DOCKET NO: A-98-49; II-A4-97 

WASTE CHARACTERIZATION REPORT 

TIER 1 CHANGE: 

EVALUATION OF THE MODIFICATION OF THE CENTRAL 

CHARACTERIZATION’S REMOTE HANDLED TRU 

WASTE CHARACTERIZATION PROGRAM AT THE IDAHO NATIONAL 

LABORATORY TO ADD CONTAINERS OF K-CELL WASTE 

TO WASTE STREAM ID-ANLE-S5000 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Federal Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

January 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 ................................................................................................................. 2 

6.0 Evaluation of the K-Cell Acceptable Knowledge............................................................... 3 

6.1 Acceptable Knowledge ........................................................................................... 3 

7.0 Summary of Results .......................................................................................................... 20 
1

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 

Acceptable Knowledge (AK) process specific to one retrievably stored remote-handled 

transuranic (RH TRU) Waste Stream identified as ID-ANLE-S5000, Lots 1 through 20. Table 1 

of that report cited the inclusion of containers of K-Cell RH TRU debris wastes as a Tier 1 (T1) 

change that required EPA approval prior to implementation. On November 5, 2007, the 

Carlsbad Field Office (CBFO) requested EPA approval of a T1 change in the form of including 

56 containers of K-Cell wastes in Waste Stream No. ID-ANLE-S5000. In response to CBFO’s 

request, EPA conducted a T1 evaluation of the inclusion of the K-Cell wastes by reviewing 

documents provided by INL-CCP, supplemented by a meeting in Denver, Colorado, on January 

8 and 10, 2008. Based on EPA’s evaluation detailed in this report, EPA approves the inclusion 

of the 56 containers of K-Cell wastes in Waste Stream No. ID-ANLE-S5000, 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 the baseline 

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

implemented. 

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 
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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 more 

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 include 56 containers 

of retrievably stored RH TRU debris K-Cell wastes in Waste Stream No. ID-ANLE-S5000, as 

described in CCP-AK-INL-500, Revision 5, Draft E. This report presents the technical basis and 

results of EPA’s approval decision. EPA’s approval decision regarding the inclusion of the KCell wastes 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 inclusion of 56 containers of retrievably stored RH TRU 

debris K-Cell wastes as described in CCP-AK-INL-500, Revision 5, Draft E. The evaluation 

was performed by comparing elements assessed in the previous EPA approval against 

information about the 56 K-Cell drums that was provided by INL-CCP/CBFO to ensure that 

these drums fit within the approval issued by EPA previously. Some elements of the previous 

report, i.e., the Los Alamos National Laboratory mass spectrometry data, were not evaluated 

again because the addition of these containers did not affect these elements. Only those elements 

that were affected by the addition of the 56 containers were re-evaluated. Because this 

evaluation involved expanding an existing stream to incorporate new containers and not the 

addition of a new Summary Category Group or waste stream, an inspection checklist was not 

used. 

5.0 EVALUATION TEAM 

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

technical and regulatory support for the inclusion of the K-Cell wastes. Ms. Connie Walker 

conducted this review with support from Mr. Patrick Kelly. The review was supplemented by a 

meeting of EPA and INL-CCP technical personnel to discuss specific technical issues. This 

meeting was held in Denver, Colorado on January 8 and 10, 2008, and the personnel involved in 

the Denver meeting are listed in Table 1, along with each person’s affiliation and function for 

this evaluation. 
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Table 1. Personnel at January 8 and 10 2008, Meeting in Denver, Colorado

Personnel Affiliation Inspection Function - Area of Expertise 

Connie Walker SC&A EPA Inspector, Technical Lead 

Kevin Peters Technical Specialists AK Expert 

Steve Schafer Technical Specialists AK Expert 

6.0 EVALUATION OF THE K-CELL ACCEPTABLE KNOWLEDGE 

6.1 Acceptable Knowledge 

EPA examined the AK process and associated information to determine whether the INL-CCP 

WC program demonstrated compliance with the requirements of 40 CFR 194.8 for the addition 

of 56 K-Cell drums of retrievably stored RH debris to ANL Waste Stream No. ID-ANLE-S5000.

Waste Characterization Element Description

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

characterization as impacted by addition of the K-cell containers: 

• Waste stream identification and definition 

• Radionuclide content of K-Cell waste 

• Physical composition of K-Cell waste 

• Sufficiency of modified AK Summary to include the K-Cell waste 

• Drum data traceability 

• Defense origin of K-Cell waste 

• AK source document sufficiency 

• Modifications to the Confirmatory Test Plan (CTP) 

• Modifications to the Waste Stream Profile Form (WSPF) and Characterization 

Reconciliation Report (CRR) 

• Correlation and Surrogate Summary Form and CH-RH correlation 

• Personnel training 

• Non Conformance Reports (NCRs) and AK Discrepancy Resolution 

• AK accuracy 

• Load management 

• Identification and attainment of Data Quality Objectives (DQOs) 

Documents, Waste Containers, and Batch Data Reports Provided

EPA evaluated the documentation that INL-CCP had prepared to support the inclusion of the 56 

containers of K-Cell wastes in Waste Stream No. ID-ANLE-S5000. EPA’s evaluation was based 

on reviewing the following references: 

• CCP-AK-INL-500, Central Characterization Project Acceptable Knowledge Summary 

Report for Remote-Handled Transuranic Debris Waste from Argonne National Laboratory-
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East Stored at the Idaho National Laboratory, Waste Stream ID-ANLE-S5000, Revision 5, 

Draft E, September, 2007 

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

Implementation Plan, Revision 0D, October 30, 2003 

• C074, Letter to Mr. Hilary Rauch, Manager, U.S. Department of Energy re: "TREAT 

Experiment Program", R. Avery, Director, Reactor Analysis and Safety Division, 2694, April 

4, 1985 

• C138, Intra-Laboratory Memo to Distribution re: Hot-cell Survey, L. A. Neimark, MSD, 

ANL-26 (11-68), August 20, 1973 

• C353, Discussions with Seth Snyder and Al Young; Chemistry Division Operations in 

Building 200, M-Wing and General Description of Building 200, Tom Krause, CH Ref. AEC-015, NA, July 27, 2000 

• C358, Letter to R.H. Bauer; Activation of K2 Hot Cell for RRT Safety Program Work, J.D. 

Griffin, December 4, 1977 

• C364, Intra-Laboratory Memo to C.H. Youngquist; Priority List for Work in M-Wing Cave 

Facility for Month of October 1978, L. Neimark, October 12, 1978 

• C373, Intra-Laboratory Memo to L.A. Niemark; Cave K-2 Source Document Reference 

Information (author(s), document and revision number, date, publisher): J.R. McCreary, 

October 15, 1981 

• C378, Intra-Laboratory Memo to R.G. Matlock; Cost Estimate for ANL-E Support for 

SAREF, Source Document Reference Information (author(s), document and revision number, 

date, publisher): L.A. Neimark, October 14, 1975 

• C381, Results of Document Review Relating to the AK Available for RH TRU Waste 

Containers Generated in the Building 200 K-Cells at ANL-E, Kevin Peters, October 10, 2007 

• DR018, ID-ANLE-S5000, Discrepancy Resolution Waste Stream Description Heterogeneous 

Debris from AGHCF Operations, Kevin Peters, October 23, 2007 

• P006, Safety Analysis for Twenty Year Retrievable Storage of Intermediate Gamma Level 

Transuranic Waste, W. D. Jackson, Alpha-Gamma Hot Cell Facility, Materials Science 

Division, Argonne National Laboratory, June 1, 1976 

• P032, Procedure for Sorting Remote-Handled TRU Waste (30-Gallon Intermediate-Level 

Waste), Alpha-Gamma-Hot Cell Facility Irradiation Performance Section Materials and 

Components Technology Division, January 7, 1987 

• P055, Waste Handling Procedures, C. L. Cheever, Manager, Waste Management Operations, 

September 18, 1986 

• P074, Plan for Decommissioning TREAT Loop Disassembly Facility (K-2 Cell, Building 

200, M-Wing), W. D. Jackson, Irradiation Performance Group, M4000-0019-SA-00, June 12, 

1981 

• P614, Identification of Additional Fuel Elements/Materials Examined in the Alpha-Gamma 

Hot Cell Facility for ANL-E RH TRU Waste, Kerry Martin, EDF-6946, May 19, 2006 
5

• P615, Information on Fuel Elements Examined at the AGHCF at ANL from November 1971 

to August 7, 1995 Based on Waste Consolidation Records, P. Kuan, EDF-6685, May 19, 

2006 

• P616, Decontamination of Hot Cells K-1, K-3, M-1, M-3, and A-1, M-Wing, Building 200: 

Project Final Report Argonne National Laboratory-East, C.L. Cheever and R.W. Rose, 

ANL/D&D/TM-96/2, September, 1996 

• P617, Criticality Hazards Control Statement for Special Facility MF200-KW, W.D. Jackson, 

DOC-10146, NA, October 11, 1978

• P618, Quality Assurance Plan for RAS Loop Disassembly Facility, 0-200, M-Wing, K-1 Cell 

Source Document Reference Information (author(s), document and revision number, date, 

publisher): L.A. Neimark, M3101-0025-SE-00, January 16, 1974 

• P620, Posttest Examination Plan for the L6 Experiment, W.F. Murphy, M4000-0012-SA-00, 

Revision 0, January 5, 1981 

• P621, Posttest Examination Plan for the L7 Experiment, L.A. Neimark, M3203-008-SA-00, 

Revision 0, February 19,1979 

• P624, Quarterly Progress Report for the Period Ending June 30, 1975; Transient Fuel 

Response and Fission-Product Release Program, L.R. Kelman, July 24, 1975 

• U002, Draft Proposal For: Alpha-Gamma Hot Cell Facility Waste Management Plan, 

undated 

• U042, RH-TRU 1976 to 1982, Book 1, data pages for Lots 2, 3, 5a, 5b, and 7C that include 

all K-Cell wastes, undated 

• U339, General Description of Building 200 Provided by Al Young, Unknown, CH Ref. AEU-5, August 14, 2000 

• U839, Excerpted Pages from Various Documents Collected From the ANL-E Scanner 

Database Pertaining to Fuel Pin Information, undated 

• Schafer, Steve CCP AKE, 2007, Memorandum to Larry Porter, CCP SPM, Re: Addition of 

56 Containers to Waste Stream ID-ANLE-S5000 CCP-AK-INL-500, R.5, November 1, 2007 

and November 14, 2007 

• Attachment 4: Argonne Generated RH TRU Waste, Waste Stream Number: ID-ANLES5000, Waste Stream Description; provided by ANL January 10, 2007 

Waste Container and Batch Data Reports Reviewed

Typically, batch data reports (BDRs) containing the results of radiological and radiographic 

analysis (i.e., Real-Time Radiography or RTR) are reviewed as part of EPA’s traceability 

examination. An analysis of K-Cell containers had not been performed prior to the 2007 EPA 

baseline inspection, so traceability was evaluated by examining AK data for selected containers. 

This evaluation provided an understanding of the information available for the selected drums 

beginning with their initial packaging, through shipment and interim storage at INL, and their 

ultimate retrieval from the INL vaults. The results of this analysis are presented in Table 2, 
6

below. Note that the lot number listed for each drum corresponds to the original AGHCF lot 

evaluated by EPA during the 2007 baseline inspection. 

Table 2. Traceability Data Reviewed

Drum 

Number 

AGHCF 

Lot Number Container Data Other 

00355 Lot 3 

Intermediate Gamma Level TRU Packaging; Sectioned 

Elements Gram Pu/U worksheet; Loss/Gain SS 

Materials Sheet 

Location of Waste Material in Vault at INL including 

storage date (post shipment); Radioactive Waste Form 

(INL Transfer Form); Section 1.7 from unknown 

document, citing abnormal events and addressing Vault 

19A including retrieval date 

Drum originated from D&D of 

Cell K-1; Drum was Stored in 

INL Vault 19A where it was 

apparently nearly inundated 

(3/4 of drum was covered) with 

water at one time. 

00504 Lot 5B 

- Intermediate Gamma Level TRU Packaging 

- Sectioned Elements Gram Pu/U worksheet (loss gain

request) 

- Loss Gain SS Materials Sheet 

- Radioactive Waste form (INL) 

- Transuranic Waste Container Form (INL) including 

shipment to INL date of 1982 

- INL in Vault Storage Depth Waste Classification 

- Argonne Log of Intermediate Gamma Level 

Transuranic Waste and Bin No 

- Table 2 INL storage/retrieval information 

Drum Originated from D&D of 

K-2 Cell 

00507 Lot 5B 

- Intermediate Gamma Level TRU Packaging 

- Sectioned Elements Gram Pu/U worksheet (loss gain

request) 

- Loss Gain SS Materials Sheet 

- Radioactive Waste Form (INL) 

- Transuranic Waste Container Form (INL) including 

shipment to INL date of 1982 

- INL in Vault Storage Depth Waste Classification 

- Argonne Log of Intermediate Gamma Level 

Transuranic Waste and Bin Number 

- Table 2 INL storage/retrieval information 

Drum Originated from D&D of 

K-1 Cell 
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AK was used to characterize Waste Stream ID-ANLE-S5000 with respect to most of the DQOs 

and “confirmatory testing” was performed to confirm the AK information. All containers in this 

waste stream, including the 56 K-Cell drums, will be characterized using the same process that 

was approved by EPA in January 2007. Specifically, RH containers will not be subjected to AK 

confirmation using nondestructive assay. Instead, confirmation of the AK-reported radiological 

contents of the RH debris waste containers, TRU waste designation, and activity-related DQOs is 

performed through the application of the Dose-To-Curie (DTC) technique in conjunction with 

radionuclide scaling factors that were derived through modeling. Note that the scaling factors 

were not modified by inclusion of K-Cell drums, indicating that the composition of fuel pins 

tested in the K-1 and K-2 cells were within the compositional ranges of those used to derive the 

scaling factors. This evaluation assessed the AK process and related activities necessary for 

determining the waste’s physical and radionuclide composition. The development and 

application of modeling parameters and radionuclide scaling factors were addressed in EPA’s 

baseline approval report cited earlier, and these remain unchanged. 

Technical Evaluation

Modification of the waste stream to include 56 drums from the K-1 and K-2 cells was assessed to 

determine the following: how these data had been integrated; impacts of the information on the 

waste stream; changes to the radiological and physical characteristics of the waste; and other 

elements that could affect pertinent characteristics of Waste Stream ID-ANLE-S5000. Results of 

the analysis are presented below. When information presented in the text is supported directly 

by one of the AK references, that reference is cited in parentheses. 

(1) The adequacy of the definition of Waste Stream ID-ANLE-S5000 was examined with respect 

to the addition of the K-Cell wastes. 

The Remote-Handled TRU Waste Characterization Program Implementation Plan (WCPIP) 

defines waste stream as “waste material generated from a single process or activity, or as waste 

with similar physical, chemical, and radiological properties.” Waste Stream ID-ANLE-S5000 is 

a debris waste stream generated in the Argonne National Laboratory-East (ANL-E) Alpha 

Gamma Hot Cell Facility (AGHCF) and Cells K-1 and K-2 of the M-Wing1

. EPA found that the 

original waste stream was adequately defined, but the stream did not at that time include K-Cell 

waste. Physical and radionuclide compositions of the 56 K-Cell drums were assessed to 

determine whether these drums fit within the approval of the original waste stream. 

To determine whether the wastes fit into the original AGHCF waste stream, the origin of wastes 

from the K-Cells had to be understood. INL-CCP representatives stated that the M Wing Hot 

Cell facility, including the K-Cells, was constructed in 1964. Cell K-1 was put into use in the 

early 1970s (prior to 1972) following construction of an internal containment structure that was 

elevated or isolated above the cell floor on floor pans (P618). From 1972–1978, mixed oxide 

(MOX) and other fuels underwent physical sectioning and testing in the K-1, including direct 

 

1

 The AGHFC and the M-Wing Hot Cell Facility are distinct facilities located in the 200 Area of ANL-East that 

were used for similar purposes. The M-Wing contained hot cells other than K-1 and K-2 that were used for 

purposes unrelated to the generation of TRU wastes for WIPP. The K-Cells wastes discussed in this report include 

materials generated in both K-1 and K-2. 
8

electrical heating. Waste material generated during testing remained in the cell (data suggest that 

some may have been placed in cans). In 1978, decontamination and decommissioning (D&D) of 

K-1 began, and drummed wastes were generated from 1978–1981. Use of K-2 began in 1978 

with the construction of a similar internal containment structure that was elevated three feet 

above the cell floor (P617) in which fuels were tested. Testing occurred from 1978–1981 and 

D&D of K-2 was initiated in 1981. INL-CCP representatives stated that available data show the 

K-Cells were unused until the containment structures were installed, because no decontamination 

or other records were found that documented earlier use of the K-Cells (C358, C364, C373, and 

C378). The K-2 Cell was used for other activities following D&D of the containment structure, 

but these later wastes are not included in the waste stream. Therefore, K-1 and K-2 Cells were 

active during the time that the AGHCF was used. 

To further ensure that the K-Cell wastes are part of the original AGHCF waste stream, several 

references were examined to understand the K-Cell processes and procedures in place at the time 

of cell operations. Data examined (e.g., P032) indicate that the same procedures (i.e., testing) 

were implemented in the K and AGHCF Cells, and INL-CCP representatives stated that the fuel 

pins managed in K-Cells are directly traceable to the same fuel pins/AG Nos. in the AGHCF 

Cells, as evidenced in Reference C381. Available data indicate that the cells were in operation 

from 1972–1978, with D&D occurring up to 1981, and none of the 56 drums were generated 

outside of this time period. INL-CCP representatives stated their research did not show any fuel 

pins or material had been managed or tested in K-Cells during generation of the 56 K-Cell 

drums, other than those already identified in the AGHCF. Therefore, data indicate that common 

processes were implemented for testing and waste generation/management in the AGHCF and all 

cells within the M-Wing, and only AGHCF processes and materials were managed in K-Cells, 

according to INL-CCP representatives. 

With regard to radionuclide composition of the K-Cell containers, INL-CCP representatives 

indicated that fuel pins accepted at the AGHCF were sometimes moved to the K-Cells for 

additional sectioning and testing prior to shipment back to the AGHCF for further analysis 

and/or testing. The K-Cells sometimes accepted fuel pins first for testing or sectioning prior to 

shipment to the AGHCF. Regardless, all fuel pins within the “system” of the AGHCF/M-Wing 

operated in a closed loop in that all fuel pins tested in the K-Cells either originated or were sent 

back to the AGHCF following initial work. This guarantees that the K-Cell fuel pin population 

is actually a subset of the total fuel pins managed or tested in the AGHCF. Accordingly, the 

radionuclide composition of waste within the drums of K-Cell wastes is a subset of the waste 

stream’s overall radionuclide composition. See Item (2), below, for additional examination of 

data pertaining to radionuclide content of K-Cell wastes. 

During the original baseline inspection, EPA examined the AK-identified radionuclide (i.e., Pu 

and 235U) ratios found in the AK records with EDF-6685 to assess whether the general Pu/235U 

ratios indicated a single waste stream, rather than multiple waste streams, was present. EPA’s 

baseline evaluation showed that the Pu/U ratio for Lots 0–20 (noting that there are 5 additional 

sublots, for a total of 25 lots) varied by two orders of magnitude, i.e., 0.60 to 1.38. Of the 25 lots 

originally examined by EPA during the baseline inspection, 21 lots had Pu/235U ratios between 

0.4 and 0.85, three lots had values above 1 (Lots 2, 10, and 16) and one lot had a value below 0.1 

(Lot 11). The K-Cell wastes are included in Lots 2, 3, 5A, 5B, and 7C, which were part of 
9

EPA’s original analysis. Therefore, K-Cell wastes fell within the general radiological envelope 

assessed by EPA with respect to overall Pu/235U ratios. The purpose of this analysis was to 

assess the common elements of the radionuclide content among specific wastes based on 

available data, and it was not intended to serve as a measure of the expected waste radionuclide 

content. 

The waste stream definition includes a demonstration that wastes within the stream exhibit 

similar physical characteristics. As with the AGHCF wastes, K-Cell wastes were segregated into 

combustible and non-combustible drums according to the procedures that were in place at the 

time of waste generation (P006, P042). INL-CCP representatives indicated that the physical data 

for these early wastes from both the K-Cells and the AGHCF were limited, so physical waste 

composition was assessed using later (post-1990) AGHCF data. EPA evaluated this process and 

found it to be acceptable for the AGHCF waste stream approved in January 2007. INL-CCP 

representatives examined K-Cell data and found that this information was directly comparable to 

data generated by the AGHCF during the same time period. Inclusion of the K-Cell information 

resulted in a slight modification of the overall combustible/non-combustible ratio, as identified 

by similarly aged AGHCF waste (i.e., 25% and 75% combustible/non combustible vs. 28% and 

72% combustible/non-combustible for the AGHCF and K-Cell wastes, respectively). The KCell wastes in fact more closely mirror the 21%-79% ratios obtained from physical data for post1990 drums, so the physical waste composition that was identified through available records 

indicates that the K-Cell waste corresponded to the general combustible/non-combustible waste 

breakdowns identified for AGHCF waste. 

Of the 56 K-Cell containers, 6 underwent fast/quick scanning (“prescan”) analysis to assess drum 

composition. These scans identified a discrepancy with respect to physical composition 

including the presence of fiberfill packaging, as identified in the AK record and recalled by the 

ANL-E personnel who packaged the waste (DR018). The discrepancy does not change the 

overall composition of the stream and therefore does not affect the waste stream determination. 

Item (12), below, discusses this discrepancy in more detail. 

EPA noted that there are an additional 12 drums that were originally included in the K-Cell 

population but were removed from the grouping due to the lack of AK data at the time of this 

assessment. As discussed in Item (12), below, the physical composition of these drums assessed 

during fast/quick scan did not correspond to the anticipated composition of the waste stream 

(DR018). INL-CCP excluded the 12 drums from the stream at this time. Therefore, EPA’s 

approval only addresses the 56 containers included in the revised waste stream. 

Based on the above analysis, the 56 K-Cell drums fit into Waste Stream ID-ANLE-S5000, 

because these drums originated from the same general process and the radionuclide and physical 

composition of the K-Cell wastes determined previously. Note that K-Cell wastes were 

generated during cell D&D, while AGHCF wastes created during the same time were generated 

“in process.” Therefore, while the actual waste generation processes differ, the original input to 

the waste containers (i.e., waste generated from sectioning and/or testing of fuel pins) is the 

same, only the time of waste packaging differed.
10

(2) Radionuclide characteristics of the K-Cell waste were assessed with respect to their similarity 

to Waste Stream ID-ANLE-5000. 

Examination of data show that the K-Cell drums were grouped with AGHCF drums and were 

assessed in common batch or Lot Numbers 2, 3, 5a, 5b, and 7c. Because the K-Cell drums were 

already identified within previously assessed AGHCF batches that EPA has evaluated, reanalysis of these batches with respect to overall radionuclide content was not required. 

Reference C381 summarizes information pertaining to the fuel pins tested in the K-1 and K-2 

Cells. This reference indicates that the following AGHCF Numbers (AG Numbers) are 

associated with K-Cell wastes: 93B, 116, 125, 143J, 155A, 155B, 155C, 165R, 165P, 165L, 

165N, 171A, 171B and 171C, 171D, 171E, 178, 188, 202, and 226. Comparing this listing with 

References P614 and P615 indicates that almost all AG Numbers were identified in either the 

original or supplemental listing, both of which were used in the derivation of radionuclide 

scaling factors. AG Numbers 165 L, N, P, and R were not specifically identified, but AG 

Numbers 165A, B, and C were included. When queried about this, INL-CCP representatives 

indicated that all data showed that AG Numbers 165 L, N, P, and R were associated with the 

same uranium oxide fuels as found in AG Numbers 165 A, B, and C. Therefore, modification of 

the scaling factors is not required by inclusion of the 56 K-Cell drums. The fuel types identified 

in Reference C381 are: Mixed Oxide (MOX), Boiling Water Reactor (BWR), Pressurized Water 

Reactor (PWR), Light Water Reactor (LWR), EPRI/Exxon Uranium Oxide, Sodium Loop Safety 

Facility (SLSF), and Enriched Uranium/Natural Uranium Oxide, (EU/NU Oxide).

EPA noted that the K-Cell wastes were created during in-cell activities that took place from 

approximately 1972 through 1978 for K-1 Cell, and 1978 through 1981 for K-2 Cell. Wastes 

were packaged during D&D of the internal containment cells, and were assigned the same 

overall radionuclide composition as AGHCF process wastes that were generated at the same 

time. However, this activity was not an accurate way to represent K-1 Cell waste content, 

because the radionuclide composition of K-1 Cell wastes reflects fuel pins tested in the facilities 

from 1972 through 1978 and does not reflect the radionuclide composition of fuel pins tested in 

the AG facilities from 1979 through 1981. Based on this information, the AK Record is not 

necessarily the best representation of the K-1 Cell waste radionuclide composition. This 

assessment supports the use of radionuclide scaling factors to characterize these drums, since the 

scaling factors included the spectrum of fuel pins that were tested. This process is best suited to 

determine the radionuclide characteristics of the waste stream as a whole rather than to each 

drum within the waste stream. 

Based on this information, the radionuclide composition of K-Cell wastes is bounded by the 

composition as presented in the AK summary for Waste Stream ID-ANLE-S5000. EPA notes 

that slight revisions to weight percentages and other values in Table 6 of the AK summary are 

necessary to incorporate the additional 56 containers, and these changes are not significant. 
11

(3) Physical characteristics of the K-Cell waste were assessed with respect to the physical 

characteristics of Waste Stream ID-ANLE-5000. 

See Items (1), above, and (4), below, for a discussion of physical waste composition and the 

identification of issues pertaining to AK. INL-CCP representatives indicated that, based on RTR 

of AGHCF drums and the knowledge that similar processes were applied to the AGHCF and KCells, it is possible that the K-Cell waste will contain water and/or compressed gases. If these 

items are identified during RTR, an NCR will be issued for the container and it will not be 

shipped to WIPP until the NCR is closed in accordance with the INL-CCP process.

(4) Sufficiency of the AK summary and implementation of AK as required in Attachment A of 

the WCPIP were evaluated. 

Attachment A of the WCPIP specifies that the following elements be a part of every AK 

summary: 

• Executive summary 

• Waste stream identification summary 

• AK data and information description 

• Program information 

• Waste stream information 

• Qualification of AK information 

• Container-specific information 

EPA examined the AK Summary and discussed technical content with INL-CCP representatives. 

As a result of this exchange, INL-CCP agreed to several “freeze file” changes to 

CCP-AK-INL-500 Revision 5, Draft E. The sections of the text that will be revised are shown 

below: 

1. Replace the last paragraph on page 11 (Section 2.0) with the following: 

The 200 Area building containing the M-Wing Hot Cell Facility was built in 1951. In 1962, 

the M-Wing was added to the building to support isotopes separation and research on heavy 

radioactive isotopes. The M-Wing Hot Cell Facility was added in 1964 to support analyticalchemical research on irradiated alpha-emitting materials. These cells were not designed to 

support the destructive examination associated with the disassembly and sectioning of 

irradiated fuel elements being conducted in the AGHCF. Based on the review of the AK 

record, a containment enclosure was incorporated into the K-1 Cell as early as 1972 to 

support direct electrical heating experiments of breeder reactor mixed oxide fuel samples. 

From 1973 to 1974, plans were implemented to further expand the AGHCF destructive 

examination capabilities by expanding the containment in the K-1 Cell and constructing 

another inert gas alpha-containment enclosure within the K-2 Cell in anticipation of a major 

increase in demand for destructive examination capabilities associated with the fast breeder 

reactor and light water reactor fuels. The K-1 Cell operated from 1972 to 1978 and 

supported direct electrical heating experiments on light water reactor and breeder reactor fuel 

pin samples. The K-2 Cell operated from1978 to 1981 in support of the AGHCF fuel 
12

disassembly and macroexamination operations. The K-1 and K-2 Cell waste included in 

waste stream ID-ANLE-S5000 was generated both during the cell operations and cell 

decontamination, with the later taking place during the 1978 to 1981 time frame. 

2. Make changes to the following discussion in Section 3.0 (pages 15 and 16) so that it reads as 

follows: 

In addition to the 549 containers of RH waste generated by the AHGCF facility at ANL-E 

originally included in Waste Stream ID-ANLE-S5000, INL manages an additional 56 

30-gallon drums generated in containment boxes in the K-Cells of the M-Wing Hot Cell 

Facility. In an effort to collect sufficient AK to demonstrate that these containers should be 

included in waste stream ID-ANLE-S5000, information from the following sources were 

collected and reviewed (Reference C381): 

• CCP AK records collected for the characterization of Contact Handled (CH) TRU waste 

generated at ANL-E were reviewed and 15 documents contained relevant information 

relating to M-Wing Hot Cell Facility operations; 

• CCP AK records collected during the preparation of AK Summary Report for the 

AGHCF debris. These documents included information relating to operations in M-Wing 

Hot Cell Facility supporting operations in the AGHCF; 

• A record search was performed at ANL-E for the documents that were scanned into their 

database for information relating to K-1 and K-2 operations. Numerous documents were 

obtained that contained relevant information relating to these operations; 

• Interviews with generators of the waste containers from the K-1 and K-2 Cells 

(References C380, C381, and DR018); and 

• Review of quick scan RTR examinations performed on a selected number of these 

containers (Reference U343). 

3. Make changes to the last paragraph of Section 4.2.1 (pg. 28) so that it reads as follows: 

Based on a review of the AK, it has been determined that K-Cell debris should be included in 

Waste Stream ID-ANLE-S5000 meeting the WCPIP and the WIPP WAP waste stream 

definition of waste material generated from a single process or from an activity which is 

similar in material, physical form, and radiological constituents. The K-Cells debris waste 

containers are “similar” physically and chemically, since these operations were an extension 

of the AGHCF operations conducting the same destructive operations utilizing AGHCF 

procedures. In addition, the K-Cell wastes are bounded radiologically by the waste generated 

in the AGHCF. The operations in these areas worked together to receive, process, and 

examine the same irradiated breeder reactor and LWR fuel materials identified and included 

in the radiological evaluations performed by ANL-E on the batches shipped to INL 

(References 1, 19, C347, C348, C380, C381, DR018, U042, and U343). 
13

4. Make changes to these paragraphs in Section 4.1.3 (pg. 20) so that they read as follows: 

The original mission for the beta-gamma cells in M-Wing Hot Cell Facility was to support 

analytical-chemical research on irradiated alpha-emitting materials. These cells were not 

designed to support the destructive examination associated with the disassembly and 

sectioning of irradiated fuel elements being conducted in the AGHCF. During the 1973–

1974 time frame, plans were implemented to formally expand the AGHCF destructive 

examination capabilities by constructing inert gas alpha-containment enclosures within the 

K-Cells in anticipation of a major increase in demand for destructive examination capabilities 

associated with the fast breeder reactor fuels to be discharged from the Hanford Fast Flux 

Test Facility (FFTF), TREAT, and EBR-II reactors (References C138, C141, C365, C366, 

C378, C380, C381, P618, P619, and U340). 

In April 1975, the containment enclosure constructed in the K-1 Cell to support the direct 

electric heating examination of mixed-oxide fuels since the early 1970s was added to the 

AGHCF Criticality Hazards Control Statement. Existing AGHCF procedures were to be 

used during operations in the cell. The K-1 Cell supported AGHCF direct electrical heating 

experiments on Light Water Reactor (LWR) fuels from the Saxton, Dresden-1, and 

H.B. Robinson reactors during the 1975–1976 time frame. Cleanup of the cell was 

conducted in late 1978, corresponding with the generation dates for containers originating 

from K-1 between August and December 1978 (References C364, C380, C381, U042, P618, 

P622, P623, and P624). 

5. Make changes to this paragraph in Section 5.4.3.1 (pg. 48) so that it reads as follows: 

Table 6, Summary of ANL-E Reported Radionuclides, presents the distribution of generatorreported radionuclides for containers in waste stream ID-ANLE-S5000. As discussed in this 

section, the radionuclides reported by ANL-E varied significantly over the time period of 

waste shipments to INL, which is reflected by the data in Table 6. The “Total Radionuclide 

Weight %” values in Table 6 are the reported gram values for each radionuclide over the 

entire waste stream divided by the total radiological mass reported by the generator in all 

containers in the waste stream. The same calculation produced the values for the “Total 

Radionuclide Curie %” using the sum of activity values for each radionuclide over the entire 

waste stream. These values have been updated to include the 56 containers of debris waste 

originating from the K-Cell activities supporting AGHCF operations (References C095, 

C348, U014, U015, U017, U018, U019, U020, U021, U022, U041, U042, and U043). 
14

6. Make changes to Table 6.0 (pg. 49) so that it reads as follows: 

Radionuclide 

No. of 

Drums 

With 

Reported 

Values 

Total 

Radionuclide 

Wt. %

Radionuclide Wt. % 

Range for 

Individual Drums 

Total 

Radionuclide 

Ci %

Radionuclide Ci% 

Range for 

Individual Drums 

WIPP Required Radionuclides 

Am-241 0 --- --- --- --- --- --- 

Pu-238 0 --- --- --- --- --- --- 

Pu-239 603 30.59% 5.67% - 56.81% 1.82% 0.01% - 99.99% 

Pu-240 120 0.85% 5.81% - 11.12% 0.18% 0.02% - 5.16% 

Pu-242 0 --- --- --- --- --- --- 

U-233 0 --- --- --- --- --- --- 

U-234 0 --- --- --- --- --- --- 

U-238 8 Trace Trace - Trace Trace Trace - Trace 

Cs-137 116 0.20% 0.02% - 11.12% 16.77% 1.39% - 96.47% 

Sr-90 28 0.06% 0.55% - 5.44% 8.02% 6.76% - 13.31% 

Additional Reported Radionuclides

Pu-241 120 0.03% 0.23% - 0.58% 3.40% 0.31% - 91.81% 

U-235 603 68.03% 40.76% - 94.33% Trace Trace - 0.06% 

Np-237 8 Trace Trace - Trace Trace Trace - Trace 

MFP 79 MFP Mass Not Reported 13.41% 21.02% - 99.97% 

Mn-54 28 Trace Trace - 0.03% 0.80% 0.63% - 2.13% 

Fe-55 28 0.01% 0.08% - 2.11% 20.35% 15.97% - 54.12% 

Co-60 28 Trace 0.01% - 0.18% 0.79% 0.62% - 2.10% 

Kr-85 18 Trace 0.02% - 0.16% 0.16% 0.63% - 0.69% 

Zr-93 28 0.10% 0.87% - 8.56% Trace Trace - Trace 

Tc-99 28 0.10% 0.92% - 9.06% Trace Trace - Trace 

Ru-106 28 Trace 0.03% - 0.27% 9.73% 8.18% - 16.17% 

Ag-110 28 Trace Trace - Trace Trace Trace - Trace 

Cd-113 28 Trace 0.01% - 0.13% 0.31% 0.26% - 0.52% 

Sn-123 28 Trace Trace - Trace Trace Trace - Trace 

Sb-125 28 Trace 0.01% - 0.05% 0.56% 0.47% - 0.93% 

Sn-126 28 Trace 0.04% - 0.37% Trace Trace - Trace 

Te-127 28 Trace Trace - Trace 0.04% 0.03% - 0.07% 

Cs-134 28 Trace Trace - Trace Trace Trace - Trace 

Ce-144 28 Trace 0.04% - 0.43% 14.71% 12.40% - 24.41% 

Pm-147 28 0.10% 0.09% - 0.85% 8.54% 7.19% - 14.19% 

Sm-151 28 0.01% 0.10% - 1.02% 0.29% 0.24% - 0.48% 

Eu-152 28 Trace Trace - Trace Trace Trace - Trace 

Eu-154 28 Trace Trace - Trace Trace Trace - Trace 

Eu-155 28 Trace Trace - 0.02% 0.09% 0.08% - 0.15% 

Note: “Trace” indicates less than 0.01 weight or activity percent. 
15

7. Make the following changes to the AK SOURCE DOCUMENTS table in Section 9.0 

(pg. 66) so that it reads as follows: 

C347 

Evaluation of Combustible versus 

Noncombustible Waste Drums in Waste Stream 

ID-ANLE-S5000 

N/A K. J. Peters 9/19/2007 

C348 

Evaluation of Generator Reported 

Radionuclides for Waste Stream ID-ANLES5000 N/A S. Schafer 9/19/2007 

8. Make the changes to the RECORD OF REVISION (pg. 2) so that it reads as follows: 

Revision 

Number 

Date 

Approved Description of Revision 

0 02/09/2006 Initial issue. 

1 04/28/2006 Revised to address Carlsbad Field Office (CBFO) Document Review 

Record (DRR) comments. 

2 06/01/2006 Revised to remove potential Official Use Only (OUO) information 

as identified by Idaho National Laboratory (INL). Also revised to 

address miscellaneous editorial and Acceptable Knowledge (AK) 

reference corrections and to address concerns identified during the 

May 9 through May 12, 2006, INL/Central Characterization Project 

(CCP) Program Evaluation. 

3 07/07/2006 Revised to address findings identified during the U.S. Environmental 

Protection Agency (EPA) Inspection EPA-INL-RH-CCP-06.06-8. 

4 11/16/2006 Revised to implement the Waste Isolation Pilot Plant Hazardous 

Waste Facility Permit requirements and associated Section 

311/Remote-Handled (RH) Permit Modification Request (PMR) 

changes. Also revised to address the resolution of CCP NCRRHINL-0007-06 to incorporate dried paint into the waste stream 

description. 

5 11/01/2007 Revised to incorporate 56 containers originating from activities 

supporting Alpha Gamma Hot Cell Facility (AGHCF) examination 

operations conducted in the K-1 and K-2 cells of the M-Wing Hot 

Cell Facility. Also revised to incorporate miscellaneous freeze file 

changes and identify the potential for prohibited items (liquids, 

unpunctured aerosol cans, and sealed containers greater than 4 liters) 

identified during Real-Time Radiography (RTR). 

6 XX/XX/2008 Revised to incorporate comments provided by EPA inspector during 

Tier 1 review of this report incorporating 56 containers of K-1 and 

K-2 cell debris waste into waste stream ID-ANLE-S5000. 
16

9. Make changes to Table 2 (pg. 37) so that it reads as follows: 

Waste Material Parameter Avg. Weight Percent Weight Percent Range 

Iron-based Metals/Alloys 30.6 0.0 – 87.5 % 

Aluminum-based Metals/Alloys 13.5 % 0.0 – 66.2 % 

Other Metals 20.4 % 0.0 – 60.0 % 

Other Inorganic Materials 13.5 % 0.0 – 53.6 % 

Cellulosics 12.0 % 0.0 – 80.1 % 

Rubber 4.5 % 0.0 – 64.5 % 

Plastic (waste materials) 5.0 % 0.0 – 57.4 % 

Organic Matrix 0.6 % 0.0 – 30.7 % 

Total Inorganic Waste Avg. 78.0 % 

Total Organic Waste Avg. 22.0 

INL-CCP personnel stated that the freeze file changes presented above will be included in 

Revision 6 of CCP-AK-INL-500 that will be provided to EPA upon completion of the internal 

CCP review and approval process. 

(5) Data traceability of K-Cell waste was examined. 

EPA typically evaluates data traceability by examining data for a given container from its 

genesis through the entire characterization process, including historic AK data pertaining to the 

waste. In the case of K-Cell waste, WC activities such as DTC or RTR had not yet been 

performed on any container. Therefore, data traceability was limited to evaluating and tracing 

the container based on AK data. INL-CCP provided three drums with traceability information: 

355 and 507 from K-1 Cell, and 504 from K-2 Cell. The information provided for review 

included: 

• Intermediate Gamma Level TRU Packaging 

• Sectioned Elements Gram Pu/U worksheet (loss gain request) 

• Loss Gain SS Materials Sheet 

• Radioactive Waste Form (INL) 

• Transuranic Waste Container Form (INL) including shipment to INL date of 1982 

• INL In Vault Storage Depth Waste Classification 

• ANL-E Log of Intermediate Gamma Level Transuranic Waste and Bin Number 

• Table 2 INL storage/retrieval information 

INL-CCP representatives stated that this information was not available for each of the 56 

containers in the waste stream, but enough of the information was found to indicate that records 

were initiated and maintained to characterize each drum and track its movement from ANL-E to 

INL. EPA performed a fuel pin traceability analysis for these wastes as part of its original 

baseline inspection to support the correlation of fuel pins and given container groupings. This 

analysis was not repeated, since new fuel pins were not identified by INL-CCP. 
17

(6) Defense Origin of K-Cell waste was assessed. 

Page 20 of the AK summary, Revision 5 states that fuels from the commercial Saxton, Dresden, 

and HB Robinson reactors were tested in K-1 Cell. Revision 4 in Item 4, above, was added to 

indicate that INL-CCP also contends that defense-related MOX fuel was managed in K-1 Cell, 

so any waste originating from that cell may contain defense-related material. 

(7) Sufficiency of AK support documents and related document tracking with respect to the 

addition of K-Cell references was evaluated. 

An AK Source Document Reference List was prepared using unique identifiers for the different 

document types, following the format typically used by INL-CCP for CH wastes. The listing 

provided is based on CCP-TP-005 Revision 18, Attachment 4, and was provided on January 10, 

2008. The listing is complete, and is easy to understand. As shown in the bulleted list at the 

beginning of this section, INL-CCP identified several references specific to K-Cell wastes. Of 

the available references, a subset was provided for the purpose of assessing how the information 

therein pertained to the K-Cell additions to the AK Summary. The reference list at the back of 

the AK Summary had been updated to include this information, and a revised “Attachment 4” 

complete reference list was also provided. Available information indicates that the evaluated 

references support the overall inclusion of K-Cell waste into the existing ID-ANLE-S5000 

stream. EPA only examines the documentation specific to the technical element in the AK 

summary that identifies a reference as relevant to be selected for examination. 

(8) Modification of the Waste Stream Profile Form and related Characterization Reconciliation 

Report (CRR) were assessed. 

INL-CCP representatives indicated that neither a revision to the WSPF nor the CRR had been 

prepared, since characterization of the K-Cell containers has not begun. As required in EPA’s 

baseline approval, revision of the WSPF and related attachments including the CRR is a Tier 2 

change, and EPA will receive notification of these changes when they are made. 

(9) Changes to the Confirmatory Test Plan were evaluated. 

Revisions to the proposed characterization process were not required by the addition of these 56 

containers of K-Cell waste. Therefore, changes to CCP-TP-502 were not necessary. Such 

changes are a Tier 2 requirement under EPA’s baseline approval, so EPA will receive 

notification of changes if or when they are made.

(10) Use of a Correlation and Surrogate Summary Form was evaluated. 

Revisions to the Correlation and Surrogate Summary Form were not made in response to 

inclusion of the K-Cell wastes. It is conceivable that some RH drums will be identified as CH 

upon application of the DTC procedure. Should this occur and the assay data for the containers 

are available and are used for characterization, EPA’s prior approval of INL-CCP describes the 

appropriate action. 
18

(11) Personnel training was evaluated. 

Training records for Kevin Peters (AKE) and Steve Schafer (AKE) were examined. Records 

were provided on January 10, 2007. Both must be trained to requirements of the WCPIP 

Attachment A which includes training to: the RH TRU WCPIP; non-conformance and 

corrective action processes; the AK procedure presented in Attachment A of the WCPIP; sitespecific training relative to the contents of the subject waste stream(s); and determination of 

radiological contents of individual drums. Messrs. Peters and Schafer demonstrated training in 

the first four areas. With respect to determination of radiological contents of each drum, EPA 

previously examined the training of Jene Vance, since he assembled and assessed the AK data 

that were used to derive the radionuclide scaling factors. Although Mr.Vance did not show 

direct training with respect to this area, his resume showed sufficient expertise to demonstrate 

proficiency. 

(12) Non Conformance Reports (NCRs) and Discrepancy Resolution (DR) Forms were 

examined. 

NCRs were not available for the K-Cell wastes. DR018 pertained to discrepancies in K-Cell 

waste physical waste form, and this was provided. Portions of this DR are applicable to the 56 

drum K-Cell population, and they are summarized as follows: 

Mr. William Kettman was responsible for K-Cell waste packaging and shipment during 

the waste generation time period. Mr. Kettman was interviewed to ascertain a 

description of the waste in K-Cell containers, which is provided in reference C380. This 

reference indicates, in part, that the waste was packaged into “SAW” (fiber pac) 

cardboard cans with metal bottoms closed with gasketless metal lids clamped onto the 

containers. He indicated that these were unsealed containers that were bagged out of the 

area in heat-sealed plastic pouches that were packaged in the same configuration before 

shipping to Idaho. Quick or “pre” Scan of six K-Cell containers in the 56-container 

grouping showed that the “SAW” container fiber pacs were not observed as described by 

Mr.Kettman. Instead, drums 00346 and 00354 have a large fiber pac with a slip lid 

(unsealed) inside of the rigid liner; drums 00352 and 00355 have two cardboard liners 

no lids shorter than fiber pac; and drums 00478, and 00496 do not have a cardboard 

liner or fiber pac. Mr. Kettman was interviewed again, and he confirmed that the 

packaging was consistent with the drums that he packaged. Though none of these drum 

contained the fiber pacs (in the waste cans) Mr. Ketterman described in his original 

interview, he thought that he may have been mistaken, but future drums from the fifty-six 

drum population may show this configuration. To address this, the AK Summary was 

revised to address the different packaging configurations. If fiber pacs are discovered, 

an NCR will be initiated to evaluate this packaging configuration and to determine if 

these containers meet the definition of sealed containers greater than 4 liters. 

Examination of this DR indicates that INL-CCP representatives performed a thorough evaluation 

of the information pertinent to the 56 K-Cell drums. It should be noted that a portion of the DR 

addressed issues pertaining to the 12 drums that have yet to be added to the waste stream. INLCCP representatives stated that they anticipate they will ultimately be able to link these 
19

containers to K-Cell activities, but the DR related to these drums was not included because 

EPA’s review was limited to the 56 drums included in the Tier 1 revision. 

(13) AK accuracy was assessed. 

INL-CCP revises its AK Accuracy Report annually. The last AK Accuracy Report was provided 

to EPA during the June 2006 baseline inspection that was the basis for EPA’s January 2007 

approval. INL-CCP representatives indicated that they were not aware of the preparation of a 

new AK Accuracy Report specific to Waste Stream No. ID-ANLE-S5000. EPA’s baseline 

approval did not include changes or updates to the AK Accuracy Report as a Tier 2 change. 

Therefore, INL-CCP/CBFO will not automatically notify EPA when the next AK Accuracy 

Report specific to this waste stream is available. 

(14) Load Management was evaluated. 

INL-CCP representatives indicated that load management is not intended for this Waste Stream 

No. ID-ANLE-S5000 and this will not change with inclusion of the K-Cell wastes that comprise 

this T1 evaluation. EPA’s baseline inspection report indicated that the implementation of load 

management is a Tier 1 change requiring EPA prior approval. 

(15) Continued attainment of DQOs with addition of K-Cell waste was evaluated. 

As a result of the analysis presented in items AK (1) through (14), above, EPA was able to assess 

continued attainment of each DQO. Specifically: 

- Defense determination 

- TRU waste determination 

- RH waste determination 

- Activity determination (TRU Alpha activity per canister, including quantification and 

identification of 10 WIPP-tracked radionuclides) 

- Residual liquids 

- Physical form, including metals and CPR 

All of these DQOs, except for RH waste and defense determination, are based on AK that is 

confirmed through various WCPIP-allowed techniques or variants thereof, including RTR and 

DTC. Defense determination is based on AK alone and cannot be confirmed. TRU waste 

determination was confirmed through scaling factor verification. RH status is confirmed through 

direct measurement of each container’s external radiation field, as described in CCP-TP-504, 

Revision 2. Determination of the 10 WIPP-Tracked radionuclides will be performed through 

application of scaling factors and DTC measurements, as described in CCP-TP-504, Revision 2. 

Physical form information, including the presence of liquids, will be assessed through RTR. As a 

result of information provided and EPA’s analysis of these data, EPA concludes that INL-CCP 

adequately presents how DQOs will be obtained, including the additional 56 K-Cell drums. 
20

7.0 SUMMARY OF RESULTS 

Findings 

The EPA Inspection Team did not identify any findings relative to the inclusion of the 56 

containers of K-Cell wastes to Waste Stream No. ID-ANLE-S5000 during this T1 change 

evaluation. 

Concerns 

The EPA Inspection Team did not identify any concerns relative to the inclusion of the 56 

containers of K-Cell wastes to Waste Stream No. ID-ANLE-S5000 during this T1 change 

evaluation. 

Conclusions 

During this T1 change evaluation, EPA examined the inclusion of the 56 containers of K-Cell 

retrievably stored RH TRU debris wastes in Waste Stream No. ID-ANLE-S5000. Based on the 

results of this evaluation, EPA is approving the inclusion of the 56 containers of K-Cell wastes in 

Waste Stream No. ID-ANLE-S5000 with the limitations discussed above.