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 NATIONAL 

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
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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 
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1.0 EXECUTIVE SUMMARY 

In accordance with 40 CFR 194.8(b), the U.S. Environmental Protection Agency (EPA or the 

Agency) conducted Baseline Inspection No. INL-CCP-RH-6.06-8 of the Central 

Characterization Project Waste Characterization Program at the Idaho National Laboratory 

(INL-CCP) on June 12–16, 2006, with follow-up inspections 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 the INL-CCP waste characterization 

(WC) program with conditions and limitations, as documented in the INL Baseline Final 

Inspection Report (see EPA Docket No. A-98-49; II-A4-72). This report approved the Dose-toCurie (DTC) process specific to one retrievably-stored remote-handled (RH) transuranic (TRU) 

waste stream using an RO-7 Ion Chamber with two probes: 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 Table 1 of the INL-CCP baseline inspection report 

identified the use of the high range probe as a Tier 1 change. 

The Department of Energy’s Carlsbad Field Office (DOE 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 specific 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 measurement system and probe, consistent 

with the conditions and limitations discussed in this 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 through 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 the baseline inspection must be reported to, 

and, if applicable, approved by EPA, according to the tiering requirements set forth in the INL 

Baseline Final Report cited above. 

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 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 applicable conditions and limitations, can 

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

TRU wastes destined for disposal at the WIPP. An EPA inspection team conducts an on-site 

inspection to verify that the site’s system of controls is technically adequate and properly 

implemented. 
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Following the EPA’s approval of WC processes evaluated during the baseline inspection, EPA is 

authorized to evaluate and approve, if necessary, changes to the site’s approved WC program by 

conducting additional inspections under the authority of 40 CFR 194.24(h). Under 

40 CFR 194.24, EPA has the authority to conduct continued 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 requirements. Based on the adequacies of the WC 

processes demonstrated during the baseline inspection, including all conditions and limitations, 

EPA specified which subsequent WC program changes or modifications must undergo further 

EPA inspection or approval under 40 CFR 194.24. This was accomplished by assigning a tier 

level to each aspect of the INL-CCP’s characterization 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 inspections are conducted can be found in the 

Federal Register (Vol. 69, No. 136, pages 42571–42583 of July 16, 2004). 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of the EPA’s evaluation of a T1 change to modify the 

instrumentation used in the execution of INL-CCP procedure 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 report 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 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). 

4.0 SCOPE OF REVIEW

The scope of this evaluation was the modification of the INL-CCP RH procedure CCP-TP-504, 

CCP Dose-to-Curie Survey Procedure, Revision 6, February 6, 2008, to allow the use of the high 

range probe for RH TRU Waste. The EPA baseline inspection that was the basis for approval of 

the INL-CCP RH WC program included using the RO-7 Ion Chamber with two probes, the RO7LD (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 identified 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 with 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-504 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 discontinue use of the RO-7 Ion Chamber 

measurement system altogether and replace it with the FH 40 G and FHS 612 Probe. The scope 
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of this evaluation was the assessment of the new measurement system proposed for use in 

measuring dose rates associated with containers of RH TRU in INL RH Waste Stream IDANLE-S5000 and corresponding changes to CCP Procedure CCP-TP-504, Revision 6. 

5.0 EVALUATION TEAM 

This evaluation consisted of reviewing documents provided by INL-CCP that presented the 

technical support for the modification of CCP-TP-504. Mr. Patrick Kelly conducted this review. 

The review was supplemented by two telephone conversations the Patrick Kelly had with CBFO 

and INL-CCP technical personnel to request information 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 CCP-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 use 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-scale 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 between 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 the inspection. The High Range probe 

was not observed in use, INL-CCP personnel stated that 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. 
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• The ion chamber used to measure the dose or exposure rate of containers for the DTC 

method had been calibrated, as evidenced by the calibration due dates on the ion 

chamber itself and the probes, see previous bullet. 

• Instrument calibration was performed by the Battelle Energy Alliance (BEA) Health 

Physics Instrument Laboratory (HPIL) located at INL, and this facility is on the WTS 

Qualified Suppliers List. Calibration was performed in accordance with HPIL 

Procedure CW1-240, Revision 2, which was reviewed during the inspection. INL-CCP 

personnel had a spare RO-7 Ion Chamber that had been calibrated but was not observed 

in use. 

• It was verified that the scale used to weigh the containers has been calibrated and that 

the scale has been checked daily. 

• The battery and performance checks for the instrument used to measure the dose or 

exposure rate of containers for the DTC method had been performed and documented at 

least once per day prior to the first measurement of the shift. 

• The background rate was measured and recorded. Measurement 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 container dose or exposure rate, as 

required by the WCPIP and CCP-TP-504, Revision 1. 

Based on the evaluation cited above, EPA approved the use of the RO-7 Ion Chamber with the 

low and medium range probes at INL-CCP to characterize RH TRU wastes. The RO-7BH High 

Range Probe was not in use during the baseline inspection 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 instruments were appropriate for performing 

dose-rate surveys in support of INL-CCP’s DTC procedure and the application of radionuclide 

scaling factors. Subsequent to EPA’s baseline approval of INL-CCP’s RH WC program, 

Revision 4 of procedure CCP-TP-504 removed the RO-7BH 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-504, Revision 6 

Documents Reviewed

EPA evaluated the documentation that INL-CCP had provided 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, ESM 
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• The Modular System for Radioactivity Measurements, Digital Survey Meters, Thermo 

Electron Corporation Brochure 

Description of Proposed Measurement System and Changes to CCP-TP-504

The measurement systems used for the execution of CCP-TP-504 consist of survey instruments 

that are typically used to perform gross determinations of the external exposure rate1

 of an item 

or area. They represent the most basic types of radiation detection instruments used within the 

nuclear industry and are significantly less complex than the neutron and gamma spectrometric 

nondestructive assay (NDA) systems typically used for contact-handled (CH) TRU wastes. 

Evaluation of the proposed modification of CCP-TP-504 to incorporate the FH 40G System and 

FHZ 612 Probes is relatively simple. The specifications of the proposed measurement system 

were assessed to ensure that they were appropriate for the RH TRU Waste Stream ID-ANLES5000 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 and 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 somewhat conflicting directions in that it 

requires performance of a daily source check for both low and high ranges and then allows for 

performing source checks for both low and high ranges “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 containers 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 allow the measurement of drums with dose 

rates of 8 – 9 mR/hr to meet the RH Program Implementation Plan (PIP) performance criterion 

 

1

 The terms dose rate, exposure rate and external exposure rate are technically different, but for the purposes of this 

report are used interchangeably. In this context, each refers to the measured gamma radiation field associated with a 

TRU waste container measured in roentgens per hour (R/hr). 
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of the drum’s measured dose rate exceeding the measured 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 compliance with the PIP. The use of a more 

sensitive probe to measure background and a less sensitive 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 findings relative this T1 change evaluation. 

Concerns 

The EPA Inspection Team did not identify any concerns relative to this T1 change evaluation. 

Limitations 

No radiation measurement systems other than those expressly approved by EPA can be used to 

measure assay RH TRU wastes at INL-CCP in accordance with CCP Procedure CCP-TP-504. 

The Daily Source Checks described in CCP-TP-504, Section 4.1.2, page 13, NOTE must be 

performed for both high and low ranges, in all instances, irrespective of what ranges (low or 

high) are measured for RH TRU waste containers during a given time period. Use of the 

RO-7HB High Range Gamma Probe with the RO-7 Ion Chamber 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 the Dose-to-Curie survey procedure for RH 

TRU wastes at INL-CCP. Based on the results of this 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.