DOCKET NO: A-98-49; II-A4-98

WASTE CHARACTERIZATION REPORT

TIER 1 CHANGE:

EVALUATION OF THE MODIFICATION OF THE CENTRAL

CHARACTERIZATION PROGRAM’S REMOTE-HANDLED TRU

WASTE CHARACTERIZATION PROGRAM AT THE IDAHO NATIONA L

LABORATORY TO USE A HIGH RANGE GAMMA PROBE

AND CHANGES TO THE INL-CCP DOSE-TO-CURIE PROCEDURE CCP-TP-504

U.S. Environmental Protection Agency

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

April 2008**i** TABLE OF CONTENTS

**Section Page** 

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

**................................................... ........................... 1** 

**2.0 Purpose of Inspections and Tier 1 Evaluations ..**

**................................................... .............. 1** 

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

**................................................... ............................ 2** 

**4.0 Scope of Review................................**

**................................................... ............................... 2** 

**5.0 Evaluation Team ................................**

**................................................... .............................. 3** 

**6.0 Technical Evaluation...........................**

**................................................... ............................. 3** 

**7.0 Summary of Results .............................**

**................................................... ............................ 6** **1**

1.0 EXECUTIVE SUMMARY

**In accordance with 40 CFR 194.8(b), the U.S. Enviro nmental Protection Agency (EPA or the**  **Agency) conducted Baseline Inspection No. INL-CCP-R H-6.06-8 of the Central**  **Characterization Project Waste Characterization Pro gram at the Idaho National Laboratory**  **(INL-CCP) on June 12–16, 2006, with follow-up inspe ctions on August 9 and 22, 2006. The**  **scope of this baseline inspection included several aspects of the site’s program to characterize**  **wastes proposed for disposal in the Waste Isolation Pilot Plant (WIPP). As a result of Baseline**  **Inspection No. EPA-INL-CCP-RH-6.06-8, EPA approved t he INL-CCP waste characterization**  **(WC) program with conditions and limitations, as do cumented in the INL Baseline Final**  **Inspection Report (see EPA Docket No. A-98-49; II-A4-72). This report approved** **the Dose-to Curie (DTC) process specific to one retrievably-sto**  **red remote-handled (RH) transuranic (TRU) waste stream using an RO-7 Ion Chamber with two pro**  **bes: RO-7 LD Low Range Probe No. 802038; and RO-7BM Medium Range Probe No. 801254.**  **INL-CCP personnel stated that a third probe was available, the RO-7BH High Range Probe.**  **However, the high range probe was not operational at the time of the inspection, and Tabl**  **e 1 of the INL-CCP baseline inspection report identified the use of the high range probe as a Tie**  **r 1 change.**

**The Department of Energy’s Carlsbad Field Office (D OE CBFO) requested that EPA approve**  **the use of a high range probe on January 30, 2008. In response to CBFO’s request, EPA**  **conducted a T1 evaluation of the proposed use of a high range probe during a teleconference**  **with INL-CCP and CBFO personnel on March 5, 2008. The call included a discussion of the**  **scope of the proposed change, and identified specif ic documents that were subsequently sent to** 

**EPA for review. Based on EPA’s evaluation detailed in this report, EPA approves the** 

**modifications to CCP-TP-504 and use of the new meas urement system and probe, consistent** 

**with the conditions and limitations discussed in th is report.** 

**This report serves as EPA’s public notification of the results of the proposed T1 change and its**  **evaluation. This information will be provided thro ugh the EPA website and by sending e-mails**  **to the WIPPNEWS list, in accordance with 40 CFR 194. 8(b)(3). This approval does not make**  **any changes to the tiering table provided with the baseline approval.** 

2.0 PURPOSE OF INSPECTIONS AND TIER 1 EVALUATIONS

**Any changes to the WC activities from the date of t he baseline inspection must be reported to,**  **and, if applicable, approved by EPA, according to t he tiering requirements set forth in the INL**  **Baseline Final Report cited above.**

**Under the changes to 40 CFR 194.8 promulgated in th e July 16, 2004,**  Federal Register **notice, EPA must perform a single baseline inspection of a**  **TRU waste generator site’s WC program. The purpose of a baseline inspection is to approve**  **the site’s WC program based on the demonstration that the program’s components, with a**  **pplicable conditions and limitations, can adequately characterize TRU wastes and comply with**  **the regulatory requirements imposed on TRU wastes destined for disposal at the WIPP. An E**  **PA inspection team conducts an on-site inspection to verify that the site’s system of cont**  **rols is technically adequate and properly implemented.** **2**

**Following the EPA’s approval of WC processes evalua ted during the baseline inspection, EPA is**  **authorized to evaluate and approve, if necessary, c hanges to the site’s approved WC program by**  **conducting additional inspections under the authori ty of 40 CFR 194.24(h). Under**  **40 CFR 194.24, EPA has the authority to conduct con tinued compliance inspections to verify**  **that the site continues to use only the approved WC processes to characterize the waste and**  **remains in compliance with all the regulatory requi rements. Based on the adequacies of the WC**  **processes demonstrated during the baseline inspecti on, including all conditions and limitations,**  **EPA specified which subsequent WC program changes o r modifications must undergo further**  **EPA inspection or approval under 40 CFR 194.24. Th is was accomplished by assigning a tier**  **level to each aspect of the INL-CCP’s characterizat ion program. T1 activities have stringent**  **reporting requirements and require that DOE notify EPA, and that EPA provide approval prior to**  **implementation. The rule under which baseline insp ections are conducted can be found in the**  Federal Register

**(Vol. 69, No. 136, pages 42571–42583 of July 16, 2 004).** 

3.0 PURPOSE OF THIS REPORT

**This report presents the results of the EPA’s evalu ation of a T1 change to modify the**  **instrumentation used in the execution of INL-CCP pr ocedure CCP-TP-504, Revision 6,**  **February 6, 2008. The modifications were initially identified as the use of the RO-7BM High**  **Range Gamma Probe in conjunction with the RO-7 Ion Chamber in the CBFO notification to**  **EPA provided on January 30, 2008. However, INL-CCP and CBFO personnel indicated that the**  **change included the use of a new measuring system, the FH 40 G Multipurpose Measuring**  **System and the model FHZ 612 gamma probe. This rep ort presents the technical basis and**  **results of EPA’s approval decision. EPA’s approval decision regarding the modifications to**  **CCP-TP-504 has been conveyed to DOE separately by l etter. As discussed previously, EPA will**  **also announce the decision on its website at www.ep a.gov/radiation/WIPP**  **, in accordance with 40 CFR 194.8(b)(3).** 

4.0 SCOPE OF REVIEW

**The scope of this evaluation was the modification o f the INL-CCP RH procedure CCP-TP-504,**  **CCP Dose-to-Curie Survey Procedure, Revision 6, Feb ruary 6, 2008, to allow the use of the high**  **range probe for RH TRU Waste. The EPA baseline ins pection that was the basis for approval of**  **the INL-CCP RH WC program included using the RO-7 I on Chamber with two probes, the RO**  **7LD (low range probe) and the RO-7BM (medium range probe). Use of the RO-7BH High**  **Range Probe was not evaluated and its use was ident ified as a T1 change in EPA’s baseline**  **inspection report. The scope of this T1 review was to evaluate the use of a high range probe, as**  **requested by CBFO. However, upon discussing this w ith INL-CCP and CBFO, EPA learned**  **that the change did not refer to the use of the RO- 7BH High Range Probe cited in the baseline**  **inspection report. In fact, Revision 4 of CCP-TP-5 04 on February 27, 2007, removed reference**  **to the RO-7BH Probe. The requested change amounted to revising Procedure CCP-TP-504 to**  **include the use of a different measurement system, the FH 40 G Radiameter, in conjunction with**  **the FHS 612 gamma probe. INL-CCP personnel stated that it was not their intention to use the**  **RO-7BH High Range Probe, but rather to eventually d iscontinue use of the RO-7 Ion Chamber**  **measurement system altogether and replace it with t he FH 40 G and FHS 612 Probe. The scope** **3**

**of this evaluation was the assessment of the new me asurement system proposed for use in**  **measuring dose rates associated with containers of RH TRU in INL RH Waste Stream ID**  **ANLE-S5000 and corresponding changes to CCP Procedu re CCP-TP-504, Revision 6.** 

5.0 EVALUATION TEAM

**This evaluation consisted of reviewing documents pr ovided by INL-CCP that presented the**  **technical support for the modification of CCP-TP-50 4. Mr. Patrick Kelly conducted this review.**  **The review was supplemented by two telephone conver sations the Patrick Kelly had with CBFO**  **and INL-CCP technical personnel to request informat ion and discuss specific issues. The**  **personnel involved in the discussions are listed in Table 1, along with each person’s affiliation.** 

Table 1. Personnel Involved with Tier 1 Evaluation

Personnel Affiliation Inspection Function - Area of Expertise

**Patrick Kelly SC&A EPA Inspector, Technical Lead Larry Porter INL-CCP SPM - INL RH** 

6.0 TECHNICAL EVALUATION

**EPA examined the specifications of the measurement system proposed for use in conducting**  **dose-rate surveys of INL-CCP RH TRU wastes under CC P-TP-504, Revision 6 to determine**  **whether this proposed modification was technically adequate and in compliance with the**  **requirements of 40 CFR 194.8.**

Background Information

**The technical evaluation of the DTC procedure from EPA’s baseline inspection report is**  **excerpted below:**

The EPA inspection team verified the following:

• There are three ion chamber probes available for us e with the RO-7 Ion Chamber: RO-7LD with a full-scale range of 1,999 mR/hr and a resolution of 1 mR/hr (Low Range); RO-7BM, with a full-scale range of 199,900 mR/hr and a resolution of 100 mR/hr (Medium Range); and, RO-7BH with a full-s cale range of 199,900,000 mR/hr and a resolution of 10,000 mR/hr (High Range). The calibrations are essentially probespecific, allowing the probes to be interchanged be tween ion chamber bodies.

• The Low Range Probe No. 802038 and the Medium Range Probe No. 801254 had been calibrated and were in calibration at the time of t he inspection. The High Range probe was not observed in use, INL-CCP personnel stated t hat it had been neither calibrated nor source checked. INL-CCP personnel stated that there was no intention of using this probe in the foreseeable future.**4**

• The ion chamber used to measure the dose or exposur e rate of containers for the DTC method had been calibrated, as evidenced by the cal ibration due dates on the ion chamber itself and the probes, see previous bullet.

• Instrument calibration was performed by the Battell e Energy Alliance (BEA) Health Physics Instrument Laboratory (HPIL) located at INL , and this facility is on the WTS Qualified Suppliers List. Calibration was performe d in accordance with HPIL
Procedure CW1-240, Revision 2, which was reviewed d uring the inspection. INL-CCP personnel had a spare RO-7 Ion Chamber that had bee n calibrated but was not observed

in use.

• It was verified that the scale used to weigh the co ntainers has been calibrated and that the scale has been checked daily.

• The battery and performance checks for the instrume nt used to measure the dose or exposure rate of containers for the DTC method had b een performed and documented at least once per day prior to the first measurement o f the shift.

• The background rate was measured and recorded. Mea surement personnel stated that they would take actions to reduce the background if the measured background radiation levels are greater than one-tenth of the expected c ontainer dose or exposure rate, as required by the WCPIP and CCP-TP-504, Revision 1.

**Based on the evaluation cited above, EPA approved t he use of the RO-7 Ion Chamber with the**  **low and medium range probes at INL-CCP to character ize RH TRU wastes. The RO-7BH High**  **Range Probe was not in use during the baseline insp ection and accordingly was not evaluated**  **and approved by EPA at that time. EPA’s technical evaluation of the RO-7 and associated low**  **and medium range probes concluded that these instru ments were appropriate for performing**  **dose-rate surveys in support of INL-CCP’s DTC proce dure and the application of radionuclide**  **scaling factors. Subsequent to EPA’s baseline appr oval of INL-CCP’s RH WC program,**  **Revision 4 of procedure CCP-TP-504 removed the RO-7 BH High Range Probe. This T1**  **evaluation consisted of the following:**

• **Understanding the scope of the proposed change**

• **Obtaining and reviewing CCP-TP-504, Revision 6**

• **Obtaining technical specifications for the proposed new measurement system** 

• **Determining the technical adequacy of the proposed equipment for the RH TRU**  **dose-rate determinations, as described in CCP-TP-50 4, Revision 6** 

Documents Reviewed

**EPA evaluated the documentation that INL-CCP had pr ovided to support the use of a high range**  **probe. EPA’s evaluation was based on reviewing the following:** 

• **CCP-TP-504, CCP Dose-to-Curie Survey procedure for Remote-Handled Transuranic Waste,**  **Revision 6, February 6, 2008**

• **FH 40 G/GL Advanced Survey Meter System Brochure, E SM** **5**

• **The Modular System for Radioactivity Measurements, Digital Survey Meters, Thermo**  **Electron Corporation Brochure**

Description of Proposed Measurement System and Chan ges to CCP-TP-504

**The measurement systems used for the execution of C CP-TP-504 consist of survey instruments**  **that are typically used to perform gross determinat ions of the external exposure rate**  **1 of an item**  **or area. They represent the most basic types of ra diation detection instruments used within the**  **nuclear industry and are significantly less complex than the neutron and gamma spectrometric**  **nondestructive assay (NDA) systems typically used f or contact-handled (CH) TRU wastes.**  **Evaluation of the proposed modification of CCP-TP-5 04 to incorporate the FH 40G System and**  **FHZ 612 Probes is relatively simple. The specifica tions of the proposed measurement system**  **were assessed to ensure that they were appropriate for the RH TRU Waste Stream ID-ANLE**  **S5000 that INL-CCP is currently assaying.**

**The proposed system consists of an FH 40 G display unit and an FHZ 612 Gamma Probe. The**  **FH 40 G System functions as a display unit only and does not require calibration. Each FHZ 612**  **Probe must be calibrated prior to use according to CCP-TP-504. The FHZ 612 Probe is, in fact,**  **two Geiger-Mueller (GM) probes, one for low range a nd one for high range, with a range**  **switching function that is automatically activated in a radiation field in excess of 800 mR/hr.**  **CCP-TP-504, Section 4.1.2, page 13, NOTE presents so mewhat conflicting directions in that it**  **requires performance of a daily source check for bo th low and high ranges and then allows for**  **performing source checks for both low and high rang es “if the expected dose is to span both**  **ranges.” The first requirement is more restrictive and it is our understanding that source checks**  **for both ranges would be provided in all instances, irrespective of what ranges (low or high) are**  **measured for RH TRU waste containers during a given time period. Technical specifications for**  **the FHZ 612 detector are provided below.**

Detector Attribute Specification **Measurement Range 10 mR/hr – 1000 R/hr Sensitivity 0.1 mR/hr**  **Energy Range 83 keV – 1.3 MeV**

**The technical specifications of the FH 40 G display and the FHZ 612 Probe are adequate for**  **conducting dose rate measurements of RH TRU waste c ontainers in accordance with**  **CCP-TP-504, Revision 6.**

**Additionally, Revision 6 of CCP-TP-504, Section 4.1 .2, NOTE allows the use of a low range**  **probe for the background determination and a higher range probe for the drum assay. This**  **modification was initiated apparently as a way to a llow the measurement of drums with dose**  **rates of 8 – 9 mR/hr to meet the RH Program Impleme ntation Plan (PIP) performance criterion** 

**1 The terms**  dose rate

**,** exposure rate **and** external exposure **rate are technically different, but for the purpos es of this**  **report are used interchangeably. In this context, each refers to the measured gamma radiation field a**  **ssociated with a TRU waste container measured in roentgens per hour**  **(R/hr). 6** 

**of the drum’s measured dose rate exceeding the meas ured background by a factor of ten. An**  **instrument with a sensitivity on the order of 1 mR/ hr can provide a valid measurement only for**  **drums with dose rates in excess of 10 mR/hr, in com pliance with the PIP. The use of a more**  **sensitive probe to measure background and a less se nsitive probe to measure the drum is**  **acceptable, provided that the probes used for both measurements are appropriately calibrated and**  **controlled, as specified in CCP-TP-504.**

7.0 SUMMARY OF RESULTS

Findings

**The EPA Inspection Team did not identify any findin gs relative this T1 change evaluation.** 

Concerns

**The EPA Inspection Team did not identify any concer ns relative to this T1 change evaluation.** 

Limitations

**No radiation measurement systems other than those ex pressly approved by EPA can be used to**  **measure assay RH TRU wastes at INL-CCP in accordanc e with CCP Procedure CCP-TP-504.**  **The Daily Source Checks described in CCP-TP-504, Se ction 4.1.2, page 13, NOTE must be**  **performed for both high and low ranges, in all inst ances, irrespective of what ranges (low or**  **high) are measured for RH TRU waste containers duri ng a given time period. Use of the**  **RO-7HB High Range Gamma Probe with the RO-7 Ion Cha mber is not allowed**  **for**

**measurements of RH TRU at INL-CCP.**

Conclusions

**During this T1 change evaluation, EPA examined the proposed modification of CCP-TP-504 by**  **incorporating a new measurement system to perform t he Dose-to-Curie survey procedure for RH** 

**TRU wastes at INL-CCP. Based on the results of thi s evaluation, EPA is approving the**  **modification of CCP-TP-504 presented in Revision 6 of this document, incorporating the use of**  **the FH 40 G Survey Meter System in conjunction with the FHZ 612 External Dose Rate**  **(gamma) probe, with the limitations discussed above**

**.**