EPA DOCKET NO: A-98-49, II-A4-135

WASTE CHARACTERIZATION REPORT

EPA TIER 1 EVALUATION OF THE CENTRAL CHARACTERIZATION PROJECT (CCP)

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION P ROGRAM

AT THE IDAHO NATIONAL LABORATORY (INL):

ADDITION OF WASTE STREAM IN-ID-NRF-153

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

November 2010i TABLE OF CONTENTS

Section Page

Acronyms ..........................................

................................................... ........................................... ii

1.0 Executive Summary .................................

................................................... .........................1

2.0 Purpose of Tier 1 Evaluations .....................

................................................... ......................4

3.0 Purpose of This Report ............................

................................................... .........................4

4.0 Scope of This Evaluation ..........................

................................................... ........................5

5.0 Evaluation of New Waste Stream IN-ID-NRF-153 ......

................................................... ....5

5.1 Acceptable Knowledge ..............................

................................................... ..................7

5.2 Radiological Characterization .....................

................................................... ...............16

5.3 Real-Time Radiography .............................

................................................... ................24

6.0 Summary of Results ................................

................................................... ........................26

ATTACHMENTS

Attachment A: Approval Summary for INL-CCP Remote-H andled Waste Characterization

Program Attachment B: Listing of Documents Reviewed for Thi s Evaluation Attachment C: EPA Evaluation Issue Tracking Form – Real-Time Radiographyii ACRONYMS

AK acceptable knowledge

AKE acceptable knowledge expert

AKSR acceptable knowledge summary report

Am americium

BDR batch data report

CBFO Carlsbad Area Field Office

CCP Central Characterization Project

CFR Code of Federal Regulations

CH contact-handled

Ci curie

cm centimeter

Cm curium

CRR Characterization Reconciliation Report

Cs cesium

CSSF Correlation and Surrogate Summary Form

CTP Confirmatory Test Plan

DOE U.S. Department of Energy

DQO data quality objective

DR discrepancy resolution

DTC dose-to-curie

ECF Expended Core Facility

EPA U.S. Environmental Protection Agency

Eu europium

FGE fissile gram equivalent

g gram or grams
g/cm 3 grams per cubic centimeter

HFEF Hot Fuel Examination Facility

HLW high-level waste

INL Idaho National Laboratory

INTEC Idaho Nuclear Technology and Engineering Cent er
IWTS Integrated Waste Tracking Systemiii

LANL Los Alamos National Laboratory

LLW low-level waste

LOQI list of qualified individuals

LWA WIPP Land Withdrawal Act

MCNP5 Monte Carlo N-Particle Transport Code RSICC C omputer Code

Collection, Oak Ridge National Laboratory

mR/hr/Ci milli Roentgen per hour per Curie

mRem/hr milliRem per hour

nCi/g nanocurie per gram

NCR non-conformance report

NDA nondestructive assay

NOFORN Not Releasable to Foreign Nationals/Governme nts/Non-US Citizens

(Document Handling Instruction )

NRF Naval Reactor Fuel

NWPA Nuclear Waste Policy Act

ORIGEN Oak Ridge Isotope Generation

PE Ci plutonium equivalent Curies

Pu plutonium

QA quality assurance

QC quality control

RH remote-handled

RTR real-time radiography

RWMC Radiological Waste Management Complex

SNF spent nuclear fuel

SPC sludge pan containers

SPM Site Project Manager

Sr strontium

T1 Tier 1

T2 Tier 2

TMU Total Measurement Uncertainty

TRU transuranic

U uranium

UCNI Unclassified Controlled Nuclear Informationiv

VE visual examination

WCPIP Waste Characterization Program Implementation Program

WDS WIPP Waste Data System

WIPP Waste Isolation Pilot Plant

WMC waste matrix code

WMP waste material parameter

WSPF Waste Stream Profile Form

WWIS WIPP Waste Information System1

1.0 EXECUTIVE SUMMARY

This report supports the U.S. Environmental Protect ion Agency’s (EPA’s) approval of remotehandled (RH) transuranic (TRU) organic debris (S530 0) waste stream IN-ID-NRF-153 from the U.S. Department of Energy’s (DOE) Idaho National La boratory (INL) Naval Reactor Fuel (NRF) facility.

On February 8, 2010, the Carlsbad Field Office (CBF O) requested that EPA review a proposed Tier 1 (T1) change for approving the RH Waste Strea m IN-ID-NRF-153 consisting of 27 containers. On June 3, 2010, CBFO provided summary information on the subject waste and

characterization documentation. The Central Charact erization Project (CCP) is responsible for characterizing RH wastes at INL using a system of c ontrols, which EPA approved in January 2007 (baseline inspection dated July 2006) and subs equent process- and equipment-specific Tier 1 change approvals. A summary of EPA’s approvals of the INL-CCP RH TRU waste characterization program is included as Attachment A. Because there were no new equipment or processes used when characterizing this waste strea m, EPA chose to conduct a desktop review of this change in Denver on August 9-10, 2010.

Section 4.0 of this report presents the results of this T1 evaluation. EPA did not identify any findings but identified one concern (not requiring a response) during this evaluation. No open issues remain relative to this T1 change. EPA deter mined that the procedures and processes used by INL-CCP for the characterization of Waste Stream IN-ID-NRF-153 were EPA-approved and were adequately implemented. EPA, therefore, approv es Waste Stream IN-ID-NRF-153 currently in 27 30-gallon containers 1 as a T1 change to INL-CCP’s RH baseline approval.

In an event that one or more of these 27 containers have to be repackaged, such additional containers can be processed for disposal by using t he EPA-approved system of controls (including approved radiological scaling factors) a s a T2 change. The T2 change requirements

include: EPA notification of additional containers and submission of a revised acceptable knowledge summary report, radiological characteriza tion report, and pertinent batch data reports for EPA review. In the future, when characterizing debris from INL’s naval reactor facility where a different radiological characterization pro cess and/or with different scaling factors is warranted, then EPA approval of this characterizati on step is necessary as a T1 change prior to disposal. Table 1 below presents changes to the tie ring table to add the above modification.

1 Containers is a generic term which applies to cans, canisters , drums, and any other types of waste packaging units that may be characterized individually for th eir radiological and physical contents.2Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Approval Date Nov1, 2010)RH Process ElementsINL-CCP RH WC Process - T1 ChangesINL-CCP RH Process - T2 Changes2Acceptable Knowledge (AK)Addition of containers to approved waste streams ifnew ordifferent radionuclide scaling factors are requiredAny new waste streams not approved under thebaseline or asa T1 approvalSubstantive modification(s) that have the potentialto affect thecharacterization process: CCP-AK-INL-500, CCP-AK-INL501, or CCP-AK-INL-502Load management for any RH waste streamNotification to EPA when AKSRs, Radiological CharacterizationReport and Certification Confirmation Test Plans (i.e., CCP-AKINL-500, CCP-AK-INL-501, and CCP-AK-INL-502) updates areapproved by CBFONotification to EPA when changes to AK documentation as a resultof WCPIP revisions have been made (e.g., CRR)Notification to EPA when a CSSF is completed for each of the RHcontainers in this waste stream identified as CH based on measureddose rates that present NDA results for assayed containersNotification to EPA once waste stream data packagefor debriswaste stream and any modifications to the WSPF, including theCRR and AK Summary, are completedNotification to EPA that the final DTC determination is completefor RH containers numbers 728 through 737, as identified in AKReference P030AK accuracy reports (prepared annually, at a minimum)Notification to EPA when additional containers areadded to RHTRU Waste Stream AERHDM and the containers werecharacterized using the same radionuclide scaling factors*Notification to EPA of availability of a revised AKSR and sourcedocuments supporting the addition of containers tothe approvedwaste stream*Notification to EPA when Attachment 4 of CCP-TP-005isgenerated to reflect the updated AKSR Source Document ReferenceListNotification of availability of additional discrepancy resolutionspertinent to RH Waste Stream IN-ID-NRF-153Radiological Characterization, includingDose-to-Curie (DTC)Application of new scaling factors for isotopic determinationother than those documented in CCP-AK-INL-501Use of any alternate radiological characterizationprocedureother than DTC with established scaling factors asdocumentedin CCP-TP-504 or substantive modification of the DTCprocedureUse of any alternate gamma detector with the OSPREYTMsystem characterization procedure other than the La3Br(Ce)Notification to EPA upon completion of revisions ofCCP-AK-INL501 or CCP-TP-504 that require CBFO approvalNotification to EPA of availability of a revised radiologicalcharacterization report, if required for the addition of containers tothe approved waste stream*Radiological content data provided in BDRs for thepopulation ofadditional containers*3Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Approval Date Nov1, 2010)RH Process ElementsINL-CCP RH WC Process - T1 ChangesINL-CCP RH Process - T2 Changes2detector observed at INTEC in July 2010Any new RH waste stream not approved under this baseline oraddition of containers to Waste Stream ID-ANLE-S5000 thatrequires changing the established radionuclide scaling factorsCharacterizing another NRF debris waste using differentradiological characterization process and/or differentscaling factorsVisual Examination (VE) VE using audio/video mediato characterize additional debriswaste streams other than Waste Stream ID-ANLE-S5000orwaste from other Summary Waste CategoriesNotification to EPA upon completion of changes to VEprocedure(s) that require CBFO approvalPhysical content data provided in BDRs for the population ofadditional containers*Real-Time Radiography (RTR) Any new S5000 RH wastestream other than ID-ANLE-S5000,ID-MFC-S5400-RH, and IN-ID-NRF-153or wastes from aS3000 or S4000 RH waste streamNotification to EPA prior to addition of a new RTRunit(s)Notification to EPA upon completion of changes to RTRprocedure(s) that require CBFO approvalPhysical content data provided in BDRs for the population ofadditional containers*WIPP Waste Data System, WDS (previouslyknown as WWIS)NoneChanges made to WDS procedure(s) that require CBFOapprovalNotes:- This table has been modified by deleting the references to specific sections of the baseline inspection report where each T1 or T2 element is discussed.- INL-CCP will report all T2 changes to EPA everythree months.- Notification to EPA is not necessary when document updates are editorial in nature or are requiredto address administrative concerns.-Substantive modificationrefers to a change with the potential to affect INL-CCP’s RH waste characterization process, e.g., theuse of an inherently different type of measurementinstrument or the use of the high-range probe as described in CCP-TP-504.- Additions to the tiering table as a result of this T1 evaluation appear inbold.* These marked changes apply when containers are added to Lot 1B of waste stream ID-HFEF-S5400-RH andare characterized using the same radionuclide scaling factors as wereused to characterize the original approved waste stream. EPA notification is required when the site identifies the need to characterize additional containers belonging to theapproved waste stream.4

2.0 PURPOSE OF TIER 1 EVALUATIONS

Certain changes to the waste characterization activ ities from the date of the site’s baseline inspection must be reported to and, if applicable, approved by EPA according to the tiering requirements set forth in 40 Code of Federal Regulations (CFR) 194.8 and incorporated in the INL-CCP RH Baseline Final Report cited in Attachmen t A.

Under the changes to 40 CFR 194.8 promulgated in th e July 16, 2004 Federal Register notice, EPA must perform a single baseline inspection of a TRU waste generator site’s waste characterization program (Vol. 69, No. 136, pages 4 2571–42583, July 16, 2004). The purpose of EPA’s baseline inspection is to approve the site’s waste characterization program, based on the demonstration that the program’s components, with a pplicable conditions and limitations, can adequately characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes destined for disposal at the WIPP.

Following EPA’s baseline approval, EPA is authorize d to evaluate and approve changes, if necessary, to the site’s approved waste characteriz ation program by conducting additional inspections under the authority of 40 CFR 194.24(h) . Changes requiring EPA notification and approval prior to implementation (T1), and those re quiring post-implementation (T2) notification, are identified in the site-specific b aseline inspection reports. When evaluating proposed T1 changes for approval, EPA may conduct a site inspection to observe first-hand the implementation of the change, or can opt to conduct a “desktop” review of information provided specific to a change. DOE may choose to characteriz e and dispose of, at risk of subsequent EPA disapproval, any previously approved TRU waste usin g processes/procedures/equipment implemented as T2 changes. EPA reviews T2 changes o n a quarterly basis and EPA may conduct continued compliance inspections to evaluate implem ented T2 changes to verify adequacy.

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluatio n of T1 changes to dispose of 27 fullycharacterized containers of INL RH Waste Stream IN- ID-NRF-153 (Section 5.0, below), as described in CCP-AK-INL-560, Revision 2 at the WIPP . This report presents the technical basis and results of EPA’s approval decision. EPA’s appro val decision regarding this waste stream, INL RH Waste Stream IN-ID-NRF-153, is conveyed to D OE separately by letter. As discussed previously, EPA will also announce the decision on its website at www.epa.gov/radiation/WIPP, in accordance with 40 CFR 194.8(b)(3).

The DOE documents that EPA reviewed for this evalua tion are cited in different sections throughout the report and are listed in Attachment B. Any of these documents can be requested from the following address:

Carlsbad Field Office Manager, National TRU Program U S Department of Energy

P O Box 3090 Carlsbad, NM 88221-30905

4.0 SCOPE OF THIS EVALUATION

This T1 evaluation encompassed the addition of the INL RH Waste Stream IN-ID-NRF-153 consisting of 27 30-gallon drums. The evaluation of this waste stream included three waste characterization areas: Acceptable Knowledge (AK), radiological characterization, and RealTime Radiography (RTR), each of which is addressed separately in this report. Personnel who participated in the T1 evaluation are listed in Tab le 2, along with each person’s affiliation and function during the evaluation.

Table 2. Tier 1 Evaluation Participants

Name Affiliation & Function Edward Feltcorn Lead Inspector, U. S. EPA
Rajani Joglekar Inspector, U. S. EPA
Connie Walker Technical Evaluator – AK, SC&A
Kira Darlow Technical Evaluator – AK, SC&A
Patrick Kelly Technical Evaluator – Radiological Ch aracterization, SC&A
Amir Mobasheran* Technical Evaluator – Radiological Characterization, SC&A
Dorothy Gill* Technical Evaluator – RTR, SC&A
James Luginbyhl Acceptable Knowledge Expert, CCP, L ANL Steve Schafer Acceptable Knowledge Expert, CCP
Lisa Watson Acceptable Knowledge Expert, CCP, LANL
Irene Quintana Site Project Manager, INL-CCP, WTS
Jene Vance Radiological Characterization Subject Ma tter Expert, CCP
James Holderness Radiological Characterization Subj ect Matter Expert, CCP
Thomas L. Clements, Jr. CH2M-Washington Group International, Observer
Michael Walentine WTS-CCP Project Management, Obser ver Courtland Fesmire U.S. DOE, Observer *Amir Mobasheran and Dorothy Gill did not attend t he evaluation in Denver, CO, but conducted reviews in support of this T1 change.

5.0 EVALUATION OF NEW WASTE STREAM IN-ID-NRF-153

Waste Stream IN-ID-NRF-153 is composed of organic d ebris generated through cleaning the Alpha Box in Cell 14 at the NRF Expended Core Facil ity (ECF). The Alpha Box was a carbon

steel containment box in which fuel elements were r emotely cut for performance evaluation using a slow-speed abrasive cut-off wheel to slice a specimen from the fuel element. Waste material and water were collected in an underlying sludge pan. During the cutting process, water and swarf or fuel particulates were dispersed withi n the Alpha Box. The inside of the Alpha Box was cleaned when a fuel type being sectioned was ch anged, and the combustible waste generated during cleaning was placed in either a 12- or 17-in ch Rabe (plastic) bottle. Sludge pan waste was also collected and placed into Sludge Pan Container s (SPCs) between sectioning of different fuel types, so the radioactive material in the SPCs is c ompositionally similar to the radioactive material on the organic debris generated during cel l cleaning, if both were generated at the same time (i.e., on or near the same date). Approximatel y 85% of the fuel chips removed during the cutting operation ended up in the sludge pan below the cut-off wheel. Approximately 15% of the6

fuel chips were lost to the Alpha Box and then ende d up in the combustible waste after the box was cleaned. The SPC waste is important because the radiological composition of this material has been identified by NRF as that for Waste Stream IN-ID-NRF-153. NRF and SPC wastes are closely related and are comparable.

As discussed in CCP-AK-INL-561, Revision 1, the was te stream is contaminated with mixtures of radionuclides generated from the cutting operati ons of five basic fuel types that were sectioned within the Alpha Box between 1975 and 197 9. One or more of the five fuel types was assigned to each SPC by NRF when the sludge pan was changed, and these generally correlate with the associated Rabe containers. However, note the cell clean-out between fuels was not thorough, so waste from one fuel sectioning event c ould be present within subsequent clean-out waste. Regardless, the radionuclide distributions w ere calculated for each of the five fuel types and this information was used to determine isotopic ratios representative of individual types, as well as of the waste stream (i.e., all types) as a whole.

INL-CCP originally sampled the waste stream with th e intent of developing waste-streamspecific scaling factors. However, the data obtaine d from sampling could not be used directly to determine scaling factors. Because the NRF radiolog ical data were collected outside of an approved quality assurance (QA) program, INL-CCP us ed these sampling data to qualify the original NRF-assigned radiological composition and, hence, the subsequent scaling factors developed from these data. The Certification Plan ( CCP-AK-INL-562, Revision 1) presents the Data Quality Objectives (DQOs) and qualification ap proaches used.

Documents, Waste Containers, and Batch Data Reports Reviewed

Several attachments, source documents, forms, and o ther data were provided to EPA, and the relevant sources were examined as part of this T1 i nspection. The listing of all documentation examined is in Attachment B, and the list of BDRs e xamined is presented in Table 3.

Table 3. BDRs Examined

Drum Number RTR BDR Number DTC BDR Number Radiochemistry

BDR Numbers

IDINEC0100001 INLRHRTR09004 INLRHDTC100007 ALD09002R,

ALD09006IR1

IDINEC0100002 INLRHRTR09004 INLRHDTC100007 ALD09002R,

ALD09006IR1 IDINEC0100003 INLRHRTR09003 INLRHDTC100006 No analy sis

IDINEC0100004 INLRHRTR09002,

INLRHRTR09005 INLRHDTC100007 No analysis

IDINEC0100005 INLRHRTR09004 INLRHDTC100007 ALD09002R,

ALD09006IR1

IDINEC0100006 INLRHRTR09003 INLRHDTC100006

IDINEC0100007 INLRHRTR09005 ALD09002R,

ALD09006IR1 IDINEC0100008 INLRHRTR09002 INLRHDTC100006 No analy sis
IDINEC0100009 INLRHRTR09003 INLRHDTC100006 No analy sis

IDINEC0100010 INLRHRTR09003,

INLRHRTR09004 INLRHDTC100006,

INLRHDTC100007 No analysis7 Table 3. BDRs Examined

Drum Number RTR BDR Number DTC BDR Number Radiochemistry

BDR Numbers

IDINEC0100011 INLRHRTR09005 INLRHDTC100007 ALD09002R,

ALD09006IR1

IDINEC0100012 INLRHRTR09004 INLRHDTC100007 ALD09002R,

ALD09006IR1 IDINEC0100013 INLRHRTR09002 INLRHDTC100006 No analy sis IDINEC0200001 INLRHRTR09004 INLRHDTC100007 No analy sis IDINEC0200004 INLRHRTR09002 INLRHDTC100006 No analy sis
IDINEC0200005 INLRHRTR09002 INLRHDTC100006 No analy sis IDEC0200006 INLRHRTR09003 INLRHDTC100006 No analysi s IDINEC0200007 INLRHRTR09003 INLRHDTC100007 No analy sis

IDINEC0200008 INLRHRTR09005 INLRHDTC100007 ALD09002R,

ALD09006IR1

IDINEC0200009 INLRHRTR09004 Not provided ALD09002R,

ALD09006IR1

IDINEC0300001 INLRHRTR09005 INLRHDTC100007 ALD09002R,

ALD09006IR1 IDINEC0300002 INLRHRTR09003 INLRHDTC100006 No analy sis IDINEC0300004 INLRHRTR09004 INLRHDTC100007 No analy sis

IDINEC0300005 INLRHRTR09004 INLRHDTC100007 ALD09002R,

ALD09006IR1 IDINEC0300006 INLRHRTR09002 INLRHDTC100006 No analy sis
IDINEC0300007 INLRHRTR09002 INLRHDTC100006 No analy sis

5.1 Acceptable Knowledge

EPA examined the AK process and associated informat ion to approve the Tier 1 request for RH

Waste Stream IN-ID-NRF-153.

Waste Characterization Element Description

As part of the inspection, EPA reviewed the followi ng with respect to the use of AK for waste

characterization:

• Definition and identification of the waste stream

• Radiological characteristics of the waste

• Physical composition of the waste

• Sampling Plan and use of AK Data

• Identification of High-Level Waste (HLW) and Spent Nuclear Fuel (SNF)

• Compiling AK documentation and assembly of required information, including the AK Summary and adequacy of the Remote-Handled Waste Ch aracterization Program Implementation Plan (WCPIP) AK process implementati on

• AK data traceability8

• AK source document sufficiency

• WCPIP interpretation, including AK qualification, a nd Certification Plan/Confirmatory Test Plan (CTP) preparation/adequacy and use of Los Alamos National Laboratory (LANL) mass spectrometry data

• Characterization Reconciliation Report (CRR) adequa cy

• Correlation and Surrogate Summary Form (CSSF) and C ontact Handled (CH)-RH

correlation

• Personnel training

• Waste Stream Profile Form (WSPF) adequacy and compl iance with WCPIP requirements

• Non-Conformance Reports (NCRs) and AK discrepancy r esolution (DR)

• AK accuracy

• Defense determination

• Load management

• DQOs attained through AK Qualification

Technical Evaluation

(1) The definition of Waste Stream IN-ID-NRF-153 wa s examined and was found to be adequate.

The WCPIP, Revision 0D defines a waste stream as co nsisting of “waste material generated from a single process or activity, or as waste with simi lar physical, chemical, and radiological properties.” Waste Stream IN-ID-NRF-153 was evaluat ed against this definition to assess if the processes and activities associated with waste gene ration were adequately addressed, and if the physical, chemical and radiological composition of the waste stream was adequately defined.

Waste Stream IN-ID-NRF-153 was generated between 19 75 and 1979 in the Alpha Box within Cell 14 of Building 618 in the ECF at NRF. The Alph a Box was used exclusively to remotely cut sections of expended fuel elements for evaluation, and was the only location in the ECF where cutting through the fuel region of SNF was allowed. Sectioning activities generated five outputs: fuel samples; excess pieces of fuel elements not us ed as samples; fuel chips collected in the sludge pans and placed into SPCs; non-combustible d ebris such as tools, glassware, etc.; and

combustible debris. Waste Stream IN-ID-NRF-153 cons ists of 27 30-gallon drums of combustible debris waste, 26 of which were overpack ed into 55-gallon drums. The 30-gallon

drums contain 37 Rabe bottles: 17 17-inch Rabe bott les and 20 12-inch Rabe bottles. 2 The Rabe bottles were generated by Alpha Box operations betw een April 1975 and February 1979. INLCCP indicated that this waste stream will never be combined with any of the other five Alpha Box outputs, so it is defined by time of generation and output. Further, wastes were generated by a distinct and well-defined process.

2 Rabe bottles are 12- or 17-inch tall polyethylene canisters. Th e 12-inch tall canister contains approximately 6 gallons and the 17-inch tall canister contains appr oximately 10 gallons.9

The radiological composition of the waste stream is defined by the types of fuels cut within the Alpha Box, because the combustible material is cont aminated with residual fines, particulates, and water thrown onto the sides of the Alpha Box du ring cutting activities. The fuels sectioned in the Alpha Box are well known, as are their radioact ive contents. NRF kept detailed records of the sectioned fuels, and defined not only the radiologi cal composition of these wastes (U019), but also the anticipated amount of residual radiation t hat would be on combustible waste vs. SPC waste. See Item 2, below, for additional informatio n about the radiological composition of the

waste stream.

The physical composition of the waste stream is wel l known as ascertained though original packaging records, Fast Scan information, and RTR. It is composed of cellulosics like paper, cotton, and cloth items, including wipes, diaper cl oth, towels, rags, vacuum bags, cardboard, and wooden items such as rulers, file handles, and pain t brushes. It also contains plastics like nylon, as well as rubber and glass and may also contain me tal in limited quantities. While the Acceptable Knowledge Summary Report (AKSR) includes the caveat that the waste stream may contain “lesser amounts (less than 50% by volume in any container) of homogeneous organic and inorganic materials,” review of the packaging a nd RTR data indicate that none of the containers include anywhere near the 50% value. Bas ed on this information and as detailed in Item 3, below, the physical composition of the wast e stream is appropriately defined (References C029, P008, and P012). Notification of revision to the AKSR is a T2 change. As part of this requirement, notification to EPA of availability of a revised AKSR and source documents supporting the addition of containers to Waste Stre am IN-ID-NRF-153 is a T2 change.

(2) The radiological characteristics of the waste s tream were evaluated and found to be adequate.

The radiological composition of the waste stream is defined by five general fuel types:

1. Type I – Advanced Fuel (irradiated core material ) 2. Type II – Standard Fuel (irradiated core materia l) 3. Type III – Uranium-235 ( 235 U) + Thorium (Th) Fuels 4. Type IV – Blanket Fuels 5. Type V – 233 U + Th Fuels

INL-CCP provided sufficient radiological informatio n in references and the AKSR to develop scaling factors (see Section 5.2 below). INL-CCP ba sed the radiological characterization of the waste stream on document EDF-8775, which is a NOFOR N reference that included the properties of SPC waste from NRF. This document ass ociates each SPC with radiological composition and Reference U019 associates each SPC with a fuel type. There are 91 SPCs, but

not all of these are associated with Waste Stream I N-ID-NRF-153.

INL-CCP took the radiological information by SPC/fu el type in these two references and constructed radiological distributions by fuel type . The combustible debris wastes were generated at specific times, as were the SPCs. Sinc e the radiological contamination on the combustible waste was generated upon cleaning up th e associated SPC, the radiological10

composition of the SPC is common to the combustible waste, with the exception of cesium-137 ( 137 Cs), as discussed in Section 5.2. INL-CCP used the waste type distributions obtained through averaging the values in Reference U109 (Table 6, Ra diological Distribution of the Fuel Types in Waste Stream IN-ID-NRF-153, in the AKSR, Revision 2 ), and knowing which fuel type was present in each Rabe bottle, as well as estimated a ctivities/quantities from the packaging documentation. This allowed them to assign a curie (Ci) and mass value to that container. All of the Rabe bottles were summed to generate Table 7, W aste Stream IN-ID-NRF-153 Radiological Characterization, in the AKSR, Revision 2.

The radiological characterization is based on EDF-8 775 and U019, which contain Ci estimates

for each Rabe bottle. The bases for these estimates were not provided to INL-CCP because NRF deemed this information to be sensitive. At the req uest of INL-CCP, NRF personnel provided a memorandum that stated the origin of the radionucli de values.

These data indicate that the radiological compositi on of Waste Stream IN-ID-NRF-153 is generally well understood, based on AK data. Notifi cation of revisions to the Radiological Characterization Report CCP-AK-INL-561, Revision 1 is a T2 change. Addition of containers characterized using new or different radionuclide s caling factors or a different radiological characterization approach is a T1 change.

(3) Physical characteristics of the waste stream w ere examined, including the presence of prohibited items (liquids), and found to be adequat ely addressed.

Waste Stream IN-ID-NRF-153 was packaged as a “combu stible” stream by the waste generator.

INL-CCP examined the waste container records for ea ch Rabe bottle, as well as the Quick Scan results for each waste drum, to determine the physi cal composition of the waste. Based on the evaluation of the materials and NRF waste managemen t practices, INL-CCP concluded that the waste stream is composed of more than 80% organic d ebris, and is represented by Waste Matrix Code S5300, Organic Debris. The AKSR states that th e waste material parameters (WMPs) for

Waste Stream IN-ID-NRF-153 were estimated based on the descriptions of waste and the WMP estimates performed during the RTR prescreens perfo rmed in August 2007. The estimates showed that the waste is composed of approximately 97.1% (by weight) organic waste materials (primarily organic debris), and 2.9% inorganic mate rials. Examination of the associated BDRs confirmed that the physical composition of the drum s corresponds to the description in the AKSR and the physical composition of the stream is adequately defined.

(4) The identification of the waste as transuranic and not high-level waste or spent nuclear fuel was examined and found to be adequate.

The AKSR states that according to the Nuclear Waste Policy Act of 1982 (NWPA), SNF is “fuel

that has been withdrawn from a nuclear reactor foll owing irradiation, the constituent elements of which have not been separated by reprocessing.” HLW is defined by the NWPA as “the highly radioactive material resulting from the reprocessin g of [SNF], including liquid waste produced directly in reprocessing and any solid material der ived from such liquid waste that contains fission products in sufficient concentrations, and other highly radioactive material that the commission, consistent with existing law, determine s by rule requires permanent isolation.”11

INL-CCP stated that while spent fuel segments were sectioned in the Alpha Cell, Waste Stream IN-ID-NRF-153 is contaminated by residual radioacti ve material from sectioning of these fuels, and does not include partial or intact spent fuel e lements. INL-CCP stated that the only activities performed in the Alpha Cell were destructive sectio ning of fuel elements. These activities did not involve the separation or reprocessing of constitue nt elements from reactor fuel. Therefore, the waste is not a SNF or HLW (References P005, P006, P 008, P012, and P019).

(5) Sufficiency of the Acceptable Knowledge Summar y Report and implementation of the Acceptable Knowledge process were evaluated and fou nd to be adequate.

EPA found that Section 5.4.3 did not adequately rep resent the radiological data obtained or evaluated by INL-CCP for Waste Stream IN-ID-NRF-153 . Specifically, the section did not adequately explain the origin and nature of the var ious fuel types. It also did not adequately explain how tables 6 and 7 were generated [see item (2) above] in sufficient detail. Section

5.4.3.1 included references to “canisters” that inf erred shipping casks, and also included radiological characterization done by NRF and the N avy that was not well explained. Uncertainty analysis was included, but not well exp lained.

INL-CCP prepared a freeze file 3 modification that better explained the origin of T ables 6 and 7 in the AKSR. The freeze file change also clarified the historic activities performed by NRF and INL to characterize waste placed into storage and t he relative uncertainty. In addition it indicated that the characterization assigned as a r esult of these activities was not used by INLCCP to evaluate the radiological composition of the waste stream based on AK. Additionally, the freeze file modification changed the word "canister " to "bottle" in conjunction with the Rabe

containers. 4 With the proposed modifications, the AKSR is adequ ate. EPA expects a formal revision of the AKSR to be completed prior to the C CP’s 2011 1 st quarter submission of T2 changes to EPA for review and concurrence.

(6) Data traceability was examined and found to be adeq uate.

Data traceability was evaluated to determine whethe r the radiological data are traceable from the Rabe bottle to the SPC and associated fuel types by selecting four drums. The Rabe bottles in

each drum were identified and cross referenced to r elated SPCs, which were in turn correlated to fuel types (e.g., EDF-8775, U019, and U151). Table 4 below shows traceability of the Rabe bottle, SPC, and fuel type.

Table 4. Batch Document Reports Examined

Drums Rabe Bottle SPC Fuel Type Package Dates
IDINEC0100006 NG296 15, 18, 22 III 4/13/1976
IDINEC0100004 EC 10 and 9 32, 33, 34 II, V 1/5/1977 , 1/25/1977, 4/27/1977

3 Freeze File : As a result of EPA inspections, if CCP must revis e documents to address EPA issues, CCP makes those changes and provides a copy to EPA as objecti ve evidence for the changes made. These revisions a re then processed by CCP’s document control process to gene rate an official version as the most current revisi on.
4 Containers is a generic term which applies to cans, canisters , drums, and any other types of waste packaging units that may be characterized individually for th eir radiological and physical contents.12 IDINEC0200004 NB 267 28 II 4/13/1976
IDINEC0300004 EC 1 and 2 32, 33 II 1/5/1977, 1/25/7 7

Traceability was also established for the container s from the point of Rabe bottle packaging, through loading into 30-gallon drums and movement t o the Intermediate Level Transuranic Storage Facility and then to Idaho Nuclear Technolo gy and Engineering Center (INTEC), to Quick or Fast Scan RTR of the containers and subseq uent side-punching of containers and overpacking into 55 gallon drums (References P029, U004, U009, U012, and U088). Data evaluated showed that traceability was adequately e stablished.

(7) Sufficiency of Acceptable Knowledge Support Do cuments and Related Document Tracking was evaluated and found to be adequate.

Examination of Attachment 4, reference lists in CCP -AK-INL-561, Revision 1 and CCP-AK-INL-560, Revision 2 showed inconsistencies a mong the various documents. For example, EDF-8775, which is a key AK document provi ding radiological data, was not included in either the AKSR or Attachment 4. Also, U109 and U106 were not on the Attachment 4 reference list, although both were provided as obje ctive evidence during the inspection. EPA expects the AKSR to be updated to include all relev ant references, as well as Attachment 4.

Notification of revision of Attachment 4 to include all relevant references is a T2 change.

(8) Interpretation of WCPIP, with respect to contents o f the Certification Plan and Confirmatory Test Plan, was evaluated, including ma ndatory content of the Confirmatory Test Plan and the use of gamma/alpha spectrometry a nd mass spectrometry data for sampled waste to support Acceptable Knowledge Quali fication, and were found to be adequate.

EPA’s March 26, 2004, RH WCPIP letter required that sites generate a Certification Plan that explains how RH waste characterization will take pl ace at each site, as well as a Confirmatory Test Plan (CTP), when this plan is required as part of the AK qualification process. This were to require that the sites specify and document exactly how characterization is to take place on a waste stream basis, followed by a detailed plan exp laining implementation of confirmatory testing when this is to take place. CCP-AK-INL-562, Revision 1 explains that INL-CCP intended to use a combination of methods to qualify the AK i nformation defining the radionuclide ratios, physical form, and absence of prohibited items asso ciated with this waste stream.

Radiological components and the isotopic distributi on were determined through confirmation of AK. INL-CCP originally intended to collect represen tative samples of Waste Stream IN-ID-NRF-153 and use these data to develop waste s tream-specific scaling factors separate from the data provided by NRF. The sampling plan (C CP-AK-INL-565, Revision 1) was prepared in August 2009, and EPA did not review the plan prior to implementation.

INL-CCP reviewed the data (Reference C114) and foun d that they did not support the stated objective of the sampling plan, and scaling factors derived from the sample data could not be directly applied to radiological characterization o f the waste stream. However, INL-CCP also concluded that the radiological data could instead be used to verify the NRF data (provided as classified, NOFORN, or Unclassified Controlled Nucl ear Information [UCNI]), which was then13

used to develop scaling factors used in conjunction with DTC. EPA agrees that the plan was not written with the objective of confirming the NRF da ta and also agrees that the sampling data presented in CCP-AK-INL-561, Revision 1, can be use d to confirm pre-existing AK information. The CTP also indicates that other radiological char acteristics, including TRU waste determination and RH determination, will be establi shed using DTC and surface measurements. It should be noted that the sampling and analysis t est plan was provided as CCP-AK-INL-565

and was summarized in the CTP.

CCP-AK-INL-562, Revision 1 states that AK informati on regarding the physical form, absence of residual liquids and prohibited item identificat ion will be qualified using radiography, which will also be used to determine that packaging DQOs have been met. Prescreening containers with radiography to identify presence of any liquids and un-punctured aerosol cans; therefore, will require some remediation. The DQO for Defense Deter mination is met solely through documented AK compiled and reported using the proce dure found in Attachment A of the WCPIP, Revision 0D.

EPA identified a statement in the CTP that required clarification. The CTP stated that systematic clean-out of the Alpha Box did not take place, but the occurrence of somewhat systematic cleanout allowing correlation of the SPF and debris wast e stream is a core argument in the radiological characterization approach. INL-CCP mod ified the CTP to state: "Although there were cleanup efforts on the Alpha Box between the e xaminations of different fuel types, the cleanup was not complete, and consequently signific ant comingling of the contamination from different fuel types onto the debris waste is expec ted. Therefore, it is expected that the

radionuclide distributions in the contamination wil l not vary significantly from drum to drum." This modification is adequate.

EPA evaluated the Certification Plan and CTP to det ermine whether they included the required

elements as defined in the WCPIP. When evaluated as a whole, CCP-AK-INL-562, Revision 1, CCP-AK-INL-565, Revision 2, CCP-AK-INL-560, Revisio n 2, the freeze file change, and the supporting source documents indicate that the DQOs specified in the WCPIP have been met. Notification of revision to CCP-AK-INL-562, Revisio n 1 is a T2 change and EPA expects formal revision to be completed prior to INL-CCP’s 2011 1 st quarter submission of T2 changes

to EPA for review and concurrence.

(9) Content and technical adequacy of the Waste Stream Profile Form and Characterization Reconciliation Report were evaluated and both were found to be adequate.

INL-CCP provided a draft WSPF. The document was not complete, noting, for example, the lack of a DTC BDR listing. The Draft WSPF is adequate. N otification of availability of the final WSPF is a T2 change.

The content of the CRR was examined to ensure that it reflected requirements of CCP-TP-506, CCP Preparation of the Remote-Handled Transuranic W aste Acceptable Knowledge Characterization Reconciliation Report. Specificall y, the CRR was evaluated to determine the completeness and adequacy of its contents, as requi red in the WCPIP, and was found to be adequate. Notification of availability of a final a nd/or revised CRR is a Tier 2 change.14

(10) Use of a Correlation and Surrogate Summary Fo rm was evaluated and found to be not applicable.

Completion of a Correlation and Surrogate Summary F orm (CSSF) is required when AK

information from a related CH waste stream is used in the RH waste characterization process. The INL-CCP representatives indicated that CH data were not used in this manner, so a CSSF was not required or prepared for this waste stream.

(11) Personnel were evaluated to be adequately tra ined.

Jim Luginbyhl is the Acceptable Knowledge Expert (A KE) who prepared the AKSR, and Larry Porter is the Site Project Manager (SPM) who signed off on the Certification Plan/CTP. Jene

Vance edited the Certification Plan. The AKE and RH Qualification Cards for Messrs. Luginbyhl and Vance were examined to determine whet her their training was up to date. The RH qualification cards indicated that Messrs. Vance an d Luginbyhl had read the WCPIP, but there is

no documentation to indicate whether these individu als were trained to EPA requirements, or were they trained with respect to radiological char acterization aspects, both of which are required in the WCPIP. Mr. Vance is not an AKE, but he assem bles and uses AK information as part of the radiological characterization program. Since th e WCPIP is currently under revision, EPA will examine future training against the modified WCPIP. However, EPA expects to be able to see

documentation that all AKEs and other individuals w ho prepared, edited, contributed to, or signed off on AK related documents have up-to-date training on the WCPIP and its requirements, as well as related AK procedures.

(12) Non-Conformance Reports and Discrepancy Resol ution Forms were examined and found to be adequate.

Only one DR Form was presented, and it addressed th e assignment of hazardous waste numbers to a previously identified non-hazardous waste stre am. EPA expects additional DRs will be generated as the characterization and documentation process progresses, particularly in the areas of AK-AK radiological discrepancy analysis. Notific ation of the availability of additional DRs pertinent to this waste stream and all other RH was te streams is a T2 change.

Example NCRs were provided. NCR-RH-INL-0001-10 addr essed measurement data indicating that 12 drums were non-TRU following implementation of DTC. These 12 drums are: IDINEC200004, IDINEC200007, IDINEC300007, IDINEC100 010, IDINEC100003, IDINEC100010, IDINEC300005, IDINEC100012, IDINEC100 00l, IDINEC100002, IDINEC200008 and IDINEC100011. As a result, the was te stream was reduced from 27 to 16 drums, 15 55-gallon drums and 1 30-gallon drum. Thi s affected the determination of AK accuracy, which is discussed in (13), below.

(13) Acceptable Knowledge accuracy was assessed a nd found to be adequate.

The AK accuracy report states that eleven of the 27 containers were calculated to have TRU activity less than 100 nanocuries per gram (nCi/g), and therefore are not considered TRU waste.15

Of the 11 containers, 5 were measured to have conta ct dose rates less than 200 milirem per hour (mRem/hr) and are not considered RH. The AK accurac y for waste stream IN-ID-NRF-153 is expressed as the ratio of actual TRU drums divided by the number of anticipated TRU drums or 16/27, which equals 59%.

(14) Defense status of the waste was evaluated and found to be adequate.

The WIPP Land Withdrawal Act (LWA) allows only defense-related waste to be disp osed at the WIPP facility. The AKSR provides information and re ferences supporting the defense-related

status of Waste Stream IN-ID-NRF-153 and concludes that naval reactor fuels were the primary source of fuels sectioned in the Alpha Box. The fue l elements were from nuclear-powered warships, prototype plants, irradiated test specime ns, and the Shippingport Atomic Power Station (Reference P019). The defense status of the waste i s supported by the references and information

examined.

(15) Load Management was assessed and does not app ly to this waste stream.

INL-CCP representatives indicated that load managem ent will not be performed for this waste stream. Implementation of load management is a T1 c hange.

(16) Attainment of Data Quality Objectives through Accep table Knowledge qualification was evaluated and found to be adequate.

As a result of the analysis presented in Items 1-16 , above, EPA was able to assess how each DQO will be addressed. The following DQOs must be a ddressed as per the WCPIP:

• Defense determination

• TRU waste determination

• RH waste determination

• Activity determination (total and activity per cani ster, including quantification and
identification of the 10 EPA WIPP-tracked radionucl ides)

• Residual liquids

• Physical form, including metals and cellulose, plas tic, and rubber

When evaluated as a whole, CCP-AK-INL-560, Revision 2, CCP-AK-INL-561, Revision 1, CCP-AK-INL-562, Revision 1, and other AK and suppor ting source documents presented in Attachment B of this report indicate that the DQOs, as specified in the WCPIP, have been met.

Summary of Results

Findings or Concerns16

The EPA Inspection Team did not identify any findin gs relative to the addition of the containers from Waste Stream IN-ID-NRF-153, which were the sub ject of this T1 change evaluation.

Tiering Changes

Based on the results of this evaluation, there are no changes to the AK T1 designations, and there is one change to the AK T2 designations as identifi ed during the Baseline Inspection and subsequent T1 evaluations. Notification of availabi lity of additional DRs pertinent to this waste stream is a T2 change.

5.2 Radiological Characterization

EPA examined the radiological characterization proc ess and associated information to determine whether INL-CCP demonstrated compliance with 40 CFR 194.8 requirements for INL-CCP RH

Waste Stream IN-ID-NRF-153.

Radiological Characterization Overview

Waste Stream IN-ID-NRF-153 consists of combustible RH debris from the cleanup operations in the Alpha Box installed in hot cell No. 14 in the N RF ECF generated from April 1975 to 1979. Cleanup operations followed fuel cutting operations in support of reactor fuel and material type

examinations at the ECF. This NRF waste stream cont ains the five fuel types that were examined in the ECF: Advance Fuel, Standard Fuel, 235 U+Th Fuel, Natural or Depleted Uranium Blanket Fuels, and 233 U+Th Fuel.

The fuel fines and water spray – water was used to cool the silicon carbide cut-off wheel and to reduce contamination spread – were the source of th e Alpha Box contamination, resulting in the contamination of the cleanup materials used in thes e box operations. According to an NRF study, 15% of the fuel fine was deposited in the Alpha Box and the remaining 85% was deposited in the sludge pans beneath the cut-off wheel. After replac ement, the sludge pans containing the fuel fines were placed into a total of 48 SPCs during th e time period mentioned above. It was expected that the 137 Cs would be soluble in the water used during the cu tting operations, which would affect the ratios of the radioisotopes in the fuel matrix.

The debris wastes from the cleanup operations were placed in either 12-inch-tall or 17-inch-tall Rabe bottles which were placed inside 30-gallon dru ms. Each 30-gallon drum contained either

one 17-inch-tall Rabe bottle or two 12-inch-tall Ra be bottles. Twenty-seven 55-gallon drums were used to overpack the 30-gallon drums and these 27 55-gallon drums identified as INL-CCP Waste Stream IN-ID-NRF-153 are the subject of this T1 evaluation.

Radiological Characterization Overview

The overall approach to characterizing the IN-ID-NR F-153 waste drums is DTC in conjunction with radionuclide-specific scaling factors, a techn ique that EPA has observed and approved at several RH sites previously. The radionuclide-speci fic scaling factors were developed based on the NRF-supplied information on the estimated activ ity content of each SPC, as representative of17

the contamination deposited on the debris waste mat erials. The NRF radionuclide data and their confirmation by radiochemical analyses and mass spe ctrometry of samples collected resulted in a single set of 137 Cs-based scaling factors (each having been divided by the 137 Cs enhancement factor of 4.17) to be applied to the entire waste s tream. The NRF radiological data were activity

estimates in curies of radionuclides contained in e ach SPC/fuel type, obtained from the mass quantity of fuel in each SPC (based on the known di mensions of the fuel elements and the width of the cut made by the cut-off wheel) and mass-to-c urie reactor physics calculations performed by application of ORIGEN.

The waste sampling results were used as confirmatio n data to qualify the NRF radiological data, not to determine the scaling factors, as ”only thre e of the five fuel types expected in the waste stream were detected on the waste samples” (CCP-AK- INL-560, Revision 2). The information obtained from samples was also used to determine wh ether and to what extent the 137 Cs remained in the fuel matrix ( 137 Cs partitioning). An overview of the radiological c haracterization process used for the IN-ID-NRF-153 wastes is provided in Fi gure 1, below.18

* The 137 Cs enhancement factor (Cs EF) represents the increa se in the 137 Cs levels on the debris transferred into the Alpha Box by the cut-off wheel cooling water. 137 Cs EF is defined as ( 90 Sr/ 137 Cs) mix /( 90 Sr/ 137 Cs) sample data without regard to the likely mix of fuel types contributing to the sample data.

The DTC measurement aspect of this RH TRU debris wa ste stream, IN-ID-NRF-153, was not directly assessed during this T1 evaluation in Denv er. This aspect had been evaluated initially during the INL-CCP baseline inspection and more rec ently during the T1 evaluation of the OSPREY gamma system at INTEC (see EPA Docket No.A-9 8-49; II-A4-131). There were no significant changes. EPA did evaluate the character ization methods used for the IN-ID-NRF-153 RH wastes in terms of the technical adequacy of the approach, as supported by the program’s documents, procedures, and controls, and the knowle dge and understanding of the personnel involved in the RH waste characterization program. Figure 1. Flow Diagram of the Characterization Proc ess: IN-ID-NRF-153 Use the MicroShield ® computer code to model the gamma dose

rate at one meter from the drum surface as a functi on of waste density to develop a 137 Cs DTC correlation based on a 1-Ci source

of 137 Cs

Develop DTC correlation factors (mR/hr/Ci)-density relationships

for 137 Cs

Execute DTC to Determine Drum’s 137 Cs Activity:

Find mean gamma dose rate at 1 m from the surface o f the drum based on four measurements; and determine the waste density based on the actual weight of drum contents and fil l factor

Divide the mean measured dose rate by the DTC conve rsion factor

to find the 137 Cs activity in Curies

Multiply the 137 Cs activity by the scaling factors to determine

the activities of the radionuclides of interest Determine Scaling Factors: Determine DTC Conversion Factor:

Locate and retrieve relevant records

Use the NRF fuel mass data, ORIGEN, and the 137 Cs enhancement factor (4.17) * to determine the scaling factors, i.e.,

1/4.17 times the ratio of the total activity of each radionuclide divided by the total 137 Cs activity, for all five fuel types

Validate ORIGEN results by comparing the model outputs to sample and similar modeling data19

Documents Reviewed

The list provided in Attachment B includes all docu ments related to the INL-CCP RH TRU radiological characterization program that were exa mined to support this T1 evaluation.

Technical Evaluation

(1) The EPA inspection team evaluated the correlati on of the waste records for the 27 55-gallon drums of IN-ID-NRF-153 with the 137 Cs concentration.

The information that formed the basis of the radiol ogical characterization process, the NRF radiological data used in combination with sample d ata, was reviewed. Specifically, the confirmation of the radiological data by the sample results, as documented in the technical report CCP-AK-INL-561, Revision 1, and its supporting calc ulation packages, as listed in Appendix A to this evaluation report, were reviewed. The curie estimates of the radioisotope contents of the 48 SPCs, corresponding to the five fuel types invol ved in the fuel examination program, had been determined via reactor physics calculations pe rformed on the NRF mass estimates, using the ORIGEN computer code. These curie quantities we re used to find the 137 Cs-based scaling factors from the NRF radiological data. The samplin g results were used to determine the

137 Cs-based scaling factors from the 10 samples obtain ed from the 27 drums of waste.

While the sample-based scaling factors were not use d for the characterization of the IN-ID-NRF153 debris waste, they were used to confirm and qua lify the NRF radiological data. The analysis and comparison of the two sets of scaling factors r evealed the need for applying the 137 Cs enhancement factor to the scaling factors determine d from the NRF radiological data. This was because the sampling resulted had revealed that the scaling factors obtained from sampling results were less than their counterparts obtained from the NRF radiological data by a factor of about 4.17. The lower values of the sample-based sc aling factors were due to the fact that the transfer of cut-off wheel cooling water into the Al pha Box had resulted in an increased level of

137 Cs on the debris waste. The application of the 137 Cs enhancement factor to the scaling factor obtained from the NRF radiological data resulted in a new set of scaling factors. The new set of scaling factors would be used, as discussed below, along with the relationship between a waste drum’s easily measurable 137 Cs gamma dose and waste density to determine the cu rie amounts of all reportable radionuclides in each waste drum. Th ese activities are documented in INL-RH-70, INL RH-71, and INL-RH-73 through INL-RH-76 and inco rporate the following information:

• Radiochemistry and mass spectrometry measurements m ade on all samples

• Scaling factors obtained from the sampling results

• Activity estimates of a relatively large number of radionuclides, including the actinides and fission products, contained in each of the 48 S PCs

• Scaling factors for the five fuel types derived fro m the NRF radiological data

• Qualification of NRF radiological information using the sampling results

• Determination of the 137 Cs enhancement factor20

• Additional calculations to confirm modeling approac h selected.

Calculation of the 137 Cs activity for a container allows the further calc ulation of the following quantities for each RH container measured:

• Activity in curies (Ci) and mass in grams (g) for e ach of the 10 WIPP-tracked radionuclides, i.e., 137 Cs, 241 Am, 238 Pu, 239 Pu, 240 Pu, 242 Pu, 90 Sr, 233 U, 234 U, and 238 U

• Associated uncertainty for all radionuclide values listed in previous bullet

• Fissile Gram Equivalent (FGE)

• Pu Equivalent Curies (PE Ci)

• Decay heat in Watts

The constants and other values required for these c alculations were taken from the appropriate sources (TRAMPAC) and were spot-checked for accurac y.

A total of nine shielding calculations were perform ed using MicroShield ® with the 1-Curie

source of 137 Cs uniformly distributed throughout a 55-gallon was te drum for a range of waste densities from 0.2 g/cm 3 to 1.8 g/cm 3 . The results of these were then used to derive a D TC correlation as a function of density for 137 Cs, as shown in CCP-AK-INL-561, Revision 1, Figure 5-1. The actual DTC calculations are perform ed using an Excel spreadsheet where the input includes [see Section (3), below]:

• Drum identification number

• Container gross weight

• Fill height in percent

• Fill height material type (concrete, organic, or st eel)

• Four external dose rate measurements

There were no concerns regarding the correlation of waste records for the 27 55-gallon drums containing the INL NRF RH TRU debris waste with 137 Cs concentration for this IN-ID-NRF-153

waste stream.

(2) The development of radionuclide scaling factors was evaluated and was found to be technically adequate and appropriately documented.

EPA evaluated the following aspects:

• Activity values were derived from modeling and stat istical metrics using the mean and
standard deviation values for each radionuclide

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

attribute21

• Isotopic activity values are correlated to the radi onuclides whose physical half-lives are such that they could be responsible for the measure d external dose rate, i.e., 137 Cs for

these IN-ID-NRF-153 wastes

• Adjustment of the source distribution inside the dr ums for 137 Cs using earlier MCNP5 calculations, calculated as a function of bulk wast e density

• Potential contributions of the short-lived radionuc lides to the total measured dose rate

• Appropriate decay correction according to INL-CCP p rocedure (CCP-TP-504, Revision 8) of all radionuclide values for purposes of model development.

Note: Decay corrections should be made to a new shi pping date.

• The ORIGEN results are used to develop radionuclide -specific scaling factors that, in turn, after dividing by the 137 Cs enhancement factor, are used to determine activi ty levels

of the radionuclides of interest from 137 Cs activity obtained from the measured external dose rates and DTC relationship

• Activity and uncertainty values determined for the ten WIPP-Tracked radionuclides ( 233 U, 234 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 242 Pu, 241 Am, 137 Cs, and 90 Sr)

• The determination of the contribution of all radion uclides to the radiological hazard 5

• Shielding and other calculations supporting the sca ling factors performed using MCNP5 to derive the appropriate DTC relationships as a fu nction of waste density for the appropriate geometry following repackaging (55-gall on drum)

• Estimation of the variation in the scaling factor d ue to reasonable variation in the fuel composition, burnup, and decay period, apparently u sed as normal fuel parameters in the NRF ORIGEN calculations, by earlier ORIGEN analyses at SRS and LANL

The radionuclide-specific scaling factors for these IN-ID-NRF-153 wastes that were developed, as shown in Table 5, below, are taken from INL-RH-7 4:

Table 5. Radionuclide-Specific Scaling Factors

Radionuclide DTC Scaling Factor

228 Th 1.18E-04

232 U 1.15E-04

233 U 6.83E-05

234 U 1.91E-05

235 U 6.55E-07

236 U 2.09E-06

238 U 4.23E-09

238 Pu 1.47E-02

239 Pu 4.61E-05

240 Pu 2.19E-05

5 Although the determination of a waste container’s radiological hazard is not an EPA requirement, this information may be useful in understanding other as pects of a container’s radiological characterizatio n.22 Table 5. Radionuclide-Specific Scaling Factors

Radionuclide DTC Scaling Factor

241 Pu 1.82E-03

242 Pu 6.47E-08

241 Am 2.24E-04

244 Cm 6.78E-05

154 Eu 2.94E-03

137 Cs 1.00E+00

90 Sr 2.26E-01

There are no issues related to the technical adequa cy or documentation of radionuclide scaling

factors for NRF RH TRU Waste Stream IN-ID-NRF-153.

(3) The technical basis of the DTC correlation and its documentation were evaluated and both aspects were acceptable.

The DTC correlation was evaluated based on DTC BDR No. INLRHDTC09006, which INLCCP provided to EPA for review during this T1 evalu ation. The correct version of the DTC Excel spreadsheet was used for the calculations, i. e., it contained the radionuclide scaling factors that were developed and documented in INL-RH-74, an d Table 5, above. EPA technical personnel verified that the DTC BDR cited above inc luded the following:

• BDR Cover Sheet, Attachment 4

• BDR Table of Contents, Attachment 5

• BDR Narrative Summary, Attachment 6

• ITR Review Checklist, Attachment 7

• Measurement Control Report, Attachment 1

• Container Data Sheet(s), Attachment 2

• Waste Container DTC Conversion Record(s), Attachmen t 3

• Evidence of signatures by the ITR and a SPM

• Type of waste in each container (steel, concrete, o rganics)

• Fill height of the container: < 25% full; 25% - 66% full; 66% - 90% full; > 90% full

There were no issues related to the DTC correlation and its documentation for these

IN-ID-NRF-153 wastes.

(4) Technical aspects and documentation of the rad iological characterization process were evaluated and found to be acceptable.

The Technical Report CCP-AK-INL-561 is the main doc ument that describes the radiological characterization process that INL-CCP used for the NRF RH TRU wastes. This document is supported by a series of 11 calculation packages, l isted in Attachment 1 to the Technical Report, that were reviewed in the process of evaluating the NRF RH TRU wastes. These packages had been prepared and reviewed initially by Jene Vance, Jim Holderness, Dave Moody, and Jessie23

Klingensmith to support several CCP RH TRU evaluati ons. The EPA evaluation team reviewed these packages in conjunction with Revision 1 of CC P-AK-INL-561 in advance of the formal T1 evaluation meeting at EPA headquarters. Several doc uments had been revised more recently and these revisions were evaluated during the meeting a s they were provided by INL-CCP. During these discussions, the EPA evaluation team had the opportunity to discuss all technical concerns and apparent discrepancies with INL-CCP personnel a nd to raise a variety of technical and documentation-related questions regarding technical aspects related to the NRF RH TRU wastes. Several of these questions required revisions to CC P-AK-INL-561, and INL-CCP personnel stated that these would be incorporated in a freeze -file that would be provided following the evaluation in Denver. Upon evaluation, the EPA eval uation team found that the freeze-file changes made to CCP-AK-INL-561 adequately addressed all of EPA’s questions. Upon incorporation of the freeze-file changes, the revis ed document adequately supported the radiological characterization process for the NRF R H TRU wastes, and the calculation packages cited above provided adequate technical support for the radiological characterization of NRF RH

TRU wastes. There were no issues related to the doc umentation of technical aspects of the INLCCP radiological characterization approach for the NRF RH TRU wastes.

(5) The technical basis and derivation of Total Mea surement Uncertainty were evaluated and were found to be adequate.

The development of Total Measurement Uncertainty (T MU) for Waste Stream IN-ID-NRF-153 waste is based on the propagation of uncertainties present in all aspects of the determination of the radiological constituents of RH TRU waste. Thes e aspects are assumed to be independent, which allows them to be added in quadrature. The TM U determination included contributions of the following:

• DTC correlation – including drum weight measurement , MicroShield ® code, and modeling uncertainties

• Measurement uncertainty – including dose rate uncer tainty from 137 Cs

• Scaling factor uncertainty – including ORIGEN

• Contributions of other gamma emitters

• Drum-to-drum variation

A general treatment of TMU for this NRF RH TRU wast e stream is presented in CCP-AK-INL561 and Calculation Package INL-RH-77, Revision 1, Uncertainty Analysis of for NRF Debris. The principal sources of uncertainty are uncertaint ies in 137 Cs enhancement factor, ORIGEN benchmarking, variation in code input, and drum-to drum variability. There were no concerns regarding the technical derivation and documentatio n of TMU for INL-CCP Waste Stream

IN-ID-NRF-153.

(6) RH and TRU determinations were assessed and wer e found to be adequate.

The determinations that these containers met the de finitions of TRU waste and RH waste were examined during the baseline inspection based on DT C BDR Nos. INLRHDTC09006 and24

INLRHDTC09007. Both the RH and TRU determination ar e parts of the DTC measurements that are performed at the INTEC Facility at INL, wh ich was not assessed directly during this T1 evaluation. EPA did verify that no aspects of the D TC process had changed significantly from what EPA had observed during the baseline inspectio n. Additionally, EPA had evaluated the INTEC DTC process as part of the OSPREY  gamma system for assaying HFEF Lot 1B RH TRU wastes, see EPA Docket No. A-98-49; II-A4-131. The results for the containers that were reviewed as part of this T1 evaluation, as document ed in the DTC BDR, indicated the following:

• All containers were clearly TRU, i.e., contained mo re than 100 nCi/g of transuranic

radionuclides.

• All containers were clearly RH, i.e., had an extern al contact dose rate greater than 200
mRem/hr.

There were no technical or documentation-related co ncerns regarding the TRU and RH

determinations for the containers in Waste Stream I N-ID-NRF-153.

Summary of Radiological Characterization

Findings or Concerns

The EPA inspection team did not identify any findin gs or concerns related to radiological

characterization.

Tiering Changes

Based on the results of this T1 evaluation, there a re no changes to the T1 and T2 designations that were assigned to radiological characterization for INL-CCP during the baseline approval. However, the Tiering Table for INL-CCP RH has been modified to reflect the need for all waste streams to have similar reporting requirements.

5.3 Real-Time Radiography

EPA reviewed four RTR BDRs to support this T1 reque st for addition of Waste Stream IN-ID-NRF-153. The containers reviewed were subject to RTR examination in February and March of 2009. EPA’s review included RTR written pr ocedures, audio/visual and written records, and operator training. The following is a list of the documents and records reviewed by

EPA:

• BDR Numbers INLRHRTR090002, INLRHRTR090003, INLRHRT R090004 and INLRHRTR090005, both written and audio/visual recor ds

• List of Qualified Individuals (LOQI) for the time p eriods covered by the BDRs listed in previous bullet

• CCP-TP-508, RH Standard Real-Time Radiography Inspe ction Procedure, Revision 525

• Demonstration of Capability audio/visual recordings for two of the operators responsible for RTR of the subject containers

• RH Radiography Test Drum Inventory Sheet for contai ners INL-RH-NDE-TEST-05,
INL-RH-NDE-TEST-06 and INL-RH-NDE-TEST-07

• CCP Training Log of Inventory Test Drum Number, RH- INL

EPA randomly selected for review containers from av ailable BDRs, as listed in Table 6.

Table 6. RTR BDRs Reviewed

BDR Number Container Number

INLRHRTR090002 EC0300003; IDINEC0300006; IDINEC030 0007, original and replicate INLRHRTR090003 IDINEC0100003, original and independ ent observation INLRHRTR090004 IDINEC0100012; IDINEC0300004 INLRHRTR090005 IDINEC0100007; IDINEC0100011

Before commencing RTR operations, the resolution of the X-ray system was verified as meeting requirements by performing an Image Test Pattern Te st. The number of lines-pair/cm recorded for each day of operations met the minimum requirem ents of 5 lines-pair/cm. Through review of the BDRs, EPA verified that data sheets were comple ted and signed as required. The quality control (QC) examinations, specifically the replica te and independent observations, had been performed for all four BDRs. An NCR, NCR-RHINL-0503 -10, was written for all containers in BDR INLRTR09002 because the operator recorded the w aste matrix code (WMC) as S5400 instead of S5300. The NCR was processed in accordan ce with CCP procedures.

During the examination of container IDINEC0300006 f rom BDR INRHRTR09002, the operator stopped the audio/visual recording to further inves tigate the presence of free liquid. The operator did not describe what was done during the off-line time. EPA discussed this with INL-CCP RTR personnel and generated an EPA Concern NRF-RH-RTR-1 0-001C to address this issue (see Attachment C for a copy of this concern).

T1 Evaluation Concern NRF-RH-RTR-10-001C: While performing RTR on container No. IDINEC0300006, the operator went off line to furthe r investigate the presence/absence of prohibited liquid. The operator did not state speci fically or document in the written record what

was done while off line. The INL-CCP SPM contacted the operator regarding this issue; the operator stated that she could not remember what sh e had done during that break in recording.

EPA is concerned about the completeness of RTR reco rds. While 100% of the container was viewed, analyzed and recorded, the undocumented sto pping of the recording to verify a component critical to compliance is not a desirable practice. EPA is concerned that complete records of what the operator did when characterizin g a container must be generated for all containers examined. All actions of an operator tha t have a technical bearing on the acceptability of data used to support waste characterization (was te isolation) must be available for internal reviewers and federal inspectors. Specifically, act ions that are relevant to identification of physical contents and/or prohibited items (waste ch aracterization/isolation) must be part of the auditable record. The RTR operators must be trained to understand that these actions must be26

performed in such a way that they are part of the o fficial auditable record that documents container’s characterization, i.e., can serve as ob jective evidence to support EPA’s approval decision. As part of future continued compliance in spection(s) EPA would verify whether steps have been taken to include RTR operator’s actions r elevant to identification of physical contents and/or prohibited items are documented in auditable record.

Status of Concern: This concern did not require a response.

Demonstrations of Capability for audio/visual recor dings were reviewed for 2 RTR operators. Using the inventory sheet supplied by INL-CCP, EPA identified that test drum INL-RH-NDETEST-07 had apparently been built after examination by the operators. Documentation suggests that the inventory sheet was accepted and used by I NL-CCP without any internal identification of this problem. INL-CCP provided information that demonstrated that the inventory should have been dated September 8, 2008, which EPA accept ed. RTR characterization activities for these drums were performed in accordance with requi red procedures by trained and qualified
operators.

Summary of Real-Time Radiography

Findings or Concerns

The EPA inspection team did not identify any findin gs related to RTR. EPA identified once concern related to RTR which did not require a resp onse. There are no open issues relative to

RTR as a result of this T1 evaluation.

Tiering Changes

Based on the results of this T1 evaluation, there a re no changes to the T1 and T2 designations that were assigned to RTR for INL-CCP during the ba seline approval. However, the Tiering

Table for INL-CCP RH has been modified to reflect t he need for all waste streams to have similar reporting requirements.

6.0 SUMMARY OF RESULTS

EPA concluded that the waste characterization proce sses of AK, radiological characterization, and RTR proposed for use by INL-CCP to characterize RH TRU wastes from the Alpha Box within Cell 14 of Building 618 in the ECF at NRF ar e acceptable. There are no open issues

relative to this T1 evaluation.

Findings and Concerns

The EPA inspection team did not identify any findin gs during the inspection. One concern related to RTR was identified during the inspection as discussed in Section 5.3. This concern did not require a response and no issues remain open re lative to this T1 change.27

Tiering Changes

Based on the results of this evaluation, there are a few changes to the INL RH Tiering Table included in the August 2010 dated report evaluating RH debris containers from Lot 1B of Waste

Stream ID-HFEF-S5400-RH. These modifications are sh own (in bold ) in Table 1 of the Executive Summary above and include one change each to the AK T1 and T2 designations, one T1 change added to radiological characterization, a nd a Tier 1 item for RTR has been modified

to reflect the need for all waste streams to have s imilar reporting requirements.

Approval

EPA determined that the procedures and processes us ed by INL-CCP for the addition of Waste Stream IN-ID-NRF-153, consisting of 27 30-gallon dr ums, were adequate. EPA, therefore, approves Waste Stream IN-ID-NRF-153 as a T1 change to INL-CCP’s RH baseline approval.ATTACHMENT A

APPROVAL SUMMARY FOR INL-CCP

REMOTE-HANDLED WASTE CHARACTERIZATION PROGRAMA-1

Approval Summary for INL-CCP Remote-Handled Waste C haracterization Program

Specific INL RH Approval Date EPA Docket Number

INL RH Baseline Approval January 2007 A-98-49; II-A4-72

Tier 1 Change – Approval of Visual Examination Janu ary 2007 A-98-49; II-A4-75

Tier 1 Change – Approval of Real Time Radiography F ebruary 2007 A-98-49; II-A4-80

Tier 1 Change – Approval of K Cell Wastes January 2 008 A-98-49; II-A4-97

Tier 1 Change – Approval of High Range Gamma Probe for DTC April 2008 A-98-49; II-A4-98

Tier 1 Change – Approval of Visual Examination Tech nique September 2009 A-98-49; II-A4-118

Tier 1 Change – Addition of Twelve Containers to Wa ste Stream

ID-ANLE-S5000 and Addition of Waste Stream

ID-HFEF-S5400-RH January 2010 A-98-49; II-A4-122

Tier 1 Change – Approval of Waste Stream ID-MFC-S54 00-RH June 2010 A-98-49; II-A4-126

Tier 1 Change – Approval of Waste Stream ID-INTEC-S 5400-RH August 2010 A-98-49; II-A4-130

Tier 1 Change – Addition of Lot 1B to Waste Stream

ID-HFEF-S5400-RH August 2010 A-98-49; II-A4-131ATTACHMENT B

LISTING OF DOCUMENTS REVIEWED FOR THIS EVALUATIONB-1 Listing of Documents Reviewed for this Evaluation

CCP-AK-INL-560 Central Characterization Project Acc eptable Knowledge Summary Report for Idaho National Laboratory Remote-Handled Transurani c Debris Waste from the Naval Reactors Facility, Waste Stream: IN-ID-NRF-153, Revision 2, September 30, 2009

CCP-AK-INL-561, Central Characterization Project Re mote-Handled Transuranic Radiological Characterization Technical Report for Remote-Handle d Transuranic Debris Waste From Idaho National Laboratory Naval Reactors Facility, Waste Stream IN-ID-NRF-153, Revision 1,
May 10, 2010

CCP-AK-INL-562, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation Test Plan for INL RH Waste Stream: IN-ID-NRF153, Revision 1, November 18, 2009

CCP-AK-INL-565, Central Characterization Project Sa mpling and Analysis Plan for RemoteHandled Transuranic Debris from the Naval Reactors Facility at the Idaho National Laboratory,
Waste Stream IN-ID-NRF-153, Revision 2, March 16, 2 010

CCP-QP-005, Revision 18, CCP TRU Nonconforming Item Reporting and Control, Attachment 1 – CCP Nonconformance Report (NCR), NCR No. NCR-RH INL-0100-10, Revision 0,
March 30, 2010

CCP-TP-005, Revision 12, CCP Acceptable Knowledge D ocumentation, Attachment 5 –
Hazardous Constituents, Waste Stream IN-ID-NRF-153, April 26, 2010

CCP-TP-005, Revision 18, CCP Acceptable Knowledge D ocumentation, Attachment 1 – Acceptable Knowledge Documentation Checklist, Waste Stream IN-ID-NRF-153, May 27, 2010

CCP-TP-005, Revision 18, CCP Acceptable Knowledge D ocumentation, Attachment 4 –
Acceptable Knowledge Source Document Reference List , Waste Stream IN-ID-NRF-153,
August 10, 2010

CCP-TP-005, Revision 18, CCP Acceptable Knowledge D ocumentation, Attachment 6 – Waste
Form, Waste Material Parameters, Prohibited Items, and Packaging, Waste Stream IN-ID-NRF153, January 28, 2009

CCP-TP-005, Revision 18, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste Containers, Waste Stream IN-ID-NRF-153, February 5, 2009B-2

CCP-TP-512, Revision 2, CCP Remote-Handled Waste Sa mpling, Attachment 6 – Site Project Manager Sampling Batch Data Report Checklist, BDR N o. IDRH0901, July 5, 2009

CCP-TP-512, Revision 2, CCP Remote-Handled Waste Sa mpling, Attachment 7 - Site Project Manager Radiochemistry or ICP-MS Analytical Batch D ata Report Checklist, BDR No. ALD09002R, July 22, 2009

CCP-TP-512, Revision 2, CCP Remote-Handled Waste Sa mpling, Attachment 7 - Site Project Manager Radiochemistry or ICP-MS Analytical Batch D ata Report Checklist, BDR No. ALD09006I_R1, July 22, 2009

Characterization Reconciliation Report for IN-ID-NR F-153, Draft for Audit Purposes, Provided
June 3, 2010

DOE WIPP 02-3214, Remote-Handled TRU Waste Characte rization Program Implementation
Plan, Revision 0D, October 30, 2003

Freeze File Modifications to CCP-AK-INL-560, Revisi on 2 and CCP-AK-INL562, Revision 1, provided August 11, 2010

Inter-Office Correspondence, from C. M. Gomez to M. Sensibaugh, Acceptable Knowledge Accuracy Report, Idaho National Laboratory, Waste S tream IN-ID-NRF-153, Lot 1, For Audit
Purposes Only, March 26, 2010

P-TS Screenshots/Traceability Information for Drums 100004, 100006, 200004, and 300004, Provided to EPA on August 10, 2010

Training documentation, Qualification Cards and Sit e-Specific RH Training for J. Luginbyhl and I. Quintana, provided August 10, 2010

WCPIP Revision 0D, Attachment 4 - Waste Stream Profile Form, Waste Stream IN-ID-NRF153, Draft for Audit Purposes, Provided June 3, 201 0

All C, DR, P, and U source documents were provided for review. Full documents were reviewed by EPA for all except UCNI, Classified, or NOFORN d ocuments, for which only Attachment 3 summaries were provided and reviewed. The list belo w is a subset of the provided source documents representing some of the more pertinent r eferences examined. Any UCNI, Classified,

or NOFORN documents show below were either examined only through Attachment 3 Summary review, or were examined during the audit with no c opies of the documents provided to the EPA.B-3

C004, Letter to M. DiBattista from J. Raros, Re: Re mote-Handled (RH) Transuranic (TRU) Acceptance Knowledge (AK) Collection -Request for N RF Action, J. Roros, IBO-07/084, September 6, 2007

C006, Letter to G. B. Bragg from J. E. Schmucher, R e: ECF Transuranic Waste Shipments to the INEL Radioactive Waste Management Complex (RWMC) (U CNI), J. E. Schmucker, NRFE-TS2421, September 27, 1979

C009, Letter to Mr. D. J. Miller from G. D. Carpent er, Re: Transuranic Curie Content of Enriched Uranium Fuels TWR No. 09865 pp. 93-100 (NO FORN), G. D. Carpenter, WAPDMT(IP)-552, October 12, 1978

C010, Letter to T. H. Alff, Re: Transuranic Curie C ontent of Partially Enriched Uranium Fuels, R. L. Underwood, WAPD-MT(IP)-1069, December 18, 197 9

C011, Interview of N. Spackman and S. Lundt, Re: Fl ow Diagram for Alpha Box Operations, James Luginbyhl, March 20, 2008

C012, Letter to D. R. Hyster from W. F. Irvine, Re: Request for Fuel Shipment Approval, W. F. Irvine, NRFE-0-6679, March 2, 1981

C016, Memorandum to Harker/Wade, Re: Alpha Box Wast e Material Identification, J. F. Ruggiero, October 12, 1976

C019, Letter to P. W. Eselgroth, Re: Information to Support Previous Request, H. F. Daugherty, NRFE-O-5878, January 9, 1979

C020, Memorandum to J. Ruggiero, Re: Trans U Conten t of EC 10, 11, and 12, Ken Barr, December 2, 1977

C021, Letter to Manager, Pittsburgh Naval Reactors Office, Re: Approval Request of NRF Alpha-Box Waste Accountability Facilities, R. F. Be yer, WAPD-F(NMM)-1, July 31, 1978

C022, Letter to C. H. Price, Re: Documentation of M easurement Methods for Accountable Nuclear Material Content of Transuranic Waste, ECF Examination Engineering, NRFE-EE-7565, July 6, 1978

C026, Correspondence to C. H. Price, Re: Documentat ion of Measurement Methods for Accountable Nuclear Material Content of Scrap, ECF Examination Engineering, NRFE-EE-7541, March 31, 1978

C027, Correspondence to C. H. Price, Re: Documentat ion of Measurement Methods for Accountable Nuclear Material Content of Scrap, ECF Examination Engineering, NRFE-EE-7559, June 15, 1978B-4

C029, Interview of J. F. Ruggiero, Re: History of N RF Combustible TRU Waste, James Luginbyhl, January 22, 2008

C030, Telephone Conference With ECF Examination Eng ineering on Combustible Transuranic Waste from the ECF Hot Cell Alpha Box, J. F. Ruggie ro, NRFE-EE-7906T, January 21, 1982

C113, Memo to Irene Quintana, Re: Analysis of Sampl e Data for RH Debris Waste Generated from the NRF at INL, J. Holderness, June 26, 2009

C114, Memo to Irene Quintana, Re: Analysis of Sampl e Data for RH Debris Waste Generated from the NRF at INL, J. Vance, August 23, 2009

DR001, Attachment 11, Acceptable Knowledge Source D ocument Discrepancy Resolution (Hazardous Waste Numbers), James Luginbyhl, DR001, May 15, 2008

P001, Letter to T. Clements from T. N. Miller, Re: Attachment 1: Cover Letter and Attachment 2: A Short History of the Expended Core Facility (1 953 to June 1990) (NOFORN), T. N. Miller, NRF-E(RME)-779, November 26, 2007

P002, Diagrams of ECF Container: Trash Disposal Rab e Bottle, ECF Hot Cell Alpha Box Waste Canister Assembly, and a Sketch of 12 inch Rabe Bot tle, D. Corrigan, 927F315/974D600, July 26, 1994

P003, Expended Core Facility Maintenance and Operat ions Guide (NOFORN), Technical Manual 7959, June 1, 1958

P004, RWMIS Integrated Waste Tracking System (IWTS) Historical Disposed Shipment Detail Listing, HIST_ST127B14, August 20, 2002

P005, Transmittal of the Evaluation of Naval Reacto rs Facility Radioactive Waste Disposed Of at the Radioactive Waste Management Complex, S. L. Dunn, NR: IBO-057023, February 3,

2005

P007, Alpha Box Support Operations, NRF 1661.22, Re vision 9, March 1, 1983

P008, Alpha Box Operations and Maintenance, NRF 166 1.22, Revision 9, February 7, 1986

P009, Integrated Waste Tracking System Historical I nformation on Naval Reactor Facility (NRF) Waste Disposal, August 20, 2002

P011, NRF Procedure 1201.4, Section 10-Nuclear Mate rial Measurements and Analysis (UCNI), NRF 1201.4, Revision 11, February 1, 1982

P015, Management of Alpha Box Waste, NRF 1661.22, M arch 1, 1982

P016, The NRF Environmental Monitoring Program, NRF 2455, December 1, 2006B-5

P018, Canister Remediation Prioritization (NOFORN), B. F. Kammenzind, TRR-ECF(FP291)FP0103 6-TR1, December 12, 2003

P019, Attachment B: Description of Naval Spent Nucl ear Fuel Receipt and Handling at the Expended Core Facility at the Idaho National Engine ering Laboratory, WAPD-OT(E)-107

P021, Internal Technical Report Waste Characterizat ion for INEL Remote-Handled/Special-Case Stored Transuranic Wastes, Dennis A. Peterson, WM-P D-85-014, November 1, 1985

P022, Radiological Properties of Remote-Handled Tra nsuranic Waste Inventory at the Radioactive Waste Management Complex, Cecilia R. Ho ffman, EDF-4687, May 20, 2005

P023, Baseline Estimate of the Volume of Remote-Han dled Transuranic Waste Stored at the Radioactive Waste Management Complex, Cecilia R. Ho ffman, EDF-4379, March 16, 2005

P024, Characterization and Shipping Records for Rem ote Handled (RH) Transuranic (TRU) Waste Stored at the Radioactive Waste Managment Com plex (RWMC); Volumes XI, H. D. Killian and S. K. Mcdermott, 3460-94-084, September 1, 1994

P027, AK Summary Documentation RH TRU Repackaging, Ken Krivanek, RPT-456, October 1,

2007

P028, Email from Raj Bhatt, Re: Fast Scan Report Di screpancies, Ral Bhatt, July 18, 2007

P029, ILTSF Drum Retrieval Completion Report, Fairf ield Service Group, ICP/EXT-05-00886, January 2006

U001, Attachment-Table I-Pu Curie Conversion Factor s and Figures (NOFORN), WAPD-MT(IP)-1069

U002, ECF Route Card on Resin Column Beads and Fuel Chips Disposal (NOFORN), J. F. Ruggiero, 30729, January 18, 1980

U003, NRF Radioactive Waste Forms 10-27-77 through 11-4-77

U004, NRF Radioactive Waste Forms and Material Tran sfer Forms 11-19-78 through 3-1-79

U005, NRF Radioactive Waste Forms and Material Tran sfer Forms 01-01-79 through 12-31-79

U006, NRF Radioactive Waste Forms and Material Tran sfer Forms 01-01-78 through 12-31-78

U007, NRF Radioactive Waste Forms and Material Tran sfer Forms 01-01-77 through 12-31-77

U008, Form 828, RH TRU RTR Prescreen for Repackagin g/AK Worksheet for NRF Drums, August 14, 2007B-6

U009, RH TRU Overpack Log, J. Hegsted, November 21, 2007

U010, ECF Route Card -Disposition of Scrap Canniste r, NB-200, J. F. Ruggiero, 20986, November 17, 1975

U011, Route Card Change Form - Load & Ship Combusti ble Trans-U Waste, J. F. Ruggiero, 29874, December 5, 1978

U012, ECF Route Card -Combustible Transuranic Waste Disposal-Loading & Shipment to INEL RWMC, J. F. Ruggiero, 29182, October 12, 1977

U013, NRF Onsite Radioactive Material Shipping Reco rd

U014, Transuranic Waste Container Form and Attachme nts, R. K. Hines, April 10, 1981

U015, General Procedures for the Expended Core Faci lty Nuclear Material Balance Area (UCNI), NRF1202, WP/169, Revision 5, August 1, 1984

U016, Pyrophoricity and Ignitability of SPC Content s

U017, ECF Route Card-Load and Ship Combustible Tran s-U Waste, RC 30020, March 5, 1979

U018, Route Card Change Form-Prep Trans-U Waste Shi pping Drums Change Notice No. 1, RC 30022, March 12, 1979

U019, Summation of Partial Activities of SPCs (NOFO RN)

U020, Low Level Trans U Waste

U022, ECF Route Card-Dispose Alpha Box Waste, J. F. Ruggiero, RC 32195, August 8, 1986

U023, ECF Route Card-Alpha Box Waste Disposal (Poly Canisters-EC-51 through EC-60), RC 32836, November 8, 1988

U027, Alpha Box Log Volume 1 (NOFORN), March 1, 197 6

U028, Alpha Box Log Volume 2 (NOFORN), March 26, 19 85

U030, ECF Route Card: Unload Trans-U Waste Storage Vault-TR-U-Poly-7 (November 1976), J. F. Ruggiero, RC 29447, February 3, 1978

U032, ECF Route Card-Load and Ship Transuranic Wast e 3D-Gallon Drums, J. F. Ruggiero, RC 29333, December 19, 1977B-7

U033, Radiological Control Survey Maps and Rabe Bot tle Radiation Readings, Joe Bates and S. Marriott, October 25, 1977

U060, Results of Plutonium Analysis of Core

U061, Plutonium and Uranium Content per Drum Number

U062, Combustible Transuranic Waste-ILTSF Shipment Summary

U063, Transuranic Waste Disposition (Proposed) Proj ection, November 4, 1977

U064, RH Waste Characterization Questionnaire

U066, Alpha Box Combustible Waste Record Sheet, Feb ruary 2, 1978

U067, Transuranic Noncombustible Waste Record Sheet , January 14, 1980

U070, ANL Radiation Dose to Packaging Over 20 Year Storage Hand Calculations

U072, Review of the intermediate Level Transuranic Storage Facility Mixed Waste

U073, List of Shipments from ANL-W, NRF, TRA

U074, Drum Evaluation, WMP, Rad, James Luginbyhl, M ay 15, 2008

U106, SPC Load Logs for SPCs 31-85, 87-89, 71A, and 39A

U109, Data Logs for SPCs in TUVs

U149, CCP Calc Package: Sample Data Input Check, J. Vance, INL-RH-70, August 28, 2009

U150, CCP Calc Package: Scaling Factor Development for Fuel Types, J. Vance, INL-RH-71, July 11, 2009

U151, CCP Calc Package: Fuel Type Assignment to SPC s, James Holderness, INL-RH-72, August 24, 2009

U152, CCP Calc Package: Sample Scaling Factors, J. Vance, INL-RH-73, July 11, 2009

U153, CCP Calc Package: Waste Stream Scaling Factor Development for NRF Debris, J. Vance, INL-RH-74, July 11, 2009

U154, CCP Calc Package: Analysis of Fuel Type Contr ibution to Samples, James Holderness, INL-RH-75, August 24, 2009B-8

U155, CCP Calc Package: Comparison of Sample Scalin g Factors to NRF Scaling Factors, J. Vance, INL-RH-76, July 11, 2009

U156, CCP Calc Package: Uncertainty Analysis for NR F Debris Drums, James Holderness, INL-RH-77, August 22, 2009

U157, CCP Calc Package: INL NRF Cs-137 Dose-to-Curi e Correlation for 55-Gallon Drums, Jene Vance, INL-RH-78, July 18, 2009

U158, CCP Calc Package: Determination of Reportable Isotopes - Debris, Jene Vance, INL-RH-79, Revision 1, March 3, 2010

U159, CCP Calc Package: DTC Spreadsheet for NRF Deb ris, James Holderness, INL-RH-80, September 24, 2009

U168, Cs-137 DTC Correlation for 55-Gal Drums with Internal Shielding, James Holderness, INL-RH-89, August 7, 2009

U169, DTC Spreadsheet for 55-Gal Drums with interna l Lead Shielding, J. Vance, INL-RH-90, August 28, 2009

Spreadsheet, Draft, Summarizing Non-Classified Info rmation Pertaining to Drum Numbers, Rabe/Canister Numbers, SPCs, Fuel Type (I-V), and P ackaging Dates, provided August 11, 2010

Engineering Design File EDF-8775, Revision 1, Radio logical Properties of Sludge Pan Container Waste from Naval Reactors Facility, Augus t 27, 2009, NOFORNATTACHMENT C

EPA EVALUATION ISSUE TRACKING FORM –

REAL-TIME RADIOGRAPHYC-1 Inspection No. T1, Waste Stream IN-ID-NRF-153 Issue Number: NRF-RH-RTR-10-001C

Date: August 11, 2010
Inspector: Dorothy E. Gill

Attachments? YES NO Sample Size : 1 Population size (if known): Unknown

Description of Issue: Specifically, while performing RTR on container ID INEC0300006, the operator went off line to further investigate the presence/absenc e of prohibited liquid. The operator did not state specifically or document in the written record what was done while off line. The CCP SPM contacted the operator regarding this issue stated that the opera tor could not remember what she had done during tha t break in recording.

EPA is concerned about the completeness of RTR reco rds. While 100% of the container was viewed, analyzed and recorded, the undocumented stopping of the recording to verify a component critical to compliance is not a desirable practice. In a simila r instance, during the Hanford-CCP baseline inspect ion, EPA inspectors observed a calculation of free liqui d in a container that did not form part of the offi cial record (Hanford-CCP-CH-RTR-10-001CR). While the two specific occurrences described here may not have affected the RTR data generated, EPA is concer ned that complete records of what operator did when characterizing a container must be generated for al l containers examined.

All actions of an operator that has a technical bea ring on the acceptability of data used to support w aste characterization (waste isolation) must be availabl e for internal reviewers and federal inspectors. Specifically, actions that are relevant to identifi cation of physical contents and/or prohibited items (waste characterization/isolation) must be part of the aud itable record. The RTR operators must be trained to understand that these actions must be performed in such a way that they are part of the official audit able record that documents container’s characterization, i.e., can serve as objective evidence to support E PA’s approval decision.

B. Regulatory Reference: 40 CFR 194.24(c)(4) and WCPIP, Revision 2, Draft D, Section 4.1.4.3, Completeness QAO.

C. Site requirement(s): Not applicable

D. Discussed with: Irene Quintana (CCP SPM), Court Fesmire (CBFO, NTP) , Mike Wallentine (CCP)

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES NO