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 PROGRAM 

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 2010
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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-Handled Waste Characterization 

Program 

Attachment B: Listing of Documents Reviewed for This Evaluation 

Attachment C: EPA Evaluation Issue Tracking Form – Real-Time Radiography 
ii

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/cm3

 grams per cubic centimeter 

HFEF Hot Fuel Examination Facility 

HLW high-level waste 

INL Idaho National Laboratory 

INTEC Idaho Nuclear Technology and Engineering Center 

IWTS Integrated Waste Tracking System 
iii

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 Computer 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/Governments/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 Information 
iv

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 System 
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1.0 EXECUTIVE SUMMARY 

This report supports the U.S. Environmental Protection Agency’s (EPA’s) approval of remotehandled (RH) transuranic (TRU) organic debris (S5300) waste stream IN-ID-NRF-153 from the 

U.S. Department of Energy’s (DOE) Idaho National Laboratory (INL) Naval Reactor Fuel 

(NRF) facility. 

On February 8, 2010, the Carlsbad Field Office (CBFO) requested that EPA review a proposed 

Tier 1 (T1) change for approving the RH Waste Stream 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 Characterization Project (CCP) is responsible for 

characterizing RH wastes at INL using a system of controls, which EPA approved in January 

2007 (baseline inspection dated July 2006) and subsequent 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 stream, 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 determined 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, approves Waste Stream IN-ID-NRF-153 

currently in 27 30-gallon containers1

 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 the EPA-approved system of controls 

(including approved radiological scaling factors) as a T2 change. The T2 change requirements 

include: EPA notification of additional containers and submission of a revised acceptable 

knowledge summary report, radiological characterization 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 process and/or with different scaling factors is 

warranted, then EPA approval of this characterization step is necessary as a T1 change prior to 

disposal. Table 1 below presents changes to the tiering 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 their radiological and physical contents. 
2

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Approval 

RH Process Elements INL-CCP RH WC Process - T1 Changes INL-CCP RH P

Acceptable Knowledge (AK) Addition of containers to approved waste streams if new or 

different radionuclide scaling factors are requiredAny new waste streams not approved under the baseline or as a T1 approval Substantive modification(s) that have the potential to affect the characterization process: CCP-AK-INL-500, CCP-AK-INL501, or CCP-AK-INL-502 Load management for any RH waste stream 

Notification to EPA when AKS

Report and Certification ConfirINL-500, CCP-AK-INL-501, aapproved by CBFO 

Notification to EPA when chan

of WCPIP revisions have been 

Notification to EPA when a CS

containers in this waste stream dose rates that present NDA re

Notification to EPA once waste 

waste stream and any modificaCRR and AK Summary, are co

Notification to EPA that the fin

for RH containers numbers 728 Reference P030 AK accuracy reports (prepared 

Notification to EPA when addi

TRU Waste Stream AERHDM characterized using the same ra

Notification to EPA of availabi

documents supporting the additwaste stream* 

Notification to EPA when Atta

generated to reflect the updated List Notification of availability of pertinent to RH Waste Stream 

Radiological Characterization, including Dose-to-Curie (DTC) 

Application of new scaling factors for isotopic determination other than those documented in CCP-AK-INL-501 Use of any alternate radiological characterization procedure other than DTC with established scaling factors as documented in CCP-TP-504 or substantive modification of the DTC 

procedure 

Use of any alternate gamma detector with the OSPREYTM system characterization procedure other than the La3Br(Ce) 

Notification to EPA upon comp

501 or CCP-TP-504 that requir

Notification to EPA of availabi

characterization report, if requithe approved waste stream* Radiological content data provadditional containers* 
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Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Approval 

RH Process Elements INL-CCP RH WC Process - T1 Changes INL-CCP RH P

detector observed at INTEC in July 2010Any new RH waste stream not approved under this baseline or addition of containers to Waste Stream ID-ANLE-S5000 that requires changing the established radionuclide scaling factors Characterizing another NRF debris waste using different radiological characterization process and/or different scaling factors 

Visual Examination (VE) VE using audio/video media to characterize additional debris 

waste streams other than Waste Stream ID-ANLE-S5000 or waste from other Summary Waste Categories 

Notification to EPA upon compprocedure(s) that require CBFO 

Physical content data provided additional containers* 

Real-Time Radiography (RTR) Any new S5000 RH waste stream other than ID-ANLE-S5000, 

ID-MFC-S5400-RH, and IN-ID-NRF-153 or wastes from a 

S3000 or S4000 RH waste stream 

Notification to EPA prior to addition of a new RTR unit(s) 

Notification to EPA upon comp

procedure(s) that require CBFO 

Physical content data provided 

additional containers* 

WIPP Waste Data System, WDS (previously known as WWIS) 

None Changes made to WDS proced

Notes: 

- This table has been modified by deleting the references to specific sections of the baseline inspection report where each T1 or T2 element is d

- INL-CCP will report all T2 changes to EPA every three months. - Notification to EPA is not necessary when document updates are editorial in nature or are required to address administrative concerns. - Substantive modification refers to a change with the potential to affect INL-CCP’s RH waste characterization process, e.g., the use of an inher

instrument 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 in bold. 

* These marked changes apply when containers are added to Lot 1B of waste stream ID-HFEF-S5400-RH and are characterized using the same 

used to characterize the original approved waste stream. EPA notification is required when the site identifies the need to characterize additionapproved waste stream.
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2.0 PURPOSE OF TIER 1 EVALUATIONS 

Certain changes to the waste characterization activities 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 Attachment A. 

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004 Federal Register notice, 

EPA must perform a single baseline inspection of a TRU waste generator site’s waste 

characterization program (Vol. 69, No. 136, pages 42571–42583, July 16, 2004). The purpose of 

EPA’s baseline inspection is to approve the site’s waste characterization program, based on the 

demonstration that the program’s components, with applicable conditions and limitations, can 

adequately characterize TRU wastes and comply with the regulatory requirements imposed on 

TRU wastes destined for disposal at the WIPP. 

Following EPA’s baseline approval, EPA is authorized to evaluate and approve changes, if 

necessary, to the site’s approved waste characterization 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 requiring post-implementation (T2) 

notification, are identified in the site-specific baseline 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 characterize and dispose of, at risk of subsequent EPA 

disapproval, any previously approved TRU waste using processes/procedures/equipment 

implemented as T2 changes. EPA reviews T2 changes on a quarterly basis and EPA may conduct 

continued compliance inspections to evaluate implemented T2 changes to verify adequacy. 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation 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 approval decision regarding this waste stream, 

INL RH Waste Stream IN-ID-NRF-153, is conveyed to DOE 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 evaluation 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 88221-3090 
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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 Table 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 Characterization, SC&A 

Amir Mobasheran* Technical Evaluator – Radiological Characterization, SC&A 

Dorothy Gill* Technical Evaluator – RTR, SC&A 

James Luginbyhl Acceptable Knowledge Expert, CCP, LANL 

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 Matter Expert, CCP 

James Holderness Radiological Characterization Subject Matter Expert, CCP 

Thomas L. Clements, Jr. CH2M-Washington Group International, Observer 

Michael Walentine WTS-CCP Project Management, Observer 

Courtland Fesmire U.S. DOE, Observer 

 *Amir Mobasheran and Dorothy Gill did not attend the 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 debris generated through cleaning the 

Alpha Box in Cell 14 at the NRF Expended Core Facility (ECF). The Alpha Box was a carbon 

steel containment box in which fuel elements were remotely 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 within the Alpha Box. The inside of the Alpha Box 

was cleaned when a fuel type being sectioned was changed, and the combustible waste generated 

during cleaning was placed in either a 12- or 17-inch Rabe (plastic) bottle. Sludge pan waste was 

also collected and placed into Sludge Pan Containers (SPCs) between sectioning of different fuel 

types, so the radioactive material in the SPCs is compositionally similar to the radioactive 

material on the organic debris generated during cell cleaning, if both were generated at the same 

time (i.e., on or near the same date). Approximately 85% of the fuel chips removed during the 

cutting operation ended up in the sludge pan below the cut-off wheel. Approximately 15% of the 
6

fuel chips were lost to the Alpha Box and then ended 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 waste stream is contaminated with mixtures 

of radionuclides generated from the cutting operations of five basic fuel types that were 

sectioned within the Alpha Box between 1975 and 1979. 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 could be present within subsequent clean-out 

waste. Regardless, the radionuclide distributions were 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 the intent of developing waste-streamspecific scaling factors. However, the data obtained from sampling could not be used directly to 

determine scaling factors. Because the NRF radiological data were collected outside of an 

approved quality assurance (QA) program, INL-CCP used 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 approaches used. 

Documents, Waste Containers, and Batch Data Reports Reviewed

Several attachments, source documents, forms, and other data were provided to EPA, and the 

relevant sources were examined as part of this T1 inspection. The listing of all documentation 

examined is in Attachment B, and the list of BDRs examined 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 analysis 

IDINEC0100004 INLRHRTR09002, 

INLRHRTR09005 INLRHDTC100007 No analysis 

IDINEC0100005 INLRHRTR09004 INLRHDTC100007 ALD09002R, 

ALD09006IR1 

IDINEC0100006 INLRHRTR09003 INLRHDTC100006 

IDINEC0100007 INLRHRTR09005 ALD09002R, 

ALD09006IR1 

IDINEC0100008 INLRHRTR09002 INLRHDTC100006 No analysis 

IDINEC0100009 INLRHRTR09003 INLRHDTC100006 No analysis 

IDINEC0100010 INLRHRTR09003, 

INLRHRTR09004 

INLRHDTC100006, 

INLRHDTC100007 No analysis 
7

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 analysis 

IDINEC0200001 INLRHRTR09004 INLRHDTC100007 No analysis 

IDINEC0200004 INLRHRTR09002 INLRHDTC100006 No analysis 

IDINEC0200005 INLRHRTR09002 INLRHDTC100006 No analysis 

IDEC0200006 INLRHRTR09003 INLRHDTC100006 No analysis 

IDINEC0200007 INLRHRTR09003 INLRHDTC100007 No analysis 

IDINEC0200008 INLRHRTR09005 INLRHDTC100007 ALD09002R, 

ALD09006IR1 

IDINEC0200009 INLRHRTR09004 Not provided ALD09002R, 

ALD09006IR1 

IDINEC0300001 INLRHRTR09005 INLRHDTC100007 ALD09002R, 

ALD09006IR1 

IDINEC0300002 INLRHRTR09003 INLRHDTC100006 No analysis 

IDINEC0300004 INLRHRTR09004 INLRHDTC100007 No analysis 

IDINEC0300005 INLRHRTR09004 INLRHDTC100007 ALD09002R, 

ALD09006IR1 

IDINEC0300006 INLRHRTR09002 INLRHDTC100006 No analysis 

IDINEC0300007 INLRHRTR09002 INLRHDTC100006 No analysis 

5.1 Acceptable Knowledge 

EPA examined the AK process and associated information 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 following 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 Characterization Program 

Implementation Plan (WCPIP) AK process implementation 

• AK data traceability 
8

• AK source document sufficiency 

• WCPIP interpretation, including AK qualification, and Certification Plan/Confirmatory 

Test Plan (CTP) preparation/adequacy and use of Los Alamos National Laboratory 

(LANL) mass spectrometry data 

• Characterization Reconciliation Report (CRR) adequacy 

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

correlation 

• Personnel training 

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

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

• AK accuracy 

• Defense determination 

• Load management 

• DQOs attained through AK Qualification 

Technical Evaluation

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

adequate. 

The WCPIP, Revision 0D defines a waste stream as consisting of “waste material generated from 

a single process or activity, or as waste with similar physical, chemical, and radiological 

properties.” Waste Stream IN-ID-NRF-153 was evaluated against this definition to assess if the 

processes and activities associated with waste generation 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 1975 and 1979 in the Alpha Box within 

Cell 14 of Building 618 in the ECF at NRF. The Alpha 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 used as samples; fuel chips collected in the 

sludge pans and placed into SPCs; non-combustible debris such as tools, glassware, etc.; and 

combustible debris. Waste Stream IN-ID-NRF-153 consists of 27 30-gallon drums of 

combustible debris waste, 26 of which were overpacked into 55-gallon drums. The 30-gallon 

drums contain 37 Rabe bottles: 17 17-inch Rabe bottles and 20 12-inch Rabe bottles.2

 The Rabe 

bottles were generated by Alpha Box operations between 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. The 12-inch tall canister contains approximately 6 

gallons and the 17-inch tall canister contains approximately 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 contaminated with residual fines, particulates, 

and water thrown onto the sides of the Alpha Box during cutting activities. The fuels sectioned in 

the Alpha Box are well known, as are their radioactive contents. NRF kept detailed records of the 

sectioned fuels, and defined not only the radiological composition of these wastes (U019), but 

also the anticipated amount of residual radiation that would be on combustible waste vs. SPC 

waste. See Item 2, below, for additional information about the radiological composition of the 

waste stream. 

The physical composition of the waste stream is well 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 cloth, towels, rags, vacuum bags, cardboard, and 

wooden items such as rulers, file handles, and paint brushes. It also contains plastics like nylon, 

as well as rubber and glass and may also contain metal 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 and RTR data indicate that none of the 

containers include anywhere near the 50% value. Based on this information and as detailed in 

Item 3, below, the physical composition of the waste 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 Stream IN-ID-NRF-153 is a T2 change. 

(2) The radiological characteristics of the waste stream 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 material) 

3. Type III – Uranium-235 (235U) + Thorium (Th) Fuels 

4. Type IV – Blanket Fuels 

5. Type V – 233U + Th Fuels 

INL-CCP provided sufficient radiological information in references and the AKSR to develop 

scaling factors (see Section 5.2 below). INL-CCP based the radiological characterization of the 

waste stream on document EDF-8775, which is a NOFORN reference that included the 

properties of SPC waste from NRF. This document associates 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 IN-ID-NRF-153. 

INL-CCP took the radiological information by SPC/fuel 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. Since the radiological contamination on the 

combustible waste was generated upon cleaning up the associated SPC, the radiological 
10

composition of the SPC is common to the combustible waste, with the exception of cesium-137 

(

137Cs), as discussed in Section 5.2. INL-CCP used the waste type distributions obtained through 

averaging the values in Reference U109 (Table 6, Radiological 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 activities/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, Waste Stream IN-ID-NRF-153 Radiological 

Characterization, in the AKSR, Revision 2. 

The radiological characterization is based on EDF-8775 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 request of INL-CCP, NRF personnel provided a 

memorandum that stated the origin of the radionuclide values. 

These data indicate that the radiological composition of Waste Stream IN-ID-NRF-153 is 

generally well understood, based on AK data. Notification 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 scaling factors or a different radiological 

characterization approach is a T1 change. 

(3) Physical characteristics of the waste stream were examined, including the presence of 

prohibited items (liquids), and found to be adequately addressed. 

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

INL-CCP examined the waste container records for each Rabe bottle, as well as the Quick Scan 

results for each waste drum, to determine the physical composition of the waste. Based on the 

evaluation of the materials and NRF waste management practices, INL-CCP concluded that the 

waste stream is composed of more than 80% organic debris, and is represented by Waste Matrix 

Code S5300, Organic Debris. The AKSR states that the 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 performed 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 materials. Examination of the associated BDRs 

confirmed that the physical composition of the drums 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 following 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 reprocessing of [SNF], including liquid waste produced 

directly in reprocessing and any solid material derived from such liquid waste that contains 

fission products in sufficient concentrations, and other highly radioactive material that the 

commission, consistent with existing law, determines 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 radioactive material from sectioning of these fuels, 

and does not include partial or intact spent fuel elements. INL-CCP stated that the only activities 

performed in the Alpha Cell were destructive sectioning of fuel elements. These activities did not 

involve the separation or reprocessing of constituent elements from reactor fuel. Therefore, the 

waste is not a SNF or HLW (References P005, P006, P008, P012, and P019). 

(5) Sufficiency of the Acceptable Knowledge Summary Report and implementation of the 

Acceptable Knowledge process were evaluated and found to be adequate. 

EPA found that Section 5.4.3 did not adequately represent 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 various 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 inferred shipping casks, and also included 

radiological characterization done by NRF and the Navy that was not well explained. 

Uncertainty analysis was included, but not well explained. 

INL-CCP prepared a freeze file3

 modification that better explained the origin of Tables 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 the relative uncertainty. In addition it 

indicated that the characterization assigned as a result 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 adequate. EPA expects a formal 

revision of the AKSR to be completed prior to the CCP’s 2011 1st quarter submission of T2 

changes to EPA for review and concurrence. 

 

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

Data traceability was evaluated to determine whether 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 related 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 revise documents to address EPA issues, CCP makes 

those changes and provides a copy to EPA as objective evidence for the changes made. These revisions are then 

processed by CCP’s document control process to generate an official version as the most current revision.

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 their radiological and physical contents. 
12

IDINEC0200004 NB 267 28 II 4/13/1976 

IDINEC0300004 EC 1 and 2 32, 33 II 1/5/1977, 1/25/77 

Traceability was also established for the containers from the point of Rabe bottle packaging, 

through loading into 30-gallon drums and movement to the Intermediate Level Transuranic 

Storage Facility and then to Idaho Nuclear Technology and Engineering Center (INTEC), to 

Quick or Fast Scan RTR of the containers and subsequent side-punching of containers and 

overpacking into 55 gallon drums (References P029, U004, U009, U012, and U088). Data 

evaluated showed that traceability was adequately established. 

(7) Sufficiency of Acceptable Knowledge Support Documents 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 among the various documents. For 

example, EDF-8775, which is a key AK document providing 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 objective evidence during the inspection. EPA 

expects the AKSR to be updated to include all relevant 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 of the Certification Plan and 

Confirmatory Test Plan, was evaluated, including mandatory content of the Confirmatory 

Test Plan and the use of gamma/alpha spectrometry and mass spectrometry data for 

sampled waste to support Acceptable Knowledge Qualification, 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 place 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 explaining 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 information defining the radionuclide ratios, 

physical form, and absence of prohibited items associated with this waste stream. 

Radiological components and the isotopic distribution were determined through confirmation of 

AK. INL-CCP originally intended to collect representative samples of Waste Stream 

IN-ID-NRF-153 and use these data to develop waste stream-specific scaling factors separate 

from the data provided by NRF. The sampling plan (CCP-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 found 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 of 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 Nuclear Information [UCNI]), which was then 
13

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 data and also agrees that the sampling data 

presented in CCP-AK-INL-561, Revision 1, can be used to confirm pre-existing AK information. 

The CTP also indicates that other radiological characteristics, including TRU waste 

determination and RH determination, will be established using DTC and surface measurements. 

It should be noted that the sampling and analysis test plan was provided as CCP-AK-INL-565 

and was summarized in the CTP. 

CCP-AK-INL-562, Revision 1 states that AK information regarding the physical form, absence 

of residual liquids and prohibited item identification 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 Determination is met solely through 

documented AK compiled and reported using the procedure 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 waste stream is a core argument in the 

radiological characterization approach. INL-CCP modified the CTP to state: "Although there 

were cleanup efforts on the Alpha Box between the examinations of different fuel types, the 

cleanup was not complete, and consequently significant comingling of the contamination from 

different fuel types onto the debris waste is expected. Therefore, it is expected that the 

radionuclide distributions in the contamination will not vary significantly from drum to drum." 

This modification is adequate. 

EPA evaluated the Certification Plan and CTP to determine 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, Revision 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, Revision 1 is a T2 change and EPA expects 

formal revision to be completed prior to INL-CCP’s 2011 1st 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. Notification 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 Waste Acceptable Knowledge 

Characterization Reconciliation Report. Specifically, the CRR was evaluated to determine the 

completeness and adequacy of its contents, as required in the WCPIP, and was found to be 

adequate. Notification of availability of a final and/or revised CRR is a Tier 2 change. 
14

(10) Use of a Correlation and Surrogate Summary Form was evaluated and found to be not 

applicable. 

Completion of a Correlation and Surrogate Summary Form (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 trained. 

Jim Luginbyhl is the Acceptable Knowledge Expert (AKE) 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 whether their training was up to date. The RH 

qualification cards indicated that Messrs. Vance and Luginbyhl had read the WCPIP, but there is 

no documentation to indicate whether these individuals were trained to EPA requirements, or 

were they trained with respect to radiological characterization aspects, both of which are required 

in the WCPIP. Mr. Vance is not an AKE, but he assembles and uses AK information as part of 

the radiological characterization program. Since the 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 who 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 Resolution Forms were examined and found 

to be adequate. 

Only one DR Form was presented, and it addressed the assignment of hazardous waste numbers 

to a previously identified non-hazardous waste stream. EPA expects additional DRs will be 

generated as the characterization and documentation process progresses, particularly in the areas 

of AK-AK radiological discrepancy analysis. Notification of the availability of additional DRs 

pertinent to this waste stream and all other RH waste streams is a T2 change. 

Example NCRs were provided. NCR-RH-INL-0001-10 addressed measurement data indicating 

that 12 drums were non-TRU following implementation of DTC. These 12 drums are: 

IDINEC200004, IDINEC200007, IDINEC300007, IDINEC100010, IDINEC100003, 

IDINEC100010, IDINEC300005, IDINEC100012, IDINEC10000l, IDINEC100002, 

IDINEC200008 and IDINEC100011. As a result, the waste stream was reduced from 27 to 16 

drums, 15 55-gallon drums and 1 30-gallon drum. This affected the determination of AK 

accuracy, which is discussed in (13), below. 

 (13) Acceptable Knowledge accuracy was assessed and 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 contact dose rates less than 200 milirem per hour 

(mRem/hr) and are not considered RH. The AK accuracy 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 disposed at the 

WIPP facility. The AKSR provides information and references 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 fuel elements were from nuclear-powered 

warships, prototype plants, irradiated test specimens, and the Shippingport Atomic Power Station 

(Reference P019). The defense status of the waste is supported by the references and information 

examined. 

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

INL-CCP representatives indicated that load management will not be performed for this waste 

stream. Implementation of load management is a T1 change. 

(16) Attainment of Data Quality Objectives through Acceptable 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 addressed as per the WCPIP: 

• Defense determination 

• TRU waste determination 

• RH waste determination 

• Activity determination (total and activity per canister, including quantification and 

identification of the 10 EPA WIPP-tracked radionuclides) 

• Residual liquids 

• Physical form, including metals and cellulose, plastic, 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 supporting 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 Concerns 
16

The EPA Inspection Team did not identify any findings relative to the addition of the containers 

from Waste Stream IN-ID-NRF-153, which were the subject 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 identified during the Baseline Inspection and 

subsequent T1 evaluations. Notification of availability of additional DRs pertinent to this waste 

stream is a T2 change. 

5.2 Radiological Characterization 

EPA examined the radiological characterization process 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 NRF 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 contains the five fuel types that were examined 

in the ECF: Advance Fuel, Standard Fuel, 235U+Th Fuel, Natural or Depleted Uranium Blanket 

Fuels, and 233U+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 the Alpha Box contamination, resulting in the 

contamination of the cleanup materials used in these 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 replacement, the sludge pans containing the fuel 

fines were placed into a total of 48 SPCs during the time period mentioned above. It was 

expected that the 137Cs would be soluble in the water used during the cutting 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 drums. Each 30-gallon drum contained either 

one 17-inch-tall Rabe bottle or two 12-inch-tall Rabe 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-NRF-153 waste drums is DTC in conjunction 

with radionuclide-specific scaling factors, a technique that EPA has observed and approved at 

several RH sites previously. The radionuclide-specific scaling factors were developed based on 

the NRF-supplied information on the estimated activity content of each SPC, as representative of 
17

the contamination deposited on the debris waste materials. The NRF radionuclide data and their 

confirmation by radiochemical analyses and mass spectrometry of samples collected resulted in a 

single set of 137Cs-based scaling factors (each having been divided by the 137Cs enhancement 

factor of 4.17) to be applied to the entire waste stream. The NRF radiological data were activity 

estimates in curies of radionuclides contained in each SPC/fuel type, obtained from the mass 

quantity of fuel in each SPC (based on the known dimensions of the fuel elements and the width 

of the cut made by the cut-off wheel) and mass-to-curie reactor physics calculations performed 

by application of ORIGEN. 

The waste sampling results were used as confirmation data to qualify the NRF radiological data, 

not to determine the scaling factors, as ”only three 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 whether and to what extent the 137Cs remained 

in the fuel matrix (137Cs partitioning). An overview of the radiological characterization process 

used for the IN-ID-NRF-153 wastes is provided in Figure 1, below. 
18

* The 137Cs enhancement factor (Cs EF) represents the increase in the 137Cs levels on the debris transferred into the 

Alpha Box by the cut-off wheel cooling water. 137Cs EF is defined as (90Sr/137Cs)mix /(90Sr/137Cs)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 waste stream, IN-ID-NRF-153, was not 

directly assessed during this T1 evaluation in Denver. This aspect had been evaluated initially 

during the INL-CCP baseline inspection and more recently during the T1 evaluation of the 

OSPREY gamma system at INTEC (see EPA Docket No.A-98-49; II-A4-131). There were no 

significant changes. EPA did evaluate the characterization 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 knowledge and understanding of the personnel 

involved in the RH waste characterization program. 

Figure 1. Flow Diagram of the Characterization Process: IN-ID-NRF-153 

Use the MicroShield® computer code to model the gamma dose 

rate at one meter from the drum surface as a function of waste 

density to develop a 137Cs DTC correlation based on a 1-Ci source 

of 137Cs 

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

for 137Cs 

Execute DTC to Determine Drum’s 137Cs Activity: 

Find mean gamma dose rate at 1 m from the surface of the drum 

based on four measurements; and determine the waste density 

based on the actual weight of drum contents and fill factor

Divide the mean measured dose rate by the DTC conversion factor 

to find the 137Cs activity in Curies 

Multiply the 137Cs 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 137Cs 

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 137Cs activity, 

for all five fuel types

Validate ORIGEN results by 

comparing the model outputs to 

sample and similar modeling data
19

Documents Reviewed

The list provided in Attachment B includes all documents related to the INL-CCP RH TRU 

radiological characterization program that were examined to support this T1 evaluation. 

Technical Evaluation

(1) The EPA inspection team evaluated the correlation of the waste records for the 27 

55-gallon drums of IN-ID-NRF-153 with the 137Cs concentration. 

The information that formed the basis of the radiological characterization process, the NRF 

radiological data used in combination with sample data, 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 calculation 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 involved in the fuel examination program, had 

been determined via reactor physics calculations performed on the NRF mass estimates, using 

the ORIGEN computer code. These curie quantities were used to find the 137Cs-based scaling 

factors from the NRF radiological data. The sampling results were used to determine the 

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

While the sample-based scaling factors were not used for the characterization of the IN-ID-NRF153 debris waste, they were used to confirm and qualify the NRF radiological data. The analysis 

and comparison of the two sets of scaling factors revealed the need for applying the 137Cs 

enhancement factor to the scaling factors determined 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 scaling factors were due to the fact that the 

transfer of cut-off wheel cooling water into the Alpha Box had resulted in an increased level of 

137Cs on the debris waste. The application of the 137Cs 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 137Cs gamma dose and waste density to determine the curie amounts of 

all reportable radionuclides in each waste drum. These activities are documented in INL-RH-70, 

INL RH-71, and INL-RH-73 through INL-RH-76 and incorporate the following information: 

• Radiochemistry and mass spectrometry measurements made 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 SPCs 

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

• Qualification of NRF radiological information using the sampling results 

• Determination of the 137Cs enhancement factor 
20

• Additional calculations to confirm modeling approach selected. 

Calculation of the 137Cs activity for a container allows the further calculation of the following 

quantities for each RH container measured: 

• Activity in curies (Ci) and mass in grams (g) for each of the 10 WIPP-tracked 

radionuclides, i.e., 137Cs, 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 90Sr, 233U, 234U, and 238U 

• 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 calculations were taken from the appropriate 

sources (TRAMPAC) and were spot-checked for accuracy. 

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

source of 137Cs uniformly distributed throughout a 55-gallon waste drum for a range of waste 

densities from 0.2 g/cm3

 to 1.8 g/cm3. The results of these were then used to derive a DTC 

correlation as a function of density for 137Cs, as shown in CCP-AK-INL-561, Revision 1, 

Figure 5-1. The actual DTC calculations are performed 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 steel) 

• 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 137Cs 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 statistical metrics using the mean and 

standard deviation values for each radionuclide 

• The appropriateness of the choice of physical constants and radionuclide-specific 

attributes (specific activity, physical half-life, decay heat, neutron cross-sections, photon 

transition probabilities, etc.) and the technical correctness of the values assigned to each 

attribute 
21

• Isotopic activity values are correlated to the radionuclides whose physical half-lives are 

such that they could be responsible for the measured external dose rate, i.e., 137Cs for 

these IN-ID-NRF-153 wastes 

• Adjustment of the source distribution inside the drums for 137Cs using earlier MCNP5 

calculations, calculated as a function of bulk waste density 

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

• Appropriate decay correction according to INL-CCP procedure (CCP-TP-504, 

Revision 8) of all radionuclide values for purposes of model development. 

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

• The ORIGEN results are used to develop radionuclide-specific scaling factors that, in 

turn, after dividing by the 137Cs enhancement factor, are used to determine activity levels 

of the radionuclides of interest from 137Cs activity obtained from the measured external 

dose rates and DTC relationship 

• Activity and uncertainty values determined for the ten WIPP-Tracked radionuclides 

(

233U, 234U, 238U, 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 137Cs, and 90Sr) 

• The determination of the contribution of all radionuclides to the radiological hazard5

• Shielding and other calculations supporting the scaling factors performed using MCNP5

to derive the appropriate DTC relationships as a function of waste density for the 

appropriate geometry following repackaging (55-gallon drum) 

• Estimation of the variation in the scaling factor due to reasonable variation in the fuel 

composition, burnup, and decay period, apparently used 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-74: 

Table 5. Radionuclide-Specific Scaling Factors 

Radionuclide DTC Scaling Factor 

228Th 1.18E-04 

232U 1.15E-04 

233U 6.83E-05 

234U 1.91E-05 

235U 6.55E-07 

236U 2.09E-06 

238U 4.23E-09 

238Pu 1.47E-02 

239Pu 4.61E-05 

240Pu 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 aspects of a container’s radiological characterization. 
22

Table 5. Radionuclide-Specific Scaling Factors 

Radionuclide DTC Scaling Factor 

241Pu 1.82E-03 

242Pu 6.47E-08 

241Am 2.24E-04 

244Cm 6.78E-05 

154Eu 2.94E-03 

137Cs 1.00E+00 

90Sr 2.26E-01 

There are no issues related to the technical adequacy 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 evaluation. 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, and Table 5, above. EPA technical 

personnel verified that the DTC BDR cited above included 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), Attachment 3 

• Evidence of signatures by the ITR and a SPM 

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

• 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 radiological characterization process were 

evaluated and found to be acceptable. 

The Technical Report CCP-AK-INL-561 is the main document 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, listed 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 Jessie 
23

Klingensmith to support several CCP RH TRU evaluations. The EPA evaluation team reviewed 

these packages in conjunction with Revision 1 of CCP-AK-INL-561 in advance of the formal T1 

evaluation meeting at EPA headquarters. Several documents had been revised more recently and 

these revisions were evaluated during the meeting as 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 and 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 CCP-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 evaluation 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 revised document adequately supported the 

radiological characterization process for the NRF RH 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 documentation of technical aspects of the INLCCP radiological characterization approach for the NRF RH TRU wastes. 

(5) The technical basis and derivation of Total Measurement Uncertainty were evaluated and 

were found to be adequate. 

 

The development of Total Measurement Uncertainty (TMU) 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. These aspects are assumed to be independent, 

which allows them to be added in quadrature. The TMU determination included contributions of 

the following: 

• DTC correlation – including drum weight measurement, MicroShield®

 code, and 

modeling uncertainties 

• Measurement uncertainty – including dose rate uncertainty from 137Cs 

• Scaling factor uncertainty – including ORIGEN

• Contributions of other gamma emitters 

• Drum-to-drum variation 

A general treatment of TMU for this NRF RH TRU waste 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 uncertainties in 137Cs enhancement factor, ORIGEN 

benchmarking, variation in code input, and drum-to drum variability. There were no concerns 

regarding the technical derivation and documentation of TMU for INL-CCP Waste Stream 

IN-ID-NRF-153. 

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

The determinations that these containers met the definitions of TRU waste and RH waste were 

examined during the baseline inspection based on DTC BDR Nos. INLRHDTC09006 and 
24

INLRHDTC09007. Both the RH and TRU determination are parts of the DTC measurements 

that are performed at the INTEC Facility at INL, which was not assessed directly during this T1 

evaluation. EPA did verify that no aspects of the DTC process had changed significantly from 

what EPA had observed during the baseline inspection. 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 documented in the DTC BDR, indicated the following: 

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

radionuclides. 

• All containers were clearly RH, i.e., had an external contact dose rate greater than 200 

mRem/hr. 

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

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

Summary of Radiological Characterization

Findings or Concerns 

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

characterization. 

Tiering Changes 

Based on the results of this T1 evaluation, there are 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 request 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 procedures, 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, INLRHRTR090004 and 

INLRHRTR090005, both written and audio/visual records 

• List of Qualified Individuals (LOQI) for the time periods covered by the BDRs listed in 

previous bullet 

• CCP-TP-508, RH Standard Real-Time Radiography Inspection Procedure, Revision 5 
25

• 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 containers 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 available BDRs, as listed in Table 6. 

Table 6. RTR BDRs Reviewed 

BDR Number Container Number 

INLRHRTR090002 EC0300003; IDINEC0300006; IDINEC0300007, original and replicate 

INLRHRTR090003 IDINEC0100003, original and independent 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 Test. The number of lines-pair/cm recorded 

for each day of operations met the minimum requirements of 5 lines-pair/cm. Through review of 

the BDRs, EPA verified that data sheets were completed and signed as required. The quality 

control (QC) examinations, specifically the replicate 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 waste matrix code (WMC) as S5400 

instead of S5300. The NCR was processed in accordance with CCP procedures. 

During the examination of container IDINEC0300006 from BDR INRHRTR09002, the operator 

stopped the audio/visual recording to further investigate 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-10-001C 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 further investigate the presence/absence of 

prohibited liquid. The operator did not state specifically 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 she had done during that break in recording. 

EPA is concerned about the completeness of RTR records. 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. EPA is concerned that complete 

records of what the operator did when characterizing a container must be generated for all 

containers examined. All actions of an operator that have a technical bearing on the acceptability 

of data used to support waste characterization (waste isolation) must be available for internal 

reviewers and federal inspectors. Specifically, actions that are relevant to identification of 

physical contents and/or prohibited items (waste characterization/isolation) must be part of the 

auditable record. The RTR operators must be trained to understand that these actions must be 
26

performed in such a way that they are part of the official auditable record that documents 

container’s characterization, i.e., can serve as objective evidence to support EPA’s approval 

decision. As part of future continued compliance inspection(s) EPA would verify whether steps 

have been taken to include RTR operator’s actions relevant 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 recordings 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 INL-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 accepted. RTR characterization activities for 

these drums were performed in accordance with required procedures by trained and qualified 

operators. 

Summary of Real-Time Radiography

Findings or Concerns 

The EPA inspection team did not identify any findings related to RTR. EPA identified once 

concern related to RTR which did not require a response. 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 are no changes to the T1 and T2 designations 

that were assigned to RTR 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. 

6.0 SUMMARY OF RESULTS 

EPA concluded that the waste characterization processes 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 are acceptable. There are no open issues 

relative to this T1 evaluation. 

Findings and Concerns 

The EPA inspection team did not identify any findings 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 relative 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 shown (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, and a Tier 1 item for RTR has been modified 

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

Approval 

EPA determined that the procedures and processes used by INL-CCP for the addition of Waste 

Stream IN-ID-NRF-153, consisting of 27 30-gallon drums, 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 PROGRAM 
A-1 

Approval Summary for INL-CCP Remote-Handled Waste Characterization 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 January 2007 A-98-49; II-A4-75 

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

Tier 1 Change – Approval of K Cell Wastes January 2008 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 Technique September 2009 A-98-49; II-A4-118 

Tier 1 Change – Addition of Twelve Containers to Waste 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-S5400-RH June 2010 A-98-49; II-A4-126 

Tier 1 Change – Approval of Waste Stream ID-INTEC-S5400-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-A4-131 
ATTACHMENT B 

LISTING OF DOCUMENTS REVIEWED FOR THIS EVALUATION
B-1 

Listing of Documents Reviewed for this Evaluation

CCP-AK-INL-560 Central Characterization Project Acceptable Knowledge Summary Report for 

Idaho National Laboratory Remote-Handled Transuranic 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 Remote-Handled Transuranic Radiological 

Characterization Technical Report for Remote-Handled 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 Sampling 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, 2010 

CCP-QP-005, Revision 18, CCP TRU Nonconforming Item Reporting and Control, Attachment 

1 – CCP Nonconformance Report (NCR), NCR No. NCR-RHINL-0100-10, Revision 0, 

March 30, 2010 

CCP-TP-005, Revision 12, CCP Acceptable Knowledge Documentation, Attachment 5 – 

Hazardous Constituents, Waste Stream IN-ID-NRF-153, April 26, 2010 

CCP-TP-005, Revision 18, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Documentation Checklist, Waste Stream IN-ID-NRF-153, May 27, 2010 

CCP-TP-005, Revision 18, CCP Acceptable Knowledge Documentation, 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 Documentation, 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 Documentation, Attachment 8 – Waste 

Containers, Waste Stream IN-ID-NRF-153, February 5, 2009 
B-2 

CCP-TP-512, Revision 2, CCP Remote-Handled Waste Sampling, Attachment 6 – Site Project 

Manager Sampling Batch Data Report Checklist, BDR No. IDRH0901, July 5, 2009 

CCP-TP-512, Revision 2, CCP Remote-Handled Waste Sampling, Attachment 7 - Site Project 

Manager Radiochemistry or ICP-MS Analytical Batch Data Report Checklist, BDR No. 

ALD09002R, July 22, 2009 

CCP-TP-512, Revision 2, CCP Remote-Handled Waste Sampling, Attachment 7 - Site Project 

Manager Radiochemistry or ICP-MS Analytical Batch Data Report Checklist, BDR No. 

ALD09006I_R1, July 22, 2009 

Characterization Reconciliation Report for IN-ID-NRF-153, Draft for Audit Purposes, Provided 

June 3, 2010 

DOE WIPP 02-3214, Remote-Handled TRU Waste Characterization Program Implementation 

Plan, Revision 0D, October 30, 2003 

Freeze File Modifications to CCP-AK-INL-560, Revision 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 Stream 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 Site-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, 2010 

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 documents, for which only Attachment 3 

summaries were provided and reviewed. The list below is a subset of the provided source 

documents representing some of the more pertinent references 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 copies of the documents provided to the EPA. 
B-3 

C004, Letter to M. DiBattista from J. Raros, Re: Remote-Handled (RH) Transuranic (TRU) 

Acceptance Knowledge (AK) Collection -Request for NRF Action, J. Roros, IBO-07/084, 

September 6, 2007 

C006, Letter to G. B. Bragg from J. E. Schmucher, Re: ECF Transuranic Waste Shipments to the 

INEL Radioactive Waste Management Complex (RWMC) (UCNI), J. E. Schmucker, NRFE-TS2421, September 27, 1979 

C009, Letter to Mr. D. J. Miller from G. D. Carpenter, Re: Transuranic Curie Content of 

Enriched Uranium Fuels TWR No. 09865 pp. 93-100 (NOFORN), G. D. Carpenter, WAPDMT(IP)-552, October 12, 1978 

C010, Letter to T. H. Alff, Re: Transuranic Curie Content of Partially Enriched Uranium Fuels, 

R. L. Underwood, WAPD-MT(IP)-1069, December 18, 1979 

C011, Interview of N. Spackman and S. Lundt, Re: Flow 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 Waste 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 Content 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. Beyer, WAPD-F(NMM)-1, July 31, 1978 

C022, Letter to C. H. Price, Re: Documentation of Measurement 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: Documentation 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: Documentation of Measurement Methods for 

Accountable Nuclear Material Content of Scrap, ECF Examination Engineering, 

NRFE-EE-7559, June 15, 1978 
B-4 

C029, Interview of J. F. Ruggiero, Re: History of NRF Combustible TRU Waste, James 

Luginbyhl, January 22, 2008 

C030, Telephone Conference With ECF Examination Engineering on Combustible Transuranic 

Waste from the ECF Hot Cell Alpha Box, J. F. Ruggiero, NRFE-EE-7906T, January 21, 1982 

C113, Memo to Irene Quintana, Re: Analysis of Sample Data for RH Debris Waste Generated 

from the NRF at INL, J. Holderness, June 26, 2009 

C114, Memo to Irene Quintana, Re: Analysis of Sample Data for RH Debris Waste Generated 

from the NRF at INL, J. Vance, August 23, 2009 

DR001, Attachment 11, Acceptable Knowledge Source Document 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 (1953 to June 1990) (NOFORN), T. N. Miller, 

NRF-E(RME)-779, November 26, 2007 

P002, Diagrams of ECF Container: Trash Disposal Rabe Bottle, ECF Hot Cell Alpha Box Waste 

Canister Assembly, and a Sketch of 12 inch Rabe Bottle, D. Corrigan, 927F315/974D600, 

July 26, 1994 

P003, Expended Core Facility Maintenance and Operations 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 Reactors 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, Revision 9, March 1, 1983 

P008, Alpha Box Operations and Maintenance, NRF 1661.22, Revision 9, February 7, 1986 

P009, Integrated Waste Tracking System Historical Information on Naval Reactor Facility 

(NRF) Waste Disposal, August 20, 2002 

P011, NRF Procedure 1201.4, Section 10-Nuclear Material Measurements and Analysis (UCNI), 

NRF 1201.4, Revision 11, February 1, 1982 

P015, Management of Alpha Box Waste, NRF 1661.22, March 1, 1982 

P016, The NRF Environmental Monitoring Program, NRF 2455, December 1, 2006 
B-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 Nuclear Fuel Receipt and Handling at the 

Expended Core Facility at the Idaho National Engineering Laboratory, WAPD-OT(E)-107 

P021, Internal Technical Report Waste Characterization for INEL Remote-Handled/Special-Case 

Stored Transuranic Wastes, Dennis A. Peterson, WM-PD-85-014, November 1, 1985 

P022, Radiological Properties of Remote-Handled Transuranic Waste Inventory at the 

Radioactive Waste Management Complex, Cecilia R. Hoffman, EDF-4687, May 20, 2005 

P023, Baseline Estimate of the Volume of Remote-Handled Transuranic Waste Stored at the 

Radioactive Waste Management Complex, Cecilia R. Hoffman, EDF-4379, March 16, 2005 

P024, Characterization and Shipping Records for Remote Handled (RH) Transuranic (TRU) 

Waste Stored at the Radioactive Waste Managment Complex (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 Discrepancies, Ral Bhatt, July 18, 2007 

P029, ILTSF Drum Retrieval Completion Report, Fairfield Service Group, ICP/EXT-05-00886, 

January 2006 

U001, Attachment-Table I-Pu Curie Conversion Factors 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 Transfer Forms 11-19-78 through 3-1-79 

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

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

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

U008, Form 828, RH TRU RTR Prescreen for Repackaging/AK Worksheet for NRF Drums, 

August 14, 2007 
B-6 

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

U010, ECF Route Card -Disposition of Scrap Cannister, NB-200, J. F. Ruggiero, 20986, 

November 17, 1975 

U011, Route Card Change Form - Load & Ship Combustible 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 Record 

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

U015, General Procedures for the Expended Core Facilty Nuclear Material Balance Area 

(UCNI), NRF1202, WP/169, Revision 5, August 1, 1984

U016, Pyrophoricity and Ignitability of SPC Contents 

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

U018, Route Card Change Form-Prep Trans-U Waste Shipping Drums Change Notice No. 1, RC 

30022, March 12, 1979 

U019, Summation of Partial Activities of SPCs (NOFORN) 

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, 1976 

U028, Alpha Box Log Volume 2 (NOFORN), March 26, 1985 

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 Waste 3D-Gallon Drums, J. F. Ruggiero, 

RC 29333, December 19, 1977 
B-7 

U033, Radiological Control Survey Maps and Rabe Bottle 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) Projection, November 4, 1977 

U064, RH Waste Characterization Questionnaire 

U066, Alpha Box Combustible Waste Record Sheet, February 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, May 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 SPCs, 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 Contribution to Samples, James Holderness, 

INL-RH-75, August 24, 2009 
B-8 

U155, CCP Calc Package: Comparison of Sample Scaling Factors to NRF Scaling Factors, 

J. Vance, INL-RH-76, July 11, 2009 

U156, CCP Calc Package: Uncertainty Analysis for NRF Debris Drums, James Holderness, 

INL-RH-77, August 22, 2009 

U157, CCP Calc Package: INL NRF Cs-137 Dose-to-Curie 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 Debris, 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 internal Lead Shielding, J. Vance, INL-RH-90, 

August 28, 2009 

Spreadsheet, Draft, Summarizing Non-Classified Information Pertaining to Drum Numbers, 

Rabe/Canister Numbers, SPCs, Fuel Type (I-V), and Packaging Dates, provided August 11, 2010 

Engineering Design File EDF-8775, Revision 1, Radiological Properties of Sludge Pan 

Container Waste from Naval Reactors Facility, August 27, 2009, NOFORN 
ATTACHMENT C 

EPA EVALUATION ISSUE TRACKING FORM – 

REAL-TIME RADIOGRAPHY
C-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 IDINEC0300006, the operator went 

off line to further investigate the presence/absence 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 operator could not remember what she had done during that 

break in recording. 

EPA is concerned about the completeness of RTR records. 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 similar instance, during the Hanford-CCP baseline inspection, 

EPA inspectors observed a calculation of free liquid in a container that did not form part of the official 

record (Hanford-CCP-CH-RTR-10-001CR). While the two specific occurrences described here may not 

have affected the RTR data generated, EPA is concerned that complete records of what operator did when

characterizing a container must be generated for all containers examined. 

All actions of an operator that has a technical bearing on the acceptability of data used to support waste 

characterization (waste isolation) must be available for internal reviewers and federal inspectors. 

Specifically, actions that are relevant to identification of physical contents and/or prohibited items (waste 

characterization/isolation) must be part of the auditable 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 auditable 

record that documents container’s characterization, i.e., can serve as objective evidence to support EPA’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