart from the
obvious personnel concerns associated with working in external radiation
fields in excess of 200 millirem per hour (mrem/hr), RH TRU waste
containers typically contain concentrations of energetic photon
emitters, i.e., ^137^Cs and/or ^60^Co that prevent a meaningful
measurement-based isotopic determination. Accordingly, RH radiological
characterization relies heavily on alternate methods such as the
development of scaling factors that can correlate an easily measured
parameter like external exposure (dose) rate with isotopic distributions
for target radionuclides.

#### Overview of SRS Radiological Characterization Program {#overview-of-srs-radiological-characterization-program .unnumbered}

SRS-CCP's approach to radiological characterization is generally
consistent with the requirements and guidance provided in the WCPIP. The
overall approach to radiological characterization SRS-CCP used for the
BCLDP RH waste has several elements in common with the RH
characterization approach EPA observed in the LANL-CCP RH program during
EPA inspection No. EPA-LANL-CCP-RH-5.07-8 (see Docket No. A-98-49,
II-A4-89). During this RH inspection, the EPA inspection team evaluated
the conceptual bases of the characterization approach, including:

-   Evaluation of radiochemical analyses of 69 swipe or smear samples
    taken in the JN-1 facility to support the development of scaling
    factors using ORIGEN2.2 results

-   Development of a DTC correlation as a function of waste density
    using Microshield® based on each waste liner's measured external
    exposure (dose) rate, assuming the main contributor to the external
    exposure was ^137^Cs

-   Derivation of radionuclide scaling factors for the WIPP-tracked
    radionuclides using ORIGEN2.2 based on the attributes of LWR fuels

With the exception of the use of radionuclide data from the swipe
samples, these techniques have been evaluated in detail during previous
RH inspections. For a thorough evaluation of the conceptual basis and
application of DTC and the development and application of scaling
factors, the reader is directed to the baseline inspection reports for
these RH inspections (see Docket Nos. A‑98‑49, II‑A4‑72; A‑98‑49,
II‑A4‑73; and A-98-49, II-A4-89). These characterization methods used
for the BCLDP SRS RH wastes were evaluated in terms of the technical
adequacy of the approach as supported by the SRS-CCP WC program's
documents, procedures, and controls, and the knowledge and understanding
of the personnel involved in the RH WC program.

**[Technical Evaluation]{.underline}**

The EPA inspection team evaluated the following aspects:

###  {#section-3 .unnumbered}

\(1\) The technical adequacy of the radiochemical swipe data was
evaluated and was found to be adequate.

CCP-SSR personnel stated that between 1996 and 1999 hundreds of swipe
samples were taken from various areas within the JN-1 Facility as part
of the site's routine contamination control program. These samples were
collected periodically, depending on the conditions or activities within
the facility. Some of the swipe samples were also used to identify the
radionuclide content of the subject waste stream and thee swipe sample
assay results were used to support the derivation of radionuclide
scaling factors. During these surveys, surfaces were identified for the
collection of one or more swipe samples of floors, work surfaces,
equipment, waste containers and tools that were subsequently submitted
for radiochemical analysis. Table 4-2 of CCP‑AK‑SRS‑501 lists the types
of surfaces within JN-1 that were swiped. This process produced a total
of 47 of swipes and 22 additional samples from high-efficiency
particulate air filters from the ventilation system servicing areas
within the JN-1 HCL for a total of 69 samples that were submitted for a
suite of radiochemical analyses. The analyses consisted of: alpha
spectrometry for isotopes of americium, uranium, plutonium and
thorium[^10]; gamma spectrometry for specific isotopes of cobalt,
cesium, europium and antimony; and liquid scintillation counting for the
beta-emitting ^90^Sr.

The EPA inspection team did not observe objective evidence documenting
the purpose for which the swipes were taken, although SRS-CCP personnel
stated they were collected to support the development of radionuclide
scaling factors, as stated in CCP-AK-SRS-501. SRS-CCP records indicate
that while many of the 10 WIPP-tracked radionuclides were among the list
of target radionuclides some were not, specifically ^241^Pu[^11] and
^242^Pu. SRS-CCP personnel stated that the radioanalytical values in
CCP-AK-SRS-501 represent all the available values, and that it is
possible that all 69 swipe samples were analyzed for the full list of
target radionuclides but not all samples showed measurable values for
these radionuclides. Accordingly, although 69 swipe samples were
analyzed for ^238^Pu, ^60^Co and ^90^Sr, the analytical results showed
69 measurable values for ^238^Pu, 61 measurable values for ^60^Co and 13
measurable values for ^90^Sr. Analytical results that were not detected,
i.e., below the assay system's lower limit of detection (LLD)[^12] for a
specific radionuclide, are not available. The numbers of usable values
based on these analyses are shown in Table 4, below. Because the EPA
inspection team was unable to determine how many swipe samples were
taken in JN-1, it is not possible to establish what fraction of the
total sampling effort within the JN-1 facility the 69 samples represent,
which has bearing on the samples' representativeness, as discussed in
Sections 8.1 (1) and 8.2 (2), below. Based on the available information
the EPA inspection team accepted that the 69 analytical results that are
available constitute all useable radionuclide values discussed in
Section 8.1 above and item (2), below.

The analyses were conducted by a commercial laboratory (Data Chem) and
by BMI. The criteria for deciding where the samples were analyzed are
not clear but available information suggests that BMI performed all of
the gamma spectrometry analyses, Data Chem performed the early alpha
spectrometry analyses and BMI performed the later alpha spectrometry
analyses. No formal evaluation of the Data Chem and BMI radioanalytical
data provided by SRS-CCP was deemed unnecessary. Both laboratories
provided report sheets that were reviewed during the inspection and
examples of these are included in attachments to CCP-AK-SRS-501. The EPA
inspection team reviewed a sampling of these data sheets for gamma
spectrometry, alpha spectrometry and isotopic uranium from BMI and all
were adequate. The swipe data are technically adequate and sufficiently
documented to support the development of radionuclide scaling factors.

+------------------+----------------+----------------+----------------+
| **Table 4.       |                |                |                |
| Summary of the   |                |                |                |
| Reported         |                |                |                |
| Radionuclides in |                |                |                |
| the 69 Smear     |                |                |                |
| Samples**        |                |                |                |
+------------------+----------------+----------------+----------------+
| ###### Radionuc  | **Number of    | **Number of    | **Number of    |
| lide {#radionucl | Samples        | Values Above   | Values Below   |
| ide .unnumbered} | Analyzed**     | MDA**          | MDA**          |
+------------------+----------------+----------------+----------------+
| ^241^Am          | 69             | 69             | 0              |
+------------------+----------------+----------------+----------------+
| ^244^Cm          | 69             | 69             | 0              |
+------------------+----------------+----------------+----------------+
| ^238^Pu          | 69             | 69             | 0              |
+------------------+----------------+----------------+----------------+
| ^239^Pu/ ^240^Pu | 69             | 69             | 0              |
+------------------+----------------+----------------+----------------+
| ^60^Co           | 69             | 61             | 8              |
+------------------+----------------+----------------+----------------+
| ^154^Eu          | 69             | 54             | 15             |
+------------------+----------------+----------------+----------------+
| ^134^Cs          | 69             | 49             | 20             |
+------------------+----------------+----------------+----------------+
| ^233^U/ ^234^U\* | 29             | 24             | 5              |
+------------------+----------------+----------------+----------------+
| ^90^Sr           | 13             | 13             | 0              |
+------------------+----------------+----------------+----------------+
| ^238^U\*         | 29             | 13             | 16             |
+------------------+----------------+----------------+----------------+
| ^235^U/^236^U    | 29             | 4              | 25             |
+------------------+----------------+----------------+----------------+
| ^237^Np          | 24             | 4              | 20             |
+------------------+----------------+----------------+----------------+
| ^230^Th          | 24             | 12             | 12             |
+------------------+----------------+----------------+----------------+
| ^125^Sb          | 69             | 8              | 61             |
+------------------+----------------+----------------+----------------+

-   Two anomalous uranium results were removed from population

(2) Representativeness of Radiochemical Swipe Data

The degree to which the 69 swipe samples that were subjected to
radiochemical analysis are representative of the wastes that were
handled within the JN-1 HCL is of key importance \[see Section 8.1, (1),
above\]. Specifically, the contamination on the swipes must represent
the types and characteristics of fuel rods that were handled in JN-1 to
technically support the scaling factor development presented in
CCP-AK-SRS-501. As discussed above, apart from the analytical results,
initially SRS-CCP did not produce additional objective evidence to
support the design or intent of the sample collection and analysis
process. The most important piece of documentation would be a sampling
plan, which would ideally discuss the measures taken to ensure that the
samples collected were indeed representative of the materials used
within the sampled area. Similarly, detailed information on the types
and characteristics of fuel rods that were handled in the JN-1 was not
available. Without this information, EPA cannot confirm that the
areas/materials that were swiped are representative of the fuels that
were handled in JN-1 on the basis of documentation. Accordingly, the EPA
inspection team concluded during the July 2007 inspection, that
SRS-CCP's contention that the swipes are representative was not
adequately supported. This was discussed with SRS-CCP personnel during
the inspection and EPA included this in the EPA finding discussed
throughout this report.

In the absence of documentation regarding sample collection, the EPA
inspection team focused on an empirical determination to address the
issue of representativeness. Because exact information regarding the
contribution of the fuels handled within JN-1 was unknown, the average
scaling factors for all fuel types, i.e., LWR, highly enriched uranium
(HEU) and thorium, were plotted against the scaling factors derived from
the swipe data and the application of ORIGEN2.2. The comparison is shown
in Figure 5-1, of CCP-AK-SRS-501 and is reproduced in this report as
Figure 2, below. This plot indicates good agreement between the results
of the swipe analyses and the characteristics of LWR fuel for the
majority of the radionuclides, with the exception of ^230^Th, the
uranium isotopes and ^154^Eu. SRS-CCP personnel stated that these
differences can be explained based on: a lack of equivalent data for
^230^Th; the unexpected processing of unirradiated fuel which would skew
the uranium values; and, simple radioactive decay of ^154^Eu due to its
shorter physical half-life. These issues are discussed in detail in
CCP-AK-SRS-501, Revision 2.

Upon examination during and after the inspection, the EPA inspection
team personnel agreed that the empirical demonstration shown in Figure
2, below, had considerable technical merit. EPA's acceptance of
SRS-CCP's assertion of representativeness is based on the technical
merit of the empirical demonstration, as discussed in the preceding
paragraph. EPA inspection team personnel revisited this issue following
revision of CCP-AK-SRS-501 and the other documents discussed in Section
8.1 (1), above, during the July and December 2007 meetings. The revised
documents provide additional details relative to the representativeness
of the swipe samples. However, the lack of specific information
regarding the design or intent of sample collection is a weakness. In
the future, when sample collection plays as important a role in a site's
RH WC program as it does for this waste stream, EPA will require that
the site provide a sampling plan as required as part of EPA's site
procedures review and approval prior to the baseline inspection. Based
on the strength of the empirical demonstration supported by the revised
documents, EPA agrees that there is sufficient support for SRS-CCP's
contention that the swipes are representative of the attributes of LWR.
Also, as discussed in Section 8.1 above, based on the additional
documentation provided by CCP, EPA concurs that the 69 swipe samples are
representative of the different fuel types handled in the hot cell.

![](media/image2.wmf){width="6.752777777777778in"
height="4.613194444444445in"}**Figure 2. Comparison of Scaling Factors
Representative of Different Fuel Types Against Average Smear Sample
Scaling Factors**

\(3\) The development of radionuclide scaling factor was evaluated and
found to be technically adequate.

In the absence of specific fuel irradiation data, information regarding
the fuels materials' ^235^U content, burn-up and decay was selected
based on the assumption that the majority of the TRU materials within
the JN-1 facility were LWR fuels. Ranges for these parameters were
developed in 1999 \[see Section 8.1 (1)\] as input for 1000 ORIGEN2.2
calculations, the results of which were used to derive radionuclide
scaling factors for ^241^Am, ^238^Pu, ^239^Pu, ^240^Pu, ^241^Pu,
^242^Pu, ^234^U, ^235^U, ^238^U and ^60^Co plus the fission product
^154^Eu. These scaling factors were compared with radionuclide-specific
data generated by the radiochemical analysis of 69 swipe samples that
were collected from locations inside the JN-1 facility, as discussed in
the previous section. The scaling factor for ^233^U was developed
exclusively on the basis of the ^234^U results of the swipe sample
analyses, as discussed below. The determination of ^154^Eu and ^60^Co
was necessary to account for their potential contribution to the
measured dose rate and to identify all radionuclides that contribute to
95% of each liner's radiological hazard[^13].

The EPA inspection team evaluated the following aspects:

-   Activity values that are used are derived from modeling and
    statistical metrics that support their use, and the statistical
    metrics include mean and standard deviation values for each measured
    radionuclide.

-   The appropriateness of the choice of physical constants and
    radionuclide-specific attributes (specific activity, physical
    half-life, decay heat, neutron cross-sections, photon transition
    probabilities, etc.) and the technical correctness of the values
    assigned to each attribute.

-   Isotopic activity values are correlated to each drum liner's major
    radionuclide content(s) responsible for the measured external dose
    rate, i.e., ^137^Cs and ^60^Co.

-   The calculated results used to develop the factors and convert the
    measured external dose rates to radionuclide activity levels.

-   Calculations supporting the scaling factors were performed using
    appropriate shielding analysis techniques, i.e., Microshield^®^.

Regarding the second bullet, above, Revision 1 of CCP-AK-SRS-501 did not
cite the source of the specific activity and physical half-life values,
although SRS-CCP personnel stated that these values were taken from the
CH TRAMPAC. The lack of this reference was included in EPA Finding No.
SRS-RH-AK-07-001F, that is discussed in Section 8.2 (7), below. All
references were appropriately cited in Revision 2 of CCP-AK-SRS-501 that
the EPA inspection team reviewed during the December 2007 meeting, which
closed this part of the finding.

The purpose of a radionuclide scaling factor is to provide a technically
sound method of deriving values for the 10 WIPP-tracked radionuclides
within each container based on the container's measured external dose
rate. ORIGEN2.2 was used to derive scaling factors for all of the
reportable radionuclides based on the ranges of the three parameters
listed below as input:

-   ^235^U enrichment -- 2.0 to 4.0 (weight percent)

-   Burn-up -- 15k through 45k

-   Decay (years post-irradiation to 2002) -- 13 through 30

These ranges were based on the assumption that the materials processed
in the JN-1 HCL were predominantly LWR fuels, which is discussed earlier
in this report. With the exception of ^233^U, the scaling factor for
each radionuclide was determined by taking the arithmetic mean of 1000
ORIGEN2.2 runs. The treatment of ^233^U is addressed below. The scaling
factors are multiplied by the ^137^Cs concentration, which is derived
based on the measured dose rate of each drum and the DTC technique
discussed below. The mass (gram) quantities of the actinides were
extracted from the ORIGEN2.2 output results along with the activity
(curie) quantities of the fission products. Mass and activity values can
be converted interchangeably using the specific activity values provided
in the Contact-Handled Transuranic Waste Authorized Methods for Payload
Control (CH-TRAMPAC). The average scaling factors representing the total
fuel pin population were calculated by taking the ratios of the average
curies of each radionuclide to the average curies of ^137^Cs in a metric
ton of fuel. These averages are the actual scaling factors used to
derive the quantities and distribution of the radionuclides for all 87
drum liners in this population of BCLDP RH wastes. The standard
deviation for each radionuclide was used to calculate the relative
standard error associated with its variation in the fuel compositions.
CCP-AK-SRS-501, Table 6-1, lists the scaling factors derived in this
manner for each of the radionuclides that was used to characterize the
87 drum liners. This table is reproduced as Table 5, below, and lists
the scaling factors in units of curies of each radionuclide per curie of
^137^Cs (Ci/Ci ^137^Cs).

+----------------------------------+-----------------------------------+
| **Table 5. Radionuclide Scaling  |                                   |
| Factors**                        |                                   |
+----------------------------------+-----------------------------------+
| **Radionuclide**                 | **Scaling Factor,**               |
|                                  |                                   |
|                                  | **Ci/Ci ^137^Cs**                 |
+----------------------------------+-----------------------------------+
| U-233                            | 5.12E-05                          |
+----------------------------------+-----------------------------------+
| U-234                            | 2.59E-05                          |
+----------------------------------+-----------------------------------+
| U-235                            | 3.58E-07                          |
+----------------------------------+-----------------------------------+
| U-238                            | 5.89E-06                          |
+----------------------------------+-----------------------------------+
| Pu-238                           | 3.41E-02                          |
+----------------------------------+-----------------------------------+
| Pu-239                           | 5.83E-03                          |
+----------------------------------+-----------------------------------+
| Pu-240                           | 9.48E-03                          |
+----------------------------------+-----------------------------------+
| Pu-241                           | 6.87E-01                          |
+----------------------------------+-----------------------------------+
| Pu-242                           | 3.01E-05                          |
+----------------------------------+-----------------------------------+
| Am-241                           | 5.00E-02                          |
+----------------------------------+-----------------------------------+
| Cm-244                           | 1.76E-02                          |
+----------------------------------+-----------------------------------+
| Co-60                            | 2.27E-02                          |
+----------------------------------+-----------------------------------+
| Sr-90                            | 6.77E-01                          |
+----------------------------------+-----------------------------------+
| Y-90                             | 6.77E-01                          |
+----------------------------------+-----------------------------------+
| Cs-137                           | 1.00E+00                          |
+----------------------------------+-----------------------------------+
| Ba-137m                          | 9.46E-01                          |
+----------------------------------+-----------------------------------+

The scaling factor for ^233^U was developed from the geometric mean of
the swipe sample data discussed in a previous section. Because the
analytical technique of alpha spectrometry is unable to resolve the
peaks of ^233^U and ^234^U, the ^233^U activity would be reported as
^234^U, a value that includes both ^233^U and ^234^U. To provide an
upper estimate of both radionuclides, the scaling factor derived for
^234^U based on the swipe sample data is used for ^233^U also.

\(4\) The DTC Correlation was evaluated and found to be technically
adequate.

The DTC correlation was based on the following assumptions:

-   The waste density was uniform within the liner.

-   All liners were nearly completely filled with waste material.

-   An iron matrix is the most representative, i.e., photon attenuation
    is primarily a function of the matrix density rather than
    composition.

-   The vast majority of the measured external exposure rate consists of
    ^137^Cs and/or ^60^Co.

Using Microshield^®^, SRS-CCP developed a DTC correlation for the drum
liner configuration illustrated in Figure 1 and expressed it in terms of
Roentgen per hour per curie of ^137^Cs (R/hr/Ci of ^137^Cs). This was
based in large part on the shielding calculations for a BCLDP liner
filled with RH TRU waste assuming a 1curie source of either ^137^Cs or
^60^Co uniformly distributed about the waste. Figure 3, below, shows the
results of these calculations and the polynomial fit to the calculated
data for ^137^Cs and ^60^Co as a function of waste density. This plot is
a composite of Figures 3 and 4 from SRS-RH-02, Revision 1, and is also
presented in CCP-AK-SRS-501 as Figure 7-3.

The DTC calculations were performed using an EXCEL spreadsheet using the
container's gross weight, the estimated fill percentages, and the two
dose rate measurements as input. An example of the DTC spreadsheet is
shown in Figure 4 for an actual BCLDP RH-TRU waste drum liner, using
measured dose rates and container weights from 2002 and the more
recently developed radionuclide scaling factors described above. The
uncertainties shown in the spreadsheet are associated with this drum
liner and indicate the relative magnitude of the overall uncertainties
in each of the radionuclide quantities listed on the spreadsheet.

> **Figure 3. DTC Correlations as a Function of Waste Density at a
> Distance of 1 meter Centered on a RH TRU Drum Liner**

  --------------- -------------- --------------- ----------------- ---------- ---------- ----------- ----------------- --------------- ---------------
                                 **Waste                                                                                               
                                 Container                                                                                             
                                 Dose-to-Curie                                                                                         
                                 Conversion                                                                                            
                                 Record**                                                                                              

                                                 DTC Spreadsheet                                                                       
                                                 Version 1 102307                                                                      

                                                                                                                                       

                                                                                                                                       

  Date of Survey                                 8/22/2002                                                                             

  Waste Stream                                   SR-RL-BCLDP.001                                                                       
  Designation                                                                                                                          

  Container                                      BC00AA                                                                                
  Number                                                                                                                               

  Container Gross                                147.4             kg                                                                  
  Weight                                                                                                                               

  Estimate Fill                                  100               \%                                                                  
  Percentages                                                                                                                          

  Container Net                                  46.7                                                                                  
  Weight                                                                                                                               

  Measured                                                                                                                             
  Container Dose                                                                                                                       
  Rate                                                                                                                                 

                  Detector #1                    100               mR/hr                                                               

                  Detector #2                    100               mR/hr                                                               

  Calculated                                     100               mR/hr                                                               
  Average Dose                                                                                                                         
  Rate                                                                                                                                 

                                                                                                                                       

  **Nuclide**     **Curie        **Activity      **Grams**         **FGE**    **PECi**   **Watts**   **Uncertainty**   **Uncertainty   **Uncertainty
                  Scaling        (Ci)**                                                                                in Curies**     in Grams**
                  Factors**                                                                                                            

  **U-233**       **5.12E-05**   2.81E-05        2.88E-03          2.59E-03   7.21E-06   8.18E-07    164.41%           4.62E-05        4.73E-03

  **U-234**       **2.59E-05**   1.42E-05        2.25E-03          0.00E+00   0.00E+00   4.09E-07    85.55%            1.22E-05        1.92E-03

  **U-235**       **3.58E-07**   1.96E-07        8.97E-02          5.77E-02   0.00E+00   5.42E-09    101.10%           1.99E-07        9.07E-02

  **U-238**       **5.89E-06**   3.24E-06        9.52E+00          0.00E+00   0.00E+00   8.20E-08    65.33%            2.11E-06        6.22E+00

  **Pu-238**      **3.41E-02**   1.87E-02        1.08E-03          1.22E-04   1.70E-02   6.20E-04    76.34%            1.43E-02        8.26E-04

  **Pu-239**      **5.83E-03**   3.20E-03        5.09E-02          5.09E-02   3.20E-03   9.92E-05    64.30%            2.06E-03        3.27E-02

  **Pu-240**      **9.48E-03**   5.21E-03        2.27E-02          5.10E-04   5.21E-03   1.62E-04    62.80%            3.27E-03        1.42E-02

  **Pu-241**      **6.87E-01**   2.90E-01        2.79E-03          6.28E-03   5.69E-03   9.23E-06    79.63%            2.31E-01        2.22E-03

  **Pu-242**      **3.01E-05**   1.65E-05        4.16E-03          3.12E-05   1.50E-05   4.87E-07    88.12%            1.46E-05        3.67E-03

  **Am-241**      **5.00E-02**   3.04E-02        8.76E-03          1.64E-04   3.04E-02   1.02E-03    76.10%            2.31E-02        6.66E-03

  **Cm-244**      **1.76E-02**   7.85E-03        9.60E-05          8.64E-06   4.13E-03   2.70E-04    152.91%           1.20E-02        1.47E-04

  **Cs-137**      **1.00E+00**   4.85E-01        5.51E-03          0.00E+00   0.00E+00   5.36E-04    54.30%            2.63E-01        2.99E-03

  **Ba-137m**     **9.46E-01**   4.59E-01        8.53E-10          0.00E+00   0.00E+00   1.81E-03    54.30%            2.49E-01        4.63E-10

  **Sr-90**       **6.77E-01**   3.26E-01        2.36E-03          0.00E+00   0.00E+00   3.78E-04    55.75%            1.82E-01        1.32E-03

  **Y-90**        **6.77E-01**   3.26E-01        5.99E-07          0.00E+00   0.00E+00   1.80E-03    55.75%            1.82E-01        3.34E-07

  **Totals**                     1.95E+00        9.71E+00          1.18E-01   6.57E-02   6.70E-03                                       

                                                                                                                                       

                                                                                         Value       (one Sigma)                       

  TRU Alpha                                                                              1.23E+03    6.55E+02          nCi/g           
  Activity                                                                                                                             
  Concentration                                                                                                                        

  TRU Alpha                                                                              5.75E-02    3.06E-02          Ci              
  Activity                                                                                                                             

  Total Pu-239                                                                           6.57E-02    3.57E-02          Ci              
  Equiv Activity                                                                                                                       

  Total Pu-239                                                                           1.18E-01    7.39E-02          g               
  Fissile Gram                                                                                                                         
  Equiv                                                                                                                                

  Total Decay                                                                            6.70E-03    3.62E-03          W               
  Heat                                                                                                                                 

  Volume Activity                                                                        1.72E-02    9.69E-03          Ci/L            
  --------------- -------------- --------------- ----------------- ---------- ---------- ----------- ----------------- --------------- ---------------

**Figure 4. Example Waste Drum DTC Conversion Record**

\(4\) The definition of this RH waste stream was assessed and found to
be adequate.

This inspection focused on a group of 87 drum liners of RH wastes that
SRS-CCP stated were contained in a single waste stream, all of which
were generated from the D&D of the JN-1 HCL under the BCLDP. The EPA
inspection team concluded that the assignment of all 87 RH drum liners
to a single waste stream was technically supportable.

(5) Several technical aspects of the radiological characterization
    process were evaluated and were found to be acceptable.

Fourteen calculation packages were prepared and reviewed by Jene Vance,
Jim Holderness, Rob Tayloe and Larry Porter to document development of
the scaling factors and the DTC correlation discussed above. These
packages provide the technical basis for several aspects, including:

-   Application and verification of Microshield^®^ and ORIGEN2.2

-   Evaluation of all potential contributors to a container's dose rate,
    specifically ^137^Cs and ^60^Co, and addressing contribution of
    other fission products

-   Development and comparison of scaling factors for three fuel types:
    LWR, thorium uel, and HEU

-   The nature and history of the LWR fuels examined in the JN-1
    facility

-   Decay correction of the BCLDP swipe data used to confirm the
    ORIGEN2.2 LWR calculations

-   Potential sources of uncertainty \[see total measurement uncertainty
    (TMU), below\]

The EPA inspection team members reviewed these 14 packages during the
July 2007 inspection and discussed them with the documents' authors and
other SRS-CCP personnel. During these discussions, the EPA inspection
team questioned several aspects and identified instances where
modifications to the calculation packages were required. Some of the
modifications required a formal revision of the calculation package (see
"Documents Reviewed" in Section 8.0, above). The EPA inspection team
reviewed the revised documents at the December 2007 meeting and also had
the opportunity to discuss all technical concerns and discrepancies with
SRS-CCP personnel. The EPA inspection team found the revised calculation
packages to adequately document the technical activities upon which the
radionuclide scaling factors were based. All technical issues related to
the documentation of technical aspects of the SRS-CCP RH WC approach
were resolved.

(6) Evaluation of TMU was performed and found to be adequate following
    revision of specific SRS-CCP documents.

The development of TMU for the 87 drum liners in Waste Stream
SR-RL-BCLDP.001 is based on the propagation of uncertainties present in
all aspects of the determination of the radiological constituents of RH
TRU waste. The TMU determination included the contributions of:

-   Drum liner weight measurement

-   ^137^Cs measurement uncertainty

-   Scaling factor uncertainty

-   MicroShield^®^ issues

-   Other gamma emitters

-   Individual fuel pin contribution to the total in waste liner

-   Burnup history

-   Internal code issues

-   Modeling

The treatment of TMU is presented in CCP-AK-SRS-501, Revision 1, and
Calculation Package No. SRS-RH-06, Revision 0, "Uncertainty Analysis".
During the July 2007 inspection, the EPA inspection team determined that
these documents did not adequately present the technical basis for the
TMU related to the SRS-CCP BCLDP wastes, as discussed below.
Additionally, operational aspects of the TMU process were not adequately
documented. This issue was discussed with SRS-CCP personnel during the
July 2007 inspection and was included as one aspect of Issue (d) in EPA
Finding No.SRS-RH-AK-07-001F (see Attachment A of this report for a copy
of this form). The other aspect of Issue (d) is addressed in Section
(7), below.

**EPA Finding No. SRS-RH-AK-07-001F, Issue (d):** The technical basis
for the characterization of these RH wastes with respect to the
documentation of Total Measurement Uncertainty (TMU) was not adequately
documented in CCP-AK-SRS-501, Revision 1 and Calculation Package No.
SRS-RH-06, Revision 0.

**EPA Finding No. SRS-RH-AK-07-001F, Issue (d) Resolution:** Following
the July 2007 inspection, SRS-CCP produced Revision 2 of CCP-AK-SRS-501,
and Revision 1 of SRS-RH-06, both of which were reviewed by the EPA
inspection team member assessing radiological characterization during
the December 2007 meeting. Both documents had been modified to better
present the technical basis for the TMU determination and to
appropriately document the process. They included contributions of all
pertinent aspects of the TMU, which are summarized in CCP-AK-SRS-501,
Table 8-3, and reproduced as Table 6, below. Upon reviewing the revised
documents the EPA inspection team determined that the treatment of TMU
for the BCLDP RH wastes was technically adequate and appropriately
documented and that the aspect of this issue related to TMU was
addressed.

**EPA Finding No. SRS-RH-AK-07-001F, Issue (d) Status:** This issue is
closed.

  ---------------------------------------------------------------------------------------------------------------------
  **Table 6. Overall                                                                                    
  Uncertainty Listed                                                                                    
  by Radionuclide at                                                                                    
  a Density of 1.0                                                                                      
  g/cm^3^**                                                                                             
  ------------------ --------------- ------------ ------------------ ------------------ --------------- ---------------
  **Radionuclide**   **Dose Rate     **Other      **Microshield^®^   **Microshield^®^   **Scaling       **Total
                     Measurement     Gamma        Code Uncertainty** Model              Factor          Uncertainty**
                     Uncertainty**   Emitters**                      Uncertainty**      Uncertainty**   

  ^233^U             25.0%           45.6%        10.0%              31.4%              155.2%          167.0%

  ^234^U             25.0%           45.6%        10.0%              31.4%              66.1%           90.4%

  ^235^U             25.0%           45.6%        10.0%              31.4%              85.3%           105.2%

  ^238^U             25.0%           45.6%        10.0%              31.4%              36.3%           71.5%

  ^238^Pu            25.0%           45.6%        10.0%              31.4%              53.7%           81.7%

  ^239^Pu            25.0%           45.6%        10.0%              31.4%              34.4%           70.6%

  ^240^Pu            25.0%           45.6%        10.0%              31.4%              31.6%           69.2%

  ^241^Pu            25.0%           45.6%        10.0%              31.4%              58.2%           84.8%

  ^242^Pu            25.0%           45.6%        10.0%              31.4%              69.4%           92.8%

  ^241^Am            25.0%           45.6%        10.0%              31.4%              53.3%           81.5%

  ^244^Cm            25.0%           45.6%        10.0%              31.4%              143.0%          155.7%

  ^90^Sr             25.0%           45.6%        10.0%              31.4%              12.6%           62.9%

  ^137^Cs            25.0%           45.6%        10.0%              31.4%              N/A             61.6%
  ---------------------------------------------------------------------------------------------------------------------

\(7\) Radionuclide Documentation in lieu of BDRs was assessed and found
to be adequate upon revision of specific SRS-CCP documents.

The 87 drum liners of SRS-CCP RH TRU waste were not documented in BDRs,
as is typically done at TRU waste sites. Instead, the formal
documentation for each canister's radionuclide values was presented in
CCP-AK-SRS-501, Revision 1, Attachment 3, pages 47 through 134. The EPA
inspection team verified that the data sheet for each RH TRU liner
contained the following information:

-   Container number

-   Waste stream designation

-   Net waste weight

-   Waste material type

-   Measured dose rates from two detectors and the calculated average
    dose rate in mR/hr

-   Scaling factor in grams or curies per mR/hr

-   Activity values and uncertainties for the 10 WIPP-tracked
    radionuclides in nCi/g

-   TRU alpha activity and concentration

-   Plutonium equivalent curies (PE Ci) in curies

-   Fissile gram equivalents (FGE) in grams

-   Decay heat in watts

-   Volume activity in curies per liter

There were several aspects of CCP-AK-SRS-501, Revision 1, that required
clarification, and these prevented a complete technical evaluation of
the radiological characterization of the 87 RH TRU drum liners during
the Denver inspection. These aspects were discussed with SRS-CCP
personnel during the inspection, and were included as the second aspect
of Issue (d) in EPA Finding No. SRS-RH-AK-07-001F, part of which is
discussed in Section (6), above (see Attachment A of this report for a
copy of this form). The other aspects of this finding related to
radiological characterization are discussed below.

**EPA Finding No. SRS-RH-AK-07-001F, Issue (d):** The general issue was
that CCP‑‑AK‑SRS‑501 did not adequately document the technical basis for
the characterization of these RH wastes with respect to the development
of radionuclide scaling factors. The specific issues are as follows:

-   CCP-AK-SRS-501 provides the technical basis of the derivation of the
    radionuclides values for each of the 87 RH TRU drum liners. This
    document is based on statistical treatments of various data sets
    that are presented in the calculation packages listed in Section 8.0
    above. However, the statistical approaches incorporate both simple
    arithmetical means and standard deviations, as well as geometric
    mean and standard deviations, and the documentation of which
    statistic is used is often unclear. It appears the incorrect
    statistic is used in some cases, but the calculation packages are
    not sufficiently clear to allow their technical evaluation.

-   CCP-AK-SRS-501 contains several areas that require rewriting to
    accurately document the technical basis of a specific aspect of the
    radiological characterization process. Examples include:
    clarification that the uncertainty for ^233^U is based on the
    standard deviation of the ^234^U; treatment of the LLD; inclusion of
    references for specific activity, decay heat, etc.; and addressing
    where in the process the TRU determination is performed.

**EPA Finding No. SRS-RH-AK-07-001F, Issue (d) Resolution:**
CCP-AK-SRS-501 and other calculation packages were revised appropriately
and were provided to EPA at a December 2007 meeting (see "Documents
Reviewed" in Section 8.0, above). The statistical inconsistencies in
CCP-AK-SRS-501 and the accompanying calculation packages were corrected,
as documented in the revised documents the EPA inspection team reviewed.
Clarification regarding the ^233^U uncertainty, additional details
regarding the LLD, and the appropriate references for specific activity,
decay heat and other derived quantities were included (CH-TRAMPAC) in
the revised documents made available to EPA at the December 2007 meeting
in Carlsbad, New Mexico. The treatment of TMU presented in Revision 2 of
CCP-AK-SRS-501 provides details that were missing from Revision 1 that
was evaluated at the July 2007 meeting in Denver. Revision 2 of
CCP-AK-SRS-501 and the revisions of the accompanying calculation
packages discussed earlier contained sufficient technical details to
adequately address the EPA concern.

**EPA Finding No. SRS-RH-AK-07-001F, Issue (d) Status:** This issue is
closed.

\(8\) RH and TRU determinations were evaluated and found to be adequate.

The records addressing the determination that the 87 RH TRU drum liners
met the definition of TRU wastes (TRU alpha activity concentration
greater than 100 nCi/g) and RH waste (contact dose equivalent rate in
excess of 200 mrem/hr) were examined, as discussed below.

-   TRU definition: As stated previously, BDRs were not prepared for the
    87 RH TRU drum liners in this waste stream. The radionuclide values
    that were determined for the liners are contained in CCP-AK-SRS-501,
    Attachment 3, pages 47 through 134. All liners indicate TRU
    concentrations greater than 100 nCi/gram.

-   RH definition: The external exposure rate (dose rate) measurements
    of each of the RH TRU liners were made at the time the liners were
    filled, and the measured values are recorded on Health Physics
    Survey Reports Form DDO-138 in mR/hr. All measurements were made at
    a distance of 1 meter at the midpoint of the liner's height in two
    locations 180º degrees apart, i.e., at the three o'clock and nine
    o'clock positions, and the value recorded for each liner was the
    arithmetical average of both measurements. The documentation
    examined during the inspection shows that radiation surveys were
    controlled by a formal, written procedure, HP-OP-019, "Radiation and
    Contamination Survey Techniques"; survey procedures cite the
    appropriate consensus standard, ANSI/NCSL Z540-1; all dose rate
    measurements were made with the appropriate type of instrument; the
    serial number for each instrument was listed; all instruments had a
    current calibration at the time of measurement; and all surveys were
    performed under a radiation work permit that was identified. The
    measurement records for the liners indicate external dose rates
    greater than 200 mR/hr in all cases.

There were no concerns regarding the TRU and RH determinations for Waste
Stream SR‑RL‑BCLDP.001.

## Physical Form and Prohibited Item Characterization -- Visual Examination

From July 31 through August 1, 2007, EPA performed an inspection of
SRS-CCP's VE activities for RH TRU waste from the BCLDP in storage at
SRS. SRS-CCP possesses both written and audio/video records of packaging
of 87 drum liners from Waste Stream SR-RL-BCLDP.001. During this
inspection EPA's focus was on independent verification of the
acceptability of VE data contained within the historic records. The
review took place at the CBFO offices located in the Skeen Whitlock
Building in Carlsbad, New Mexico.

The VE data reviewed were generated between late 1999 and late 2002, in
accordance with procedure TC-OP-01.4 and work instructions WI-956 and
958. The procedure had been revised during this time period and SRS-CCP
had retrieved Revisions 1 and 2 but did not possess Revision 0. Training
of VE personnel was performed in accordance with TCP-98-05 and TRU‑100.

\(1\) Training of VE personnel was assessed and found to be adequate.

All of the personnel who performed VE were contract employees, and all
had been trained to applicable site procedures. How these employees were
used is documented in the interface document TCP-98-04. The practice at
the time the RH drum liners were packaged was to destroy old training
records as new ones were generated. Consequently, SRS-CCP could not
obtain complete training records for all VE personnel that were involved
in the BCLDP project. However, EPA was able to review some training
records from the packaging time period, approximately 1999 to 2002.

Procedure TC-OP-01.4 refers to a Visual Examination Expert (VEE)
performing the examinations. From the activities performed, EPA
concluded that at the time of packaging Waste Certification Officials
(WCOs) were equivalent to present day VEEs and VEEs were equivalent to
present day VE operators. VE operators and VEEs were required to read
procedures and be re-qualified every three years.

\(2\) Audio/video and written records were reviewed and found to be
adequate.

The EPA inspection team selected a random sample of four RH drum liners
containers to review during this inspection, Nos. BC0035, BC0051,
BC0070, and BC012. Because drum liners were filled over extended periods
of time, the recordings for many containers were recorded on multiple
tapes. For example, the VE of container No. BC0035 is recorded on tapes
E00025, E00034, E00035, E00036, E0038, E00038, E00039, and E00040. Two
types of recordings were made, one from a movable focus/angle camera and
one from a fixed camera. Although the movable camera images are required
to review the VE event, the fixed camera image shows a much wider field
of view and provides a superior overview of the process. For the purpose
of this inspection, EPA reviewed the movable camera audio/visual tapes
for selected packages. They were evaluated as follows:

-   BC0035, packages 15, 29, 59, and 66: The EPA inspection team did
    briefly review the static video for this drum liner but it was not
    possible to verify the waste items placed in the receiving container
    using this recording. However, using the movable camera recording
    the EPA inspection team verified that the waste items individually
    placed into the receiving container were correctly identified and
    recorded. The waste items in this drum liner included plastic,
    rubber, cloth, and paper. The original packaging took place in
    November 2000 and was reviewed in October 2002. The revision date
    for the TRU Waste Packaging Loading Record, Loading -- Itemized Data
    record was February 1999.

-   BC0051, packages 7 and 17: The majority of waste in this drum liner
    was steel and other metals. The original packaging took place during
    July and August 2000 and review of the paper and visual records was
    performed in February 2003. The EPA inspection team did not identify
    any discrepancies between the written and visual/audio records. The
    revision date for the TRU Waste Packaging Loading Record, Loading --
    Itemized Data record was February 1999.

-   BC0070, packages 11 and 14: The revision date for the TRU Waste
    Packaging Loading Record, Loading -- Itemized Data record was
    August 2001. This revision of the sheet required additional
    information to be recorded, including the number of the liner
    filter, drum filter number and seal, and WMC. This drum liner
    arrived in the processing area already full of waste. The waste was
    tipped onto the sorting tray, identified, and then loaded. Similar
    waste items were loaded into opaque, white buckets, which were then
    emptied into the receiving container. Placing of items in the white
    buckets was not recorded, but the items from each bucket were called
    out (identified orally), as it was loaded. This was discussed with
    SRS-CCP and the EPA inspection team agreed that this method of drum
    liner loading did not compromise the technical adequacy of the VE
    data. Packaging took place in June 2002 and the records were
    reviewed in November 2002.

-   BC0120, packages 4 and 7: This bucket was empty when first viewed on
    the audio/visual recording. The VE process for this container was
    similar to the process used for BC0070, because the placing of items
    in white buckets was not recorded. Waste items were identified as
    they were tipped into the receiving container. Packaging took place
    in December 2001, and the records were reviewed in January 2002 and
    November 2002.

The absence of prohibited items was verified during packaging and review
of records and no discrepancies between the written and visual/audio
records for these drum liners were identified. The EPA inspection team
determined that WMPs were correctly identified and the physical form of
the waste was verified. There are no issues related to the use of VE for
SRS-CCP RH TRU wastes as a result of this inspection.

## WIPP Waste Information System

From July 31 through August 1, 2007 EPA reviewed SRS-CCP's WWIS
activities for RH TRU waste in Carlsbad, New Mexico because access to
the WWIS database and CCP personnel responsible for maintaining the
database were readily available.

EPA previously approved this process and the purpose of this review was
to ensure continued compliance with the requirements of the WCPIP. At
the time of the review, a total of 132 RH waste containers from INL and
ANLE had been emplaced in the WIPP repository, and an additional 68 RH
waste containers had been approved for shipment. The EPA inspection team
interviewed a CCP WCO and investigated the CCP WWIS procedure by
reviewing data for Canister No. ID0051. The canister housed three
containers of RH waste, Container Nos. 001131, 001141, and 001143, from
RH Waste Stream ID-ANLE-S5000. The same CCP WWIS procedure is used for
RH wastes from all DOE sites.

Since EPA approval, CCP has successfully submitted characterization and
certification data into WWIS for RH waste from INL and ANL. EPA had
conducted a baseline inspection at both sites and approved them for RH
WC activities previously. The DTC, VE, or RTR data sheets are used to
populate a WWIS Data Entry Summary spreadsheet. The WCO interviewed was
able to retrieve the spreadsheet and characterization data sheets for
container No. 001131. The EPA inspection team verified that the
spreadsheet information matched that in the WIPP Waste Container Report
for this container. No discrepancies were identified. The WIPP Waste
Container Report for Canister No. ID0051 was also retrieved and
reviewed. Using the WIPP Waste Container Reports for the internal
containers, the EPA inspection team verified that there were no data
errors or discrepancies between these reports.

The EPA inspection team verified that all WMPs for each RH container
were reported to WWIS as plastic. EPA calculated the material parameter
weights provided in the Waste Container Data Report for each of the
inner containers of Canister No. ID0051 and ensured that value was the
same as the reported container gross weight. No discrepancies were found
for the three containers the EPA inspection team reviewed.

Prior to submitting container data to the WWIS for certification, the
NCR and Corrective Action Report (CAR) status of each container was
verified. Container data were uploaded to WWIS after this check, based
on information that was obtained from CCP QA personnel. EPA verified
this process by reviewing an email verifying the NCR/CAR status for
containers in INL RH Lot 9. If data were rejected by WWIS, actions were
taken to correct and resubmit the data. EPA verified this process by
reviewing the history for Container No. 001117 that was rejected by WWIS
on June 7, 2007. CCP resolved the data issue and successfully
resubmitted the container to WWIS on July18, 2007. As required by the
WCPIP, all WMPs are reported to WWIS as plastic. CCP continues to
successfully submit RH TRU data for both characterization and
certification to WWIS. There were no issues relative to CCP's
implementation of the WWIS for RH TRU wastes identified during this
audit.

## Attainment of Data Quality Objectives

\(1\) Verification methods for each DQO were assessed and found to be
compliant with the WCPIP.

SRS-CCP-BCLDP representatives indicated that AK is the basis for all
characterization, and AK will be qualified entirely through
demonstration of an equivalent QA program. As indicated previously, this
approach comports with requirements set forth in the WCPIP.

\(2\) Attainment of DQOs was evaluated and found be adequate.

As a result of the analyses presented in Sections 8.1 through 8.4,
above, the EPA inspection team assessed how each DQO was addressed. As
required in the WCPIP, the following DQOs must be addressed:

-   Defense determination

-   TRU waste determination

-   RH waste determination

-   Activity determination (TRU alpha activity per drum liner, including
    identification and quantification of 10 WIPP-tracked radionuclides)

-   Residual liquids

-   Physical form, including metals and cellulosics, plastic and rubber

All DQOs are based on AK that is verified through demonstration of an
equivalent QA program, and EPA has assessed each element for its
technical merit based on the AK record. EPA concludes that SRS-CCP-BCLDP
has adequately presented how DQOs will be obtained.

# Response to Comments 

This section is reserved for public comments.

# Summary of Results 

##  {#section-4 .unnumbered}

## EPA Findings and Concerns

The one EPA finding identified during the July 2007 inspection and
SRS-CCP's responses are discussed in the preceding sections of this
report. A copy of the EPA Inspection Issue Tracking Form that captures
the finding is included in Attachment A of this report. All open issues
were adequately addressed and no EPA issues remain open at this time.

## Conclusions

EPA's inspection team determined that SRS-CCP's RH WC program activities
were technically adequate. EPA is proposing to approve the SRS-CCP-RH WC
program as supported in the documentation examined during this
inspection, as described in this report. The proposed approval includes
the AK process for one RH retrievably-stored TRU debris waste stream,
SR‑RL‑BCLDP.001, that was generated by the BCLDP and consists of 87 drum
liners that are currently stored at SRS. All aspects of the SRS‑CCP
documentation in support of this RH waste stream are technically
adequate.

EPA requires that all site-specific CCRs at RH TRU sites must address
the ten WIPP-tracked radionuclides as discussed in Section 8.1, (8) of
this report. SRS-CCP must provide to EPA a copy of the WWIS controlled
spreadsheet showing the manual data entries that were downloaded from
CCP-AK-SRS-501 upon completion. In the future, when sample collection
plays as important a role in a site's RH WC program as it does for this
BCLDP waste stream, EPA will require that the site provide a sampling
plan prior to EPA approval.

## Baseline Approval

There are no outstanding issues related to the SRS-CCP RH WC program
that EPA evaluated during this inspection. The documents that EPA
reviewed during the inspection that are listed in Section 8 of this
report adequately support the characterization of SRS RH Waste Stream
SR-RL-BCLDP.001. The waste stream proposed for approval is of a finite
nature (i.e., 87 TRU RH drum liners) generated and packaged in the past
and no additional waste containers from BCL belonging to this waste
description exist at SRS or would be subjected to the WC techniques
described in the report in the future. Hence, when approved, this
baseline approval remains applicable to the debris waste from BCL
consisting of 87 TRU RH drum liners and will not be implemented to
characterize any additional waste containers from this waste stream.

The wastes to which this proposed approval applies are discussed in this
report and were generated at the BCLDP; the fact that they are stored at
SRS has no bearing on characterization activities performed on any other
CH or RH TRU materials at SRS or any other DOE site. Should DOE identify
additional containers of RH TRU wastes (e.g., solids or soil/gravel)
associated with the D&D of the Building JN-1 HCL at the Jefferson North
Facility apart from the 87 liners that may be eligible for WIPP
disposal, EPA notification and approval would be necessary as a T1
change. This report does not list any specific T1 or T2 designations
relative to these 87 waste liners and the WC components inspected and
proposed for approval by EPA at this time.

# References

U.S. Department of Energy, Carlsbad Area Field Office, "Contact-Handled
Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot
Plant (CH-WAC)," Revision 3, DOE/WIPP-02-3122, Carlsbad, New Mexico,
April 25, 2005.

U.S. Environmental Protection Agency, "Criteria for the Certification
and Recertification of the Waste Isolation Pilot Plant's Compliance with
the Disposal Regulations: Certification Decision; Final Rule," *Federal
Register*, Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405.

U.S. Code of Federal Regulations, *Title 40*, *Protection of
Environment*, Part 191, "Environmental Radiation Protection Standards
for Management and Disposal of Spent Nuclear Fuel, High-Level and
Transuranic Radioactive Wastes."

U.S. Code of Federal Regulations, *Title 40*, *Protection of
Environment*, Part 194, "Criteria for the Certification and
Re-Certification of the Waste Isolation Pilot Plant's Compliance with
the 40 CFR Part 191 Disposal Regulations."

U.S. Department of Energy, Carlsbad Area Field Office, "Remote Handled
TRU Waste Characterization Program Implementation Plan",
DOE/WIPP-02-3214, Revision 0D, Carlsbad, New Mexico, October 30, 2003.

U.S. Department of Energy, Title 40 CFR Part 191, Compliance
Certification Application for the Waste Isolation Pilot Plant, DOE/CAO
1996-2184, Carlsbad, New Mexico, 1996.

U.S. Department of Energy, Title 40 CFR Part 191, SUBPART D AND C,
Compliance Recertification Application 2004, DOE/WIPP/2004-3231.

U.S. Department of Energy, Carlsbad Area Field Office, "Quality
Assurance Program Description (QAPD)", DOE/CBFO-94-1012, Revision 7,
Carlsbad, New Mexico, July 2005.

U.S. Nuclear Regulatory Commission, "Contact-Handled Transuranic Waste
Authorized Methods for Payload Control (CH-TRAMPAC)."

####### Attachment A  {#attachment-a .unnumbered}

+------------------------------------+---------------------------------+
| Attachment A                       |                                 |
|                                    |                                 |
| **EPA Inspection Issue Tracking    |                                 |
| Form, EPA Issue No.                |                                 |
| SRS‑CCP‑RH‑AK‑07‑001F**            |                                 |
+====================================+=================================+
| **Inspection No.**                 | **Issue Number:**               |
| EPA-SRS-CCP-RH-07.07-8             | SRS-RH-AK-07-001F**,** Revision |
|                                    | 3                               |
|                                    |                                 |
|                                    | **Date:** July 19, 2007         |
+------------------------------------+---------------------------------+
| **Inspectors:** C. Walker/P. Kelly | **Sample Size:** RH             |
|                                    | Documentation                   |
| **Attachments?** YES NO            |                                 |
|                                    | **Population size (if known):** |
|                                    | NA                              |
+------------------------------------+---------------------------------+
| **Description of Issue:** In       |                                 |
| August 2001, EPA conducted a       |                                 |
| surveillance of the Battelle       |                                 |
| Columbus (BC) Remote-Handled (RH)  |                                 |
| Waste Characterization Program. In |                                 |
| the report sent to DOE (cited      |                                 |
| below), EPA stated that: "BC's RH  |                                 |
| Program could be improved through  |                                 |
| more diligent acquisition and      |                                 |
| integration of AK-based            |                                 |
| radionuclide information to        |                                 |
| determine isotopic distributions". |                                 |
| EPA also questioned the            |                                 |
| representativeness of swipe        |                                 |
| samples collected that were later  |                                 |
| used as part of scaling            |                                 |
| factor/JN-1 isotopic mix           |                                 |
| development. EPA concluded that    |                                 |
| the "AK program data               |                                 |
| assembly/compilation elements were |                                 |
| not complete" (EPA's Technical and |                                 |
| Regulatory Support Document for RH |                                 |
| Waste Determination, February      |                                 |
| 2004, transmitted to DOE by Frank  |                                 |
| Marcinowski, March 26, 2004). EPA  |                                 |
| also concluded that while the      |                                 |
| radioassay approach had merit,     |                                 |
| characterization activities        |                                 |
| performed to support the approach  |                                 |
| at the time of the 2001            |                                 |
| Surveillance "were not technically |                                 |
| adequate". EPA's current           |                                 |
| inspection identifies the          |                                 |
| following issues related to the    |                                 |
| completeness and adequacy of AK    |                                 |
| and radiological characterization  |                                 |
| documents, many of which are       |                                 |
| related to issues identified in    |                                 |
| our August 2001 surveillance:      |                                 |
|                                    |                                 |
| a\. Isotopic ratio/composition     |                                 |
| information from two primary       |                                 |
| sources was used to develop        |                                 |
| scaling factors (also the JN-1     |                                 |
| Standard Isotopic Mix). The        |                                 |
| factors were derived from a        |                                 |
| combination of swipe sample and    |                                 |
| modeling results, with input data  |                                 |
| to the model (ORIGEN2.2) covered   |                                 |
| in a memorandum of a meeting in    |                                 |
| 1999. In order for this to serve   |                                 |
| as an auditable record additional  |                                 |
| information and rationale          |                                 |
| supporting the approach are        |                                 |
| required for both the isotopic     |                                 |
| swipe data and the recommended     |                                 |
| burn up, enrichment, and decay     |                                 |
| data contained in the 1999 meeting |                                 |
| memorandum. Documentation of the   |                                 |
| references and data sources        |                                 |
| reviewed and evaluated during the  |                                 |
| 1999 meeting is necessary to       |                                 |
| support conclusions. With regard   |                                 |
| to the swipe data, the sampling    |                                 |
| plan, collection, number, results  |                                 |
| and other relevant information     |                                 |
| must be summarized to show that    |                                 |
| the sample data are sufficiently   |                                 |
| representative of the wastes       |                                 |
| within waste stream                |                                 |
| SR-RL-BCLDP.001.                   |                                 |
|                                    |                                 |
| b\. CCP-AK-SRS-500 must be revised |                                 |
| to address the following:          |                                 |
|                                    |                                 |
| -   Only describe the SRS waste    |                                 |
|     stream of 87 liners subject to |                                 |
|     this inspection.               |                                 |
|                                    |                                 |
| -   The document states that there |                                 |
|     are wastes in this stream that |                                 |
|     exhibit both "standard" and    |                                 |
|     "non-standard" isotopic        |                                 |
|     distributions and that         |                                 |
|     non-standard waste will        |                                 |
|     undergo separate sampling and  |                                 |
|     analysis. However, the AKE     |                                 |
|     indicated that only "standard" |                                 |
|     isotopic mix wastes are        |                                 |
|     included in the stream, and    |                                 |
|     there are no wastes that       |                                 |
|     underwent the alternative      |                                 |
|     sampling and analysis approach |                                 |
|     discussed in the text.         |                                 |
|                                    |                                 |
| -   Include a thorough             |                                 |
|     presentation of general        |                                 |
|     radiological characteristics   |                                 |
|     of wastes. Information such as |                                 |
|     types of radionuclides handled |                                 |
|     in JN-1 in the various         |                                 |
|     cells/areas, origin of         |                                 |
|     radionuclides (e.g., LWR),     |                                 |
|     outliers, and other            |                                 |
|     information necessary to       |                                 |
|     provide a general overview of  |                                 |
|     the radionuclides handled      |                                 |
|     through the course of JN-1     |                                 |
|     operations are necessary.      |                                 |
|                                    |                                 |
|     c\. Through the course of the  |                                 |
|     AK information acquisition and |                                 |
|     interpretation process, the    |                                 |
|     number of waste streams        |                                 |
|     identified in JN-1 has changed |                                 |
|     over time. Specifically, the   |                                 |
|     current SR-RL-BCLDO.001 stream |                                 |
|     was originally identified as   |                                 |
|     four separate waste streams.   |                                 |
|     There is no information given  |                                 |
|     to show these waste streams    |                                 |
|     were combined into a single    |                                 |
|     stream.                        |                                 |
|                                    |                                 |
| d\. CCP-AK-SRS-501 does not        |                                 |
| adequately document the technical  |                                 |
| basis for the characterization of  |                                 |
| these RH wastes with respect to    |                                 |
| the development of radionuclide    |                                 |
| scaling factors and Total          |                                 |
| Measurement Uncertainty.           |                                 |
+------------------------------------+---------------------------------+
| **B. Regulatory Reference:** 40    |                                 |
| CFR 194.24(c)                      |                                 |
+------------------------------------+---------------------------------+
| **C. Site requirement(s):**        |                                 |
+------------------------------------+---------------------------------+
| **D. Discussed with:** J.R.        |                                 |
| Stroble, Eric D'Amico, Larry       |                                 |
| Porter, K. Peters, S. Schafer, R.  |                                 |
| Tayloe, M. Doherty                 |                                 |
+------------------------------------+---------------------------------+
| **E. Additional Comments:** Item c |                                 |
| above is resolved as a result of   |                                 |
| the preparation of reference C509. |                                 |
| As a result of changes made to     |                                 |
| primary documents to resolve items |                                 |
| b and d above, there may be a need |                                 |
| to make changes to other primary   |                                 |
| or secondary documents. EPA        |                                 |
| expects to receive revised copies  |                                 |
| of these documents with the        |                                 |
| response to this finding.          |                                 |
+------------------------------------+---------------------------------+
| **F. Site Response Information:**  |                                 |
|                                    |                                 |
| **Site Response Required?** YES NO |                                 |
|                                    |                                 |
| **Site Response Due Date:** August |                                 |
| 13, 2007                           |                                 |
+------------------------------------+---------------------------------+

[^1]: ^?^ A liner is a 55-gallon rigid steel liner that fits within a
    standard 55-gallon drum and acts as an overpack. Specifications for
    drum liners are provided in Section 8, and are shown in Figure 1.

[^2]: As of the FR notice of July 16, 2004, EPA has replaced the term
    *process knowledge* with *acceptable knowledge*. Acceptable
    knowledge refers to any information about the process used to
    generate waste, material inputs to the process, and the time period
    during which the wastes were generated, as well as data resulting
    from the analysis of waste conducted prior to or separate from the
    waste certification process authorized by an EPA certification
    decision to show compliance with Condition 3 of the certification
    decision.

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

[^4]: The potential contents of a single waste stream or group of waste
    streams determine which processes can adequately characterize the
    waste. For example, if AK suggests that the waste form is
    heterogeneous, the site should select the matrix-appropriate
    radiological characterization technique to obtain adequate
    radionuclide measurements. VE serves to confirm and quantify waste
    components, such as cellulosics, rubbers, plastics, and metals. Once
    the nature of the waste has been confirmed, characterization
    techniques quantify selected radionuclides in the waste. In some
    cases, a TRU waste generator site may be able to characterize a
    range of heterogeneous waste streams or only a few. A site's stated
    limits on the applicability of proposed WC processes govern the
    scope of EPA's inspection.

[^5]: The West Jefferson North Site included: Building JN-2 (Critical
    Assembly Laboratory); Building JN-3 (Research Reactor Building); and
    Building JN-4 (Plutonium Laboratory). This waste stream only
    includes wastes from JN-1.

[^6]: ^?^ Forty seven of these drums are stored at Hanford and the one
    drum that SRS-CCP excluded from this waste prior to this inspection
    is stored at SRS.

[^7]: ^?^ The terms *swipe* and *smear* refer to a small piece of
    absorbent material that is wiped or smeared on a surface area and
    subsequently analyzed by destructive or nondestructive radiometric
    techniques to estimate the amount of removable radioactive
    contamination on the area or item that was wiped. Standard Health
    Physics practices typically express swipe/smear results in activity
    units per area or per swipe, e.g., µCi/100 cm^2^ or dpm/swipe.
    Consistent with the usage observed in the BCLDP documents reviewed
    during this inspection, these two terms are used interchangeably in
    this report.

[^8]: ^?^ Although the terms *dose rate*, *dose equivalent rate*, and
    *external exposure rate* have different meanings, they are
    sufficiently similar in this context to allow their use
    interchangeably in this report. The most prevalent terminology used
    to express this waste attribute in BCLDP documents is *dose rate*,
    stated in milliRoentgens per hour (mR/hr), which for our purposes is
    the equivalent of *dose equivalent rate* expressed in mRem/hr from
    the standpoint of determining a container's RH status.

[^9]: ^?^ The computer code used in ORIGEN2, Version 2.2, which is
    expressed as ORIGEN2.2 throughout this report.

[^10]: SRS-CCP records do not indicate the specific methodology used to
    quantify ^244^Cm and ^237^Np although alpha spectrometry is the
    usual analytical approach used to identify and quantify these
    radionuclides.

[^11]: ^241^Pu is not one of the 10 WIPP-tracked radionuclides but it
    may be useful in developing radionuclide scaling factors.

[^12]: Although they are technical different, in this context the term
    *LLD* is taken to be synonymous with Minimum Detectable Activity
    (MDA).

[^13]: Although the determination of a waste container's radiological
    hazard is not an EPA requirement, this information may be useful in
    understanding other aspect of a container's radiological
    characterization.