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 NATIONA L
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**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 ................................**

**................................................... .............................. 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. 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 Acceptable Knowledge (AK) process specific to one r**  **etrievably 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 implemen**  **tation. 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. I D-ANLE-S5000. In response to CBFO’s**  **request, EPA conducted a T1 evaluation of the inclu sion of the K-Cell wastes by reviewing**  **documents provided by INL-CCP, supplemented by a me eting 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 Stre am 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 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 the baseline inspection to verify that the site’s system of cont**  **rols is technically adequate and properly implemented.** 

**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** **2**

**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 more**  **stringent reporting requirements and require that D OE notify EPA, and that EPA provide**  **approval prior to implementation. The rule under w hich baseline inspections are conducted can** 
**be found in the** Federal Register **(Vol. 69, No. 136, pages 42571–42583 of July 16, 20 04).** 

3.0 PURPOSE OF THIS REPORT

**This report presents the results of the EPA’s evalu ation of a T1 change to include 56 containers**  **of retrievably stored RH TRU debris K-Cell wastes i n 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 K**  **Cell 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 5 6 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 prov ided by INL-CCP/CBFO to ensure that**  **these drums fit within the approval issued by EPA p reviously. Some elements of the previous**  **report, i.e., the Los Alamos National Laboratory ma ss 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 contai ners 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 s tream, an inspection checklist was not** 
**used.**

5.0 EVALUATION TEAM

**This evaluation consisted of reviewing documents pr ovided 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 d iscuss specific technical issues. This**  **meeting was held in Denver, Colorado on January 8 a nd 10, 2008, and the personnel involved in**  **the Denver meeting are listed in Table 1, along wit h each person’s affiliation and function for** 
**this evaluation. 3** 

Table 1. Personnel at January 8 and 10 2008, Meeti ng 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 KNOW LEDGE

6.1 Acceptable Knowledge

**EPA examined the AK process and associated informat ion to determine whether the INL-CCP**  **WC program demonstrated compliance with the require ments 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 followi ng with respect to the use of AK for waste**  **characterization as impacted by addition of the K-c ell 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 (WSP F) and Characterization**  **Reconciliation Report (CRR)**

• **Correlation and Surrogate Summary Form and CH-RH co rrelation** 

• **Personnel training**

• **Non Conformance Reports (NCRs) and AK Discrepancy Res olution** 

• **AK accuracy**

• **Load management**

• **Identification and attainment of Data Quality Objec tives (DQOs)** 

Documents, Waste Containers, and Batch Data Reports Provided

**EPA evaluated the documentation that INL-CCP had pr epared to support the inclusion of the 56** 
**containers of K-Cell wastes in Waste Stream No. ID-A NLE-S5000. EPA’s evaluation was based**  **on reviewing the following references:**

• **CCP-AK-INL-500, Central Characterization Project Ac ceptable Knowledge Summary**  **Report for Remote-Handled Transuranic Debris Waste from Argonne National Laboratory-** **4**

**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 Characte rization Program**  **Implementation Plan, Revision 0D, October 30, 2003**

• **C074, Letter to Mr. Hilary Rauch, Manager, U.S. Dep artment of Energy re: "TREAT**  **Experiment Program", R. Avery, Director, Reactor An alysis 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; Ch emistry Division Operations in**  **Building 200, M-Wing and General Description of Bui lding 200, Tom Krause, CH Ref. AE**  **C-015, NA, July 27, 2000**

• **C358, Letter to R.H. Bauer; Activation of K2 Hot Ce ll for RRT Safety Program Work, J.D.**  **Griffin, December 4, 1977**

• **C364, Intra-Laboratory Memo to C.H. Youngquist; Pri ority List for Work in M-Wing Cave**  **Facility for Month of October 1978, L. Neimark, Octo ber 12, 1978** 

• **C373, Intra-Laboratory Memo to L.A. Niemark; Cave K- 2 Source Document Reference**  **Information (author(s), document and revision numbe r, date, publisher): J.R. McCreary,**  **October 15, 1981**

• **C378, Intra-Laboratory Memo to R.G. Matlock; Cost E stimate for ANL-E Support for**  **SAREF, Source Document Reference Information (autho r(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 S torage of Intermediate Gamma Level**  **Transuranic Waste, W. D. Jackson, Alpha-Gamma Hot C ell Facility, Materials Science**  **Division, Argonne National Laboratory, June 1, 1976**

• **P032, Procedure for Sorting Remote-Handled TRU Wast e (30-Gallon Intermediate-Level**  **Waste), Alpha-Gamma-Hot Cell Facility Irradiation P erformance Section Materials and**  **Components Technology Division, January 7, 1987**

• **P055, Waste Handling Procedures, C. L. Cheever, Man ager, Waste Management Operations,**  **September 18, 1986**

• **P074, Plan for Decommissioning TREAT Loop Disassemb ly Facility (K-2 Cell, Building**  **200, M-Wing), W. D. Jackson, Irradiation Performanc e Group, M4000-0019-SA-00, June 12,** 

**1981**

• **P614, Identification of Additional Fuel Elements/Ma terials Examined in the Alpha-Gamma**  **Hot Cell Facility for ANL-E RH TRU Waste, Kerry Mar tin, 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 Reco rds, 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-Eas t, C.L. Cheever and R.W. Rose,**  **ANL/D&D/TM-96/2, September, 1996**

• **P617, Criticality Hazards Control Statement for Spe cial Facility MF200-KW, W.D. Jackson,**  **DOC-10146, NA, October 11, 1978**

• **P618, Quality Assurance Plan for RAS Loop Disassemb ly Facility, 0-200, M-Wing, K-1 Cell**  **Source Document Reference Information (author(s), d ocument and revision number, date,**  **publisher): L.A. Neimark, M3101-0025-SE-00, January 16, 1974** 

• **P620, Posttest Examination Plan for the L6 Experime nt, W.F. Murphy, M4000-0012-SA-00,**  **Revision 0, January 5, 1981**

• **P621, Posttest Examination Plan for the L7 Experime nt, L.A. Neimark, M3203-008-SA-00,**  **Revision 0, February 19,1979**

• **P624, Quarterly Progress Report for the Period Endi ng 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 Faci lity Waste Management Plan,** 
**undated**

• **U042, RH-TRU 1976 to 1982, Book 1, data pages for L ots 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. AE**  **U-5, August 14, 2000**

• **U839, Excerpted Pages from Various Documents Collec ted From the ANL-E Scanner**  **Database Pertaining to Fuel Pin Information, undate d** 

• **Schafer, Steve CCP AKE, 2007, Memorandum to Larry P orter, 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-ANLE**  **S5000, Waste Stream Description; provided by ANL Ja nuary 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 r eviewed 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 in formation available for the selected drums**  **beginning with their initial packaging, through shi pment and interim storage at INL, and their** 
**ultimate retrieval from the INL vaults. The result s of this analysis are presented in Table 2,** **6**

**below. Note that the lot number listed for each dru m corresponds to the original AGHCF lot**  **evaluated by EPA during the 2007 baseline inspectio n.** 

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 includin g**  **storage date (post shipment); Radioactive Waste For m**  **(INL Transfer Form); Section 1.7 from unknown**  **document, citing abnormal events and addressing Vau lt**  **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 7** 

**AK was used to characterize Waste Stream ID-ANLE-S5 000 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 b e 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 was te designation, and activity-related DQOs is**  **performed through the application of the Dose-To-Cu rie (DTC) technique in conjunction with**  **radionuclide scaling factors that were derived thro ugh modeling. Note that the scaling factors**  **were not modified by inclusion of K-Cell drums, ind icating that the composition of fuel pins** 
**tested in the K-1 and K-2 cells were within the com positional ranges of those used to derive the**  **scaling factors. This evaluation assessed the AK p rocess and related activities necessary for**  **determining the waste’s physical and radionuclide c omposition. The development and**  **application of modeling parameters and radionuclide scaling factors were addressed in EPA’s**  **baseline approval report cited earlier, and these r emain unchanged.** 

Technical Evaluation

**Modification of the waste stream to include 56 drum s from the K-1 and K-2 cells was assessed to**  **determine the following: how these data had been i ntegrated; impacts of the information on the**  **waste stream; changes to the radiological and physi cal characteristics of the waste; and other**  **elements that could affect pertinent characteristic s 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 cite d in parentheses.** 

**(1) The adequacy of the definition of Waste Stream ID-A**  **NLE-S5000 was examined with respect**
**to the addition of the K-Cell wastes.**

**The Remote-Handled TRU Waste Characterization Progr am Implementation Plan (WCPIP)**  **defines waste stream as “waste material generated f rom a single process or activity, or as waste**  **with similar physical, chemical, and radiological p roperties.” Waste Stream ID-ANLE-S5000 is**  **a debris waste stream generated in the Argonne Nati onal Laboratory-East (ANL-E) Alpha**  **Gamma Hot Cell Facility (AGHCF) and Cells K-1 and K -2 of the M-Wing**  **1 . EPA found that the**  **original waste stream was adequately defined, but t he stream did not at that time include K-Cell**  **waste. Physical and radionuclide compositions of t he 56 K-Cell drums were assessed to**  **determine whether these drums fit within the approv al of the original waste stream.** 

**To determine whether the wastes fit into the origin al AGHCF waste stream, the origin of wastes**  **from the K-Cells had to be understood. INL-CCP rep resentatives stated that the M Wing Hot**  **Cell facility, including the K-Cells, was construct ed 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 dis**  **tinct facilities located in the 200 Area of ANL-Eas t that**  **were used for similar purposes. The M-Wing contain ed 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 rep ort include**  **materials generated in both K-1 and K-2. 8** 

**electrical heating. Waste material generated durin g testing remained in the cell (data suggest that**  **some may have been placed in cans). In 1978, decon tamination and decommissioning (D&D) of**  **K-1 began, and drummed wastes were generated from 1 978–1981. Use of K-2 began in 1978** 
**with the construction of a similar internal contain ment structure that was elevated three feet**  **above the cell floor (P617) in which fuels were tes ted. Testing occurred from 1978–1981 and**  **D&D of K-2 was initiated in 1981. INL-CCP represen tatives stated that available data show the** 
**K-Cells were unused until the containment structure s 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 wast e 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 o f the original AGHCF waste stream, several**  **references were examined to understand the K-Cell p rocesses and procedures in place at the time**  **of cell operations. Data examined (e.g., P032) ind icate 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 t he same fuel pins/AG Nos. in the AGHCF**  **Cells, as evidenced in Reference C381. Available d ata 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 representativ es stated their research did not show any fuel**  **pins or material had been managed or tested in K-Ce lls during generation of the 56 K-Cell**  **drums, other than those already identified in the A GHCF. Therefore, data indicate that common**  **processes were implemented for testing and waste ge neration/management in the AGHCF and all**  **cells within the M-Wing, and only AGHCF processes a nd materials were managed in K-Cells,**  **according to INL-CCP representatives.**

**With regard to radionuclide composition of the K-Ce ll 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 fue l pins first for testing or sectioning prior to**  **shipment to the AGHCF. Regardless, all fuel pins w ithin the “system” of the AGHCF/M-Wing**  **operated in a closed loop in that all fuel pins tes ted in the K-Cells either originated or were sent**  **back to the AGHCF following initial work. This gua rantees 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 Ite m (2), below, for additional examination of**  **data pertaining to radionuclide content of K-Cell w astes.** 

**During the original baseline inspection, EPA examin ed the AK-identified radionuclide (i.e., Pu** 
**and 235**  **U) ratios found in the AK records with EDF-6685 to assess whether the general Pu/**  **235 U**  **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 orde rs of magnitude, i.e., 0.60 to 1.38. Of the 25 lot**  **s originally examined by EPA during the baseline insp**  **ection, 21 lots had Pu/ 235**  **U 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/ 235**  **U ratios. The purpose of this analysis was to**
**assess the common elements of the radionuclide cont ent 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 demonstratio n that wastes within the stream exhibit**  **similar physical characteristics. As with the AGHC F 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 rep resentatives indicated that the physical data**  **for these early wastes from both the K-Cells and th e AGHCF were limited, so physical waste**  **composition was assessed using later (post-1990) AG HCF data. EPA evaluated this process and**  **found it to be acceptable for the AGHCF waste strea m 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 pe riod. Inclusion of the K-Cell information**  **resulted in a slight modification of the overall co mbustible/non-combustible ratio, as identified**  **by similarly aged AGHCF waste (i.e., 25% and 75% co mbustible/non combustible vs. 28% and** 
**72% combustible/non-combustible for the AGHCF and K -Cell wastes, respectively). The K**  **Cell wastes in fact more closely mirror the 21%-79% ratios obtained from physical data for post**  **1990 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 i dentified in the AK record and recalled by the**  **ANL-E personnel who packaged the waste (DR018). Th e discrepancy does not change the**  **overall composition of the stream and therefore doe s not affect the waste stream determination.**  **Item (12), below, discusses this discrepancy in mor e detail.** 

**EPA noted that there are an additional 12 drums tha t were originally included in the K-Cell**  **population but were removed from the grouping due t o 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 an ticipated composition of the waste stream**  **(DR018). INL-CCP excluded the 12 drums from the st ream at this time. Therefore, EPA’s**  **approval only**

**addresses the 56 containers included in the revise d waste stream.** 

**Based on the above analysis, the 56 K-Cell drums fi t into Waste Stream ID-ANLE-S5000,**  **because these drums originated from the same genera l process and the radionuclide and physical**  **composition of the K-Cell wastes determined previou sly. Note that K-Cell wastes were**  **generated during cell D&D, while AGHCF wastes creat ed during the same time were generated**  **“in process.” Therefore, while the actual waste ge neration processes differ, the original input to**  **the waste containers (i.e., waste generated from se ctioning 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 we**  **re 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, re**  **analysis of these batches with respect to overall r adionuclide 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 wer e 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/Exxo n Uranium Oxide, Sodium Loop Safety**  **Facility (SLSF), and Enriched Uranium/Natural Uraniu m Oxide, (EU/NU Oxide).** 

**EPA noted that the K-Cell wastes were created durin g in-cell activities that took place from**  **approximately 1972 through 1978 for K-1 Cell, and 1 978 through 1981 for K-2 Cell. Wastes**  **were packaged during D&D of the internal containmen t 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 w**  **ay to represent K-1 Cell waste content, because the radionuclide composition of K-1 Cell wa**  **stes reflects fuel pins tested in the facilities from 1972 through 1978 and does not reflect the rad**  **ionuclide 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 w aste stream as a whole rather than to each** 
**drum within the waste stream.**

**Based on this information, the radionuclide composi tion of K-Cell wastes is bounded by the**  **composition as presented in the AK summary for Wast e Stream ID-ANLE-S5000. EPA notes**  **that slight revisions to weight percentages and oth er values in Table 6 of the AK summary are**  **necessary to incorporate the additional 56 containe rs, and these changes are not significant.** **11**

**(3) Physical characteristics of the K-Cell waste were a**  **ssessed with respect to the physical**
**characteristics of Waste Stream ID-ANLE-5000.**

**See Items (1), above, and (4), below, for a discuss ion 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 proce sses were applied to the AGHCF and K**  **Cells, it is possible that the K-Cell waste will co ntain water and/or compressed gases. If these**  **items are identified during RTR, an NCR will be issu ed for the container and it will not be**  **shipped to WIPP until the NCR is closed in accordanc e 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 follow ing 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 sev eral “freeze file” changes to**  **CCP-AK-INL-500 Revision 5, Draft E. The sections o f 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 Cel l Facility was built in 1951. In 1962,**  **the M-Wing was added to the building to support iso topes separation and research on heavy**  **radioactive isotopes. The M-Wing Hot Cell Facility was added in 1964 to support analytical**  **chemical research on irradiated alpha-emitting mate rials. These cells were not designed to**  **support the destructive examination associated with the disassembly and sectioning of**  **irradiated fuel elements being conducted in the AGH CF. Based on the review of the AK**  **record, a containment enclosure was incorporated in to the K-1 Cell as early as 1972 to**  **support direct electrical heating experiments of br eeder reactor mixed oxide fuel samples.**  **From 1973 to 1974, plans were implemented to furthe r expand the AGHCF destructive**  **examination capabilities by expanding the containme nt in the K-1 Cell and constructing**  **another inert gas alpha-containment enclosure withi n the K-2 Cell in anticipation of a major**  **increase in demand for destructive examination capa bilities associated with the fast breeder**  **reactor and light water reactor fuels. The K-1 Cel l 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 198 1 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 durin g 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 gener ated 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 t he 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 o f Contact Handled (CH) TRU waste**  **generated at ANL-E were reviewed and 15 documents c ontained 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 AGHC F;** 

• **A record search was performed at ANL-E for the docu ments that were scanned into their**  **database for information relating to K-1 and K-2 op erations. Numerous documents were** 
**obtained that contained relevant information relati ng 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 th e WIPP WAP waste stream**  **definition of waste material generated from a singl e process or from an activity which is**  **similar in material, physical form, and radiologica l 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 destruc tive operations utilizing AGHCF**  **procedures. In addition, the K-Cell wastes are bou nded 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, U 042, 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-em itting materials. These cells were not**  **designed to support the destructive examination ass ociated with the disassembly and**  **sectioning of irradiated fuel elements being conduc ted 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 dema nd for destructive examination capabilities** 
**associated with the fast breeder reactor fuels to b e discharged from the Hanford Fast Flux**  **Test Facility (FFTF), TREAT, and EBR-II reactors (R eferences C138, C141, C365, C366,**  **C378, C380, C381, P618, P619, and U340).**

**In April 1975, the containment enclosure constructe d in the K-1 Cell to support the direct**  **electric heating examination of mixed-oxide fuels s ince the early 1970s was added to the**  **AGHCF Criticality Hazards Control Statement. Exist ing AGHCF procedures were to be**  **used during operations in the cell. The K-1 Cell s upported 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 fr ame. Cleanup of the cell was**  **conducted in late 1978, corresponding with the gene ration dates for containers originating**  **from K-1 between August and December 1978 (Referenc es 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, p resents the distribution of generator**  **reported radionuclides for containers in waste stre am 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 d ata in Table 6. The “Total Radionuclide**  **Weight %” values in Table 6 are the reported gram v alues for each radionuclide over the**  **entire waste stream divided by the total radiologic al mass reported by the generator in all** 
**containers in the waste stream. The same calculati on produced the values for the “Total**  **Radionuclide Curie %” using the sum of activity val ues for each radionuclide over the entire**  **waste stream. These values have been updated to in clude the 56 containers of debris waste**  **originating from the K-Cell activities supporting A GHCF operations (References C095,**  **C348, U014, U015, U017, U018, U019, U020, U021, U02 2, 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 ac tivity percent.** **15**

**7. Make the following changes to the AK SOURCE DOCUMENT**  **S table in Section 9.0 (pg. 66) so that it reads as follows:** 

**C347 Evaluation of Combustible versus** 

**Noncombus tible 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-ANLE**

**S5000 N/A**  **S. Schafer 9/19/2007** 

**8. Make the changes to the RECORD OF REVISION (pg. 2) s**  **o 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 Offi ce (CBFO) Document Review**  **Record (DRR) comments. 2 06/01/2006 Revised to remove potential Official U**  **se Only (OUO) information as identified by Idaho National Laboratory (INL).**  **Also revised to address miscellaneous editorial and Acceptable Know**  **ledge (AK)**
**reference corrections and to address concerns ident ified during the**  **May 9 through May 12, 2006, INL/Central Characteriz ation 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-0**  **6.06-8. 4 11/16/2006 Revised to implement the Waste Isolati**  **on Pilot Plant Hazardous Waste Facility Permit requirements and associated S**  **ection 311/Remote-Handled (RH) Permit Modification Request**  **(PMR) changes. Also revised to address the resolution of** **CCP NCR RHINL-0007-06 to incorporate dried paint into the w**  **aste stream description.**  **5 11/01/2007 Revised to incorporate 56 containers o riginating from activities**  **supporting Alpha Gamma Hot Cell Facility (AGHCF) ex amination**  **operations conducted in the K-1 and K-2 cells of th e M-Wing Hot**  **Cell Facility. Also revised to incorporate miscell aneous freeze file**  **changes and identify the potential for prohibited i tems (liquids,**  **unpunctured aerosol cans, and sealed containers gre ater than 4 liters)**  **identified during Real-Time Radiography (RTR). 6 XX/XX/2008 Revised to incorporate comments provid**  **ed by EPA inspector during Tier 1 review of this report incorporating 56 conta**  **iners of K-1 and**
**K-2 cell debris waste into waste stream ID-ANLE-S50 00.** **16**

**9. Make changes to Table 2 (pg. 37) so that it reads a**  **s 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 chang es 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 examin ing 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 tracea bility was limited to evaluating and tracing**  **the container based on AK data. INL-CCP provided t hree 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 r equest)** 

• **Loss Gain SS Materials Sheet**

• **Radioactive Waste Form (INL)**

• **Transuranic Waste Container Form (INL) including sh ipment to INL date of 1982** 

• **INL In Vault Storage Depth Waste Classification**

• **ANL-E Log of Intermediate Gamma Level Transuranic W aste and Bin Number** 

• **Table 2 INL storage/retrieval information**

**INL-CCP representatives stated that this informatio n was not available for each of the 56**  **containers in the waste stream, but enough of the i nformation 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 analysi s for these wastes as part of its original**  **baseline inspection to support the correlation of f uel 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 f uels 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-re lated 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 doc**  **ument tracking with respect to the**
**addition of K-Cell references was evaluated.**

**An AK Source Document Reference List was prepared u sing 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, Attach ment 4, and was provided on January 10,**  **2008. The listing is complete, and is easy to unde rstand. As shown in the bulleted list at the**  **beginning of this section, INL-CCP identified sever al 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 inf ormation, and a revised “Attachment 4”**  **complete reference list was also provided. Availab le 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 specif ic 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 r**  **elated Characterization Reconciliation Report (CRR) were assessed.** 

**INL-CCP representatives indicated that neither a re vision to the WSPF nor the CRR had been**  **prepared, since characterization of the K-Cell cont ainers 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 evaluate**  **d.**

**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 baseli ne 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, EP A’s prior approval of INL-CCP describes the**  **appropriate action. 18** 

**(11) Personnel training was evaluated.** 

**Training records for Kevin Peters (AKE) and Steve S chafer (AKE) were examined. Records**  **were provided on January 10, 2007. Both must be tr ained to requirements of the WCPIP**  **Attachment A which includes training to: the RH TR U WCPIP; non-conformance and**  **corrective action processes; the AK procedure prese nted in Attachment A of the WCPIP; site**  **specific training relative to the contents of the s ubject 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 determinatio n of radiological contents of each drum, EPA**  **previously examined the training of Jene Vance, sin ce he assembled and assessed the AK data**  **that were used to derive the radionuclide scaling f actors. Although Mr.Vance did not show**  **direct training with respect to this area, his resu me showed sufficient expertise to demonstrate**  **proficiency.**

**(12) Non Conformance Reports (NCRs) and Discrepancy Resolu**  **tion (DR) Forms were**
**examined.**

**NCRs were not available for the K-Cell wastes. DR01 8 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 wast e packaging and shipment during the waste generation time period. Mr. Kettman was interviewed to ascertain a description of the waste in K-Cell containers, whic h is provided in reference C380. This reference indicates, in part, that the waste was pa ckaged into “SAW” (fiber pac) cardboard cans with metal bottoms closed with gaske tless metal lids clamped onto the
containers. He indicated that these were unsealed c ontainers that were bagged out of the area in heat-sealed plastic pouches that were packa ged in the same configuration before shipping to Idaho. Quick or “pre” Scan of six K-Ce ll 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 a nd 00355 have two cardboard liners no lids shorter than fiber pac; and drums 00478, an d 00496 do not have a cardboard liner or fiber pac. Mr. Kettman was interviewed aga in, and he confirmed that the packaging was consistent with the drums that he pac kaged. Though none of these drum contained the fiber pacs (in the waste cans) Mr. Ke tterman described in his original interview, he thought that he may have been mistake n, but future drums from the fifty-six drum population may show this configuration. To add ress this, the AK Summary was revised to address the different packaging configur ations. 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 cont ainers greater than 4 liters.

**Examination of this DR indicates that INL-CCP repre sentatives 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 ha ve yet to be added to the waste stream. INL**  **CCP representatives stated that they anticipate the y 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 i n the Tier 1 revision.** 

**(13) AK accuracy was assessed.**

**INL-CCP revises its AK Accuracy Report annually. T he last AK Accuracy Report was provided**  **to EPA during the June 2006 baseline inspection tha t was the basis for EPA’s January 2007**  **approval. INL-CCP representatives indicated that t hey 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 noti fy 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 managem ent is not intended for this Waste Stream**  **No. ID-ANLE-S5000 and this will not change with incl usion of the K-Cell wastes that comprise**  **this T1 evaluation. EPA’s baseline inspection repo rt indicated that the implementation of load**  **management is a Tier 1 change requiring EPA prior a pproval.** 

**(15) Continued attainment of DQOs with addition of K-Cel**  **l 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 cani**  **ster, 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 an d cannot be confirmed. TRU waste**  **determination was confirmed through scaling factor verification. RH status is confirmed through** 
**direct measurement of each container’s external rad iation field, as described in CCP-TP-504,** 
**Revision 2. Determination of the 10 WIPP-Tracked r adionuclides 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 o f liquids, will be assessed through RTR. As a**  **result of information provided and EPA’s analysis o f these data, EPA concludes that INL-CCP**  **adequately presents how DQOs will be obtained, incl uding the additional 56 K-Cell drums.** **20**

7.0 SUMMARY OF RESULTS

Findings

**The EPA Inspection Team did not identify any findin gs relative to the inclusion of the 56** 
**containers of K-Cell wastes to Waste Stream No. ID-A NLE-S5000 during this T1 change** 
**evaluation.**

Concerns

**The EPA Inspection Team did not identify any concer ns relative to the inclusion of the 56** 
**containers of K-Cell wastes to Waste Stream No. ID-A NLE-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 St ream No. ID-ANLE-S5000. Based on the**  **results of this evaluation, EPA is approving the in clusion of the 56 containers of K-Cell wastes in** 
**Waste Stream No. ID-ANLE-S5000 with the limitations discussed above.**