DOCKET NO: A-98-49; II-A4-140

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT

ADDITION OF ALPHA GAMMA HOT CELL FACILITY 30-GALLON FUEL PIN

FUEL EXAMINATION WASTE CONTAINERS TO REMOTE-HANDLED DEBRIS

WASTE STREAM AERHDM AT THE ARGONNE NATIONAL LABORAT ORY

U.S. Environmental Protection Agency

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

November 2010i TABLE OF CONTENTS

Section Page

Acronyms and Abbreviations ........................

................................................... .............................. ii

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

................................................... .........................1

2.0 Purpose of Tier 1 Evaluations .....................

................................................... ......................5

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

................................................... .........................5

4.0 Scope of This Evaluation ..........................

................................................... ........................6

5.0 Technical Evaluation of the Addition of 30-Gallon C ontainers of Fuel Pin Fuel Examination Waste from the Alpha Gamma Hot Cell Fac ility ...........................................7

5.1 Acceptable Knowledge ..............................

................................................... .......... 8

5.2 Radiological Characterization .....................

................................................... ....... 17

6.0 Summary of Results ................................

................................................... ........................23

7.0 Conclusions .......................................

................................................... ..............................25

ATTACHMENTS

Attachment A: Approval Summary for ANL RH Waste Ch aracterization Program Attachment B: List of Documents Reviewed by EPA du ring T1 Evaluation Attachment C: Description of the ANL Process Used f or Measurement of Surrogate FEW

Fuel Pinsii ACRONYMS AND ABBREVIATIONS

AGHCF Alpha Gamma Hot Cell Facility

AK Acceptable Knowledge

AKE Acceptable Knowledge Expert

AKSR Acceptable Knowledge Summary Report

Am americium

ANL Argonne National Laboratory

ANL-E Argonne National Laboratory – East

ANL-W Argonne National Laboratory – West

ATR Advanced Test Reactor

BDR Batch Data Report

CBFO Carlsbad Field Office

CCP Central Characterization Project

CFR Code of Federal Regulations

CH Contact-Handled

Ci curie

CRR Characterization Reconciliation Report

Cs cesium

CSSF Correlation and Surrogate Summary Form

CTP Confirmatory Test Plan

DOE U.S. Department of Energy

DQO Data Quality Objective

DR Discrepancy Resolution

DTC Dose-to-Curie

EBR-II Experimental Breeder Reactor-II

EPA U. S. Environmental Protection Agency

FEW Fuel Examination Waste

FFTF Fast Flux Test Facility

FIMS Fuel Information Management System

g gramiii

HBR H.B. Robinson

m 3 cubic meters

mrem/hr millirem per hour

NCR Non-Conformance Report

ORIGEN Oak Ridge Isotopic Generation Computer Prog ram

PTS Project Tracking System

Pu plutonium

R/hr roentgen per hour

Rem Roentgen Equivalent Man

RERTR Reduced Enrichment Research and Test Reactor Program

RH Remote-Handled

SPM Site Project Manager

Sr strontium

T1 Tier 1

T2 Tier 2

Th thorium

TMU Total Measurement Uncertainty

TREAT Transient Reactor Test Facility

TRU Transuranic

U uranium

UREX Uranium Extraction

VE Visual Examination

WCPIP Remote-Handled TRU Waste Characterization Pr ogram Implementation Plan

WIPP Waste Isolation Pilot Plant

WMC waste matrix code

WMP Waste Material Parameter

WSPF Waste Stream Profile Form

WWIS WIPP Waste Information System1

1.0 EXECUTIVE SUMMARY

This report supports the U.S. Environmental Protect ion Agency’s (EPA’s) decision to approve a Tier 1 (T1) change to add Fuel Examination Waste (F EW) to the previously-approved remotehandled (RH) transuranic (TRU) debris Waste Stream AERHDM at the U.S. Department of Energy’s (DOE’s) Argonne National Laboratory (ANL) 1 . In January 2007, EPA approved the Central Characterization Project (CCP) to character ize RH waste at ANL. Using the EPAapproved waste characterization processes discussed in this report, ANL-CCP can characterize FEW from the processing of fuel pins in the Alpha G amma Hot Cell Facility (AGHCF). This AGHCF FEW packaged in 30-gallon containers 2 and thus characterized can be added to the ANL Waste Stream AERHDM for disposal at the Waste I solation Pilot Plant (WIPP).

In accordance with 40 Code of Federal Regulations (CFR) 194.8(b), EPA conducted Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8 of the CCP was te characterization program at ANL on September 12-14, 2006. The January 2007 baseline approval applied to 45 containers of legacy RH debris waste drums. The ANL Baseline Fina l Inspection Report (see EPA Docket No. A-98-49; II-A4-73) documents the approval of the ac ceptable knowledge (AK), radiological characterization using Dose-to-Curie (DTC), and vis ual examination (VE) processes specific to ANL-CCP’s RH waste characterization program. Table 1 of that report cited the inclusion of any additional containers of debris to the approved was te stream as a T1 change that requires EPA approval prior to implementation. Since the baselin e approval, ANL-CCP added containers to the approved AERHDM waste stream as shown in Attachment A.

On July 29, 2010, the Carlsbad Field Office (CBFO) requested EPA approval of a T1 change to include all of the AGHCF FEW packaged in 30-gallon containers in Waste Stream AERHDM. ANL-CCP issued a new standing order, CCP-SO-ANLE-00 3, Revision 0, to formally introduce the technique of measuring and recording the length of the AGHCF fuel pin FEW during VE. The AGHCF fuel pin FEW were characterized by the me thod of dimensional analysis, as described in Appendix C of CCP-AK-ANLE-501, Revisio n 3.

Prior to the formal T1 request in July, EPA visited ANL in May and observed and approved this new procedure in use at ANL. Because there were no new equipment or additional new processes on site at ANL as part of the T1 request, EPA conducted a desktop review of this change, concluding that the ANL-CCP plan to use the EPA-approved system of controls to characterize the 30-gallon containers of fuel pin F EW from the AGHCF was acceptable. EPA did not identify any findings or concerns during th is evaluation. As a result, EPA approves the T1 change request to add 30-gallon containers of th e AGHCF fuel pin FEW to ANL-CCP’s previously approved AERHDM waste stream. This appro val is limited to the AGHCF fuel pin

FEW. Inclusion of additional FEW containers from th e AGHCF in Waste Stream AERHDM is a Tier 2 (T2) change if those containers have the sam e pedigree and are characterized using the

1 ANL was initially designated ANL-E to distinguish it from ANL-West. Since 2009, ANL-W was renamed the Materials and Fuel Complex and ANL-E is ANL. Both d esignations are found in the documents EPA reviewed for this evaluation and these terms are interchangeable in this report.

2 Containers is a generic term which applies to cans, canisters , drums, and any other types of waste packaging uni ts that may be characterized individually for their ra diological and physical contents.2

same dimensional analysis as the FEW discussed in t his report as shown in Table 1 below. For this T2 change, ANL-CCP must:

• Notify EPA of their intention to add containers of FEW debris from the AGHCF, including the approximate number of additional containers and the approximate additional volume of waste, and provide the timeframe for waste generati on, characterization, and disposal.

• Provide an updated AK Summary Report (AKSR) with su pporting information indicating that additional containers have the same pedigree a s that of the approved AERHDM debris waste stream and an updated radiological characteri zation report to EPA. CBFO should make clear to EPA if any of these documents are modified

.

• Acknowledge that the processes, including any scali ng factors, used for quantifying the radiological contents of these additional container s are the same as those used to support EPA’s baseline approval of this waste stream or any other portion thereof that was previously approved by EPA.

Following the initial T2 notification and upon char acterization of a sufficient number of containers to generate 1-2 Batch Data Report (BDRs) , ANL-CCP must provide the list of fully characterized containers. From this list, EPA may s elect a few containers to review the characterization information included in the respec tive VE and DTC BDRs or calculation packages and to verify that the additional containe rs belong to the approved waste stream.

Characterization of any AGHCF FEW other than the fu el pin FEW discussed in this report, specifically characterization of the Reduced Enrich ment Research and Test Reactor Program (RERTR) plates FEW and crucibles and melts FEW, is a T1 change, as shown in Table 1. Table 1 also shows new T1 changes or specific additions t o existing T1s in bold text. There are several T2 changes that were established during the baselin e approval that remain in effect, and these are listed as applicable in Section 5.1. In addition, t here are minor changes in Table 1 to incorporate recent T1 approvals and ensure consistency.

This report serves as EPA’s public notification of the results of the proposed T1 change and its evaluation. This information will be provided throu gh the EPA website and by sending e-mails to the WIPPNEWS list, in accordance with 40 CFR 194 .8(b)(3).3Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by ANL-CCP(Based on September 12–14, 2006, Baseline Inspection and Subsequent T1 Evaluations, Updated November 2010)RH Waste CharacterizationProcess ElementsANL-CCP RH Waste Characterization Process - T1 ChangesANL-CCP RH Waste Characterization Process - T2 Changes*Acceptable Knowledge (AK)Any new waste streams not approved under this baselineModification of the approved Waste Stream AERHDM toincludeadditional containers beyond the approximately 45 included inCCP-AK-ANLE-500, Revision 1, if new or different radionuclidescaling factors are required.Substantive modification(s)*** that have the potential to affect thecharacterization process to CCP-AK-ANLE-500,CCP-AK-ANLE-501 or CCP-AK-ANLE-502Implementation of load management for any RH wastestreamCharacterization of any AGHCF FEW other than the fuel pinsdiscussed in this report, specifically AGHCF RERTRplatesFEW and crucibles and melts FEWNotification to EPA that the final DTC determination is complete for RHcontainers in the approved waste streamNotification to EPA when updates are made to AK documentation as aresult of WCPIP revisions**Notification that updates have been completed to the following documents:•All future revisions of CCP-AK-ANLE-500, CCP-AK-ANLE-501,and CCP-AK-ANLE-502, including freeze file changes•Listing of the references that document the assembly of fuel pin dataand review processNotification to EPA that the data package for thisdebris waste stream iscompleted, including any modifications to the WSPFincluding the CRRand AK SummaryNotification to EPA when AK accuracy reports are completed, preparedannually at a minimumNotification to EPA when Attachment 4 of CCP-TP-005is generated toreflect the updated AKSR Source Document ReferenceListNotification to EPA when Attachment 8 of CCP-TP-005has been formallyupdatedNotification to EPA of the intention to add containers to Waste StreamAERHDM including the approximate number of containers andvolume(s) of waste, the timeframe for waste generation,characterization, and disposal and submission of anupdated AKSRdocumenting that the pedigree of the additional containers is the sameas those covered by the baseline and/or subsequentT1 approvals†Submission of a list of fully characterized containers from a population ofadditional containers proposed as a T2 change, above†Radiological Characterization,including Dose-To-Curie (DTC)Use of any alternate radiological characterizationprocedure otherthan DTC with established scaling factors as documented in CCPTP-504 and CCP-AK-ANLE-501, Revision 0, respectively, orsubstantive modification thereof***Any new waste stream not approved under this baseline or additionof containers to Waste Stream AERHDM that require changing theNotification to EPA that revisions of CCP-AK-ANLE-501 or CCP-TP-504that require CBFO approval** are completeSubmission of an updated CCP-AK-ANLE-501 documenting that theradiological characterization process(s) used for the additional containers isthe same as those covered by the baseline and/or subsequent T1 approvals†4Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by ANL-CCP(Based on September 12–14, 2006, Baseline Inspection and Subsequent T1 Evaluations, Updated November 2010)RH Waste CharacterizationProcess ElementsANL-CCP RH Waste Characterization Process - T1 ChangesANL-CCP RH Waste Characterization Process - T2 Changes*established radionuclide scaling factorsApplication of new scaling factors for isotopic determination otherthan those documented in CCP-AK-ANLE-501Application of any new characterization technique other thanthe dimensional analysis described in this report for AGHCFfuel pin FEWSubmission of DTC BDRsor calculation packagesfor containers selectedby EPA from a list of fully characterized containers provided by ANLCCP†Visual Examination (VE) VE by reviewing existing audio/visual recordings for any wasteSummary Category Group not covered by this approvalVE by any new process for S5000 debris wastesSubmission of VE BDRs for containers selected by EPA from a list of fullycharacterized containers provided by ANL-CCP†Notification to EPA that revisions of any VE procedure that require CBFOapproval are completeAddition of new S5000 debris waste streamsReal Time Radiography (RTR) Any use of RTR requiresEPA approval Submission of RTR BDRs for containersselected by EPA from alist of fully characterized containers provided byANL-CCP†WIPP Waste Data System (WDS) NoneChanges made to WDS procedure(s) that require CBFOapprovalNew T1 changes or specific additions to existing T1s inboldtext* ANL-CCP will report all unmarked T2 changes to EPA quarterly.** Excluding changes that are editorial in nature or are required to address administrative concerns.New references that are included as part of the document revision may berequested by EPA.***Substantive modificationrefers to a change with the potential to affect ANL’s RH waste characterization process, e.g., the useof an inherently different type of measurementinstrument or the use of the high range probe as described for CCP-TP-504 for radiological characterization.† ANL-CCP will report this T2 change immediately.5

2.0 PURPOSE OF TIER 1 EVALUATIONS

Any changes to the waste characterization activitie s 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 ANL 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 waste characterization program. The purpose of a baseline inspection is to approve the site’s waste characterization program based on the demonstration that the program’s components, with applicable conditions and limitations, can adequate ly characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes d estined 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 waste characterizat ion processes evaluated during the baseline inspection, EPA is authorized to evaluate and appro ve, if necessary, changes to the site’s approved waste characterization program by conducti ng additional inspections under the authority of 40 CFR 194.24(h). Under 40 CFR 194.24, EPA has the authority to conduct continued compliance inspections to verify that the site continues to use only the approved waste characterization processes to characterize the wast e and remains in compliance with all the regulatory requirements. Based on the adequacies of the waste characterization processes demonstrated during the baseline inspection, includ ing all conditions and limitations, EPA specified which subsequent waste characterization p rogram 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 ANL-CC P’s characterization program. T1 activities have more stringent reporting requirements and requ ire 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 EPA’s evaluatio n of a T1 change to include the FEW fuel pin wastes from the AGHCF packaged in 30-gallon contain ers in Waste Stream AERHDM, as described in CCP-AK-ANLE-500, Revision 5 and Discre pancy Resolution (DR) form DR023. This report presents the technical basis and result s of EPA’s approval decision. EPA’s approval decision regarding the inclusion of the AGHCF fuel pin FEW 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).

The DOE documents that EPA reviewed for this evalua tion are cited in different sections throughout the report and are listed in Attachment B. Any of these documents can be requested from the following address:6

Manager, National TRU Program

Carlsbad Field Office U.S. Department of Energy

P O Box 3090 Carlsbad, NM 88221-3090

4.0 SCOPE OF THIS EVALUATION

The scope of this evaluation covers inclusion of 30 -gallon containers of the AGHCF fuel pin FEW as described in CCP-AK-ANLE-500, Revision 5 in Waste Stream AERHDM. The evaluation was performed by comparing elements asse ssed in the previous EPA approvals with

information about the new waste containers that was provided by ANL-CCP/CBFO to ensure that they fit within the approvals issued by EPA pr eviously. Because this evaluation involved expanding an existing waste stream to incorporate n ew containers and not the addition of a new Summary Category Group or waste stream, inspection checklists were not used.

A DR form that was provided by ANL-CCP for incorpor ation into the AK Summary Report (AKSR) corrects the number of drums and waste volum e described in Revision 5 of the AKSR (DR023). The DR form describes Waste Stream AERHDM as containing (a) 15.6 cubic meters (m 3 ) of debris waste from the K-Wing in Building 205 a nd (b) 37.4 m 3 of debris waste from the AGHCF in Building 225, including the 30-gallon cont ainers of the AGHCF fuel pin FEW that are the subject of this T1 evaluation

As part of this evaluation, EPA examined the update d AK information to verify that the additional waste containers had the same pedigree a s that of the approved AERHDM debris waste stream and were characterized using an approp riate radiological characterization process. This examination applies to the AGHCF fuel pin FEW packaged in 30-gallon drums with the same pedigree as that of the previously approved Wa ste Stream AERHDM that were characterized using the dimensional analysis method , as discussed in Section 5.0 of this report.

Personnel who participated in the T1 evaluation are listed in Table 2, along with each person’s affiliation and function during the evaluation.

Table 2. T1 Evaluation Participants

Name Affiliation & Function Rajani Joglekar Lead Inspector, U.S. EPA Ed Feltcorn Inspector, U.S. EPA Connie Walker Technical Evaluator – Acceptable Know ledge, SC&A Kira Darlow Technical Evaluator – Acceptable Knowl edge, SC&A Patrick Kelly Technical Evaluator – Radiological C haracterization, SC&A Amir Mobasheran Technical Evaluator – Radiological Characterization, SC&A Kevin Peters Acceptable Knowledge Expert, ANL-CCP Irene Quintana Site Project Manager, ANL-CCP Jene Vance Radiological Characterization Subject Ma tter Expert, ANL-CCP7

5.0 TECHNICAL EVALUATION OF THE ADDITION OF 30-GALLON

CONTAINERS OF FUEL PIN FUEL EXAMINATION WASTE FROM THE

ALPHA GAMMA HOT CELL FACILITY

The population of waste approved during the Baselin e Inspection consisted of 45 30-gallon drums of RH TRU debris waste generated in the AGHCF . Revision 5 of the AKSR and DR023 incorporate and explain the addition of the AGHCF F EW packaged in 30-gallon containers to the previously approved RH debris Waste Stream AERHDM. The AGHCF FEW, historically designated as “sweeps,” “high-level scrap,” or “rec overable material,” was originally segregated

from the Waste Stream AERHDM materials. ANL-CCP is now including the AGHCF fuel pin

FEW in Waste Stream AERHDM based on review of addit ional AK information.

There are over 3,000 samples containing fuel-bearin g material within the AGHCF. This material consists of nuclear irradiated fuel specimens (fuel pins), metallography mounts, and other fuelbearing materials (RERTR plates and crucibles and m elts). This material, principally light water reactor fuels with some mixed-oxide fuel, RERTR car bide, and thorium (Th) fuels, was generated by research and experimental activities c onducted at U.S. Nuclear Regulatory Commission (NRC) and DOE facilities. The activities conducted involved sectioning, grinding, and polishing for metallography, gamma spectrometry , high temperature examination, fission gas collection and analysis, macrophotography, and profilometry. The NRC facilities included the Dresden, Limerick, H.B. Robinson (HBR), Saxton, Quad Cities, Big Rock Point, Surry, and Three Mile Island commercial nuclear power plants. The DOE sites that provided fuel-bearing material were the Advanced Test Reactor (ATR), Chic ago Pile, Experimental Breeder Reactor-II (EBR-II), Engineering Test Reactor, Fast Flux Test Facility (FFTF), Material Test Reactor, NReactor, Oak Ridge Research Reactor, Savannah River Reactor, and Transient Reactor Test Facility (TREAT). Additionally, fuel examination ma terial came from a CANada Deuterium Uranium (CANDU) reactor and the Belgonair Reactor-3 , and some was in the form of Intense Pulsed Neutron Source targets and other target disk s (P2032, U076). Sodium-bonded fuel examination materials stored in the AGHCF will be p ackaged and transferred to Idaho National Laboratory and are not included in Waste Stream AER HDM (C2025, P2032, U076).

EPA examined the AK and radiological characterizati on processes and associated information to determine whether ANL-CCP demonstrated compliance w ith 40 CFR 194.8 for a T1 change to

add containers to Waste Stream AERHDM. EPA conclude d that ANL-CCP continues to appropriately apply the system of controls approved by EPA during the Baseline Inspection.

Documents, Waste Containers, and Batch Data Reports /Calculation Packages Provided

EPA evaluated the documentation that ANL-CCP had pr epared to support the inclusion of the AGHCF fuel pin FEW in Waste Stream AERHDM. ANL-CCP provided CCP-AK-ANLE-500, Revision 5 and CCP-AK-ANLE-501, Revision 3 to EPA f or review of the AGHCF fuel pin FEW being packaged in 30-gallon containers. As a result of EPA’s initial review, several technical

issues were identified that necessitated the revisi on of two calculation packages and Revision 3 of CCP-AK-ANLE-501, Appendix C. Additionally, a new calculation package was created. The revised documents and new calculation packages were provided to EPA and were included in this T1 evaluation along with attachments, source d ocuments, required forms and other data that8

were provided to EPA. The listing of all documentat ion reviewed is in Attachment B, and the list of VE batch data reports (BDRs) and radiological ch aracterization calculation packages examined is presented in Table 3. Because the radio logical characterization process for the AGHCF fuel pin FEW waste does not involve the gener ation of BDRs, the characterization for each drum is documented in a separate calculation p ackage, as shown in Table 3.

Table 3. Batch Data Reports and Calculation Package s Examined

Drum Number VE BDR Number Calculation Package Number
952 RHANLVE100008 ANLE-RH-27, Revision 1

953 RHANLVE100008 ANLE-RH-35, Revision 1

954 RHANLVE100008 ANLE-RH-36, Revision 0*

955 RHANLVE100008 ANLE-RH-37, Revision 0*

956 RHANLVE100008 ANLE-RH-38, Revision 0*
*The calculation packages for these drums were prov ided initially but upon examination were found to require revision and the Revision 0 packages were n ot used for this T1 evaluation.

5.1 Acceptable Knowledge

EPA examined the AK process and associated informat ion to determine whether the ANL-CCP waste characterization program demonstrated complia nce with the requirements of 40 CFR 194.8 for the inclusion of the AGHCF fuel pin FEW in Wast e Stream AERHDM.

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 new con tainers:

• Waste stream identification and definition

• Radionuclide content of additional waste

• Physical composition of additional waste

• Sufficiency of modified AKSR to include the additio nal waste

• Drum data traceability and modifications to the Was te Stream Profile Form (WSPF) and Characterization Reconciliation Report (CRR)

• Defense origin of additional waste

• Identification of high-level waste and spent nuclea r fuel

• AK source document sufficiency

• Modifications to the Confirmatory Test Plan (CTP)

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

correlation

• Personnel training

• Non-Conformance Reports (NCRs) and AK DR forms

• AK accuracy

• Load management

• Identification and attainment of Data Quality Objec tives (DQOs)9

Technical Evaluation

To assess the appropriateness of inclusion of the A GHCF fuel pin FEW packaged in 30-gallon containers based on its radiological and physical c haracteristics, EPA evaluated the AK-based radiological and physical characteristics informati on. EPA evaluated the following: how these data had been integrated, impacts of the informatio n on the waste stream, changes to the radiological and physical characteristics of the wa ste and other elements that could affect pertinent characteristics of Waste Stream AERHDM. R esults of the analysis are presented below. When information presented in the text is supported directly by an AK reference, the reference is cited in parentheses.

(1) The definition of Waste Stream AERHDM was examined with respect to the addition of the Alpha Gamma Hot Cell Facility fuel pin fuel exa mination waste and found to be adequate.

Waste Stream AERHDM is a debris waste stream genera ted by ANL in two locations – the AGHCF and the K-Wing. 3 As part of the baseline approval, EPA concluded th at the waste stream was adequately defined, but the waste stream did not at that time include the AGHCF fuel pin FEW. After reviewing the provided documentation , EPA concluded that inclusion of the AGHCF fuel pin FEW in Waste Stream AERHDM is adequa tely supported.

The AGHCF fuel pin FEW containers were generated as a result of the same hot cell activities that generated the previously approved AGHCF debris waste containers (see see EPA Docket No. A-98-49; II-A4-73). As indicated in the AKSR, t he AGHCF fuel pin FEW containers under

evaluation for addition to Waste Stream AERHDM cont ain “similar debris [to the previously approved waste containers] including irradiated fue l test materials and residues (debris, fuel pin fragments, samples, capsules, and swarf) previously stored as accountable materials 4 in the AGHCF. This waste has been generated at the AGHCF d uring the examination of irradiated and un-irradiated fuel pins and other reactor materials from various reactor programs at ANL-W 5 and

other DOE reactors.”

The physical characteristics of each container are recorded on VE data sheets and the physical measurements of the AGHCF fuel pin FEW are document ed on CCP-SO-ANLE-003, Revision 0, Attachment A. The VE operators creating the VE d ata sheets (contained in the VE BDR described in Table 3, above) assigned Waste Matrix Code (WMC) S5400, Heterogeneous Debris to the examined AGHCF fuel pin FEW containers. This is the same WMC as is assigned to the previously approved containers in Waste Stream AERH DM, which is one indication that the AGHCF fuel pin FEW containers have the same physica l characteristics as those in the approved waste stream. See Item (3), below, for additional d iscussion on the physical characteristics of the AGHCF fuel pin FEW.

3 The AGHFC and the K-Wing Hot Cell Facility are dis tinct facilities located in the 200 Area of ANL-E t hat were used for similar purposes.

4 Accountable materials are items that are tracked and controlled in accor dance with DOE M 435.1-1 because of their special nuclear material content.

5 ANL-W is now the Materials and Fuels Complex (MFC) at the Idaho National Laboratory.10

The AGHCF fuel pin FEW is residual fuel materials f rom the fuel examination activities that contaminated the previously approved AGHCF debris w aste containers. The same AK source documents (including P808, P828, U1003) were used t o determine the ORIGEN2.2 inputs for both the AGHCF fuel pin FEW containers and the prev iously approved AGHCF debris waste containers. However, as indicated in the sampling p lan (CCP-AK-ANLE-502, Revision 2, Draft A), the same scaling factors were not applied to th e AGHCF fuel pin FEW containers because the radionuclide activity and mass for each contain er were more accurately calculated based on the mass of the discrete fuel specimens loaded into the individual drums. See Item (2), below, for additional discussion on the radiological character istics of the AGHCF fuel pin FEW.

Characterization of any AGHCF FEW other than the fu el pins discussed in this report is a T1 change. Specifically, this limitation is directed a t the AGHCF RERTR plates FEW and crucibles

and melts FEW.

(2) Radiological characteristics of the Alpha Gamma Hot Cell Facility fuel pin fuel examination waste were assessed with respect to the ir similarity to Waste Stream AERHDM and found to be adequate.

ANL-CCP developed a radiological characterization p rocess using dimensional analysis that fully utilizes the available AK source documentatio n. As mentioned in Item (1) above, the same AK source documents (including P808, P828, U1003) w ere used to determine the ORIGEN2.2 inputs for both the AGHCF fuel pin FEW containers a nd the previously approved AGHCF debris waste containers. The modeling produced the activit ies and masses of the individual radionuclides on a per mass unit basis of the fuel material. These radionuclide activities and masses were then multiplied by the total mass for e ach discrete fuel type within a container (as recorded in VE documentation) and summed to derive the total radionuclide activity and mass of the drum. This process resulted in more accurate ra dionuclide activity and mass calculations for each container than could be calculated using the D TC process.

The AKSR provided to EPA did not originally include sufficient discussion of the radiological characterization process to be implemented for the AGHCF fuel pin FEW containers. After discussing this with ANL-CCP representatives, ANL-C CP provided a Freeze File 6 version of the draft AKSR, Revision 6 (U911) that incorporates the radiological characterization process described above, as implemented for all of the AGHC F FEW containers. EPA finds these revisions to be adequate for the purposes of review ing the inclusion of AGHCF fuel pin FEW in Waste Stream AERHDM and expects a formal revision o f the AKSR to be completed prior to the

CCP’s 2011 1 st quarter submission of T2 changes to EPA for review and concurrence.

(3) Physical characteristics of the Alpha Gamma Hot Cel l Facility fuel pin fuel examination waste were assessed with respect to the physical ch aracteristics of Waste Stream AERHDM and were found to be adequate.

6 Freeze File: As a result of EPA inspections, if CC P must revise documents to address EPA issues, CCP makes those changes and provides a copy to EPA as objecti ve evidence for the changes made. These revisions a re then processed by CCP’s document control process to gene rate an official version as the most current revisi on.11

ANL-CCP evaluated the impact inclusion of the AGHCF fuel pin FEW, consisting of primarily metal debris, would have on the Waste Material Para meters (WMPs) previously calculated for Waste Stream AERHDM. They found that the additional fuel weight in the AGHCF fuel pin FEW-containing containers would contribute less tha n one percent to the total waste weight of the container (C2026, U2013). Therefore, the impact to the WMPs is considered to be negligible. Based on the results of this evaluation, ANL-CCP co ncluded that the AGHCF fuel pin FEW is physically similar to the AGHCF debris waste, and t hat the WMPs published in the AKSR for the AGHCF debris waste are comparable and bounding. VE will be performed at the time of packaging to confirm the absence of prohibited item s.

EPA reviewed ANL-CCP’s evaluation as presented in t he AKSR and found the logic to be sound and acceptable; however, ANL-CCP’s evaluation is ba sed on the assumption that the configuration of each AGHCF fuel pin FEW-containing 30-gallon container would be one 7- gallon container containing the AGHCF fuel pin FEW in the bottom half of the 30-gallon container and one 7-gallon container containing AGH CF debris in the upper half (C2026, U2013). The VE records provided to EPA indicate tha t each 30-gallon AGHCF fuel pin FEW container contains two 7-gallon containers of the A GHCF fuel pin FEW and no additional AGHCF debris waste. ANL-CCP explained that the pack aging configuration described in the AKSR and source document U2013 was just one example of how the AGHCF fuel pin FEW could be packaged. It was determined that the radio logical characteristics of the container could be determined more accurately if all of the radionu clide-contributing debris in a container are FEW fuel pins. Therefore, all AGHCF fuel pin FEW co ntainers are likely to contain two 7- gallon cans of the AGHCF fuel pin FEW. ANL-CCP expl ained that this does not impact the WMPs assigned to the containers in Waste Stream AER HDM because the WMP estimates are sufficiently broad to account for all possibilities , including the increased quantity of metal debris associated with the AGHCF fuel pin FEW. The AGHCF f uel pin FEW containers are expected to primarily contain iron-based, aluminum-based, and o ther metals in combinations such that the expected WMP weight percent ranges are not exceeded in any container.

The Freeze File AKSR clarified that the packaging c onfiguration implemented for all of the AGHCF FEW containers, including the AGHCF fuel pin FEW that is the subject of this T1 review, includes two AGHCF FEW 7-gallon containers and no AGHCF debris, and that the different packaging configuration will not affect t he overall contribution of the AGHCF FEW to

the WMPs of Waste Stream AERHDM as a whole. The Fre eze File also adds language defining the AGHCF FEW as debris consisting primarily of met al items. EPA finds these revisions to be adequate and expects a formal revision of the AKSR to be completed prior to the CCP’s 2011 1 st
quarter submission of T2 changes to EPA for review and concurrence.

(4) The Acceptable Knowledge Summary Report and impleme ntation of acceptable knowledge as required in Attachment A of the Waste Characterization Program Implementation Plan were evaluated and were found t o be adequate.

EPA examined Revision 5 of the AKSR and found that the document contained all the necessary pieces, but that various sections of the document d id not adequately support inclusion of the AGHCF fuel pin FEW, as summarized by the three issu es described below:12

Issue No. 1: The radionuclide characterization section did not a dequately describe the radiological characterization process as applied to the AGHCF fuel pin FEW. See item (2), above, for additional description and resolution of this issue.

Issue No. 2: The discussion of the impact the AGHCF fuel pin FE W containers would have

on Waste Stream AERHDM WMPs and the source document s supporting this discussion were not consistent with the physical characteristi cs identified in the VE BDR. See item (3), above, for additional description and resolution of this issue.

Issue No. 3: The argument that the AGHCF fuel pin FEW is not sp ent nuclear fuel or high level waste was not adequately supported in the AKS R text by references to source documentation. See item (7), below, for additional description and resolution of this issue.

ANL-CCP personnel provided AKSR modifications (draf t Revision 6, reference U911) that

addressed all three issues. The revised AKSR more c learly explains the radiological characterization process of the AGHCF fuel pin FEW containers, more clearly describes the AGHCF fuel pin FEW container packaging configuratio n and WMPs, and lists the source documents used by ANL-CCP to develop the spent nucl ear fuel/high level waste arguments.

EPA finds that the AKSR will be sufficient upon inc lusion of the revisions as demonstrated in the draft Revision 6, and expects a formal revision of the AKSR to be completed prior to the

CCP’s 2011 1 st quarter submission of T2 changes to EPA for review and concurrence.

(5) Data traceability of Alpha Gamma Hot Cell Facility fuel pin fuel examination waste and

modifications of the Waste Stream Profile Form and related Characterization Reconciliation Report were examined and were found to be adequate.

EPA examined traceability of AK data to understand the waste generation, packaging, processing, transport, and characterization process es up to and including that performed by ANL-CCP. Data management in the Project Tracking Sy stem (PTS) data system used by ANLCCP was also assessed, as well as presentation and general contents of the ANL-CCP waste

characterization data.

The AGHCF fuel pin FEW containers are newly generat ed, so there are no original data packaging sheets or other generator documentation a ssociated with individual containers. The AGHCF fuel pin FEW packaged in the containers, howe ver, has been stored in the AGHCF as

accountable materials 7 ; therefore, there are historic records for the con tents of the individual

containers. ANL-CCP indicated that five containers have been generated and undergone ANLCCP VE and radiological characterization. EPA was p rovided VE BDR RHANLVE100008 that included all five AGHCF fuel pin FEW containers – 9 52, 953, 954, 955 and 956. Examination of

these data indicated that each drum contained two 7 -gallon containers with a shield pot, each of which held nine to ten fuel specimens. Calculation packages ANLE-RH-27 and ANLE-RH-35 – 38 were provided and included measurements for Drum Nos. 952 – 956, respectively. Using these packages, EPA traced the accountable material s identified in drum Nos. 953 and 956 backwards from the PTS screenshots through VE docum entation and the 7-gallon container

7 See Footnote 4 above.13

packaging records to the Fuel Information Managemen t System (FIMS) that identified the host reactor and acquisition date for each specimen. Doc umentation included data and the radiological characterization calculations for each container. The documents associated with each drum and 7-gallon can are summarized in Table 4, below.

Table 4. Alpha Gamma Hot Cell Facility Fuel Examination Waste Fuel Pin Data Tracking References

Drum Can Shield

Pot Fuel Elements FEW Tracking

Form Record FIMS Inventory (U076) Calculation

Package

953 597 7021 604D1-604D9 953-597-7021.pdf Page 14 A NLE-RH-35
953 604 7020 604A1-604A5 953-604-7020.pdf Page 13 A NLE-RH-35
953 604 7020 606A1-606A5 953-604-7020.pdf Page 13 A NLE-RH-35
956 909 7034 604E1-604E9 956-909-7034.pdf Page 14 A NLE-RH-38*
956 570 7033 604C1-604C9 956-570-7033.pdf Page 14 A NLE-RH-38*
*Revision 0 of calculation package Nos. ANLE-RH-36, ANLE-RH-37 and ANLE-RH-38 were not technically acceptable for radiological characterization, and w ere revised. However, they contained sufficient inf ormation to support the traceability analysis.

A copy of the Attachment 8 container list was provi ded, but it was dated 2007 and did not include the AGHCF fuel pin FEW containers. However, the July 22, 2010 Add Container Memo (provided separately) requested the inclusion of th e five AGHCF fuel pin FEW containers in the waste stream. EPA expects that Attachment 8 will ev entually be formally updated to include the AGHCF fuel pin FEW containers. As required in EPA’s baseline approval, notification to EPA of the availability of an updated Attachment 8 rema ins a T2 change.

ANL-CCP did not originally provide documentation pe rtaining to the management of drum data in the CCP PTS system, nor did they provide Site Pr oject Manager (SPM) review documentation, or a CRR that addressed the AGHCF fu el pin FEW. Also, the five AGHCF fuel pin FEW containers mentioned above had not been ent ered into the WDS. EPA requested a CRR that addressed the AGHCF FEW, as well as modificati ons (change requests) to the WSPF related to the AGHCF fuel pin FEW and print-outs of each dr um as currently documented in the PTS and AK Tracking Spreadsheet. ANL-CCP provided all o f the requested information, except for the revised WSPF, which will be completed once EPA approves the waste stream and it is subsequently certified by CBFO. The CRR was provide d in draft form solely for the purpose of

EPA’s T1 review. EPA evaluated the draft CRR and fo und it to be adequate. As required in EPA’s baseline approval, revision of the WSPF and r elated attachments including the CRR remains a T2 change, and EPA requires notification of these changes when they are made. Providing these data demonstrated that ANL-CCP is a ble to generate the required documentation for the AGHCF fuel pin FEW containers.

(6) The identification of the Alpha Gamma Hot Cell Faci lity fuel pin fuel examination waste as defense waste was examined and found to be adequ ate.

EPA previously evaluated and approved the defense w aste determination of Waste Stream AERHDM for the AGHCF waste during the baseline insp ection (No. EPA-ANL-CCP-RH-9.06- 8). EPA determined that the AK record contains suff icient evidence to demonstrate that all of the14

TRU wastes generated by AGHCF operations are contam inated with materials from atomic energy defense activities associated with naval rea ctor development, materials security and safeguards, and defense research and development ac tivities. ANL has also played an integral role supporting the underlying historical and ongoi ng defense missions associated with DOE test and research reactor programs, including the ANL-W EBR-II, Zero Power Plutonium (Physics) Reactor, ATR, TREAT, and Hanford FFTF (C124, C330, P002, P585, U009, U076). The AGHCF fuel pin FEW wastes are a subset of the mater ials processed in the AGHCF and, as stated in Item (1) above, the AGHCF fuel pin FEW wa s generated as a result of defense-related hot cell activities. Therefore, the AGHCF fuel pin FEW containers that are added to Waste Stream AERHDM meet the WIPP requirement of defense- related waste.

(7) Rationale for why the Alpha Gamma Hot Cell Facility fuel pin fuel examination waste is not high-level waste or spent nuclear fuel was exam ined and found to be adequate.

The AKSR, Revision 5, as presented to EPA for this T1 evaluation did not reference any of the AGHCF FEW materials or any AK source documents in t he statement regarding spent nuclear fuel and high-level waste. EPA discussed this issue with ANL-CCP representatives who then provided EPA with a Freeze File containing the draf t revised AKSR (U911). EPA finds the discussion presented in U911 and summarized below t o be adequate and expects a formal revision of the AKSR to be completed prior to the C CP’s 2011 1 st quarter submission of T2 changes to EPA for review and concurrence.

According to the Nuclear Waste Policy Act (NWPA), spent nuclear fuel is fuel that has been withdrawn from a nuclear reactor following irradiat ion, the constituent elements of which have not been separated by reprocessing. DOE’s M 435.1-1

, DOE Radioactive Waste Management

Manual expands on this definition to clarify that test spe cimens of fissionable material irradiated for research and development only may be classified as TRU waste, as appropriate. ANL-CCP

determined that the waste containers in Waste Strea m AERHDM, including the AGHCF fuel pin FEW containers, “contain test residues, test materi als, and the resultant test fragments from the fuel pin test specimens, including irradiated pin f ragments and dispersed particulate (fines and dust).” ANL-CCP reviewed the AGHCF accountable mate rials inventories to verify that the materials to be packaged did not contain intact irr adiated fuel pins (U076). EPA inspected the AGHCF fuel information management system (FIMS) dat abase documentation and agrees that the radiological materials managed in the AGHCF wer e primarily fuel samples and swarf, as indicated by the size of the material and the segme nt/sample identification record (U076). ANLCCP also states that the intact irradiated fuel pin test specimens were managed separately and are not included in this waste stream. As a result, the AGHCF fuel pin FEW is not considered spent

nuclear fuel.

High-level waste is defined by the NWPA as the high ly radioactive material resulting from the reprocessing of spent nuclear fuel, including liqui d waste produced directly in reprocessing and any solid material derived from such liquid waste t hat contains fission products in sufficient concentrations, and other highly radioactive materi al that the Commission, consistent with existing law, determines by rule requires permanent isolation. ANL-CCP determined that the AGHCF fuel pin FEW is not spent nuclear fuel, so by definition the waste could not contain high-level waste. Also, the waste produced at the A GHCF, including the fuel pin FEW,15

originated from laboratory operations associated pr imarily with the examination of irradiated materials and research and development of laborator y-scale technology (P004 and P380). ANLCCP concluded that the waste is not a spent nuclear fuel or high-level waste, and EPA accepts these arguments.

(8) Sufficiency of Acceptable Knowledge support documen ts and related document tracking with respect to the addition of the Alpha Gamma Hot Cell Facility fuel pin fuel

examination waste references was evaluated and was found to be adequate.

An AK Source Document Reference List was prepared u sing unique identifiers for the different document types, following the format typically used by ANL-CCP for RH wastes. The listing is complete, and is easy to understand. ANL-CCP identi fied several references specific to the AGHCF FEW, including the AGHCF fuel pin FEW. As dis cussed elsewhere in this T1 evaluation [items (2), (3), and (7)] EPA identified several places in the AKSR that required revision, including places where statements were ma de about the AGHCF fuel pin FEW without listing associated source documents to support the statements. EPA discussed this with ANLCCP representatives, and source document references were added to the text in a draft revision of the AKSR (U911). No additional source documents wer e added to the AK Source Document

Reference List as a result of this T1 evaluation. E PA only examined the documentation specific

to the technical elements discussed in the AKSR and not the individual source documents used by the AK Expert (AKE) to prepare the AK basis for the waste stream in question (see Attachment B for a list of reviewed references).

(9) Evaluation of the Certification Plan and Confirmato ry Testing Plan was found to be satisfactory.

RH sites must generate a Certification Plan that ex plains how RH waste characterization will take place at each site, as well as a CTP when this plan is required as part of AK Qualification. ANL-CCP provided a combined Certification Plan and CTP for EPA review and EPA reviewed its compatibility with the Waste Characterization P rogram Implementation Plan (WCPIP) requirements. ANL-CCP’s characterization program fo r the AGHCF fuel pin FEW includes the use of fuel specimen dimensional analysis in combin ation with ORIGEN2.2 modeling output to quantify the WIPP-tracked radionuclides, and VE dur ing packaging to identify the physical WMPs. The length of each fuel specimen will be meas ured and documented during VE (EPA observed this operation at ANL, in May 2010, as dis cussed later in this report under Section 5.2 below). The measured length will be multiplied by t he fuel mass per unit length value derived from fuel specimen design information in the AK rec ord. ORIGEN2.2 modeling resulted in the activities of the individual radionuclides on a per mass unit basis of the fuel material, which when multiplied by the total mass of the discrete f uel specimens will determine the activity values for each quantity of fuel specimen. The acti vity values for each fuel specimen loaded into

a container will be summed to derive the total acti vity for any given container of the AGHCF fuel pin FEW.

Review of the CTP showed that all of the required c haracterization elements were adequately addressed. Based on the information above, EPA dete rmined that ANL-CCP adequately used a combination of approaches to characterize and quali fy AK data as required in 40 CFR 194.24/22.16

(10) Personnel training was evaluated and was found to b e adequate.

Training records for Kevin Peters (AKE), Steve Scha fer (AKE), and Irene Quintana (SPM) were examined. Records were provided on July 21, 2010. I t should be noted that the documentation

examined did not indicate that ANL-CCP individuals are trained to EPA requirements, nor are they trained with respect to radiological character ization aspects, both of which are required in the WCPIP. Since the WCPIP is currently under revis ion, EPA will examine future training against the modified WCPIP.

(11) Non-Conformance Reports and Discrepancy Resolution Forms were examined and were found to be adequate.

EPA examined Non-Conformance Reports (NCRs) and Dis crepancy Resolution (DR) forms related to Waste Stream AERHDM during Baseline Insp ection No. EPA-ANL-CCP-RH-9.06-8 and found the preparation of these documents to be adequate. No NCRs are available for the AGHCF fuel pin FEW as only five drums have been ful ly characterized at this time 8 . One DR form (DR023) addresses the change in the estimated volume of the AGHCF FEW as a whole. Based on this single DR, and NCRs and DR forms eval uated during previous reviews, EPA understands and expects that the process EPA evalua ted in the past would be used to develop these documents when necessary.

(12) Acceptable knowledge accuracy was assessed and was found to be adequate.

ANL-CCP revises its AK Accuracy Report annually. Th e last AK Accuracy Report was completed on May 13, 2010, but does not include eva luation of the AK accuracy for any AGHCF fuel pin FEW containers. EPA’s baseline appro val includes changes or updates to the AK Accuracy Report as a T2 change. Therefore, ANL-C CP/CBFO would automatically notify EPA when the next AK Accuracy Report specific to th is waste stream is available.

(13) Use of a Correlation and Surrogate Summary Form and Load Management were evaluated and were determined to not apply to these wastes.

Completion of a Correlation and Surrogate Summary F orm (CSSF) is required when AK

information from a related CH waste stream is used in the RH waste characterization process. During Baseline Inspection No. EPA-ANL-CCP-RH-9.06- 8, ANL-CCP indicated that CH data

was not used in this manner. Inclusion of the AGHCF fuel pin FEW in Waste Stream AERHDM also did not require completion of a CSSF.

ANL-CCP representatives indicated that load managem ent is not intended for Waste Stream AERHDM and this will not change with inclusion of t he AGHCF fuel pin FEW that was the focus of this T1 evaluation. EPA’s baseline inspect ion report indicated that the implementation of load management is a T1 change requiring EPA pri or approval and this is unchanged.

8 As stated previously, only two of the original fiv e calculation packages were adequate with respect t o radiological characterization. However, this does necessarily pr eclude these calculation packages from serving as o bjective

evidence for AK or VE.17

(14) Attainment of DQOs was evaluated and found to be ad equate.

As a result of the analysis presented in Items 1-13 , above, EPA was able to assess how each Data Quality Objective (DQO) was addressed. The followin g DQOs must be addressed as per the

WCPIP:

• Defense determination

• TRU waste determination

• RH waste determination

• Activity determination, including quantification an d identification of the 10 EPA WIPPtracked radionuclides

• Residual liquids

• Physical form, including metals, cellulose, plastic and rubber

As indicated in Item (9), above, the DQOs were addr essed primarily through AK, radiological modeling and VE. When evaluated as a whole, CCP-AK- ANLE-500, Revision 5 and the draft Revision 6 prepared by ANL-CCP in September 2010; C CP-AK-ANLE-501, Revision 3; CCP-AK-ANLE-502, Revision 2, Draft A; and the revie wed supporting source documents indicate that the DQOs, as specified in the WCPIP, have been met.

Summary of Acceptable Knowledge

Findings or Concerns

The EPA evaluation team did not identify any findin gs or concerns relative to the addition of 30- gallon drums of the AGHCF fuel pin FEW during this T1 change evaluation.

Tiering Changes

Based on the results of this T1 evaluation, there i s one change to the AK T1 designations and there are no changes to the AK T2 designations. Cha racterization of any AGHCF FEW other than the fuel pin FEW discussed in this report, spe cifically AGHCF RERTR plate FEW and crucibles and melts FEW, is a new T1 change. Table 1 shows the new T1 change and specific additions to existing T1s in bold text. Some T2 cha nges that were initiated during the baseline approval remain in effect, and these are listed as applicable in Section 5.1. Additionally, there are minor changes in Table 1 to incorporate recent T1 approvals and ensure consistency.

5.2 Radiological Characterization

RH Waste Overview

Generation of the AGHCF FEW, including the fuel pin FEW, is described above in section 5.0. The AGHCF fuel pin FEW is placed into one-gallon, s hielded fuel capsules, which, in turn, are placed in 7-gallon cans; up to two cans are placed into 30-gallon drums fitted with 140-mil polyethylene liners. These 30-gallon drums of the A GHCF fuel pin FEW are the subject of this

T1 evaluation.18

Radiological Characterization Overview

The overall approach to the radiological characteri zation of the AGHCF fuel pin FEW containers is not the DTC approach that has been used on RH wa stes from other sites. Instead, radiological

characterization is based on the determination of t he total mass of discrete fuel specimen(s) loaded into the individual drums. The fuel pin spec imens are measured and their mass determined by multiplying the measured length and t he fuel mass per unit length provided by

AK. The form of the fuel materials and the availabi lity of information on the fuel specimens

allow the direct determination of each container’s radionuclides, specifically cesium-137 ( 137 Cs), americium-241 ( 241 Am), plutonium-238 ( 238 Pu), 239 Pu, 240 Pu, 242 Pu, strontium-90 ( 90 Sr), uranium233 ( 233 U), 234 U, 238 U, and other radionuclides, as applicable. Accordin gly, scaling factors and the relationship between the loaded-waste density a nd DTC conversion factor are not needed. Compared to the DTC approach, the total mass determ ination approach should be more accurate,

because the uncertainties associated with the DTC c onversion will be eliminated.

The pre-irradiation composition, burnup, reactor di scharge date, and decay time of the fuel specimens examined in the AGHCF hot cells, as obtai ned from AK records, were the input data for the ORIGEN2.2 analyses. The activities of indiv idual radionuclides on a per-mass unit basis obtained from ORIGEN2.2 are applied to the quantiti es contained in each AGHCF fuel pin FEW container, allowing the determination of the contai ner’s total activity. As described above, following measurement each specimen is placed into one-gallon, shielded fuel capsules, which are then placed in a 7-gallon can and up to two can s are placed into a 30-gallon drum. Each waste drum is unique and a calculation package will be developed to document the characterization process for each drum. There will be no radiological characterization BDRs associated with the AGHCF fuel pin FEW and instead there will be one calculation package per

waste drum. For this T1 evaluation five calculation packages were provided for Drum Nos. 952 – 956, all of which were reviewed. Upon initial revie w, EPA noted that these packages incorrectly included the mass of the shielded pots containing t he fuel pins in the calculated sample mass. Shielding included for the purpose of reducing the external radiation (dose rate) is not considered part of the sample. EPA raised this concern and two of these packages were revised by ANLCCP. This evaluation is based on a review of the re vised calculation packages for Drum Nos. 952 and 953. EPA expects that the format and techni cal approach embodied in ANL-RH-27 (Drum No. 952) and referenced in ANL-RH-35 will be employed for all of the AGHCF fuel pin FEW. An overview of the radiological characterizati on process used for the AGHCF fuel pin FEW and depicted in Figure C2-1 of CCP-AK-ANLE-501, Revision 3, is provided in Figure 1,

below.

EPA evaluated the characterization methods used for the AGHCF fuel pin FEW in terms of the technical adequacy of the approach, as supported by the program’s documents, procedures, and controls, and the knowledge and understanding of th e personnel involved in the RH waste characterization program. Additionally, EPA personn el observed the actual measurement of fuel elements at ANL, as described below.19

Figure 1. Flow Diagram of the Characterization Proc ess: AGHCF Fuel Pin FEW

Documents Reviewed

As described above in section 5.0, Attachment B inc ludes all documents related to the INL-CCP RH TRU radiological characterization program that w ere examined to support this T1 evaluation

Model drum

unshielded dose rate

Measure drum

shielded dose rate (RH determination)

Collect relevant AK on the

Waste Stream

Develop Certification Plan

Locate and retrieve relevant ANL-E records and literature sources on fuel compositions, burnups, reactor discharge dates, and fuel pin physical parameters

Make ORIGEN2.2 runs for fuel pins involved in AGHCF

activities Calculate fuel mass loading per unit length of each fuel pin

Calculate the activity and mass content of the drums for the reportable

radionuclides (TRU determination) Conduct dimensional analysis of fuel pins loaded

into drums and recorded in VE logbook

Determine uncertainties in the reported activities and masses of the

radionuclides20

Technical Evaluation

(1) The EPA inspection team evaluated the methodolo gy and the technical approach used to characterize the Alpha Gamma Hot Cell Facility fuel pin fuel examination waste and determined that it was technically adequate.

The information that formed the basis of the radiol ogical characterization process was reviewed. Specifically, the “direct” method used to replace D TC as documented in CCP-AK-ANLE-501, Revision 3, and the supporting calculation packages were reviewed. The following aspects of the characterization process were evaluated:

• The methodology and the technical approach of the d imensional measurement

• Information on fuel pin lengths extracted from VE r ecords

• ORIGEN2.2 analyses of the AGHCF FEW, HBR high-burnu p fuel, and Th fuel

• Utilization of FIMS

• Determination of reportable radionuclide and the bo unding analysis performed

• Retrieval of records and information from the AGHCF programs

• Fuel specimen physical characteristics needed for O RIGEN2.2 for determination of the total activity content of drums

• Utilization of pre-irradiation fuel composition (in cluding enrichment), fuel burnup, date of discharge from reactor (end-of-irradiation date), a nd decay duration as input data for ORIGEN2.2 analyses

• Activity in curies (Ci) and mass in grams (g) and t he associated uncertainties that were determined for the ten WIPP-Tracked radionuclides ( 233 U, 234 U, 238 U, 238 Pu, 239 Pu, 240 Pu,

242 Pu, 241 Am, 137 Cs, and 90 Sr)

• The bounding analysis involving a set of fuel types to represent the population of fuel pins in the AGHCF inventory for Fissile Gram Equiva lent, Pu Equivalent Curies, and decay heat in Watts

• The appropriateness of the choice of physical const ants and radionuclide-specific attributes (specific activity, physical half-life, decay heat, neutron cross-sections, photon transition probabilities, etc.) and the technical c orrectness of the values assigned to each

attribute

The constants and other values required for these c alculations were taken from the appropriate sources (TRAMPAC) and were spot-checked for accurac y. Calculations are performed using an Excel spreadsheet, as shown, as an Example, in Figu re C4-6 of CCP-AK-ANLE-501, Revision 3, where the input includes:

• Container number

• Estimated fill percentage

• Container gross weight21

• Container net weight

• Waste material type

• Radionuclides and their activities

There were no concerns regarding the methodology an d the technical approach used for radiological characterization of the AGHCF fuel pin FEW.

(2) Technical aspects and documentation of the rad iological characterization process were evaluated and found to be acceptable.

The Technical Report CCP-AK-ANLE-501 is the main do cument that describes the radiological characterization process that ANL-CCP used for the AGHFC FEW fuel pins. This document is supported by a series of calculation packages that were reviewed. Additionally, the

characterization for each drum is documented in a s ingle calculation package, five of which were initially provided to EPA. These packages were prep ared and reviewed by Jene Vance and Jim Holderness. Upon initial review these were found to be in error in that the weight of the shielded containers was included in the weight of the sample s’ TRU-bearing nuclear material, e.g., 239 Pu. This was corrected in Revision 1 of calculation pac kages ANL-RH-27 and ANL-RH-35, Drum Nos. 952 and 953, respectively.

Revision 3 of CCP-AK-ANLE-501 also required revisio n to address the RH determination, which was not addressed in calculation packages or Revision 3 of CCP-AK-ANLE-501. This is typically performed in conjunction with DTC, which is not applicable to the AGHCF fuel pin FEW containers. ANL-CCP provided calculation packag e ANL-RH-31, Surface Dose Rate Multiplier for AGHCF FEW Drums , Revision 0 to address this and added language to CCP-AKANLE-501, Appendix C, Section 4 that summarized ANL -RH-31. Essentially, ANL-CCP proposed to determine a multiplication factor (the inverse of a dose reduction factor) to be applied to the measured dose rate of the shielded p ots to correct the readings to represent the

unshielded 137 Cs which must be measured to determine the drum’s s tatus relative to the RH criterion of a surface dose rate equal to or greate r than 200 millirem per hour (mrem/hr) and less than 1,000 rem/hr. The multiplication factor will b e determined using the radiation transport computer code MCNP5 and would allow conversion of t he measured (shielded) dose rate to an unshielded dose rate. EPA reviewed this approach an d found that it was technically acceptable and appropriately documented although ANL-CCP did n ot provide objective evidence of the RH determination for actual AGHCF fuel pin FEW contain ers.

The EPA evaluation team determined that upon modifi cation CCP-AK-ANLE-501 adequately documented the radiological characterization proces s for the RH TRU AGHCF fuel pin FEW, and the revised calculation packages cited above ad equately supported the activities upon which the radiological characterization of the RH TRU AGH CF fuel pin FEW containers is based. EPA may request copies of the records that document the RH determination for the AGHCF fuel pin

FEW containers for their review at a later date. Th ere were no issues related to the documentation of technical aspects of the ANL-CCP r adiological characterization approach for the AGHCF fuel pin FEW.22

(3) Measurements of the Alpha Gamma Hot Cell Facili ty fuel pin fuel examination waste at Argonne National Laboratory were observed and were found to be adequate.

On May 4, 2010, EPA inspectors observed ANL personn el measuring the length and diameter of surrogate fuel pins in a glove box as part of a dem onstration. ANL personnel followed ANL Procedures (included as Attachment C to this report ) while performing this task. The purpose of the demonstration was to show how accurately a sing le FEW sample can be measured to support the confirmation of the physical description in AK, as well as the data gathered during the ANLCCP VE process. The ability to accurately perform t hese measurements has a direct impact on the radiological characterization process performed by ANL

- CCP. The successful demonstration of this process allows ANL

- CCP to use the ORIGEN

- generated data to characterize the RH TRU material in each container, providing a significant improvement in accuracy over the DTC

method used for other RH TRU waste forms. The measu rements matched the known dimensions of the surrogate fuel pins used for demonstration p urposes. The ANL-CCP staff stated they would follow this same procedure used for the surro gate fuel pins to measure actual fuel pins before packing them in the shielded pots. EPA deter mined that the performance of ANL-CCP sampling personnel was technically adequate.

(4) The technical basis and derivation of Total Mea surement Uncertainty were evaluated and were found to be adequate.

The development of Total Measurement Uncertainty (T MU) for Waste Stream AERHDM is based on the propagation of uncertainties present i n all aspects of the determination of the radiological constituents. These aspects are assume d to be independent, which allows them to be added in quadrature. However, for the AGHCF fuel pi n FEW there are two sources of uncertainty that are statistically dependent: (1) t he specimen mass determination, and (2) a single drum containing multiple fuel specimens from the sa me fuel pin or subassembly. The TMU

determination included contributions of the followi ng sources of uncertainties:

• Specimen mass determination involving length measur ement and mass-per-unit-length uncertainty

• Specimen mass determination based on weight measure ment involving specimen weight measurement, tare weight determination, and ORIGEN2 .2 analysis uncertainty (benchmark uncertainty)

• ORIGEN2.2 inputs

A general treatment of TMU is presented in CCP-AK-A NLE-501. There were no concerns regarding the technical derivation and documentatio n of TMU for ANL Waste Stream AERHDM containing the AGHCF fuel pin FEW.

(5) Transuranic determinations were assessed and we re found to be adequate.

The determinations that these containers meet the d efinition of TRU waste were examined during the baseline inspection based on a DTC BDR. However, DTC was not used for the AGHCF fuel pin FEW and this determination had to be evaluated based on the five calculation23

packages provided for Drums Nos. 952 – 956, all of which were examined. As stated previously, these were in error and the calculation packages fo r Drum No. 952 and 953 were revised and resubmitted to EPA. Based on the two calculation pa ckages, both containers were clearly TRU, i.e., contained more than 100 nanoCuries per gram o f transuranic radionuclides. There were no technical or documentation-related concerns regardi ng the TRU determinations for the two containers of AGHFC FEW fuel pin wastes.

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

EPA evaluated ANL-CCP’s process to determine that t he containers were RH, i.e., had contact dose-rates greater than 200 mR/hr. Since these samp les are packed in shielded pots an unshielded contact dose rate is not obtainable by direct measu rement. To address this, ANL-CCP prepared calculation package ANLE-RH-31, Surface Dose Rate Multiplier AGHCF FEW Drums , which describes the technical basis for modeling the samp le’s shielded dose rate and deriving the multiplier to convert this to an unshielded dose ra te. ANL-CCP provided a copy of the

“SURFACE DOSE RATE CALCULATION WORKSHEET FOR 30 GAL LON RH FEW DRUMS” for 30-gallon container Nos. 952 and 953, bo th dated October 28, 2010. These copies documented that both containers were clearly RH wit h contact dose rates of 474.30 and 770.04 R/hr, respectively 9 . EPA had no concerns regarding the RH determinatio n for the AGHFC FEW fuel pins.

Summary of Radiological Characterization

Findings or Concerns

The EPA inspection team did not identify any findin gs or concerns related to radiological characterization. There are no open concerns relate d to radiological characterization resulting

from this T1 evaluation.

Tiering Changes

Based on the results of this T1 evaluation, there a re no changes to the T1 and T2 designations that were assigned to radiological characterization for ANL-CCP during the baseline approval.

6.0 SUMMARY OF RESULTS

Findings and Concerns

The EPA Inspection Team did not identify any findin gs or concerns relative to the addition of 30-gallon drums of the AGHCF fuel pin FEW to Waste Stream AERHDM during this T1 change

evaluation.

9 Roentgens (R) and Rems (rem) are units of radiatio n exposure and dose equivalent, respectively. Altho ugh they represent different quantities, by convention they are often considered equivalent. In this report, th ese terms are used interchangeably, which is a conservative approach t o assigning dose equivalent in rem.24

Tiering Changes

While the baseline and previous T1 changes adding R H waste to Waste Stream AERHDM have been container-limited, this approval is not limite d to the addition of a specific number of AGHCF fuel pin FEW containers to Waste Stream AERHD M. ANL-CCP may add containers to the approved ANL RH waste stream if the following c onditions apply:

• Additional containers have the same pedigree as tha t of the approved waste stream

• ANL-CCP can demonstrate that the radiological chara cterization processes, including any radionuclide scaling factors, used for the RH waste stream are technically appropriate for use in the DTC determination or other approved meth od of radiological characterization

of the additional containers

Any addition of new containers to the approved wast e stream must meet the revised ANL-CCP tiering table (Table 1), including the following T2 changes:

• Notification to EPA of the intention to add contain ers of FEW debris from the AGHCF including the approximate number of additional cont ainers and the approximate additional volume of waste, and provide the timeframe for wast e generation, characterization, and disposal.

• Providing an updated AKSR with supporting informati on indicating that additional containers have the same pedigree as that of the ap proved AERHDM debris waste stream and an updated radiological characterization report to EPA. CBFO should make clear to EPA if any of these documents are unchanged.

• Acknowledging that the processes, including any sca ling factors, used for quantifying the radiological contents of these additional container s are the same as those used to support EPA’s baseline approval of this waste stream or any other portion thereof that was previously approved by EPA.

Following the initial T2 notification and upon char acterization of a sufficient number of containers to generate 1-2 BDRs, ANL-CCP must initi ate another T2 change. ANL-CCP must provide the list of fully characterized containers. From this list, EPA may select a few containers

to review the characterization information included in the respective VE and DTC BDRs or calculation packages and to verify that the additio nal containers belong to the approved waste

stream.

Additionally, there is one new T1 change. This appr oval is limited to the AGHCF fuel pin FEW and characterization of any AGHCF FEW other than th e fuel pin FEW discussed in this report is a T1 change. Specifically, this limitation is direc ted at the AGHCF RERTR plate FEW, and

crucibles and melts FEW.25

7.0 CONCLUSIONS

During this T1 change evaluation, EPA examined the addition of 30-gallon containers of the AGHCF fuel pin FEW to Waste Stream AERHDM. Based on the results of this evaluation, EPA is approving addition of 30-gallon containers of th e AGHCF fuel pin FEW, characterized using dimensional analysis, to Waste Stream AERHDM with t he limitations discussed above. Inclusion of the AGHCF RERTR plates FEW and/or the AGHCF crucibles and melts FEW in Waste Stream AERHDM will require separate T1 evalua tions.A-1 

### ATTACHMENT A

APPROVAL SUMMARY FOR ANL RH WASTE CHARACTERIZATION

PROGRAM

Specific ANL RH Approval Date EPA Docket Number

ANL RH Baseline Approval January 2007 A-98-49; II-A4-73

Tier 1 Change – Approval of WIPP Waste Information System January 2007 A-98-49; II-A4-74

Tier 1 Change – Approval of Visual Examination for Newly

Generated Waste June 2008 A-98-49; II-A4-102

Approval of 100 additional drums of AGHCF debris wa ste to Waste

Stream AERHDM October 2008 A-98-49; II-A4-136

Tier 1 Change – Addition of K-Wing debris waste to Waste Stream

AERHDM September 2010 A-98-49; II-A4-132

Tier 1 Change – Addition of 120 containers of AGHCF debris waste

to Waste Stream AERHDM September 2010 A-98-49; II-A4-134B-1 

### ATTACHMENT B

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUAT ION

CCP-AK-ANLE-500 Central Characterization Project Ac ceptable Knowledge Summary Report For Argonne Remote-Handled Debris Waste, Waste Stre am: AERHDM, Revision 5, January 14,

2010

CCP-AK-ANLE-501, Central Characterization Project R emote-Handled Transuranic Radiological Characterization Technical Report for Remote-Handled Transuranic Debris Waste From Argonne National Laboratory-East, Revision 3, July 23, 2010

CCP-AK-ANLE-502, Central Characterization Project R H TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation Test Plan for ANL RH Waste Stream: AERHDM, Revision 2, Draft A, 2010

CCP-SO-ANLE-003, Revision 0, Attachment A – Waste C ontainer ID Number: 7017, June 1,

2010

CCP-SO-ANLE-003, Revision 0, Attachment A – Waste C ontainer ID Number: 7019, June 1,

2010

CCP-SO-ANLE-003, Revision 0, Attachment A – Waste C ontainer ID Number: 7020, June 4,

2010

CCP-SO-ANLE-003, Revision 0, Attachment A – Waste C ontainer ID Number: 7021, June 3,

2010

CCP-SO-ANLE-003, Revision 0, Attachment A – Waste C ontainer ID Number: 7022, June 4,

2010

CCP-SO-ANLE-003, Revision 0, Attachment A – Waste C ontainer ID Number: 7023, June 4,

2010

CCP-SO-ANLE-003, Revision 0, Attachment A – Waste C ontainer ID Number: 7024, June 4,

2010

CCP-SO-ANLE-003, Revision 0, Attachment A – Waste C ontainer ID Number: 7028, June 3,

2010

CCP-SO-ANLE-003, Revision 0, Attachment A – Waste C ontainer ID Number: 7033, June 3,

2010

CCP-TP-005, CCP Acceptable Knowledge Documentation , Carlsbad, New Mexico, Washington TRU Solutions, LLCB-2

CCP-TP-005, Revision 18, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste Containers, Waste Stream AERHDM, August 8, 2007

Characterization Reconciliation Report for AERHDM, Draft for Audit Purposes, Provided August 20, 2010

Inter-Office Correspondence from I. S. Quintana to CCP Records Custodian, RE: Transmittal of Waste Stream Profile Form, Attachment 4, for Remote -Handled Waste Stream AEHRDM at the Argonne National Laboratory, July 23, 2008

Inter-Office Correspondence, from C. M. Gomez to M. Sensibaugh, Acceptable Knowledge Accuracy Report, Argonne National Laboratory, Waste Stream Number AERHDM, Lots 1-5, May 13, 2010

Memorandum to Irene Quintana, CCP SPM, from Kevin P eters, CCP AKE, RE: Addition of 16 Containers to Waste Stream AERHDM, July 22, 2010

PTS Screenshots/Traceability Information for Drums 952, 953, 954, 955 and 956, Provided to EPA on August 20, 2010

RH ANLE AK Container Tracking Spreadsheet, July 26, 2010

RH Tiering of TRU Waste Characterization Processes Implemented by CCP at ANL (Based on EPA Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8 a nd updated during T1 evaluation to add K-Wing debris waste to Waste Stream AERHDM) Doc ket No. A-98-49; II-A4-132, September 2010

Training documentation, Qualification Cards and Sit e-Specific RH Training for K. Peters, S. Schafer and I. Quintana, provided July 21, 2010

C124, Fax to Mark Wyco and Larry Neimark, ANL-E re: Request for ANL-E to Identify Items of ANL-W Origin, Julia Whitworth, IT Corporation, F ebruary 21, 2002

C330, Memorandum to Ines Triay, Acting Manager, CBF O: Determination and Findings, Defense Origin of Nuclear Waste, Kerr-McGee Waste, F. Marcinowski, April 15, 2005

C2025, Communication with Dan Pancake: Inventory Up date and the Management of Potentially Reactive and Pyrophoric Materials, K. Peters, Decem ber 1, 2009

C2026, WMP Evaluation for the addition of 100 FEW C ontainers, K. Peters, December 4, 2009

DR023, Waste Stream AERHDM Volume Projection Correc tions, K.J. Peters, June 23, 2010

P002, Central Characterization Project Acceptable K nowledge Summary Report for Argonne National Laboratory-East Contact-Handled TRU Waste Facility Maintenance and LaboratoryB-3

Operations, Central Characterization Project (CCP), CCP-AK-ANLE-001, Revision 11, December 31, 2003

P004, Safety Analysis Report for the Alpha-Gamma Ho t Cell Facility, M4000-0025-SA-01, W.D. Jackson, December 6, 1982

P380, Alpha-Gamma Hot Cell Facility (AGHCF) Safety Analysis Report, IPS-221-00-01, ANL,

October 2001

P585, Safety issues at the DOE Test and Research Re actors, A Report to the U.S. Department of Energy, National Academy Press, 1988

P808, Memo from Garkisch to Kazuya Yamamoto transmi tting the SPA-1A Data Report, Data Report, SPA-1A Test Irradiation in EBR-II, NDP-94-0 28 Doc ID: WCAP-14154, WAES-TR94-001, H.D. Garkisch and K. Yamamoto, September 19 94 P828, Design, Operation, and Performance Data for H igh Burnup PWR Fuel from the H.B. Robinson Plant for Use in the NRC Experimental Prog ram at ANL, EPRI 1001558, E.J. Ruzauskas and K.N. Fardell, April 2001

P2032, Building 212 Alpha Gamma Hot Cell Facility D eactivation Project Plan with Appendix 1: Alpha-Gamma Hot Cell Facility Excess Materials a nd Waste Disposition Campaign Baseline; Appendix 2: Next Phase TRU Waste Campaign Baseline; and Appendix 3: Alpha-Gamma Hot Cell Facility Decontamination Project, NOD-190-00-0 0, NOD-192-00-00, NOD-191-00-00, NOD-194-00-00, D. Pancake, M. Sodaro, D. Hodge, Aug ust 26, 2009, August 14, 2009, August 21, 2009

U009, Transuranic Waste at Argonne National Laborat ory-West: Meeting the Waste Acceptance Criteria for the TRU Repository, August 10, 2001

U076, AGHCF Fissile Inventory Management System Dat abase, July 16, 2001 and October

2009

U911, Freeze File of Draft CCP-AK-ANLE-500, Revisio n 6, K. Peters, Provided to EPA September 7, 2010

U1003, Argonne Special Material Receipt and Transfe r Documentation by A/G Number, Various Authors, 1964-1997

U2013, 30 Gallon Drum (Spec 7A) RH-TRU Debris + FEW Configuration

ANLE-RH-20, AGHCF Fuel Information Input Check, U90 3, Revision 0, Jene Vance, July 8,

2010

ANLE-RH-21, ORIGEN2.2 Data Extraction, U904, Revisi on 0, James Holderness, July 8, 2010B-4

ANLE-RH-22, ORIGEN2.2 Analysis of AGHCF FEW, U905, Revision 0, James Holderness, July 8, 2010

ANLE-RH-23, ORIGEN2.2 Analysis of HBR High Burnup F uel, U906, Revision 0, James Holderness, July 8, 2010

ANLE-RH-24, ORIGEN2.2 Analysis of Thorium Fuel, U90 7, Revision 0, James Holderness, July 8, 2010

ANLE-RH-25, Determination of Reportable Radionuclid es, U908, Revision 0, James Holderness, July 8, 2010

ANLE-RH-26, Fuel Rod Loading, Revision 0, Jene Vanc e, July 8, 2010

ANLE-RH-27, Radiological Characterization for Drum 952, U910, Revision 0, James Holderness, July 8, 2010

ANLE-RH-27, Radiological Characterization for Drum 952, Revision 1, James Holderness, September 22, 2010

ANLE-RH-31, Surface Dose Rate Multiplier AGHCF FEW Drums, Revision 0, James Holderness, October 7, 2010

ANLE-RH-35, Radiological Characterization for Drum 953, Revision 0, James Holderness, July 22, 2010

ANLE-RH-35, Radiological Characterization for Drum 953, Revision 1, James Holderness, October 2, 2010

ANLE-RH-36, Radiological Characterization for Drum 954, Revision 0, James Holderness, July 22, 2010

ANLE-RH-37, Radiological Characterization for Drum 955, Revision 0, James Holderness, July 22, 2010

ANLE-RH-38, Radiological Characterization for Drum 956, Revision 0, James Holderness, July 22, 2010

Handouts provided following the demonstration of di mensional measurements of surrogate fuel pins on May 4, 2010.C-1 

### ATTACHMENT C

DESCRIPTION OF ANL PROCESS USED FOR THE MEASUREMENT

OF SURROGATE FEW FUEL PINSC-2 

### ATTACHMENT C-1

FEW Surrogate Sample Measurement Exercise At the ANL Alpha Gamma Hot Cell Facility, May 4, 20 10

The purpose of this exercise was for ANL-CCP to dem onstrate the ability to measure, confirm, and document the length and diameter of FEW samples inside the AGHCF. Surrogate samples were used for this demonstration that took place at ANL in the AGHCF on May 4, 2010.

The length and diameter of each sample was measured outside the cell (Initial), and the dimensions recorded. These samples were then transf erred into the hot cell, and the length and diameter were measured on the samples inside the ce ll (Observed) using the same measurement

devices. The Initial and Observed measurements were compared.

FEW Surrogate Specimen Number Initial Sample Length* (inches) Observed Sample

Length** (inches) Initial Sample

Diameter* (millimeters) Observed Sample

Diameter** (millimeters) Surrogate #001 3 3 12.5 13 Surrogate #002 2 2 12.5 13 Surrogate #003 2-1/2 2-1/2 10 10 Surrogate #004 1-3/4 1-3/4 10 10 Surrogate #005 3 3 8.5 9 Surrogate #006 1-3/4 1-3/4 8.5 9 Surrogate #007 1-3/4 1-3/4 4.5 5 Surrogate #008 1-1/4 1-1/4 4.5 5 *Measured outside the hot cell (Initial Measurement ) **Measured inside the hot cell (Observed Measu rement)

The ruler used for the Initial measurements of the samples is divided into units of 1/16 inch (in.). The observed lengths were visible at this increment during the Initial measurement. The Initial diameters could be quantified to a tolerance of +/

- 0.5 millimeters (mm), however, Observed measurements were visible only at 1 mm increments. Rulers used to collect data are certified and calibrated, and ANL-CCP provided the appropriate ce rtificates to document this.C-3 

### ATTACHMENT C-2

FEW Confirmatory Measurement Demonstration At the ANL Alpha Gamma Hot Cell Facility, May 4, 20 10

This summary describes results obtained from the co nfirmatory measurement exercise of AGHCF FEW conducted in the AGHCF at ANL on May 4, 2 010. Representatives from the US
EPA, ANL

- CCP, and the Next Phase TRU Waste Campaign were pre sent to observe the demonstration. The purpose of the exercise was for ANL-CCP to demonstrate how accurately a single FEW sample can be measured to support confir mation of the physical description in AK, as well as the data gathered during the ANL

- CCP VE process. The ability to accurately obtain these measurements has a direct impact on the radio logical characterization process performed by ANL

- CCP. The successful demonstration of this process a llows ANL

- CCP to use the

ORIGEN

- generated data to characterize the RH TRU material in each container, providing a significant improvement in accuracy over the DTC me thod used for other RH TRU waste forms. The FEW surrogate samples and measurement devices a re shown in Figure C.1, below.

Figure C.1. FEW Surrogate Samples and Measurement T ools

The goal was to demonstrate that this process allow ed each FEW specimen to be accurately

measured to +/

- 0.25 in. (length), and +/

- 2 mm (diameter). The diameter measurement is performed solely to provide confirmation of ANL-CCP AK data, where the length measurement is used both to confirm AK data and to provide the mass for radiological characterization using the known densities for each specimen. The demonstr ation was conducted in the AGHCF under the same conditions and using the same equipment th at will be used for actual FEW packaging

evolutions.C-4

Figure C.2. AGHCF Work Station No.4 – Site of FEW M easurement Confirmation Process

The FEW measurement confirmation demonstration took place at ANL in the AGHCF Work Station No.4, shown in Figure C.2, above. The speci mens used for this demonstration were surrogate FEW samples that were designed to be repr esentative of the AGHCF FEW sample inventory. Each specimen was removed from its clear polyethylene container and was measured on a ruler for length, and on a gauge for diameter. There were eight samples measured during this demonstration, each having different dimension s. In every case, the length measurements

were accurate to +/

- 1/8 in. (0.125 in.), and the diameters accurate to +/

- 1 mm. The rulers that are used to measure sample length in the AGHCF are cert ified and calibrated and the appropriate certificates documenting this are maintained by bot h ANL and ANL

- CCP. These in

- cell rulers use increments of 1/10 in. (0.1 in.), rather than 1 /8 in. (0.125 in.), and results to

- date indicate that all length measurements are now accurate to +/

- 0.1 in.