DOCKET NO: A-98-49, II-A4-158 

WASTE CHARACTERIZATION REPORT 

EPA TIER 1 EVALUATION 

OF THE CENTRAL CHARACTERIZATION PROJECT 

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM: 

ADDITION OF 8 55-GALLON K-WING FUEL EXAMINATION WASTE 

CONTAINERS TO THE REMOTE-HANDLED DEBRIS WASTE STREAM AERHDM 

AT THE ARGONNE NATIONAL LABORATORY 

September 2011

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

February 2012
i 

TABLE OF CONTENTS 

Section Page

1.0 Executive Summary ............................................................................................................ 1

2.0 Purpose of Tier 1 Evaluation .............................................................................................. 5

3.0 Purpose of This Report ....................................................................................................... 5

4.0 Scope of the Tier 1 Evaluation............................................................................................ 6

5.0 Evaluation Personnel .......................................................................................................... 6

6.0 Technical Evaluation .......................................................................................................... 7

6.1 Programmatic Requirements and Acceptable Knowledge ..................................... 8

6.2 Radiological Characterization ............................................................................... 20

7.0 Findings or Concerns ........................................................................................................ 25

8.0 Conclusions ....................................................................................................................... 25

TABLE OF TABLES 

Table 1. Tiering of RH TRU Waste Characterization Process Implemented by ANL-CCP .......3 

Table 2. T1 Evaluation Personnel ................................................................................................6 

Table 3. Batch Data Reports and Calculation Packages Examined .............................................8 

Table 4. K-Wing Fuel Examination Waste Data Tracking Summary .......................................17

Table 5. Summary of Training Records for ANL-CCP AKEs ..................................................19 

ATTACHMENTS 

Attachment A: ANL-CCP Approval Summary Table 

Attachment B: ANL-CCP Document Reference List 

Attachment C: Observation of ANL Fuel Weight Confirmation Test Program for Argonne 

Remote-Handled K-Wing Fuel Examination Waste 
ii 

ACRONYMS AND ABBREVIATIONS 

AERHDM ANL-East Remote Handled Debris Material 

AGHCF Alpha Gamma Hot Cell Facility 

AK acceptable knowledge 

AKE acceptable knowledge expert 

AKSR Acceptable Knowledge Summary Report 

Am americium 

ANL Argonne National Laboratory 

BDR batch data report 

CBFO Carlsbad Area 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 

DOE U.S. Department of Energy 

DQO data quality objective 

DR discrepancy resolution 

DU depleted uranium 

DTC dose-to-curie 

EBR-II Experimental Breeder Reactor II 

EPA U.S. Environmental Protection Agency 

FEW fuel examination waste 

FIMS fissionable isotopes mass standards 

g gram 

HBR H.B. Robinson – high burnup fuel 

HLW high-level waste 

IPNS Intense Pulsed Neutron Source 

LWA Land Withdrawal Act 

LWBR light-water breeder reactor 
iii 

MCNPX Monte Carlo N-Particle eXtended 

mrem/hr millirem per hour 

NCR nonconformance report 

NTP National TRU Program 

NWPA Nuclear Waste Policy Act 

ORIA Office of Radiation and Indoor Air 

ORIGEN Oak Ridge Isotope Generation and Depletion Code 

Pu plutonium 

R/hr Roentgen per hour 

RERTR Reduced Enrichment Research and Test Reactor 

RH remote-handled 

RTR real-time radiography 

SNF spent nuclear fuel 

Sr strontium 

T1 Tier 1 

T2 Tier 2 

TMI Three Mile Island 

TMU total measurement uncertainty 

TRU transuranic 

TRUCON TRU Content 

U uranium 

UREX Uranium extraction 

VE visual examination 

WCPIP Waste Characterization Program Implementation Plan 

WDS WIPP Waste Data System 

WIPP Waste Isolation Pilot Plant 

WMC waste matrix code 

WMP waste material parameter 

WSPF Waste Stream Profile Form 

WTS Washington TRU Solutions 
1 

1.0 EXECUTIVE SUMMARY 

This report supports the U.S. Environmental Protection Agency’s (EPA’s) decision to approve a 

Tier 1 (T1) change to implement the radiological characterization process for the K-Wing Fuel 

Examination Waste (FEW). These wastes are added to the previously approved remote-handled 

(RH) transuranic (TRU) debris Waste Stream AERHDM1 at the U.S. Department of Energy’s 

(DOE’s) Argonne National Laboratory (ANL).2 In January 2007, EPA approved the Central 

Characterization Project (CCP) to characterize RH waste at ANL. Based on EPA’s evaluation of 

ANL-CCP’s application of the EPA-approved waste characterization processes, EPA concludes 

that ANL-CCP can adequately characterize FEW from the processing of fuel pins in the K-Wing 

of Building 205 at ANL. As a result, the K-Wing FEW packaged in 55-gallon containers3 can be 

added to ANL Waste Stream AERHDM for emplacement in the Waste Isolation 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 waste characterization program at ANL 

on September 12-14, 2006. The January 2007 baseline approval applied to 45 containers of 

legacy RH debris waste. The ANL Baseline Final Inspection Report (see EPA Docket No. A-98-

49; II-A4-73) documents the approval of the acceptable knowledge (AK), radiological 

characterization using Dose-to-Curie (DTC), and visual examination (VE) processes specific to 

ANL-CCP’s RH waste characterization program. That report cited the inclusion of any 

additional containers of debris to the approved waste stream as a T1 change that requires EPA 

approval prior to implementation. Since the baseline approval, ANL-CCP has added containers 

to the approved AERHDM waste stream through T1 changes approved by EPA as shown in 

Attachment A. 

On July 11, 2011, the Carlsbad Field Office (CBFO) requested EPA approval of a T1 change to 

implement the radiological characterization process for the K-Wing FEW as part of ANL Waste 

Stream AERHDM. For all available FEW specimens with intact fuel pin cladding, ANL-CCP 

measured and recorded the length of the K-Wing FEW during VE, as described in Standing 

Order CCP-SO-ANLE-003, Revision 0. For all FEW test specimens with intact cladding but 

unavailable for measurement during VE and for all other FEW test specimens, ANL-CCP 

extracted the lengths and weights, respectively, from scientific notebooks. The K-Wing FEW 

were characterized by the method of dimensional analysis, as described in Appendix B of CCPAK-ANLE-501, Revision 5. EPA approved the use of dimensional analysis in November 2010 

(see EPA Docket No. A-98-49: II-A4-140). 

On May 18, 2010, EPA observed a method using surrogate samples to weigh fuel pin specimens 

as part of a confirmation test program to qualify the fuel specimen weights extracted from AK 

 

1

 AERHDM stands for ANL-E Remote Handled Debris Material. 

2

 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 simply ANL. Both designations are found in the documents 

EPA reviewed for this evaluation and these terms are interchangeable in this report. 

3 Containers is a generic term which applies to cans, canisters, drums, and any other types of waste 

packaging units that may be characterized individually for their radiological and physical contents. 
2 

(see Appendix C of this report). This approval confirms the adequacy of this process. 

Implementation of gravimetric analysis for waste other than debris will require EPA approval as 

a T1 change. Because this T1 request did not include any new equipment or additional new 

processes at ANL, EPA conducted a desktop review of this change. EPA did not identify any 

findings or concerns during this evaluation. As a result, EPA approves the T1 change request to 

implement the radiological characterization process for the K-Wing FEW as part of ANL-CCP’s 

previously approved AERHDM waste stream. 

This approval is limited to K-Wing FEW, but does not limit the number of containers of K-Wing 

FEW that can be characterized using the radiological process described in CCP-AK-ANLE-501, 

Revision 5, Appendix B. Inclusion of additional FEW containers from the K-Wing in Waste 

Stream AERHDM is a Tier 2 (T2) change if those containers have the same pedigree and are 

characterized using the same dimensional analysis as the FEW discussed in this report, as shown 

in Table 1 below. For such a T2 change, ANL-CCP must: 

• Notify EPA of their intention to add containers of FEW debris from the K-Wing, 

including the approximate number of additional containers and the approximate 

additional volume of waste, and provide the timeframe for waste generation, 

characterization, and disposal. 

• Provide an updated AK Summary Report (AKSR) with supporting information indicating 

that additional containers have the same pedigree as that of the approved AERHDM 

debris waste stream and an updated radiological characterization report to EPA. CBFO 

should make clear to EPA if any of these documents are modified. 

• Acknowledge that the processes, including any scaling factors, used for quantifying the 

radiological contents of these additional containers 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 characterization of a sufficient number of 

containers to generate 1-2 Batch Data Reports (BDRs), 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 additional containers belong to the approved waste stream. 

Characterization of any K-Wing FEW other than the fuel pin FEW discussed in this report is a 

T1 change, as shown in Table 1. Table 1 also shows new T1 or T2 changes or specific additions 

to existing T1s and T2s in bold text. There are several T1 and T2 changes that were established 

during the baseline approval that remain in effect, and these are listed as applicable in Sections 

6.1 and 6.2. 

This report serves as EPA’s public notification of the results of the proposed T1 change and its 

evaluation. This information will be provided through the EPA website and by sending e-mails 

to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3). 
3 

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by ANL-C

(Based on September 12–14, 2006, Baseline Inspection and Subsequent T1 Evaluations, Updated Fe

RH Waste Characterization 

Process Elements ANL-CCP RH Waste Characterization Process - T1 Changes ANL-CCP RH Waste Character

Acceptable Knowledge (AK) Any new waste streams not approved under this baseline 

Modification of the approved Waste Stream AERHDM to include additional containers beyond the approximately 45 included in 

CCP-AK-ANLE-500, Revision 1, if new or different radionuclide scaling factors are required Substantive modification(s)*** to CCP-AK-ANLE-500, CCP-AK-ANLE-501 or CCP-AK-ANLE-502 that have the potential to affect the characterization process Implementation of load management for any RH waste stream 

Characterization of any AGHCF or K-Wing FEW other than the 

fuel pins, specifically AGHCF RERTR plates FEW and crucibles 

and melts FEW (AK 1)

Notification to EPA that the final DTC 

containers in the approved waste stream 

Notification to EPA when updates are 

result of WCPIP revisions** 

Notification that updates have been com

• All future revisions of CCP-AK-

and CCP-AK-ANLE-502, includ

• Listing of the references that doc

and review process 

Notification to EPA that the data packa

completed, including any modificationWSPF, including the CRR and AK Sum

Notification to EPA when AK accurac

annually at a minimum 

Notification to EPA when Attachment 

reflect the updated AKSR Source Docu

Notification to EPA when Attachment 

updated or when Add Container Mem

Source Document C2029 (AK 5)

Notification to EPA of the intention to 

AERHDM, including the approximate of waste, the timeframe for waste geneand submission of an updated AKSR dadditional containers is the same as thosubsequent T1 approvals† Submission of a list of fully characterizadditional containers proposed as a T2 

Radiological Characterization, 

including Dose-To-Curie (DTC) 

Use of any alternate radiological characterization procedure other 

than DTC with established scaling factors as documented in CCPTP-504 and CCP-AK-ANLE-501, Revision 0, respectively, or 

Notification to EPA that revisions of C

that require CBFO approval** are comSubmission of an updated CCP-AK-AN
4 

RH Waste Characterization 

Process Elements ANL-CCP RH Waste Characterization Process - T1 Changes ANL-CCP RH Waste Character

substantive modification thereof*** Any new waste stream not approved under this baseline or addition of containers to Waste Stream AERHDM that require changing the established radionuclide scaling factors Application of new scaling factors for isotopic determination other than those documented in CCP-AK-ANLE-501 Implementation of gravimetric analysis for waste other than debris will require EPA approval as a T1 change. (RC 1) 

radiological characterization process(s) the same as those covered by the basel

Submission of DTC BDRs or calculati

by EPA from a list of fully characterize

CCP†

Visual Examination (VE) VE by reviewing existing audio/visual recordings for any waste 

Summary Category Group not covered by this approval

VE by any new process for S5000 debris wastes 

Submission of VE BDRs for containercharacterized containers provided by A

Notification to EPA that revisions of an

approval are complete Addition of new S5000 debris waste st

Real Time Radiography (RTR) Any use of RTR requires EPA approval Submission of RTR BDRs for containe

list of fully characterized containers pr

WIPP Waste Data System (WDS) None Changes made to WDS procedure(s) th

New T1 or T2 changes or specific additions to existing T1s or T2 are in bold text; references to specific sections in this report are provided on

* 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 

requested by EPA. 

*** Substantive modification refers to a change with the potential to affect ANL’s RH waste characterization process, e.g., the use of an inher

instrument 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 EVALUATION 

Certain changes to the waste characterization activities from the date of the site’s baseline 

inspection must be reported to and, if applicable, approved by EPA according to the tiering 

requirements set forth in 40 CFR 194.8 regulations and incorporated in the ANL-CCP RH 

Baseline Final Report cited above. 

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, Federal Register notice, 

EPA must perform a single baseline inspection of a TRU waste generator site’s waste 

characterization program (Vol. 69, No. 136, pages 42571–42583, July 16, 2004). The purpose of 

EPA’s 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 

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

TRU wastes destined for disposal at the WIPP. 

Following EPA’s baseline approval, EPA is authorized to evaluate and approve changes, if 

necessary, to the site’s approved waste characterization program by conducting additional 

inspections under the authority of 40 CFR 194.24(h). Changes requiring EPA notification and 

approval prior to implementation (T1), and those requiring post-implementation (T2) 

notification, are identified in the site-specific baseline inspection reports. When evaluating 

proposed T1 changes for approval, EPA may conduct a site inspection to observe first-hand the 

implementation of the change, or can opt to conduct a “desktop” review of information provided 

specific to a change. DOE may choose to characterize and dispose of any previously approved 

TRU waste using processes/procedures/equipment implemented as T2 changes at risk of 

subsequent EPA disapproval. EPA reviews T2 changes on a quarterly basis and EPA may 

conduct continued compliance inspections to evaluate implemented T2 changes to verify 

adequacy. 

3.0 PURPOSE OF THIS REPORT 

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

characterization process for the K-Wing FEW packaged in 55-gallon containers in Waste Stream 

AERHDM, as described in CCP-AK-ANLE-501, Revision 5. This report presents the technical 

basis and results of EPA’s approval decision. EPA’s approval decision regarding implementation 

of the radiological characterization process for the K-Wing 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 evaluation 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: 

Manager, National TRU Program 

Carlsbad Field Office 

U. S. Department of Energy 

P O Box 3090 

Carlsbad, NM 88221-3090 
6 

4.0 SCOPE OF THE TIER 1 EVALUATION 

The scope of this evaluation is the radiological characterization of 55-gallon containers of KWing FEW in Waste Stream AERHDM. CBFO/ANL-CCP determined that the drums containing 

K-Wing FEW are of the same pedigree as the previously approved K-Wing debris containers. 

Based on criteria set forth by EPA during Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8 

(Docket No. A-98-49; II-A4-73, January 2007) and the subsequent T1 evaluation (Docket No. A98-49; II-A4-140, November 22, 2010), a T1 request is required for characterization of any FEW 

other than the Alpha Gamma Hot Cell Facility (AGHCF) fuel pin FEW. Therefore, the scope of 

this T1 request is evaluation of the radiological characterization approach for the K-Wing FEW 

in Waste Stream AERHDM, as specified in CCP-AK-ANLE-501, Revision 5, Appendix B. 

Waste Stream AERHDM has been evaluated several times; however, this is the first EPA T1 

evaluation since implementation of Revision 2 of the Waste Characterization Program 

Implementation Plan (WCPIP). Several documents submitted along with the original July 2010 

T1 request were not compliant with the new WCPIP. EPA asked that CBFO/ANL-CCP revise 

relevant waste stream documentation to reflect the requirements of Revision 2 of the WCPIP. All 

reference to the WCPIP in this report means Revision 2, unless specified otherwise. As part of 

the review, EPA also evaluated AK to confirm that the K-Wing FEW, as described in CCP-AKANLE-500, Revision 7 (AK Summary Report or AKSR), is of the same pedigree as the 

previously approved K-Wing debris waste. 

Sections 6.1 and 6.2 of this report detail the two technical areas assessed during this evaluation: 

• Programmatic Requirements and AK, including VE 

• Radiological Characterization 

This evaluation involved expanding an existing waste stream to incorporate new containers and 

not the addition of a new Summary Category Group or waste stream; therefore inspection 

checklists were not used. 

5.0 EVALUATION PERSONNEL 

EPA and its support personnel conducted interviews with ANL-CCP personnel in several 

disciplines by telephone. The EPA evaluation team members and the personnel contacted are 

listed in Table 2 with their affiliations and technical areas of expertise. This listing includes 

personnel present at meetings conducted as part of this evaluation. 

Table 2. T1 Evaluation Personnel 

Personnel Name Affiliation Area of Expertise, Function 

Rajani Joglekar EPA ORIA Tier 1 Evaluation Lead Inspector 

Ed Feltcorn EPA ORIA Tier 1 Evaluation Inspector 

Connie Walker SC&A Acceptable Knowledge, Inspector 

Kira Darlow SC&A Acceptable Knowledge, Inspector 

Amir Mobasheran SC&A Radiological Characterization, Inspector 

Patrick Kelly SC&A Radiological Characterization, Inspector 
7 

Table 2. T1 Evaluation Personnel 

Personnel Name Affiliation Area of Expertise, Function 

Kevin Peters CCP-TechSpecs Acceptable Knowledge Expert 

Mark Doherty CCP-TechSpecs Acceptable Knowledge Expert 

Jene Vance WTS-CCP Radiological Characterization, Technical Expert 

Jim Holderness WTS-CCP Radiological Characterization, Technical Expert 

Irene Quintana WTS-CCP Site Project Manager 

Mike Sensibaugh WTS-CCP Observer 

Marcus Pinzel CBFO NTP Observer 

6.0 TECHNICAL EVALUATION 

Waste Generating Activities

The K-Wing FEW consists of residual fuel specimens and remnants from irradiated materials 

used in research conducted in K-Wing hot cells. The activities that resulted in the residual fuel 

specimens were: sample preparation for subsequent testing, including development of pyroprocessing techniques and aqueous biphasic extraction studies; leaching, degradation, and 

corrosion studies of reactor fuels intended to be disposed into the proposed Yucca Mountain 

repository; and small-scale demonstration experiments for the chemical separation of fission 

products, plutonium (Pu) and uranium (U) in the uranium extraction (UREX) process 

(References C2002, C2004, C2005, C2006, P344, P1001, P2011, P2018). The K-Wing FEW 

inventory identifies 119 discrete quantities of residual fuel pin specimens originating from 30 

fuel pin specimens (Reference U2004). These RH TRU FEW had been placed in two-liter 

shielded fuel capsules, which were subsequently placed in 55-gallon drums fitted with 140 mil 

fiberboard liners. Other non-FEW debris, including the Intense Pulsed Neutron Sources (IPNS) 

targets, was loaded in the drums with the fuel capsules (References P2038 and U2020, and VE 

BDR ANLRHVE11010). A total of eight 55-gallon drums containing K-Wing FEW have been 

generated. 

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

EPA evaluated the documentation that ANL-CCP had prepared to support the inclusion of the KWing FEW in Waste Stream AERHDM. ANL-CCP provided CCP-AK-ANLE-500, Revision 7, 

CCP-AK-ANLE-502, Revision 4, and CCP-AK-ANLE-501, Revision 5 to EPA for review. As a 

result of EPA’s review, several technical issues were identified that necessitated the revision of 

CCP-AK-ANLE-500, Revision 7, CCP-AK-ANLE-502, Revision 4, some of the associated AK 

documentation (see Section 6.1), and Revision 5 of CCP-AK-ANLE-501, Appendix B. The 

revised documents were provided to EPA prior to the conclusion of this T1 evaluation. The 

listing of all documentation reviewed is in Attachment B, and the list of VE BDRs and 

radiological characterization calculation packages examined is presented in Table 3. Because the 

radiological characterization process for the K-Wing FEW waste does not involve the generation 

of batch data reports, the characterization for each drum is documented in a separate calculation 

package, as shown in Table 3. 
8 

Table 3. Batch Data Reports and Calculation Packages Examined 

Drum Number VE BDR Number Calculation Package Number 

RW18875 RHANLVE11010 ANLE-RH-15-2 

RW18876 RHANLVE11010 ANLE-RH-15-1 

RW18877 RHANLVE11010 ANLE-RH-15-3

RW18878 RHANLVE11010 ANLE-RH-15-4

RW18879 RHANLVE11010 ANLE-RH-15-5

RW18880 RHANLVE11010 ANLE-RH-15-6

RW18881 RHANLVE11010 ANLE-RH-15-7

RW18904 RHANLVE11010 ANLE-RH-15-8

6.1 Programmatic Requirements and Acceptable Knowledge 

EPA examined the programmatic requirements and AK process and associated information to 

assess the technical adequacy of the information to support the inclusion of the K-Wing FEW in 

ANL RH Waste Stream AERHDM. 

Waste Characterization Element Description

As part of this evaluation, EPA reviewed the following with respect to programmatic 

requirements and the use of AK for RH waste characterization: 

• Evaluation scope and waste stream identification 

• Identification of the WCPIP waste characterization process 

• Adequacy of the Certification Plan and other WCPIP documentation and the waste 

qualification pathway 

• Adequacy of data management reviews, validation activities, data reporting and records 

retention 

• Adequacy of personnel training 

• Adequacy of waste stream profile form (WSPF) and related attachments 

• Adequacy of Nonconformance and Discrepancy Resolution documentation (NCRs and 

DRs, respectively) 

• Waste stream definition including radiological and physical characteristics 

• Verification that the subject waste is of defense origin and is not high-level waste (HLW) 

or spent nuclear fuel (SNF) 

• Role of AK in the characterization methodology, including radionuclide scaling factors 

• Adequacy of AK procedure and its implementation, including Attachments, AK 

Accuracy Reports, Characterization Reconciliation Reports (CRRs), and Correlation and 

Surrogate Summary Forms (CSSFs) 

• Adequacy of the AKSR and associated source documents 
9 

• AK data traceability 

• Attainment of Data Quality Objectives (DQOs) 

Technical Evaluation

EPA evaluated the adequacy of AK information specific to adding K-Wing FEW to Waste 

Stream AERHDM, as described in CCP-AK-ANL-500 (AKSR), Revision 7, CCP-AK-ANL501, Revision 5, and CCP-AK-ANL-502, Revision 4. EPA also evaluated the records relative to 

the WCPIP programmatic requirements. The specific WCPIP citation that addresses EPA 

requirements for AK is included parenthetically at the end of each component heading. 

(1) The scope of the Tier 1 request and the waste stream determination were examined for 

Waste Stream AERHDM, including the additional K-Wing fuel examination waste 

containers, and found to be adequate (WCPIP, Section 3.0, p. 13)4

.

This T1 requests approval of the radiological characterization approach for the 55-gallon 

containers of K-Wing FEW in Waste Stream AERHDM, as specified in CCP-AK-ANLE-501, 

Revision 5, Appendix B. ANL-CCP representatives stated that eight containers of K-Wing FEW 

had been characterized at the time of the T1 request and no additional containers are expected. 

The scope of the T1 request is well-defined and confined to the radiological characterization 

process for the eight 55-gallon containers of K-Wing FEW. In conjunction with evaluating the 

T1 request, EPA is evaluating the AK documentation for WCPIP compliance and to confirm that 

the K-Wing FEW is of the same pedigree as Waste Stream AERHDM. 

The WCPIP defines a waste stream as “waste material that is (1) generated from a single 

process/activity and (2) similar in material, physical form, and radiological properties.” Waste 

Stream AERHDM is a debris waste stream generated by ANL in two locations – the AGHCF 

and the K-Wing.5

 As part of the baseline and subsequent T1 approvals, EPA concluded that the 

waste stream was adequately defined but it did not at that time include K-Wing FEW. After 

reviewing the provided documentation, EPA concluded that the K-Wing FEW is of the same 

pedigree as Waste Stream AERHDM. 

The K-Wing FEW containers were generated as a result of the same hot cell activities that 

generated the previously approved K-Wing debris waste containers (see EPA Docket No. A-98-

49; II-A4-132). As indicated in the AKSR, these K-Wing FEW drums contain “fuel sections and 

fragments left over from previous experiments” and additional non-FEW debris from the same 

experiments (demonstration of the UREX process and sampling of irradiated target material). 

This non-FEW debris is from the same population of debris packaged in the previously approved 

K-Wing debris waste containers. 

 

4

 The WCPIP references are examples and are not meant to be an exhaustive list. Many of these 

requirements are discussed in several places within the WCPIP. 

5

 The AGHFC and the K-Wing Hot Cell Facility are distinct facilities located in the 200 Area of ANL-E 

that were used for similar purposes. 
10 

Based on this information, the processes that generated the source material within the waste and 

the waste itself are well understood and represent a single process or waste stream. The 

radiological and physical compositions of the waste stream are addressed in Item (7). This 

approval is limited to fuel pin FEW. (See Table 1.)

(2) The Certification Plan, including description of the waste characterization process, was 

examined and found to be complete and technically adequate (WCPIP, Section 3, pp. 14-

15). 

CCP-AK-ANL-502, Revision 4 (Certification Plan) states that a combination of characterization 

methods from WCPIP Sections 4.2 and 4.3 has been employed to characterize Waste Stream 

AERHDM, specifically the K-Wing FEW. These methods include AK, VE, and radiological 

characterization. AK is used to determine and describe the waste stream, and to define Land 

Withdrawal Act (LWA) DQOs such as the defense status of the waste [Item (9)] and absence of 

HLW and SNF [Item (8)]. VE is used to verify the physical composition of the waste stream 

[Item (7)], and modeling and AK in combination with dimensional analysis were used to 

determine the radiological composition (Section 6.2). The characterization process is adequately 

described in the Certification Plan. 

The WCPIP requires that the Certification Plan describe the process for certification of the waste 

stream, including a description of the following: 

• AK qualification and/or characterization methods selected to meet the DQOs, including 

the justification for the selection of the methods 

• Quality Assurance Objectives for the selected methods 

• Characterization and testing methods not included in the WCPIP in sufficient detail to 

allow for CBFO approval prior to implementation 

• Summary of the program documents to be prepared during the characterization and/or 

qualification methods 

EPA examined the Certification Plan and found that the document contained most of the 

fundamental information cited above plus additional information describing how AK accuracy is 

to be evaluated. The AK accuracy discussion is not a required component of the Certification 

Plan. EPA has determined that while it is not technically incorrect to include an AK accuracy 

discussion in the Certification Plan, it is acceptable if the discussion implies that AK is to be 

used to meet all of the DQOs. CCP-AK-ANLE-502, Revision 4, needed to be revised to clarify 

the relationship among AK, AK accuracy, and the DQOs. 

Additionally, the Certification Plan did not include any description of the methods implemented 

to qualify and confirm the AK-based FEW specimen weight and length measurements that were 

used in the radiological characterization process [see Item (3), below]. The Certification Plan 

must include a description of any qualification or confirmation as part of the description of the 

characterization methods used to meet the DQOs. EPA raised the issue that AK-based FEW 

specimen weight data were used for a few fuel pins, which required qualification of those data. 

ANL-CCP revised the Certification Plan to include a discussion of the AK confirmations and to 
11 

remove the initialization “DQO” from the AK accuracy discussion. The revised Certification 

Plan is technically adequate but it is in need of further editorial revision, noting that future 

certification plans developed using the text of this certification plan as a template must be 

modified to more clearly address the current WCPIP requirements. EPA may revisit this during a 

future evaluation to maintain consistency with other ANL-CCP documentation. Notification to 

EPA when formal revisions of the Certification Plan are available remains a T2 change. (See 

Table 1.) Substantive modification of CCP-AK-ANLE-502 that has the potential to affect the 

characterization process remains a T1 change. (See Table 1.) 

(3) The waste characterization methods were identified and the selected approach and 

documentation were adequate (WCPIP, Section 5, p. 13). 

Based on information presented in the Certification Plan, the physical and radiological 

compositions of the waste stream are determined through measurement, modeling, and VE. 

While some K-Wing FEW specimens were measured, the weights and lengths from the historic 

AK record are used for the following: K-Wing FEW specimens that are not contained within 

intact cladding; are contained within intact cladding but are too short to be accurately measured 

during VE (less than 0.5 inches); or, are within intact cladding but otherwise unable to be 

measured. ANL-CCP executed a Confirmation Test Program (CCP-AK-ANLE-505C, Fuel 

Weight Confirmation Test Program for Argonne Remote-Handled K-Wing Fuel Examination 

Waste) to confirm the AK-based weights and validate the AK for use in radiological 

characterization. This confirmation was correctly implemented. However, ANL-CCP did not 

confirm the AK length measurements prior to the EPA inspection. EPA discussed this with 

ANL-CCP, and a comparison of available length measurements in VE records and the 

corresponding AK was performed, as documented in Reference C3000. This comparison 

confirmed the AK length measurements for use in characterizing K-Wing FEW containers. 

After revision of the Certification Plan, EPA concluded that the AK-based data were qualified, 

and the characterization methods were adequately identified and were appropriate for this waste 

stream. 

(4) Example Nonconformance Documentation and Discrepancy Resolution forms were 

examined and found to be adequate (WCPIP, Section 3.4.2.3, p. 24). 

There have not been any NCRs or DRs generated during characterization of the K-Wing FEW 

containers. EPA examined NCRs and DR forms related to Waste Stream AERHDM during the 

ANL-CCP RH baseline inspection and subsequent T1 evaluations and found the preparation of 

these documents to be adequate. Based on EPA’s previous evaluations, EPA expects that ANLCCP would develop appropriate NCRs and DRs when necessary. 

(5) The Acceptable Knowledge procedure was examined and found to be adequate and 

appropriately implemented (WCPIP, Section 4.1, pp. 32-33). 

CCP-TP-005, Revision 23 became effective June 30, 2011. The preparation dates for the AKSR, 

Certification Plan, Radiological Characterization Report, and all revised supporting 

documentation postdate CCP-TP-005, Revision 23. Therefore, CCP-TP-005, Revision 23 is the 

appropriate revision for preparation of CCP-TP-005 attachments, noting that future changes to 
12 

any attachments should reflect the version of CCP-TP-005 in place at the time the changes are 

made. 

CCP-TP-005, Revision 23 includes 15 attachments and also requires development and 

maintenance of an AK tracking spreadsheet that presents a running compilation of drums within 

each waste stream at a site. ANL-CCP modified Attachments 1, 4, 8, and 13 to include the KWing FEW in Waste Stream AERHDM. Attachments 1, 8, and 13 were adequate as presented to 

EPA. See Item (6), below for discussion about Attachment 4. 

Attachment 8 is the waste stream container list used to develop the SWSPF. The Attachment 8 

provided for this T1 evaluation was revised July 12, 2011, and includes all containers added to 

Waste Stream AERHDM as of that date. CCP has recently implemented a new approach to 

tracking the addition of containers to approved waste streams. For all waste streams, the 

Attachment 8 will no longer be updated after approval of the AKSR; instead, it will be updated 

either after the first approval or, as for Waste Stream AERHDM, after the first approval 

following this change in CCP policy. Add Container Memoranda will be filed in single source 

documents and will serve as the official record for additional containers. 

As this change was recently implemented, EPA has not had a chance to evaluate the entire 

process. EPA confirmed that the “Waste Container Evaluation Memorandum for Waste Stream 

AERHDM” file contains all Add Container Memoranda generated since the initial AKSR 

approval (Reference C2029). ANL-CCP representatives indicated that Source Document C2029 

will be updated continuously as additional containers are added to the waste stream and that the 

AK Tracking Spreadsheet will continue to be updated, as in the past. EPA finds that this new 

process is acceptable for Waste Stream AERHDM based on review of Attachment 8, Source 

Document C2029, and the AK Tracking Spreadsheet. EPA will continue to review 

implementation of this process during future evaluations. Notification to EPA when Add 

Container Memoranda have been added to Source Document C2029 is a new T2 change. (See 

Table 1.) 

(6) The Acceptable Knowledge Summary Report was examined, along with the reference list 

and associated source documents, and found to be adequate (WCPIP, Section 4.1, p. 31). 

EPA examined Revision 7 of the AKSR and found that the document did not clearly quantify the 

impact that the K-Wing FEW would have on the waste material parameter (WMP) calculations 

and included incorrect information describing the radiological characterization process. Section 

6.0 of the AKSR also needed to be revised to correct a typographical error and to update the text 

to be WCPIP compliant and consistent with CCP-AK-ANLE-502. ANL-CCP revised the AKSR 

to correct Section 6.0 and to explicitly account for the K-Wing FEW in the WMP calculations. 

EPA finds the revised AKSR to be adequate. 

EPA also examined the source document reference list (CCP-TP-005, Revision 23, Attachment 

4) as provided July 11, 2011, and found that this document did not contain a record of the 

memorandum that ANL provided to the ANL-CCP radiological characterization personnel that 

described the radionuclide activities of the IPNS Targets [see Item (7), below]. ANL-CCP 
13 

revised the source document reference list to include this memorandum. EPA finds the revised 

Attachment 4 to be adequate. 

Any substantive modifications to the AKSR that have the potential to affect the characterization 

process continue to be T1 changes. Notification to EPA upon minor revisions of the AKSR 

continues to be a T2 change. (See Table 1.) 

(7) The radiological and physical properties of the waste stream were examined and found to 

be adequately described for the K-Wing fuel examination waste based on acceptable 

knowledge (WCPIP, Section 3.0, p. 13). 

The K-Wing FEW is residual material from fuel examinations that contaminated the previously 

approved K-Wing debris waste containers, plus four IPNS Targets. The same AK source 

documents were used to determine the ORIGEN2.2 inputs for both the K-Wing FEW containers 

and the previously approved K-Wing debris waste containers. However, as indicated in the 

Certification Plan, the same scaling factors were not applied to this set of the K-Wing FEW 

containers because the radionuclide activity and mass for each container were more accurately 

calculated based on the masses of the discrete fuel test specimens in the individual drums. The 

mass of each test specimen was determined using measurements taken during VE or using 

qualified AK-based data [see Item (3), above]. ANL-CCP calculated the radionuclide activities 

for the IPNS targets using the computer code MCNPX (see Section 6.2). The radiological 

contribution of the debris packaged with the K-Wing FEW is expected to be minimal and is 

therefore excluded. 

The physical characteristics of each container are recorded on VE data sheets and the physical 

measurements of FEW specimens in Container Nos. RW18876 (weight), RW18877 (weight and 

length), and RW18878 (weight) are documented in VE Logbook RH-ANLE-VE-009. The VE 

operators who created the VE data sheets (in VE BDR RHANLVE11010 in Table 3, above) 

assigned Waste Matrix Code (WMC) S5400, Heterogeneous Debris to the examined K-Wing 

FEW containers. This is the same WMC as was assigned to the previously approved K-Wing 

debris containers in Waste Stream AERHDM, which is one indication that the K-Wing FEW 

containers have the same physical characteristics as those in the approved waste stream. 

The K-Wing FEW is placed in shielded fuel capsules (approximately 2 liters in size) and then 

packaged in 55-gallon containers along with other K-Wing debris waste. Therefore, ANL-CCP 

considers that the K-Wing FEW will have a minor impact on the WMPs previously calculated 

for Waste Stream AERHDM (Reference U2020 and CCP-TP-005, Revision 19, Attachment 6). 

Revision 7 of the AKSR did not explicitly state that the K-Wing FEW would have minimal 

impact on the WMPs [see Item (6), above]. The AKSR was revised to include the expected 

impact of K-Wing FEW on the WMPs and a memorandum was added to CCP-TP-005 

Attachment 6 to provide additional information. VE performed at the time of packaging 

confirmed the absence of prohibited items. EPA’s review confirmed that neither prohibited items 

nor liquids were observed, and the VE BDR was adequate. 
14 

(8) The waste stream information was examined and indicates that the waste stream does not 

contain spent nuclear fuel or high-level waste (WCPIP, Section 2.2.7, p. 12). 

The LWA prohibits the WIPP disposal of SNF fuel and HLW waste, as defined by the Nuclear 

Waste Policy Act (NWPA). The NWPA states SNF is “fuel that has been withdrawn from a 

nuclear reactor following irradiation, the constituent elements of which have not been separated 

by reprocessing.” DOE M435.1-16expands on this definition and states that, “test specimens of 

fissionable material irradiated for research and development only, and not production of power 

or plutonium, may be classified as waste, and managed in accordance with the requirements of 

this Order when it is technically infeasible, cost prohibitive, or would increase worker exposure 

to separate the remaining test specimens from other contaminated material.” The NWPA defines 

HLW as “the highly radioactive material resulting from the reprocessing of spent nuclear fuel, 

including liquid waste produced directly in reprocessing and any solid material derived from 

such liquid waste that contains fission products in sufficient concentrations, and other highly 

radioactive material that the Commission, consistent with existing law, determines by rule 

requires permanent isolation.” 

ANL-CCP determined that the debris wastes generated during deactivation, decommissioning 

and demolition activities of the K-Wing facility contain residual radiological contamination from 

operations conducted from 1996 until 2007, and do not contain irradiated fuel elements 

withdrawn from a reactor. The FEW component of the K-Wing debris includes test residues and 

specimens, and the resultant test fragments from the fuel pin test specimens, including irradiated 

pin fragments, fines and dust. EPA inspected the K-Wing inventory documentation and agrees 

that the radiological materials managed in the K-Wing were primarily fuel samples and swarf7, 

as indicated by the size of the material in the K-Wing inventory (Reference U2004). ANL-CCP 

also states that the intact irradiated fuel pins were managed separately and are not included in the 

waste stream. As a result, the K-Wing FEW is not considered SNF. 

Because ANL-CCP determined that the K-Wing FEW is not SNF, the waste could not contain 

HLW, by definition. While the K-Wing UREX process demonstrations included reprocessing 

research, by virtue of taking place within a hot cell, these research and development laboratory 

operations were not production operations involving the separation or reprocessing of constituent 

elements from reactor fuels. Therefore, ANL-CCP concluded that HLW was not generated 

(References P2019, P2023, and P2024); thus the waste is not SNF or HLW and EPA accepts 

these arguments as reasonable. Note that ANL-CCP is not including any of the vitrified samples 

of HLW or waste surrogates from West Valley and Savannah River Site used during Yucca 

Mountain corrosion studies that are part of Waste Stream AERHDM and are stored in the KWing, pending further evaluation. This type of waste can only be sent to WIPP with TRU waste 

if statutory changes to the LWA occur. 

 

6

 DOE M435.1-1 is the Department of Energy’s Radioactive Waste Management Manual. 

7

Swarf is material produced by a cutting or grinding process. 
15 

(9) The waste stream information was examined and indicates the waste stream has a defense 

pedigree (WCPIP, Section 2.2.7, p. 12). 

EPA previously evaluated and approved the defense waste determination of Waste Stream 

AERHDM for the K-Wing waste during a T1 evaluation (see EPA Docket No. A-98-49; 

II-A4-132). EPA determined that the AK record contains sufficient evidence to demonstrate that 

all of the TRU wastes generated by K-Wing operations contain materials from atomic energy 

defense activities associated with naval reactor development, materials security and safeguards, 

and defense research and development activities. Defense-related spent fuels managed in KWing after 1995 included those obtained from the Experimental Breeder Reactor II, Hanford N 

reactor, Shippingport Light Water Breeder Reactor and Reduced Enrichment Research and Test 

Reactor Program (RERTR), which were also used in Yucca Mountain corrosion studies and 

high-burnup characterization studies (References C006, C2004, C2007, and U001). ANL-CCP 

representatives also indicate that because the K-Wing continues to “store, manage, and utilize 

research materials... accumulated throughout the... operational history” and the impossibility of 

“separation of contamination from destructively examined specimens,” all RH TRU debris waste 

from the K-Wing meets the WIPP requirement of defense-related waste (Reference C2027). The 

K-Wing FEW is a subset of the materials processed in the K-Wing. Therefore, the K-Wing FEW 

containers that are added to Waste Stream AERHDM meet the WIPP requirement of defenserelated waste. 

(10) The Waste Stream Profile Form and attached Characterization Reconciliation Report 

were examined and found to be adequate (WCPIP, Section 3.4.2.1, p. 22). 

The WCPIP includes specific requirements for the contents of the WSPF and the CRR. The 

WSPF for Waste Stream AERHDM does not meet the WCPIP requirements because it has not 

been revised since the WCPIP revision was approved. EPA’s policy with respect to revision of 

documents to meet requirements in Revision 2 of the WCPIP is that documents such as the 

WSPF do not need to be revised just to meet the new requirements, but if the document has to be 

revised for other reasons, it must also be brought into compliance with the revised WCPIP, and 

EPA notification of this revision is necessary. 

ANL-CCP personnel stated that change notices to WSPFs are initiated if: the addition of material 

parameter weight estimates per unit of waste is required; the TRU Content (TRUCON) Codes 

change; or, if the waste stream volume changes. The AERHDM WSPF was approved in May 

2008, and a Change Notice was approved in September 2010 in response to the addition of a 

TRUCON Code and an increase in waste stream volume. ANL-CCP personnel stated that waste 

stream volume increase included in the September 2010 Change Notice accounted for the KWing FEW and, therefore, a Change Notice will not be initiated as a result of this T1 evaluation. 

EPA agrees that the WSPF does not need to be revised for WCPIP compliance. The WSPF for 

Waste Stream AERHDM is adequate. 

The CRR is attached to the WSPF and must contain the following, at a minimum: 

• Specification of applicable site and waste stream 

• Listing of each DQO 
16 

• Data from the AK record that addresses each DQO 

• AK source document references that support/provide the data 

• Listing of AK record DRs, if any, that are relevant to each DQO 

• Documentation, including specific references, of how the AK data for each DQO were 

qualified, such as BDRs, corroborative data, proceedings of a peer review 

• Radiography and/or VE summary to document that prohibited liquids are absent from the 

waste and to confirm the physical properties of the waste 

• Summary presentation of radiological data used to meet the DQOs and to confirm AK 

• Complete AK summary (unless previously submitted) 

• Complete listing of all container identification numbers used to generate the WSPF, 

cross-referenced to each BDR 

• Signature of the Site Project Manager 

ANL-CCP representatives provided a draft CRR on July 11, 2011, that EPA evaluated and found 

was adequate, in spite of typographical errors. As required in EPA’s baseline approval, revision 

of the WSPF and related attachments, including the CRR, remains a T2 change, and EPA will 

receive notification of these changes when they are made. Notification to EPA upon availability 

of WSPF Change Notices is a new T2 change. (See Table 1.) 

(11) The AK Accuracy Report was examined and found to be adequate; a Correlation or 

Surrogate Summary Form was not required (WCPIP, Section 3.2.2, pp. 17-19, and 

Section 4.1, p. 30). 

Completion of a CSSF is required when AK from a related contact-handled (CH) waste stream is 

used in the RH waste characterization process. During the ANL-CCP baseline inspection, an 

ANL-CCP representative indicated that CH data were not used in this manner. Inclusion of KWing FEW waste in Waste Stream AERHDM also did not require completion of a CSSF. 

EPA examined the draft AK Accuracy Report provided July 11, 2011, and found that it did not 

adequately address evaluation of the expected radionuclide distribution. Also, this report implies 

that AK accuracy is used to evaluate whether the DQOs were met and that ANL-CCP used 

qualified AK information to meet all of the DQOs. ANL-CCP revised the AK Accuracy Report 

to address these issues and, while the revised draft AK Accuracy Report is in need of further 

editorial revision, it is technically adequate. Since ANL-CCP uses the same AK Accuracy Report 

template for all of the lots in a waste stream, EPA may suggest further clarification edits during a 

future review. Notification to EPA when AK accuracy reports are completed remains a T2 

change. (See Table 1.) 
17 

(12) Drum data are adequately traceable and are in the Acceptable Knowledge record 

(WCPIP, Section 3.4.4.1, p. 20; Section 3.4.2.2, p. 23, and Section 4.1, pp. 29-34). 

EPA examined traceability of AK data to understand the waste generation, packaging, 

processing, transport, and characterization processes up to and including the characterization 

activities performed by ANL-CCP. The K-Wing FEW containers are newly generated, so there 

are no original data packaging sheets or other generator documentation associated with 

individual containers. The K-Wing FEW packaged in the containers, however, has been stored in 

the K-Wing as accountable materials.8 Therefore, there are historic records for the FEW contents 

of the individual containers. ANL-CCP indicated that eight containers have been generated and 

undergone ANL-CCP VE and radiological characterization. EPA was provided VE BDR 

ANLRHVE11010 that included all eight K-Wing FEW containers, Nos. RW18875-RW18881 

and RW18904. Examination of these data indicated that each drum contained one or two 

shielded containers containing FEW along with other K-Wing trash debris. The VE BDR also 

identifies the specific FEW test specimens in each container. This information links the FEW 

contents to specific line items in the K-Wing inventory containing the historic weight and length 

measurements. The length measurements for the FEW test specimens that could be measured are 

recorded in various VE logbooks. A few of the K-Wing FEW test specimens are also traceable to 

the AGHCF inventory of accountable materials. EPA’s traceability analysis of four of these 

containers is summarized in Table 4, below. 

Table 4. K-Wing Fuel Examination Waste Data Tracking Summary

Drum FEW 

Specimens 

VE Length 

Measurement

Historic 

Length/ Weight 

Information 

Calculation 

Package 

AGHCF Record 

(information from C2027) 

RW18875 ANL #6 N/A Weight from 

U2004 ANLE-RH-15-2 

RW18878 

HBR 

(A/G611C4, 

c22) 

N/A Weight from 

U2004 ANLE-RH-15-4 

U303 (PDF p. 56): Samples from 

AGHCF to K-Wing June 2003. 

U304 (PDF p. 4): Sectioning of 

samples in AGHCF, subsequent 

analysis in K-Wing. 

RW18881 

18 from: 

Limerick 

(A/G574B2); 

Shippingport 

LWBR 

(A/G340); NReactor 

(A/G562); 

ATM-103, 

109 

N/A 

9 lengths, 9 

weights from 

U2004 

ANLE-RH-15-7 

U1003: Receipt of A/G 340 fuel 

specimens from Idaho in AGHCF 

from1986–1988. Identifies 

ongoing management of met 

mounts and samples from Sections 

340A, C, E, G, H, J and transfer of 

samples to K-Wing in 2001. 

P344: Discusses excising and 

analysis of Limerick fuel rod 

sample 574B2 in AGHCF, 

followed by preparation of 

specimen for analysis in K-Wing. 

 

8 Accountable materials are nuclear items and related materials that must be controlled as specified in DOE 

Order 410.2, Management of Nuclear Materials, and generally include fissile materials, source materials used to 

produce fissile materials and other materials of special interest. 
18 

Drum FEW 

Specimens 

VE Length 

Measurement

Historic 

Length/ Weight 

Information 

Calculation 

Package 

AGHCF Record 

(information from C2027) 

P519: Describes preparation of 

574B in AGHCF

RW18904 

53 from: 

ATM-103, 

106, 109; 

EBR-II MOX 

(A/G498); 

TMI 

(A/G536); 

Limerick 

(A/G574B2); 

N-Reactor 

(A/G562); 

LWBR 

(A/G340J); 

IPNS 

5 lengths in 

logbook: RHANLE-VE007 

2 lengths, 46 

weights from 

U2004; IPNS 

data in C2032 

ANLE-RH-15-8 

See A/G340J, A/G574B2, and 

A/G562 references above; 

U1003: Specimens 498A and 498B 

transferred in AGHCF early 1995. 

P515, P518, P523: Sectioning and 

testing TMI fuel 536, including 

AGHCF test plans. 

During the initial traceability analysis, EPA determined that the K-Wing FEW inventory in 

Source Document U2004 did not clearly match the FEW test specimens identified in the VE 

BDR. ANL-CCP representatives explained that the weights and lengths for radiological 

characterization had been gleaned from a different K-Wing inventory document provided 

directly to the radiological characterization personnel. This new K-Wing inventory document is 

AK and, as such, must be identified as a source document and filed with CCP Records. ANLCCP AK personnel added the new K-Wing inventory to Source Document U2004 and updated 

the Attachment 3, Source Document Summary Sheet to include the additional record. 

EPA repeated the traceability analysis using the new K-Wing inventory and additional logbook 

information and found that the drum data are adequately traceable in the AK record. 

(13) Acceptable Knowledge Training was examined and found to be adequate (WCPIP, 

Section 4.1, p. 32). 

The WCPIP indicates that characterization program personnel responsible for compiling AK, 

characterizing RH TRU waste streams using the AK process, and assessing the AK 

characterization shall be qualified and trained in the following: 

• The WCPIP 

• Characterization program NCR and corrective action processes 

• Site-specific training relative to the site’s waste streams, e.g., current AKSRs 

• Determination of radiological contents of individual containers

Mr. Kevin Peters wrote the AKSR and Ms. Lisa Watson signed several of the AK attachments 

revised in association with the K-Wing FEW T1. Table 5, below, summarizes the objective 

evidence provided demonstrating Mr. Peters’ and Ms. Watson’s training. The current 

qualification card for Ms. Sherry Aukland was also reviewed because she signed some of the 
19 

revised AK attachments for Mr. Peters. Ms. Aukland did not collect AK for this waste stream 

and only fulfilled the role of a clerk to expedite the revision process. Therefore, EPA agreed that 

only a review of her qualification card was necessary. 

Table 5. Summary of Training Records for ANL-CCP AKEs 

Name WCPIP 

Nonconformance 

and Corrective 

Action Process 

(CCP-QP-005) 

Site-Specific 

Training 

Determining 

Radiological 

Contents of 

Containers 

Current Revision of 

CCP-TP-005 

Kevin Peters Qual Card Qual Card

CCP Document 

Control 

Screenshot

Briefing R23: Briefing and 

Att 8, 3s, 13

Lisa Watson Qual Card Qual Card E-Mail 

Statement Briefing R23: Briefing and Att 1, 4 

Through interviews and the above-mentioned documentation, EPA finds training for AK 

personnel to be adequate. EPA notes that providing the IPNS Targets memorandum and the KWing inventory directly to ANL-CPP radiological personnel [See Items (6) and (12), 

respectively] may indicate that the radiological personnel also collect AK information and should 

therefore be subject to the same training requirements as the AK Experts (AKE). EPA will revisit 

this matter at a later date with upcoming T1 approvals, if this pattern of sharing source 

documents with the radiological personnel continues. 

(14) Data Quality Objectives were evaluated and found to be adequately met (WCPIP, Section 

3.4.2, p. 22). 

The WCPIP identifies the following DQOs that must be addressed: 

Defense Waste, High-Level Waste, and Spent Nuclear Fuel Determination (Regulatory Basis: 

LWA): This is required to ensure that the waste stream was generated by atomic energy defense 

activities, is not HLW, and is not SNF. These are addressed in CCP-AK-ANLE-500, Revision 8, 

and CCP-AK-ANLE-502, Revision 5, as discussed in Items (9) and (8), above. 

Radioactive Properties (Regulatory Basis: LWA, EPA Certification of the WIPP): 

• TRU Waste Determination: Waste must contain more than 100 nanocuries of TRU 

isotopes per gram of waste 

• RH Waste Determination: Surface dose rate must be equal to or greater than 200 millirem 

per hour (mrem/hr) and less than 1,000 rem per hour

• Activity Determination: The total waste inventory can be no more than 5.1 million curies 

(Ci) of RH TRU; activity limit per canister is 23 Ci per liter; and all radionuclides 

important to release calculations must be tracked 

These three DQOs are addressed in CCP-AK-ANLE-501, Revision 7, as discussed in Section 

6.2, below. 
20 

Physical Properties (Regulatory Basis: EPA Certification of the WIPP): 

• Liquids: The absence of liquids in excess of one percent must be confirmed 

• Physical Form: The physical form of the waste to delineate the waste stream as required 

by the final certification rule must be determined

These two DQOs are addressed in VE BDR No. ANLRHVE11010, as discussed in Items (7) and 

(12), above. 

EPA determined that the documents cited above support that all DQOs were achieved and that 

AK data used to quantify parameters were adequately qualified. 

Summary of Acceptable Knowledge Findings and Concerns

The EPA evaluation team did not identify any AK-related findings or concerns relative to the 

inclusion of K-Wing FEW in Waste Stream AERHDM during this T1 change evaluation. 

Acceptable Knowledge Approval

Based on the results of this evaluation, EPA concurs that the K-Wing FEW is of the same 

pedigree as waste already approved for inclusion in Waste Stream AERHDM and finds that all 

procedural requirements have been met. Based on this evaluation, EPA has added new T1 and 

T2 change requirements (see bold text inserts in Table 1). 

6.2 Radiological Characterization 

Radiological Characterization Overview

Radiological characterization of the K-Wing FEW is based on determining the total mass of 

discrete fuel specimens in individual drums and assigning a radionuclide activity distribution per 

unit mass of the loaded specimens. The form of the fuel materials and availability of information 

allow the direct determination of a container-specific value for the 10 WIPP-tracked 

radionuclides, specifically cesium-137 (137Cs), americium-241 (241Am), plutonium-238 (238Pu), 

plutonium-239 (239Pu), plutonium-240 (240Pu), plutonium-242 (242Pu), strontium-90 (90Sr), 

uranium-233 (233U), uranium-234 (234U), uranium-238 (238U), and other radionuclides, as 

applicable. 

The K-Wing FEW includes 30 fuel specimens, some of which are contained in intact fuel 

cladding while others are powders and irregular pieces. The fuel-pin specimens were measured 

for length and weight, as needed, and their masses were determined by multiplying the measured 

length and the fuel mass per unit length provided by AK. For fuel pin specimens that could not 

be measured, the mass and length values were taken from historic AK data, which were qualified 

using VE on a subset as part of a confirmation test program. 
21 

Figure 1. Radiological Characterization Process for FEW

Retrieve records on fuel 

compositions, burnups, 

reactor discharge dates, fuel 

pin physical parameters, 

and characterization date 

Obtain from the VE records 

the length of intact fuel pins 

loaded into the drum and 

calculate the fuel mass 

Develop and execute Test 

Program to confirm 

historical weight 

measurement data on nonclad fuel specimens 

Retrieve historical weight 

measurement data on nonclad fuel specimens 

From VE records, confirm 

containers and masses of 

non-clad fuel specimens 

loaded into the drum 

Calculate fuel mass loading 

per unit length of each fuel 

pin 

Make ORIGEN2.2 runs 

for 30 fuel pins involved 

in K-Wing hot cell 

activities to determine 

mass and/or activity of 

radionuclides of interest 

per-unit-mass 

Collect relevant AK on 

K-Wing FEW 

Develop and execute 

Waste Certification Plan 

Calculate activity and 

mass for reportable 

radionuclides 

Determine uncertainties in 

the recorded activities and 

masses of the radionuclides 

Using MCNPX, determine 

the activity of any DU 

target from IPNS if loaded 

into the drum 
22 

The activity distribution of the radionuclides was determined with ORIGEN2.2 using preirradiation composition (235U enrichment, U/Pu ratio, 240Pu enrichment), burnup, and decay time 

of the K-Wing fuel specimens obtained from AK as input. The decay time is the time difference 

between the reactor discharge date and the shipment date, assumed to be the date that the drum is 

characterized. The activities of individual radionuclides obtained from ORIGEN2.2 are applied 

to the quantities in each container, allowing the determination of the container’s total activity. 

As described above, following measurement the specimens were placed into shielded fuel 

capsules, which were then placed into eight 55-gallon drums, Nos. 18875-18881, and 18904. 

Each drum is unique and there is one calculation package per waste drum. EPA expects that the 

format and technical approach embodied in ANLE-RH-15-1 and referenced in ANLE-RH-15-2 

through ANLE-RH-15-8 will be the same for the other seven K-Wing FEW drums EPA 

evaluated for this approval. An overview of the radiological characterization process used for the 

K-Wing FEW and depicted in Figure B3-1 of CCP-AK-ANLE-501, Revision 5, is provided in 

Figure 1, above. 

EPA evaluated the characterization methods used for the K-Wing 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 the personnel involved in the RH waste characterization 

program. Additionally, EPA personnel observed the actual measurement of fuel elements at 

ANL, as described in Attachment C.

Documents Reviewed

Attachment B includes all documents related to the INL-CCP RH TRU radiological 

characterization program that were examined to support this T1 evaluation. 

Technical Evaluation

(1) The EPA inspection team evaluated the methodology and the technical approach used to 

characterize and document the K-Wing FEW and determined that they were technically 

adequate. 

The information that formed the basis of the radiological characterization process was reviewed. 

Specifically, the “direct” method used to replace DTC as documented in CCP-AK-ANLE-501, 

Revision 5, and the supporting calculation packages were reviewed. The following aspects of the 

characterization process were evaluated: 

• The methodology and the technical approach of the dimensional measurement 

• Information on fuel pin lengths extracted from VE records 

• ORIGEN2.2 analyses of the 30 fuel pins involved in K-Wing hot cells research and 

experimental activities resulting in the K-Wing FEW

• Utilization of fissionable isotopes mass standards (FIMS) data 

• Determination of reportable radionuclides and the bounding analysis performed 
23 

• Retrieval of records and information from the K-Wing programs 

• Fuel specimen physical characteristics needed for ORIGEN2.2 for determination of the 

total activity content of drums 

• Utilization of pre-irradiation fuel composition (233U enrichment, U/Pu ratio, 240Pu 

enrichment), fuel burnup, date of discharge from reactor (end-of-irradiation date), and 

decay duration as input data for ORIGEN2.2 analyses

• Activity in Ci and mass in grams (g) and the associated uncertainties that were 

determined for the ten WIPP-Tracked radionuclides (233U, 234U, 238U, 238Pu, 239Pu, 240Pu, 

242Pu, 241Am, 137Cs, and 90Sr), curium-244 (244Cm), curium-245 (245Cm), cesium-134 

(

134Cs), europium-154, yttrium-90, and barium-137m 

• The bounding analysis involving a set of fuel types to represent the population of fuel 

pins in the K-Wing inventory for Fissile Gram Equivalent, Pu Equivalent Curies, and 

decay heat in Watts 

• The appropriateness of the choice of physical constants and radionuclide-specific 

attributes (specific activity, physical half-life, decay heat, neutron cross-sections, photon 

transition probabilities, etc.) and the technical correctness of the values assigned to each 

attribute 

CCP-AK-ANLE-501, Revision 5, states that the waste stream also includes four targets from the 

IPNS, and that ANL-E staff determined the radionuclide content of each target using the 

MCNPX computer code. The total activities for these drums were obtained by adding the 

activities of the targets and fuel specimens. EPA was not provided a calculation package 

documenting this activity; however, the radiological contribution of the IPNS targets is expected 

to be minimal and was therefore excluded. 

The constants and other values in the calculation packages were taken from the appropriate 

sources and were spot-checked for accuracy. Calculations were performed using an Excel 

spreadsheet, as shown in Figure B4-3 of CCP-AK-ANLE-501, Revision 5, using the following 

input: 

• Date of characterization 

• Waste stream designation 

• Container number 

• Number of steel FEW containers 

• Container gross weight 

• Container net weight 

• Waste material type 

• Radionuclides and their activities 

There were no concerns regarding the methodology, technical approach and documentation used 

for radiological characterization of the K-Wing FEW. Implementation of gravimetric analysis for 

waste other than debris will require EPA approval as a T1 change. (See Table 1.) 
24 

(2) Technical aspects and documentation of the radiological characterization process were 

evaluated and found to be acceptable. 

CCP-AK-ANLE-501 is the main document that describes the radiological characterization 

process, supported by a series of calculation packages. EPA reviewed Revision 5 of CCP-AKANLE-501 and found it to be adequate, although it required minor corrections, e.g., citing the 

use of MCNP5 for the RH determinations as is typically performed in conjunction with DTC but 

is not applicable to the K-Wing FEW containers. EPA also reviewed 11 calculation packages 

that had been prepared by Derek Ott and James Holderness and reviewed by Jene Vance. The 

characterization for each drum is documented in a single calculation package that effectively 

replaces a BDR, in that it documents the specific details of each drum, i.e., the activities and 

masses of the 10 WIPP-tracked radionulcides and their uncertainties. Calculation package 

ANLE-RH-15-1, Revision 0, Radiological Characterization of K-Wing Drum 18876, provided 

detailed calculations for Drum No.18876, which EPA reviewed in detail. The calculations for the 

other seven drums referenced this package and showed the changes and the corresponding 

results. 

The EPA evaluation team determined that CCP-AK-ANLE-501 adequately documented the 

radiological characterization process for the K-Wing FEW, and the calculation packages 

adequately supported the activities upon which the radiological characterization is based. The 

drum-specific calculation packages adequately replaced BDRs and contained the necessary 

information to support their characterization. There were no issues related to the documentation 

of technical aspects of the ANL-CCP radiological characterization approach for the K-Wing 

FEW. 

(3) The technical basis and derivation of Total Measurement Uncertainty were evaluated and 

were found to be adequate. 

The development of Total Measurement Uncertainty (TMU) for Waste Stream AERHDM is 

based on the propagation of uncertainties present in all aspects of the determination of the 

radiological constituents. These aspects are assumed to be independent, which allows them to be 

added in quadrature.9

 However, for the K-Wing FEW there are two sources of uncertainty that 

are statistically dependent: (1) the specimen mass determination; and (2) a single drum 

containing multiple fuel specimens from the same fuel pin or subassembly. The TMU 

determination included contributions of the following sources of uncertainties: 

• Specimen mass determination involving length measurement and mass-per-unit-length 

uncertainty 

• Specimen mass determination based on weight measurement involving specimen weight 

measurement, tare weight determination 

 

9

 Adding in quadrature is a standard statistical technique that allows one to combine the square root of the 

sum of each contributor to uncertainty squared, resulting in a lower value than what would be obtained if the values 

were simply added. 
25 

• ORIGEN2.2 analysis uncertainty (benchmark uncertainty, including all sources of 

uncertainty: uncertainties in code inputs, uncertainties in the code, and the model 

uncertainties) 

A general treatment of TMU is presented in CCP-AK-ANLE-501, Revision 5. There were no 

concerns regarding the technical derivation and documentation of TMU for ANL Waste Stream 

AERHDM containing the K-Wing FEW. 

(4) Remote-handled determinations were evaluated and found to be adequate. 

The determinations that each container in the stream was RH, i.e., had a contact dose rate in 

excess of 200 mrem/hr, were based on surveys taken by ANL-E Health Physics personnel, as 

recorded on Building No. 205 K-Wing survey forms. All containers were measured using a 

Ludlum Model 9-7 portable survey meter, SN 2614, and had a current calibration for all eight 

measurements, as documented on the survey forms. The contact gamma dose rates were listed in 

R/hr (Roentgen per hour) and ranged from 11.3 R/hr to 43.3 R/hr. All eight drums had contact 

dose rates in excess of the 200 mrem/hr criterion for RH wastes. 

Summary of Radiological Characterization Findings and Concerns

The EPA evaluation team did not identify any radiological characterization-related findings or 

concerns relative to the inclusion of K-Wing FEW in Waste Stream AERHDM during this T1 

change evaluation. 

Radiological Characterization Approval

Based on the results of this evaluation, EPA approves the process of determining the radiological 

content of the K-Wing FEW, as described in this report. 

7.0 FINDINGS OR CONCERNS 

Summary of Findings and Concerns 

The EPA inspection team did not identify any findings or concerns related to AK or radiological 

characterization. EPA worked interactively with their ANL-CCP counterparts to answer 

questions, identify information needs, and acquire necessary data and references; all potential 

issues were resolved in a timely fashion. There are no open issues related to AK or radiological 

characterization resulting from this T1 evaluation.

8.0 CONCLUSIONS 

EPA concluded that the waste characterization processes of AK and radiological characterization 

used to characterize RH TRU K-Wing FEW as part of ANL Waste Stream AERHDM are 

adequate, as evidenced by the records evaluated. There are no open issues relative to this T1 

evaluation. 
26 

Approval 

This T1 change consisted of the radiological characterization technique for the K-Wing FEW as 

part of ANL Waste Stream AERHDM. Based on the results of this evaluation, EPA approves 

this T1 change for Waste Stream AERHDM, consistent with the limitations specified in this 

report. 
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 

Tier 1 Change – Approval of 100 additional drums of AGHCF debris 

waste 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-A4-134 

Tier 1 Change – Addition of AGHCF fuel pin FEW to Waste Stream 

AERHDM November 2010 A-98-49; II-A4-140 
B-1 

ATTACHMENT B 

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION 

CCP-AK-ANLE-500 Central Characterization Project Acceptable Knowledge Summary Report 

For Argonne Remote-Handled Debris Waste, Waste Stream: AERHDM, Revision 7, August 12, 

2011 and Revision 9, December 21, 2011 

CCP-AK-ANLE-501, Central Characterization Project Remote-Handled Transuranic 

Radiological Characterization Technical Report for Remote-Handled Transuranic Debris Waste 

From Argonne National Laboratory-East, Revision 5, June 22, 2011 and Revision 7, January 3, 

2012 

CCP-AK-ANLE-502, Central Characterization Project RH TRU Waste Certification Plan for 40 

CFR Part 194 Compliance and Confirmation Test Plan for ANL RH Waste Stream: AERHDM, 

Revision 2, August 3, 2011 and Revision 6, December 28, 2011 

CCP-AK-ANLE-505C, Central Characterization Project Fuel Weight Confirmation Test 

Program for Argonne Remote-Handled K-Wing Fuel Examination Waste, Waste Stream: 

AERHDM, Revision 0, May 17, 2010 

CCP-TP-005, CCP Acceptable Knowledge Documentation, Carlsbad, New Mexico, Washington 

TRU Solutions, LLC 

CCP-TP-005, Revision 19, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging, Waste Stream AERHDM, 

August 3, 2010; Memorandum added September 15, 2011

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Document Checklist, Waste Stream AERHDM, July 6, 2011 

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, Waste Stream AERHDM, July 6, 

2011 and October 20, 2011 

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers, Waste Stream AERHDM, July 5, 2011 

CCP-TP-005, Revision 23, CCP Acceptable Knowledge Documentation, Attachment 13 – CCP 

Waste Stream Characterization Checklist, Waste Stream AERHDM, Draft, Provided July 11, 

2011 

Characterization Reconciliation Report for AERHDM, Draft for Audit Purposes, Provided July 

11, 2011 

Inter-Office Correspondence, from Irene Quintana to CCP Records Custodian, Acceptable 

Knowledge Accuracy Report: Argonne National Laboratory Waste Stream Number AERHDM, 

Lot K-Wing FEW, Audit Purposes Only, July 1, 2011 and October 19, 2011 
B-2 

RH ANLE AK Container Tracking Spreadsheet, October 24, 2011 

Training documentation: Qualification Cards, Radiological Training, and Site-Specific RH 

Training for K. Peters and L. Watson; Qualification Card for S. Aukland 

Update for WIPP Operating Record (Change Notice #1) Remote Handled Heterogeneous Debris 

from the Argonne National Laboratory (AERHDM), September 21, 2010 

VE BDR ANLRHVE11010, July 5, 2011 

VE Logbook RH-ANLE-VE-007, January 14, 2010 to December 21, 2010 

VE Logbook RH-ANLE-VE-009, November 5, 2009 to December 23, 2009 

C006, Interview with L.A. Neimark re: AGHCF samples, applicable programs, defense 

relationship to materials, and commingling of waste, C. Schultz, Record of Communication: RO 

C-C6, July 17, 2001 

C2002, Memorandum from Timothy S. Crawford to Dr. Frank Y. Fradin regarding the Safety 

Analysis Report (SAR) Revision 02 and Technical Safety Requirements (TSRs) Revision 01 for 

the Argonne National Laboratory-East (ANL-E) Building 205 G & K Wing Laboratories, 

Timothy S. Crawford, 0898-016, August 07, 1998 

C2004, Safety Review for Unsaturated Testing of Uranium Metal Spent Fuel in Bldg. 205 Senior 

Cave and K-116 Facilities, R. D. Wolson, CMT50-0 US-Draft, Revision 0, March 7, 2009 

C2005, Safety Review of Tests with Samples of Spent Fuel in Bldg. 205, K-104 (Senior Cave) 

and, in K-116, Sampling of Leachate Solutions from the Tests, P. A. Finn, CMTS0-0058-EP, 

Revision 1, March 13, 2000 

C2006, Work Plan for the Preparation of Unirradiated AI-clad Specimens for GMT, T.S. Bray, 

IPS-329-00-00, December 02, 1999 

C2007, Work Plan for the Preparation of Specimens from the Characterization of Pins UW02010 

(A/G 498A) and UWOB036 (A/G 4988), L.A. Neimark, IPS-284-00-00, June 17, 1998 

C2010, Evaluation of the Physical Waste Composition for K-Wing Waste in Waste Stream 

AERHDM, Christopher Chancellor, September 24, 2009 

C2011, ANL Memorandum to R.J. Page re: Estimating Mass and Radioactivity for EBR-2 

Element Segments Stored in Building 212 - More Numbers, K.N. Grimm, April 22, 2008 

C2012, ANL Memorandum to R.J. Page re: Estimating Mass and Radioactivity for HBR Rods 

Stored in the AGHCF, K.N. Grimm, January 24, 2008 

C2013, ANL Memorandum to R.J. Page re: Estimating Mass and Radioactivity for Surry Unit 2 

Elements Stored in the AGHCF, K.N. Grimm, March 17, 2008 
B-3 

C2014, ANL Memorandum to R.J. Page re: Limerick Fuel Rod Activity Analysis, K.N. Grimm, 

March 21, 2006 

C2015, ANL Memorandum to R.J. Page re: Estimating Activity for Limerick Rods Stored in the 

AGHCF - More Numbers, K.N. Grimm, January 29, 2008 

C2016, ANL Memorandum to R.J. Page re: Quad Cities Unit 1 Fuel Rod Activity Analysis, K.N. 

Grimm, April 21, 2006 

C2017, ANL Memorandum to R.J. Page re: Estimating Activity for Quad Cities Rods Stored in 

the AGHCF - More Numbers, K.N. Grimm, January 30, 2008 

C2018, ANL Memorandum to R.J. Page re: Three Mile Island Unit 1 Fuel Rod Activity 

Analysis, K.N. Grimm, April 19, 2006 

C2019, ANL Memorandum to R.J. Page re: Estimating Activity for TMI Rods Stored in the 

AGHCF - More Numbers, K.N. Grimm, January 29, 2008 

C2020, ANL Memorandum to R.J. Page re: Estimating Mass and Radioactivity for BRP, HBR, 

and BR3 Rods Stored in the AGHCF, K.N. Grimm, March 1, 2007 

C2021, ANL Memorandum to R.J. Page re: Estimating Activity for BRP, HBR, and BR3 Rods 

Stored in the AGHCF - More Numbers, K.N. Grimm, March 18, 2008 

C2027, Waste Stream Delineation Evaluation for Waste Stream AERHDM to include K-Wing 

Waste, K. Peters, July 14, 2010 

C2029, Waste Container Evaluation Memorandum for Waste Stream AERHDM, K. Peters, May 

20, 2008 

C2032, Memorandum from L.A. Neimark to Distribution, Subject: Revision 1 to the Work Plan 

for the Preparation of Fuel Rods for Return Shipment to Idaho, HFS-01S-00-00, December 8, 

2004, L.A. Neimark, HFS-Q1S-00-01, Revision 1, December 09, 2004 

C3000, Comparison of Fuel Rod Length Measurements from AK Records and VE Records for 

K-Wing FEW, J. Vance, November 16, 2011 

P1001, From Test Tube to Pilot Plant; A 50 Year History of the Chemical Technology Division 

at Argonne National Laboratory, R.K. Steunenberg and L. Burris, ANL-00/16, ISBN 0-967168-

1-X, August 1, 2000 

P2011, Nuclear Operations Deactivation, Decommissioning, and Demolition Program: Appendix 

B: Building 205 K-Wing Hot Cell Deactivation Project Plan, D. Hodge, NOD-162-00-01, 

Revision 1, March 5, 2009 

P2018, Safety Analysis Report Building 205 G-Wing and K- Wing Laboratories, M.A. Slawecki, 

R.D. Wolson, J.B. Rajan, F.G. Teats, CMT-30-0470, Revision 2, December 1, 1997 
B-4 

P2019, Test Plan for the Characterization of an Approved Testing Material Mixed Oxide Fuel, L. 

A. Neimark, SNF-3A-004, Revision 0, April 8, 1998 

P2023, Results of the UREX+2 Spent Fuel Demonstration, C. Pereira, G.F. Vandegrift, M.C. 

Regalbuto, A. Bakel, S. Aase, D. Bowers, J.P. Byrnes, M.A. Clark, J.W. Emery, J.A. Falkenberg, 

A.V. Gelis, A. Leyva, L. Hafenrichter, Y. Tsai, K.J. Quigley, M.H. Vander Pol, and K. Wardle, 

February 28, 2005 

P2024, Results of the 2005 UREX+1a Spent Fuel Demonstration, C. Pereira, L.E. Miller, G.F. 

Vandegrift, M.C. Regalbuto, A. Bakel, J. Basco, D. Bowers, J. Bruso, J.P. Byrnes, M.A. Clark, 

J.W. Emery, J.A. Falkenberg, A V. Gelis, L. Hafenrichter, A.A. Leonard, A. Leyva, H. Mayes, 

T. Robinson, Y. Tsai, K. Quigley, March 31, 2006 

P2038, Preparation of Container Shielding Configurations for Material Transfers From C-Cell, J. 

Emery, NOD-205K-OPS-301, Revision 2, March 1, 2010 

P344, Analysis of Spent Nuclear Fuel Sample A/G 574B2 (Limerick Reactor) to Determine 

Selected Isotopes and Estimate Fuel Burnup, D.G. Graczyk, April 2003 

P515, Work Plan for Determining Hydrogen Contents in TMI-1 Cladding Memorandum to IPS 

Document File, H. Tsai, IPS-ET, IPS-331-00-00 and IPS-331-00-01, Revisions 0 and 1, February 

3, 2000 

P518, Work Plan for the Steam Oxidation Tests at 1200 degrees on Unirradiated Zry-4 and 

Irradiated TMI-1 Cladding; Memorandum to NRC Program File; Several Supplemental 

Instructions, Y. Yan, IPS-335-00-00 and IPS-335-01-00, Revisions 0 and 1, February 11, 2000 

P519, Work Plan for cutting Limerick Rod Sections and Loading into Shipping Tubes; 

Memorandum to IPS Document File, H. Tsai, IPS-ET, IPS-336-00-00, January 24, 2000 

P523, Work Plan for CMT Samples from TMI Fuel Rod Segments; Memorandum to 

Distribution, R.V. Strain, IPS-342-00-00, January 31, 2000 

U001, AGHCF Position Statement Regarding Defense Versus Non-Defense TRU Waste, April 

7, 2000 

U1003, Argonne Special Material Receipt and Transfer Documentation by A/G Number (A/G 1 - 

535), ANLE, 1964-1997 

U2004, Material in K-Wing Spreadsheet OUO, Laura E. Maggos, March 18, 2011 

U2020, FEW Shielded Pot and Capsule Photographs and Drawings, ANL, Not Dated 

U303, Notes for Correction of Fissile Ledger Database Regarding H.B. Robinson Fuel Shipment, 

T. Bray, April 17, 2004 

U304, Robinson Report, Unknown Date 
B-5 

U897, CCP Calculation Package for: ORIGEN2.2 Analysis of K- Wing FEW, J. Vance, ANLERH-14, Revision 0, June 6, 2011 

U898A, CCP Calculation Package for: Radiological Characterization of Drum 18876, J. Vance, 

ANLE-RH-15-1, Revision 0, June 1, 2011 

U898B, CCP Calculation Package for: Radiological Characterization of Drum 18875, J. 

Holderness, ANLE-RH-15-2, Revision 0, June 6, 2011 

U898C, CCP Calculation Package for: Radiological Characterization of Drum 18877, J. 

Holderness, ANLE-RH-15-3, Revision 0, June 6, 2011 

U898D, CCP Calculation Package for: Radiological Characterization of Drum 18878, J. 

Holderness, ANLE-RH-15-4, Revision 0, June 6, 2011 

U898E, CCP Calculation Package for: Radiological Characterization of Drum 18879, J. 

Holderness, ANLE-RH-15-5, Revision 0, June 6, 2011 

U898F, CCP Calculation Package for: Radiological Characterization of Drum 18880, J. 

Holderness, ANLE-RH-15-6, Revision 0, June 6, 2011 

U898G, CCP Calculation Package for: Radiological Characterization of Drum 18881, J. 

Holderness, ANLE-RH-15-7, Revision 0, June 6, 2011 

U898H, CCP Calculation Package for: Radiological Characterization of Drum 18904, J. 

Holderness, ANLE-RH-15-8, Revision 0, June 06, 2011

U900, CCP Calculation Package for: Determination of Reportable Radionuclides - K-Wing 

FEW, J. Vance, ANLE-RH-17, Revision 0, June 6, 2011

U902, CCP Calculation Package for: Fuel Rod Loading Calculation, J. Vance, ANLE-RH-19, 

Revision 0, June 6, 201 

Building #205 K-Wing Drum Survey Report, Drum No. 18875, December 4, 2009 

Building #205 K-Wing Drum Survey Report, Drum No. 18876 December 9, 2009 

Building #205 K-Wing Drum Survey Report, Drum No. 18877, December 15, 2009 

Building #205 K-Wing Drum Survey Report, Drum No. 18878, December 18, 2009 

Building #205 K-Wing Drum Survey Report, Drum No. 18879, March 11, 2010 

Building #205 K-Wing Drum Survey Report, Drum No. 18880, March 23, 2010 

Building #205 K-Wing Drum Survey Report, Drum No. 18881, April 7, 2010 

Building #205 K-Wing Drum Survey Report, Drum No. 18904, June 4, 1010 
B-6 

Building #205 K-Wing Drum Survey Report, Drum No. 18875, December 4, 2009 
C-1 

ATTACHMENT C: 

OBSERVATION OF ANL FUEL WEIGHT CONFIRMATION TEST PROGRAM FOR 

ARGONNE REMOTE-HANDLED K-WING FUEL EXAMINATION WASTE 

May 18, 2010 

This summary describes results obtained from the confirmatory test program for K-Wing FEW 

conducted in the K-Wing hot cells in Building 205 at ANL on May 18, 2010. Representatives 

from the U.S. EPA observed the exercise performed by ANL-CCP and ANL personnel 

responsible for operation of the glove box manipulators. The purpose of this exercise was for 

ANL-CCP to confirm the weight measurement data in the AK record and thereby qualify the 

existing weight measurement data for use in the RH TRU waste characterization program. The 

testing operations were performed in accordance with CCP-AK-ANLE-505C, Revision 0. 

Nine FEW specimen containers, which had not yet been packaged, had been previously weighed 

by the Argonne technical staff as part of the support for the research and experimental activities 

conducted in the K-Wing hot cells. During the exercise, the nine specimen containers were reweighed on a certified balance that was inside the hot cell. During the exercise, the FEW 

container ID, the existing container weight, and the scale readout were recorded in ANL 

Operational Logbook RH-ANLE-WS-001. This information, plus the percent difference in 

weights, is recorded in Table C-1, below. 

Table C-1. K-Wing FEW Confirmation Test Program Weights 

FEW Container 

ID Number 

Historic Weight 

(g) 

Scale Readout 

(g) 

Percent Difference 

in Weights 

106V 104.6158 107.4010 2.59% 

109CH 106.6658 106.5265 0.13% 

103H 105.2735 109.1984 3.59% 

103V 103.7844 104.0272 0.23% 

106L 103.7891 102.8279 0.93% 

109AH 108.1094 108.0222 0.08% 

109AV 107.9444 107.9677 0.02% 

109BV 107.7386 107.8363 0.09% 

109CV 108.3836 108.4857 0.09% 

All in-cell weights were obtained using a certified Mettler Toledo Balance, Model XP205-SE, 

Serial Number 1123421746. The scale calibration expiration date was March 31, 2011, and the 

scale tolerance was 0.03 milligram. The goal of the confirmation test program was to determine 

the acceptability of the existing weight measurement data. The existing weight records were 

considered acceptable if the average percent difference between the nine measurements was 

equal to or less than 20%. The acceptance criterion was determined to ensure a minimal impact 

on the total uncertainty in the estimated activity in the drums. The average difference of the 

weights recorded in Table C-1 is 0.86%, which is less than 20%. Therefore, the existing historic 

AK weights are acceptable and the population of weight data for FEW specimens packaged in 

the ANL K-Wing hot cells is qualified for use in the radiological characterization process.