DOCKET NO: A-98-49; II-A4-185 

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT 

EPA TIER 1 EVALUATION 

OF THE CENTRAL CHARACTERIZATION PROGRAM 

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM 

FOR THE IDAHO NATIONAL LABORATORY: 

ADDITION OF LOT 5C TO WASTE STREAM ID-HFEF-S5400-RH

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

 Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

July 2014
i 

TABLE OF CONTENTS 

Section Page 

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

1.0 Introduction ..........................................................................................................................4

2.0 Purpose of Tier 1 Evaluations ..............................................................................................5

3.0 Purpose of This Report ........................................................................................................6

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

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

5.1 EPA Evaluation Personnel ...................................................................................... 6

5.2 DOE Evaluation Personnel ..................................................................................... 6

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

6.1 Acceptable Knowledge ........................................................................................... 8

6.2 Radiological Characterization ............................................................................... 11

7.0 Findings and Concerns .......................................................................................................17

8.0 Conclusions ........................................................................................................................17

 

TABLE OF TABLES 

Table 1. EPA Tier 1 Evaluation Team Members ............................................................................ 6

Table 2. DOE Tier 1 Evaluation Personnel .................................................................................... 7

TABLE OF FIGURES 

Figure 1. Radiological Characterization Flow Diagram for Lot 5C ............................................. 13

ATTACHMENTS 

Attachment A: Approval Summary for INL-CCP RH Waste Characterization Program 

Attachment B: List of DOE Personnel Present at Evaluation 

Attachment C: Lot 5C Population of Liners and Drums: Identification of Drums within 

Approved Subpopulation 

Attachment D: List of Documents Reviewed by EPA during T1 Evaluation 
ii 

ABBREVIATIONS AND ACRONYMS 

AK acceptable knowledge 

AKE Acceptable Knowledge Expert 

AKSR acceptable knowledge summary report 

Am americium 

AMWTP ACL Advanced Mixed Waste Treatment Project Analytical Chemistry Laboratory 

BDR batch data report 

CBFO Carlsbad Field Office 

CCP Central Characterization Program 

CFR Code of Federal Regulations 

Ci curie 

Co cobalt 

Cs cesium 

CWI CH2M-WG Idaho, LLC 

DOE U.S. Department of Energy 

DTC dose-to-curie 

EBR-II Experimental Breeder Reactor-II 

EPA U.S. Environmental Protection Agency 

Eu europium 

FCF Fuel Conditioning Facility 

HFEF Hot Fuel Examination Facility 

HLW high-level waste 

ILTSF Intermediate Level Transuranic Storage Facility 

INL Idaho National Laboratory 

INTEC Idaho Nuclear Technology and Engineering Center 

L&O Laboratory and Office 

LANL-CO Los Alamos National Laboratory-Carlsbad Office 

m meter 

MCNP5® Monte Carlo N-Particle Transport Code, Version 5 

MFC Materials and Fuels Complex 

mR/hr/Ci milliroentgens per hour per curie 

NWP Nuclear Waste Partnership 
iii 

NWPA Nuclear Waste Policy Act 

Pu plutonium 

PWS Process Work Sheets 

RERTR Reduced Enrichment Research and Test Reactor Program 

RH remote-handled 

RSWF Radioactive Scrap and Waste Facility 

RTR real-time radiography 

SAP sampling and analysis plan 

SC&A S, Cohen and Associates 

SF scaling factor 

SNF spent nuclear fuel 

SPM Site Project Manager 

Sr strontium 

SRS Savannah River Site 

T1 Tier 1 

T2 Tier 2 

TMU total measurement uncertainty 

TRU transuranic 

U uranium 

WCPIP Waste Characterization Program Implementation Plan 

WIPP Waste Isolation Pilot Plant 
4

1.0 INTRODUCTION 

This report supports the U.S. Environmental Protection Agency’s (EPA’s) approval of a Tier 1 

(T1) change to add Lot 5C remote-handled (RH) transuranic (TRU) debris waste to the 

previously-approved Waste Stream ID-HFEF-S5400-RH at the U.S. Department of Energy’s 

(DOE’s) Idaho National Laboratory (INL). In February 2010, EPA approved the Central 

Characterization Program (CCP)1 to characterize Waste Stream ID-HFEF-S5400-RH at INL (see 

EPA Docket No. A-98-49; II-A4-122). Using the EPA-approved waste characterization 

processes discussed in this report, INL-CCP may characterize Lot 5C debris waste for disposal at 

the Waste Isolation Pilot Plant (WIPP) as part of Waste Stream ID-HFEF-S5400-RH. 

EPA conducted continued compliance inspections of INL-CCP in May 2013 and May 2014, 

concluding in both instances that INL-CCP continued to adequately implement the RH TRU 

waste characterization processes, procedures and equipment at INL that EPA approved in the 

January 2007 baseline approval and in subsequent tiering changes listed in Attachment A. On 

September 30, 2013, the Carlsbad Field Office (CBFO) requested EPA approval of a T1 change 

to include Lot 5C RH TRU debris waste in Waste Stream ID-HFEF-S5400-RH. EPA limited the 

scope of this T1 evaluation to the components of acceptable knowledge (AK) and radiological 

characterization specific to the addition of Lot 5C containers to Waste Stream ID-HFEF-S5400-

RH. Because there were no new equipment or additional new processes on site at INL as part of 

the T1 request, EPA conducted a desktop review of this change and then met with INL-CCP 

personnel in Denver, Colorado, on December 3–5, 2013. 

During the Denver meeting, EPA identified and CBFO agreed that the initial evaluation scope 

required modification. Specifically, INL-CCP removed all drums whose external dose rates were 

attributable to radionuclides other than cesium-137 (137Cs), as detailed in section 4.0 of this 

report. CBFO provided to EPA a revised T1 request on February 26, 2014, limiting the T1 scope 

to a subpopulation of drums, where at least 95% of the dose rate was attributable to 137Cs. 

EPA evaluated the T1 change to add Lot 5C containers with at least 95% of the dose rate 

attributable to 137Cs to Waste Stream ID-HFEF-S5400-RH. However, prior to issuance of EPA’s 

T1 approval, CBFO submitted another revised T1 request on April 15, 2014. The April revision 

of the T1 request reincorporated the previously excluded containers, effectively returning the T1 

change to its original scope. CBFO requested that EPA delay issuance of the T1 decision so that 

all Lot 5C containers would be evaluated at one time. EPA completed the T1 evaluation upon 

receiving revised radiological characterization documents. 

EPA did not identify any findings or concerns during this T1 evaluation. INL-CCP revised 

several documents and various calculation packages during the evaluation and provided them to 

EPA. Attachment D is a list of all documentation reviewed, including batch data reports (BDRs) 

and calculation packages. 

As a result of this evaluation, EPA did not make any changes to the INL-CCP RH T1 and Tier 2 

(T2) designations that were established during the baseline approval and modified during 

 

1

 The Central Characterization Program was formerly known as the Central Characterization Project, and 

both names are used in the documentation reviewed for this evaluation. 
5

subsequent T1 evaluations and continued compliance inspections. The tiering designations 

presented in Table 1 of the final report for EPA’s 2014 continued compliance inspection of INLCCP (see EPA Docket No. A-98-49; II-A4-190; July 15, 2014) remain in effect and are listed as 

applicable in sections 6.1 and 6.2. 

Based on the information provided, EPA is approving INL-CCP’s plan to use the EPA-approved 

system of controls to characterize 60 55-gallon drums from 13 liners that currently make up Lot 

5C.2 These 60 drums of TRU waste are the subject of this T1 report, but EPA’s approval also 

includes any additional liners or progeny drums that may be added to Lot 5C in the future, 

provided they have the same pedigree as the Lot 5C containers and are characterized using the 

same processes discussed in this report. 

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

evaluation. This information will be provided through the EPA website and by emails to the 

WIPPNEWS list, in accordance with Title 40 of the Code of Federal Regulations [40 CFR 

194.8(b)(3)]. 

2.0 PURPOSE OF TIER 1 EVALUATIONS 

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 into the INL-CCP RH 

baseline final report (see EPA Docket No. A-98-49; II-A4-72). 

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

(Vol. 69, No. 136, pages 42571–42583), EPA must perform a single baseline inspection of a 

TRU waste generator site’s waste characterization program. 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 notification (T2) 

are identified in the site-specific baseline inspection reports and subsequent T1 evaluation 

reports. When evaluating proposed T1 changes for approval, EPA may conduct a site inspection 

to observe 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 or equipment implemented as T2 changes at 

risk of subsequent EPA disapproval. 

 

2

 Lot 5C is currently defined as waste from 13 liners, as discussed in this report. The exact number of 55-

gallon drums that will be created upon completion of repackaging the wastes in these liners has not yet been 

determined. INL-CCP documents present this number as 59 or 60. This report presents the number of drums as 60, 

with the understanding that it may change. 
6

3.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation of a T1 change to add Lot 5C RH TRU 

debris waste to Waste Stream ID-HFEF-S5400-RH, as described in CCP-AK-INL-580, 

Revisions 3 and 4; CCP-RC-INL-581, Revisions 0 and 1; and CCP-AK-INL-582, Revision 3. 

This report presents the technical basis for and results of EPA’s approval decision. EPA’s 

approval decision regarding the addition of Lot 5C RH TRU debris waste to Waste Stream IDHFEF-S5400-RH has been conveyed to DOE separately by letter. EPA will also announce the 

decision on its website at www.epa.gov/radiation/wipp, in accordance with 40 CFR 194.8(b)(3). 

4.0 SCOPE OF THE TIER 1 EVALUATION 

The scope of EPA’s T1 evaluation is the AK process and radiological characterization approach 

used to characterize Lot 5C RH TRU debris waste for addition to Waste Stream ID-HFEFS5400-RH. Sections 6.1 and 6.2 of this report detail the AK and radiological characterization 

technical elements assessed during this evaluation.

5.0 EVALUATION PERSONNEL 

5.1 EPA Evaluation Personnel 

The EPA evaluation team members consisted of the personnel listed in Table 1 with their 

technical areas of expertise. 

Table 1. EPA Tier 1 Evaluation Team Members 

Name Affiliation & Function 

Ed Feltcorn Lead Inspector, U.S. EPA 

Connie Walker Technical Evaluator – Acceptable Knowledge, SC&A 

Rose Gogliotti Technical Evaluator – Radiological Characterization, SC&A 

Patrick Kelly Technical Evaluator – Radiological Characterization, SC&A 

Amir Mobasheran* Technical Evaluator – Radiological Characterization, SC&A 

*Participated remotely 

5.2 DOE Evaluation Personnel 

EPA and its support personnel conducted interviews with INL-CCP waste characterization 

personnel in radiological characterization and AK. The INL-CCP personnel contacted during the 

T1 evaluation in Denver, Colorado, are listed in Table 2 with their affiliations and areas of 

expertise or function. Following the Denver meeting, the EPA Evaluation Team had discussions 

with DOE personnel via email regarding document revisions and other technical details. All 

DOE personnel present at the evaluation are listed in Attachment B. 
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Table 2. DOE Tier 1 Evaluation Personnel 

Name Affiliation & Function 

Scott Smith INL-CCP, AK Expert 

Derek Ott URS, Radiological Characterization Technical Expert 

Thomas Clements CWI-INL, TRU Project Manager 

Irene Joo URS, CCP RH Support/SPM 

Marcus Pinzel CBFO, RH Staff 

6.0 TECHNICAL EVALUATION 

Waste-Generating Activities

Waste Stream ID-HFEF-S5400-RH consists of debris generated by hot cell and analytical 

laboratory activities at the Materials and Fuels Complex (MFC) and specifically in Building 785 

- the Hot Fuel Examination Facility (HFEF, formerly HFEF-north), Building 765 - Fuel 

Conditioning Facility (FCF, formerly HFEF-south), and Building 752 - Laboratory and Office 

(L&O) Building. INL generated the waste in Waste Stream ID-HFEF-S5400-RH in support of 

analyses and examination of Experimental Breeder Reactor-II (EBR-II) irradiated fuel, and it 

consists predominantly of organic and inorganic debris. These wastes are currently stored at the 

Idaho Nuclear Technology and Engineering Center (INTEC) and the MFC Radioactive Scrap 

and Waste Facility (RSWF), pending transfer to INTEC. CCP-RC-INL-581, Revision 1, 

describes this waste as follows: “The debris primarily consists of waste generated at the HFEF 

during the handling and examination of irradiated fuel pins and other reactor materials from 

various reactor programs. These canister liners contain debris waste such as rags, bags, bottles, 

filter bags, and floor sweepings. The waste stream also includes fuel specimens and associated 

subassembly hardware, main ion-exchange resins, cerium ion-exchange resins, South Bank and 

North Bank Filters from the HFEF, and process and casting crucibles.” 

RH Waste Overview

Waste Stream ID-HFEF-S5400-RH consists of 98 canisters or liners of RH TRU debris wastes 

generated by hot cell and analytical chemistry operations conducted in the HFEF, FCF, and the 

L&O Building Analytical Laboratory hot cells from June 1970 to November 2007. INL-CCP has 

divided this waste stream into four lots, and the subject of this T1 evaluation is exclusively the 

13 liners designated as Lot 5C, which were generated during hot cell operations within HFEF. 

INL-CCP repackaged the waste into 30- and 45-gallon drums and over-packed the smaller drums 

in 55-gallon drums. 

Packaging Configuration 

The Lot 5C waste consists of heterogeneous debris initially packaged in 86 HFEF cans (or 

inserts), eight Sodium Loop Safety Facility cans (six of which contained three 45-gallon drums), 

and four paints cans in 16-inch RSWF liners. INL-CCP repackaged these wastes into 30- or 45-

gallon drums, and over-packed them into 55-gallon drums for characterization and shipment to 

WIPP. The AK tracking spreadsheet that EPA observed at the time of the inspection showed that 

Lot 5C contains 60 55-gallon drums. INL-CCP stated that they expect to generate additional 
8

wastes of this type in the future. A comprehensive listing of all liners and the specific drums into 

which they were repacked is in Attachment C. 

Documents, Batch Data Reports and Calculation Packages Provided 

EPA evaluated the INL-CCP documentation that supported inclusion of Lot 5C debris waste in 

Waste Stream ID-HFEF-S5400-RH. EPA’s review identified several technical issues that 

necessitated the revision of several documents. Proposed modifications to these documents were 

discussed with EPA during the meeting in Denver, Colorado, and approved revised documents 

incorporating necessary changes were provided to EPA before the conclusion of this T1 

evaluation. 

The DOE documents that EPA reviewed for this evaluation, including BDRs and calculation 

packages, are cited in different sections throughout the report and are listed in Attachment D. 

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, New Mexico 88221-3090 

6.1 Acceptable Knowledge 

EPA examined the programmatic requirements and AK process and associated information 

during the continued compliance inspection in May 2013. Therefore, EPA limited the scope of 

this AK evaluation to those elements necessary to assess the technical adequacy of the 

information supporting inclusion of Lot 5C RH TRU debris waste in Waste Stream ID-HFEFS5400-RH. 

Waste Characterization Element Description 

EPA limited this T1 evaluation to the technical elements listed below. 

• Waste stream definition, including radiological and physical characteristics and inclusion 

of drums in Lot 5C. 

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

or spent nuclear fuel (SNF). 

Technical Evaluation 

EPA evaluated the adequacy of AK information specific to inclusion of Lot 5C into Waste 

Stream ID-HFEF-S5400-RH as described in CCP-AK-INL-580, Revisions 3 and 4; CCP-RCINL-581, Revision 0; applicable CCP-TP-005 attachments and supporting source documents. 
9

(1) EPA examined the waste stream determination for Waste Stream ID-HFEF-S5400-RH 

with respect to the addition of Lot 5C and found it to be adequate. 

CCP-TP-005, Revision 26, states “A waste stream is defined as waste materials that have 

common physical form, that contain similar hazardous constituents (similar radiological 

properties for WCPIP compliance), and that are generated from a single process or activity. This 

definition will be used to obtain information for the waste stream specific description to be 

written in step 4.4.34.” CCP-TP-005, Revision 26, also states that the addition of drums to an 

existing waste stream requires the AK expert (AKE) (section 4.10.2) to collect drum-specific 

documentation and evaluate the following information for each drum: 

• Waste generation location and process. 

• Time period of generation. 

• Physical form compared to the assigned Waste Material Parameters and Waste Matrix 

Code. 

• Chemical content. 

• Prohibited items. 

• Radionuclides. 

Reference C4117 documents the rationale for adding Lot 5C to Waste Stream ID-HFEF-S5400-

RH. EPA examined Reference C4117 and found it inadequate in several ways. INL-CCP revised 

this document to include accurate and consistent waste generation locations, processes and time 

period of generation, as well as more information about the physical composition of Lot 5C, 

prohibited items and radionuclide content. INL-CCP provided the final revision of C4117 to 

EPA on January 22, 2014; EPA found the revised document to be adequate. 

EPA examined Revision 3 of the AK summary report (AKSR; CCP-AK-INL-580) to determine 

whether it contained sufficient information to justify inclusion of Lot 5C in the waste stream. 

EPA found the AKSR to be inadequate and INL-CCP provided a marked-up version of Revision 

3, which also required modification. INL-CCP provided Revision 4 of the AKSR, which EPA 

found to be adequate. 

There are no issues relative to the waste stream definition for Waste Stream ID-HFEF-S5400, 

Lot 5C. 

(2) EPA examined the waste stream information that supports the absence of spent nuclear 

fuel or high-level waste in this waste stream and found it to be adequate. 

The WIPP Land Withdrawal Act prohibits WIPP disposal of SNF and HLW as defined by the 

Nuclear Waste Policy Act (NWPA). INL-CCP asserts that Waste Stream ID-HFEF-S5400-RH 

includes fragments generated by segmentation of test specimens, residues, and dust/fines from 

sectioning and testing of SNF; the waste does not contain complete fuel rods. Process and waste 

management documents do not indicate that Waste Stream ID-HFEF-S5400-RH includes intact 

fuel rods or waste from reprocessing of SNF; any waste associated with SNF or HLW is 

incidental to reprocessing and the waste stream includes only minimal solidified liquid 
10

associated with chemical tests (References C214, C465, C4100, P4024, P4025, U483, U484, 

U541, U551 and U552). Additionally, EPA examined the Lot 5C RTR BDRs, which showed 

only debris and fuel fragments or particulates. 

There are no issues relative to the absence of SNF or HLW for Waste Stream ID-HFEF-S5400, 

Lot 5C. 

(3) EPA examined the information supporting that the waste stream is defense in origin and 

found it to be adequate. 

TRU waste is eligible for disposal at the WIPP if it has been generated in whole or in part by one 

of the atomic energy defense activities listed in the Nuclear Waste Policy Act. The AKSR, 

Revision 4, concludes that, “Based on the review of AK, there is sufficient evidence to 

demonstrate that TRU wastes generated by MFC operations are contaminated with materials 

from atomic energy defense activities associated with naval reactors development, defense 

nuclear materials productions, defense nuclear waste and materials by-products management, 

and defense research and development activities” (References C002, P001, P042, P067, P144, 

P146, P186 and P187). 

Specifically, the EBR-II and Transient Reactor Test Facility reactors generated fuel and other 

material in support of defense-related programs and the radionuclides in Waste Stream IDHFEF-S5400-RH can be traced to these reactors. DOE conducted several defense-related 

experimental programs and activities at MFC, including supporting the Bettis Atomic Power 

Laboratory and the Naval Nuclear Propulsion Program, Los Alamos National Laboratory, 

Lawrence Livermore National Laboratory, the Star Wars Program, and plutonium experiments in 

support of waste disposal. The integrated use of HFEF, FCF and L&O facilities resulted in 

incidental commingling of waste from various programs, thus mixing defense and non-defense 

waste (References C002, C003, C465, P001, P047, P116, P144, P145, P146, P178, U025, U483, 

U484, U541, U551 and U552). 

EPA evaluated the Sea Lion Database (Reference U552) to confirm the building and process 

origin of each Lot 5C liner and found that Lot 5C was generated in the same buildings using the 

same processes that include defense waste. Additionally, MFC personnel did not segregate waste 

as defense or non-defense at generation, and have not packaged or repacked waste postgeneration with respect to defense/non-defense origin. The presence of defense-related material 

in each liner means that it could have contacted defense-originated waste, so it is of defense 

origin. 

There are no issues relative to the defense status for Waste Stream ID-HFEF-S5400, Lot 5C. 

(4) EPA examined individual waste container pedigrees to support their inclusion in Lot 5C 

and found this information to be adequate. 

Lot 5C is composed of 13 liners including Liner R-8, for which RTR results indicated that it 

originated from the HFEF and FCF (Reference C4123). However, CCP-RC-INL-581, Revision 

0, states that liner R-8 originated from an analytical laboratory and has a radiological 

composition different enough from the Lot 5C population to warrant its own scaling factor. 

Given the discrepancies pertaining to the origin of Liner R-8, EPA examined the traceability 
11

documentation to support inclusion in Lot 5C and this waste stream, as documented in Reference 

U522, the Sea Lion database. EPA determined that Reference U552 adequately explains the 

apparent discrepancy between the origin of Lot 5C and Liner R-8 and that Liner R-8’s physical 

attributes fall within the general waste stream and Lot 5C waste description. 

There are no issues relative to these wastes belonging in Waste Stream ID-HFEF-S5400, Lot 5C. 

Summary of Acceptable Knowledge Findings and Concerns

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

addition of Lot 5C RH TRU debris waste to Waste Stream ID-HFEF-S5400-RH during this T1 

change evaluation. 

Acceptable Knowledge Approval

Based on the results of this evaluation, EPA approves the addition of Lot 5C RH TRU debris 

waste to Waste Stream ID-HFEF-S5400-RH and finds that all AK requirements have been met. 

Based on this evaluation, there are no changes to the AK T1 or T2 designations. Characterization 

of any new waste stream not approved under the baseline or subsequent T1 evaluations or 

addition of containers to an approved waste stream that requires changing the established 

radionuclide scaling factors remains a T1 change. T1 and T2 changes that were initiated during 

the baseline approval remain in effect. 

6.2 Radiological Characterization 

EPA examined the dose-to-curie (DTC) process and associated information during the continued 

compliance inspection in May 2013. Therefore, EPA limited the scope of this radiological 

characterization evaluation to those elements necessary to assess the technical adequacy of the 

information supporting inclusion of Lot 5C RH TRU debris waste in Waste Stream ID-HFEFS5400-RH. 

Waste Characterization Element Description 

EPA evaluated the radiological characterization of HFEF Lot 5C in terms of technical adequacy, 

as supported by the documents, procedures and controls, and the knowledge and understanding 

of the personnel involved in the RH waste characterization program. During this RH evaluation, 

EPA evaluated the following elements of the INL-CCP radiological characterization program: 

• Overall radiological characterization. 

• Development of a 137Cs-based radionuclide scaling factor via sampling and analysis. 

• Representativeness and technical adequacy of the analytical data used to support the 

scaling factors. 

• OSPREY measurements to determine the relative contributions of 137Cs, cobalt-60 (60Co), 

and europium-154 (154Eu) to each container’s external dose. 
12

• Development of three independent DTC correlations for each of the four packaging 

configurations within 55-gallon drums, based on Monte Carlo N-Particle Transport Code 

(MCNP5®) modeling of the drum’s gamma dose rate using a 1-curie (Ci) source of 137Cs, 

a 1-Ci source of 60Co and a 1-Ci source of 154Eu for each configuration. 

• Uncertainty analysis. 

Each of these is discussed in the sections that follow. 

Technical Evaluation 

The EPA evaluation team evaluated the following aspects: 

(1) EPA evaluated the overall radiological characterization process and its documentation 

and found them to be adequate. 

The radiological characterization process for HFEF Lot 5C uses DTC correlations for four3

 sets 

of packaging-specific radionuclide scaling factors based on computer modeling and the 

collection and analysis of representative samples. INL-CCP scaled the modeled and measured 

radionuclide values to 137Cs, correlating a drum’s dose rate,4 packaging configuration and WIPPtracked radionuclides. The EPA inspection team prepared a flow diagram to accurately reflect 

this process, shown in Figure 1 below. 

During the course of this T1 evaluation, INL-CCP revised the documents supporting radiological 

characterization. EPA determined that the radiological characterization process for Lot 5C was 

technically adequate and appropriately documented in the revised documents. There were no 

issues regarding the radiological characterization process for Waste Stream ID-HFEF-S5400, Lot 

5C. 

Consistent with the T1 and T2 designations that EPA established during the baseline approval, 

any new RH waste stream not approved to date or the addition of drums to Waste Stream IDHFEF-S5400-RH that require a different radiological characterization process from what EPA 

previously approved remains a T1 change. Similarly, any change to CCP-RC-INL-581 that 

requires CBFO approval remains a T2 change. 

 

3

 INL-CCP initially indicated that there were three sets of scaling factors: Fuel and Hardware, General

Debris, and Analytical Laboratory Waste; however, the revised T1 scope included a distinct waste group called 

Separate (or Special) Resin Waste, which used the scaling factors developed for the General Debris group. 

4

 “Rem” or “millirem” is a unit of dose equivalent, which is often commonly called “dose” or, when it is 

expressed per unit time, a “dose rate.” The criterion for RH determination is expressed in terms of a dose rate in 

rem, which, while technically incorrect, is commonly used. In this report, the terms dose and dose rate are used in 

place of the technically correct terms “dose equivalent” or “dose equivalent rate.” The actual difference among these 

values for the purpose of this report is negligible. 
13

Figure 1. Radiological Characterization Flow Diagram for Lot 5C 

Model the 1 m dose using MCNP5 as a function of waste density to relate 137Cs, 154Eu, and 60Co to the dose rate for 

each packaging configuration

Use OSPREY to determine the relative gamma dose contributions from 137Cs, 154Eu, and 60Co

M9d

Determine 137Cs activity content in each drum 

Use DTC factors (mR/hdensity relationships fo154Eu, and 60Co to deterrespective activities

Sample waste using sampling plan Develop sampling plan to ensure various waste types are represented 

Samples are analyzed by the AMWTP ACL to determine radionuclide composition 

Review AK records to identify possible waste types that may require unique scaling factors 

Remove grouping of waste containing fuel rods, i.e., Fuel and Hardware Grouping Model Fuel and Hardware Group wastes in ORIGEN using AK records 

Review analytical results to determine if any sampled containers are sufficiently different from the other results to require unique SFs

Develop SFs unique to each grouping 

Develop SFs unique to the Fuel and Hardware grouping 

Apply relevant SF to each drum to determine radionuclides of interest for drums 
 

14

(2) EPA evaluated the collection and analysis of samples and determined these were 

adequate to support the development of radionuclide scaling factors. 

INL-CCP prepared a sampling and analysis plan (SAP) (CCP-AK-INL-585, Revision 1) for 

collecting representative samples from Waste Stream ID-HFEF-S5400-RH, Lot 5C. The SAP 

outlined collecting 14 samples from randomly selected liners or drums within the liners for each 

of the four waste types, as follows: debris (six samples), liquid filters (three samples), gas filters

(two samples), and resins (three samples). INL-CCP documented the sampling in BDR No. 

IDRH1202 and stated that there were no deviations from the sampling plan. 

The Advanced Mixed Waste Treatment Project Analytical Chemistry Laboratory (AMWTP 

ACL)5 performed radiometric and spectrophotometric analyses on the samples to quantify 

uranium-233 (233U)/234U, 235U/236U, 238U, americium-241 (241Am), plutonium-238 (238Pu), 

239Pu/240Pu, 241Pu, 242Pu, 137Cs, strontium-90 (90Sr), 60Co, 154Eu and 134Cs. The AMWTP ACL 

documented the analyses in analysis-specific BDRs. INL-CCP documented their evaluation of 

the analytical results in a post-sampling memorandum that presented the results relative to the 

Quality Assurance Objectives to support the development of scaling factors. 

EPA determined that the analytical data were representative and technically adequate to support 

the development of radionuclide scaling factors. There were no issues regarding the collection 

and analysis of samples from Waste Stream ID-HFEF-S5400, Lot 5C. 

(3) EPA found that INL-CCP correctly derived and appropriately documented cesium-137-

based radionuclide scaling factors for four waste groups. 

INL-CCP described the development of scaling factors for Lot 5C waste in CCP-RC-INL-581, 

Revision 1, and detailed it in INL-RH-142. INL-CCP recognized four distinct groups of wastes 

from the 60 drums within the Lot 5C waste and developed scaling factors for each group as 

follows: 

• Fuel and hardware: ORIGEN2.2 modeling, discussed in Item (4) below. 

• General debris: averages of the data from sampling and analysis. 

• Analytical laboratory waste: based on attributes of drum No. WSRA02. INL-CCP 

segregated these liners from the general debris group based on dose rate measurements. 

• Separate resin waste: based on the attributes of drum No. WSR080. INL-CCP segregated 

these liners from the general debris group based on dose rate measurements. 

EPA determined that INL-CCP’s scaling factor development approaches for all four waste 

groups were technically adequate. EPA did not identify any concerns regarding the technical 

adequacy of INL-CCP’s development of radionuclide scaling factors for Waste Stream IDHFEF-S5400, Lot 5C. 

 

5

 The AMWTP ACL is located on site at INL and was previously called the INTEC laboratory. EPA 

inspected and approved the laboratory for the analysis of RH TRU samples in 2010, see EPA Docket No. A-98-49; 

II-A4-130. 
 

15

(4) EPA found that INL-CCP correctly modeled the fuel and hardware waste using 

ORIGEN2.2 and appropriately developed radionuclide scaling factors using the results. 

Canister liners PP-15 and QQ-9 contained fuel and hardware components. The burnup and 

composite information for these wastes is known such that the radiological properties can be 

modeled using ORIGEN2.2. INL-CCP used information from an ANL memorandum as input 

and extracted and summarized the results of the modeling in the “Lot 5C Scaling Factors” 

Spreadsheet. INL-CCP converted radionuclide mass values to activities and generated 137Csbased scaling factors. EPA found the scaling factors to reasonably represent the wastes’ 

radionuclide composition. 

EPA did not identify any concerns regarding the technical adequacy of INL-CCP’s modeling to 

support the development of radionuclide scaling factors for Waste Stream ID-HFEF-S5400, Lot 

5C. 

(5) EPA evaluated computer modeling to develop the dose-to-curie correlation and found it 

to be adequate. 

INL-CCP used MCNP5® to develop the DTC correlation based on density for a 55-gallon drum 

of Lot 5C waste for four different packaging configurations and three gamma sources. The four 

packaging configurations consider the presence or absence of a drum liner and the size of the 

inner container. INL-CCP developed 12 DTC relationships for waste density from 0.1 to 2.0 

grams per cubic centimeter. 

INL-CCP based the modeling on the assumption that independent 1-Ci sources of 137Cs, 60Co 

and 154Eu were uniformly distributed within the drum. Using waste density and the DTC 

correlation allows calculation of the activity attributable to 137Cs, which is then used with decaycorrected scaling factors (excluding 60Co and 154Eu) to determine the activities of the 

radionuclides of interest. The activities for 137Cs, 60Co and 154Eu, are calculated directly from 

their corresponding DTC correlations. INL-CCP described the DTC correlation in CCP-RC-INL581, Revision 1, and detailed it in INL-RH-146. 

EPA did not identify any issues regarding the use of MCNP5® to support the DTC correlation for 

Waste Stream ID-HFEF-S5400, Lot 5C. 

Consistent with the T1 and T2 designations that were established during the baseline approval, 

the use of any method to determine scaling factors other than those documented in CCP-RCINL-581, Revision 1, remains a T1 change. 

(6) EPA assessed radionuclide documentation in the dose-to-curie batch data report and 

found it to be adequate. 

The radiological characterization is summarized in DTC BDR Nos. INLRHDTC11004, 

INLRHDTC12004, INLRHDTC13002, INLRHDTC13003, INLRHDTC13004, 

INLRHDTC13007 and INLRHDTC13008. INL-CCP generated the DTC BDRs using procedure 

CCP-TP-504, Revision 14, which was the current revision at the time of DTC assay. For 

logistical reasons, some containers had Waste Container DTC Conversion Records that had been 

superseded. All containers used the initial DTC measurement event as the basis for the 
 

16

radionuclide calculations, often in conjunction with more recently derived radionuclide scaling 

factors. 

EPA did not identify any concerns regarding INL-CCP’s determination of radionuclides in DTC 

BDRs for Waste Stream ID-HFEF-S5400, Lot 5C. 

(7) EPA evaluated the remote-handled determinations and found them to be adequate. 

INL-CCP performed RH determinations for Lot 5C drums in June and September 2013, and all 

drums were found to have contact dose rates in excess of 200 millirem per hour. EPA did not 

identify any concerns regarding INL-CCP’s RH determination for Waste Stream ID-HFEFS5400, Lot 5C. 

(8) EPA evaluated transuranic determinations and found them to be adequate. 

TRU determinations are documented in DTC BDRs listed in Attachment D and discussed in 

section 6.2, Item (6), above. All Lot 5C drums are documented in these BDRs and meet the 

requirements of TRU waste; i.e., had TRU alpha activity concentrations greater than 100 

nanocuries per gram. 

EPA did not identify any concerns regarding INL-CCP’s determination that the drums in Waste 

Stream ID-HFEF-S5400, Lot 5C were TRU waste. 

(9) EPA evaluated the technical basis and documentation of total measurement uncertainty 

and found them to be adequate. 

The development of total measurement uncertainty (TMU) for Lot 5C is based on the 

propagation of uncertainties present in the determination of the waste stream’s radiological 

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

quadrature.6

 The TMU determination included contributions of the following: 

•

137Cs DTC correlation—uncertainties due to MCNP5® code, waste mass and source 

distribution within drum, and waste density. 

•

137Cs activity measurement—dose rate measurement uncertainty and uncertainty due to 

the contribution of other gamma-emitting radionuclides (OSPREY measurement 

uncertainties). 

• Scaling factor uncertainty for four distinct groups of waste—sample data uncertainties or 

ORIGEN2.2 modeling. 

A general treatment of TMU for Lot 5C is presented in CCP-RC-INL-581, Revision 1, and the 

detailed treatment is provided in INL-RH-145. The overall uncertainties are consistent with what 

 

6

 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. For example, the TMU for 137Cs is derived by taking the square root of (25%)2 plus (10%)2 plus 

(4.6%)2 plus (2.41%)2

 plus (2.5%)2, which equals 27.54%, which is less than the value obtained by simply summing 

the individual uncertainty values (i.e., 44.51%), as shown in INL-RH-145 for a hypothetical drum of general debris.
 

17

EPA has observed for RH determinations at other RH TRU generator sites. Table 8-6 of CCPRC-INL-581, Revision 1, provides an example of the TMU calculation for a hypothetical drum 

using data for the Analytical Laboratory waste group. 

EPA did not identify any concerns regarding INL-CCP’s determination of TMU for Waste 

Stream ID-HFEF-S5400, Lot 5C. 

Summary of Radiological Characterization Findings and Concerns

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

concerns relative to the addition of Lot 5C RH TRU debris waste to Waste Stream ID-HFEFS5400-RH during this T1 change evaluation. 

Radiological Characterization Approval

Based on the results of this evaluation, EPA approves the addition of Lot 5C RH TRU debris 

waste to Waste Stream ID-HFEF-S5400-RH consistent with the limitations specified in this 

report. 

Based on this evaluation, there are no changes to the radiological characterization T1 or T2 

designations. Characterization of any new waste stream not approved under the baseline or 

subsequent T1 evaluations or addition of containers to an approved waste stream that requires 

changing the established radionuclide scaling factors remains a T1 change. T1 and T2 changes 

that were initiated during the baseline approval remain in effect. 

7.0 FINDINGS AND CONCERNS 

Summary of Findings and Concerns

The EPA inspection team did not identify any findings or concerns relative to the addition of Lot 

5C RH TRU debris waste to Waste Stream ID-HFEF-S5400-RH during this T1 change 

evaluation. 

8.0 CONCLUSIONS 

Changes to Tiering 

As a result of this evaluation, EPA did not make any changes to the INL-CCP RH T1 and T2 

designations that were established during the baseline approval and modified during subsequent 

T1 evaluations and continued compliance inspections. The tiering designations presented in 

Table 1 of the final report for EPA’s 2014 continued compliance inspection of INL-CCP (see 

EPA Docket No. A-98-49; II-A4-190; July 15, 2014) remain in effect and are listed as applicable 

in sections 6.1 and 6.2. 

Approval 

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

used to characterize Lot 5C RH TRU debris waste as part of Waste Stream ID-HFEF-S5400-RH 
 

18

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

evaluation. 

Based on the results of this evaluation, EPA approves this T1 change consistent with the 

limitations specified in this report. Specifically, EPA’s approval includes characterization of 60 

55-gallon drums from 13 liners that currently make up Lot 5C, and any repackaged waste 

derived from those drums. INL-CCP may add additional containers of RH TRU debris waste to 

Lot 5C as long as they are of the same pedigree as those that were approved during this T1 

evaluation. 
 

A-1

ATTACHMENT A 

APPROVAL SUMMARY FOR INL-CCP REMOTE-HANDLED WASTE 

CHARACTERIZATION PROGRAM 

Approved Activity EPA Inspection Number, 

Approval Dates EPA Docket Number 

INL-CCP RH Baseline Approval EPA-INL-CCP-RH-6.06-8, 

January 12, 2007 A-98-49; II-A4-72 

T1 Change – Approval of WIPP Waste Information 

System January 17, 2007 A-98-49; II-A4-74 

T1 Change – Approval of Visual Examination January 25, 2007 A-98-49; II-A4-75 

T1 Change – Approval of Real-Time Radiography February 12, 2007 A-98-49; II-A4-80 

T1 Change – Approval of K Cell Wastes January 1, 2008 A-98-49; II-A4-97 

T1 Change – Approval of High-Range Gamma Probe 

for DTC April 11, 2008 A-98-49; II-A4-98 

T1 Change – Approval of Visual Examination 

Technique September 22, 2009 A-98-49; II-A4-118 

T1 Change – Addition of Twelve Containers to Waste 

Stream ID-ANLE-S5000 and Addition of Waste 

Stream ID-HFEF-S5400-RH 

February 1, 2010 A-98-49; II-A4-122 

T1 Change – Approval of Waste Stream 

ID-MFC-S5400-RH June 8, 2010 A-98-49; II-A4-126 

T1 Change – Approval of Waste Stream 

ID-INTEC-S5400-RH August 17, 2010 A-98-49; II-A4-130 

T1 Change – Addition of Lot 1B to Waste Stream 

ID-HFEF-S5400-RH August 23, 2010 A-98-49; II-A4-131 

T1 Change – Approval of Waste Stream 

IN-ID-NRF-153 November 1, 2010 A-98-49; II-A4-135 

T1 Change – Approval of Waste Stream 

ID-RTC-S3000 November 1, 2010 A-98-49; II-A4-137 

2010 Continued Compliance Inspection March 16, 2011 A-98-49; II-A4-142 

T1 Change – Addition of Lot 4A to Waste Stream 

ID-HFEF-S5400-RH March 23, 2011 A-98-49; II-A4-145 

T1 Change – Approval of Waste Stream 

IN-ID-NRF-SPC March 12, 2012 A-98-49; II-A4-159 

T1 Change – Addition of Lot 2 to Waste Stream 

ID-ANLE-S5000 July 25, 2012 A-98-49; II-A4-163 

2013 Continued Compliance Inspection July 16, 2013 A-98-49; II-A4-175 

T1 Change – Addition of Waste Stream ID-EBR-S5000 April 16, 2014 A-98-49; II-A4-183 

2014 Continued Compliance Inspection July 15, 2014 A-98-49; II-A4-190 
 

B-1

ATTACHMENT B 

LIST OF DOE PERSONNEL PRESENT AT EVALUATION 

Name Affiliation Audit Function/Expertise 

David Ams LANL-CO AK Expert 

Derek Ott URS Radiological Characterization Technical Expert 

Douglas M. Pruitt DOE-ID DOE Observer 

Ed Gulbransen NWP-Areva TRU Project Manager 

Irene Joo URS RH Support 

Jason Montoya LANL-CO AK Expert 

Kevin Peters SRS-CCP AK Expert 

Lisa Watson INL-CCP AK Expert 

Marcus A. Pinzel U.S. DOE DOE Observer 

Patsy Gilbert LANL-CO Site Docs 

Scott Smith INL-CCP AK Expert 

Steve Schafer CCP AK Expert 

Thomas L. Clements, Jr. CWI-INL DOE Observer 

Tom Morgan CBFO DOE Observer 
 

C-1

ATTACHMENT C 

LOT 5C: CORRELATION OF LINERS AND DRUMS: 

Historic Liner Drum Number 

C-32 SN-132B 

SN-132A 

NN-28 NN-28B 

NN-28A 

PP-15 PP-15B 

PP-15A 

PP-30 PP-30A-1 

PP-30B-1 

QQ-9 QQ-9B 

QQ-9A 

R-11 FCO108C-2 

FCO108C-1 

FCO108A-2 

FCO108A-1 

FCO108B 

R-2 FCO100B-3 

FCO100B-4 

FCO100B-2 

FCO100B-1 

FCO100C-4 

FCO100C-3 

FCO100C-2 

FCO100C-1 

FCO100A-1 

FCO100A-4 

FCO100A-3 

FCO100A-2 

R-3 FCO101A-3 

FCO101A-2 

FCO101A-1 

FCO101C 

FCO101B 

R-4 FCO104B-2 

FCO104B-1 

FCO104C 

FCO104A 

R-6 FCO102B-2 

FCO102B-1 
 

C-2

Historic Liner Drum Number 

FCO102C 

FCO102A 

R-8 FCO105B-2 

FCO105B-1 

FCO105C-1 

FCO105C-2 

FCO105A 

T-38 SL-007C-1 

SL-007C 

SL-007F 

SL-007B 

SL-007A 

SL-007D 

SL-007E 

T-46 SL18D-1 

SL-18H 

SL-18G 

SL-18F 

SL-18E 

SL-18C 

SL18B 

SL18A 
 

D-1

ATTACHMENT D 

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION 

AK Info on Blanket Pins A794 and A795, F.S. Kirn, June 24, 2970 

INL RH AK Container Tracking Spreadsheet, December 3, 2013 

C002, Interview of Pam Crane, Analytical Laboratory, re: Analytical Laboratory Mission and 

Objectives, S. Smith, August 10, 2005 

C003, Interview of Roger Haga, MFC Safeguards, re.: Traceability of Defense Materials to 

Casting Laboratory and Analytical Laboratory, S. Smith, August 31, 2005 

C214, Telephone Interview Conducted Between CCP Personnel and John Krsul, Matt Laug, Bob 

Villarreal, Doug Porter, Roy Grant, and Bevin Brush, re: Materials and Fuels Complex (MFC) 

Analytical Laboratory Operations and Waste Management Information, S. Smith and C. 

Johnson, April 15, 2008 

C465, Evaluation and Summary of the Process Work Sheets (PWS), S. Smith, May 27, 2009 

C503, Argonne National Laboratory Intra-Laboratory Memo to Distribution, re: Identification of 

EBR-II Assemblies, W.T. Steinman, July 16, 1987 

C4100, Evaluation of 3 HFEF-5 Waste Containers Stored at the MFC Radioactive Scrap and 

Waste Facility to be Added to Waste Stream ID-HFEF-S5400-RH, S. Smith, March 15, 2010 

C4117, Evaluation of 13 RH-TRU Containers for Addition to Waste Stream ID-HFEF-S5400-

RH, J. Kleckner, September 30, 2010 

C4123, Revised Waste Stream ID-HFEF-S5400-RH Waste Stream Volume Estimates, S. Smith, 

October 22, 2010 

CCP-AK-INL-580, Central Characterization Project Acceptable Knowledge Summary Report 

for Remote-Handled Transuranic Debris Waste from Materials and Fuel complex Hot Fuel 

Examination Facility at the Idaho National Laboratory, Waste Stream: ID-HFEF-S5400-RH, 

Revisions 3, January 27, 2011; Draft Revision 4, January 22, 2014; Final Revision 4, March 24, 

2014 

CCP-RC-INL-581, Central Characterization Project Remote-Handled Transuranic Radiological 

Characterization Technical Report for Remote-Handled Transuranic Debris Waste from 

Materials and Fuel Complex Hot Fuel Examination Facility at the Idaho National Laboratory, 

Waste Stream: ID-HFEF-S5400-RH, Revision 0, September 25, 2013; Revision 1, March 12, 

2014 

CCP-AK-INL-582, Central Characterization Project RH TRU Waste Certification Plan for 40 

CFR Part 194 Compliance and Confirmation Test Plan for INL RH Waste Stream: ID-HFEFS5400-RH, Revision 3, October 21, 2011 
 

D-2

CCP-AK-INL-585, Central Characterization Program Sampling and Analysis Plan for the 

Remote-Handled Transuranic (RH-TRU) Debris Waste from Materials and Fuel Complex Hot 

Fuel Examination Facility (HFEF) at the Idaho National Laboratory (INL), Waste Stream: IDHFEF-S5400-RH, Revision 1, December 13, 2012 

CCP-TP-005, Revision 22, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers, Waste Stream ID-HFEF-S5400-RH (CCP-AK-INL-580), May 17, 2011 

CCP-TP-005, Revision 22, CCP Acceptable Knowledge Documentation, Attachment 1 – 

Acceptable Knowledge Document Checklist, HFEF Remote-Handled TRU Debris, June 8, 2011 

CCP-TP-005, Revision 22, CCP Acceptable Knowledge Documentation, Attachment 4 – 

Acceptable Knowledge Source Document Information List, HFEF Remote-Handled TRU 

Debris, June 8, 2011 

CCP-TP-005, Revision 22, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

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

Handled Debris Waste CCP-AK-INL-580 and attached memorandum, June 9, 2011 

Radiochemistry BDR No. ALD13002A, April 19, 2013 

Radiochemistry BDR No. ALD13002B, April 19, 2013 

Radiochemistry BDR No. ALD13002G, April 19, 2013 

Inductively Coupled Plasma Mass Spectrometry BDR No. ALD13002I, April 19, 2013 

Radiochemistry BDR No. ALD13002L, April 19, 2013 

Sampling BDR No. IDRH1202, May 20, 2013 

DTC BDR No. INLRHDTC11004, October 8, 2013, Revised February 26, 2014 

DTC BDR No. INLRHDTC12004, October 7, 2013, Revised February 26, 2014 

DTC BDR No. INLRHDTC13002, October 7, 2013, Revised February 26, 2014 

DTC BDR No. INLRHDTC13003, October 3, 2013, Revised February 26, 2014 

DTC BDR No. INLRHDTC13004, October 3, 2013, Revised February 26, 2014 

DTC BDR No. INLRHDTC13007, October 8, 2013, Revised February 26, 2014 

DTC BDR No. INLRHDTC13008, October 8, 2013, Revised February 26, 2014 

INL-RH-142, Calculations for INL Lot 5C Scaling Factor Development, Revision 0 and 

associated spreadsheet, July 8, 2013; Revision 1, and associated spreadsheet, March 15, 2014 
 

D-3

INL-RH-143, Calculations for Determination of Reportable Radionuclides, Revision 0 and 

associated spreadsheet, July 8, 2013; Revision 1, March 15, 2014 

INL-RH-144, Calculations for Lot 5C DTC Correlation and Sensitivity Studies, Revision 0 and 

associated spreadsheet, July 8, 2013; Revision 1 and associated spreadsheet, March 15, 2014 

INL-RH-145, Calculations for INL Lot 5C Uncertainty Analysis, Revision 0 and associated 

spreadsheet, July 8, 2013; Revision 1, and associated spreadsheet, March 15, 2014 

INL-RH-146, DTC and Related Calculations for ID-HFEF-S5400-RH, Revision 0, and 

associated spreadsheet, September 24, 2013; Revision 1, January 16, 2014, associated revised 

spreadsheet provided on February 26, 2014 

Post Sampling Analysis – INL Lot 5C Memorandum from D. Ott to I. Joo, dated 5/29/2013 

Post Sampling Analysis (Revised) – INL Lot 5C Memorandum from D. Ott to I. Joo, dated 

12/20/2013 

P001, The Defense Programs Origin of Transuranic Waste at Argonne National Laboratory – 

West, H.F. McFarlane, November 2001 

P042, Revision 4, Analytical Laboratory Safety Analysis Report, Idaho National Laboratory, 

April 6, 2006 

P047, Argonne National Laboratory Description and Proposed Operation of the Fuel Cycle 

Facility for the Second Experimental Breeder Reactor (EBR-II), J.C. Hesson, M.J. Feldman, L. 

Burris, ANL-6605, April 1963 

P067, Safeguards and Security Plan for IFR-EFL, R. Villarreal, May 1984 

P116, Dissolution and Clarification of RERTR Silicide Fuels, G.C. Rodrigues, November 8, 

1982 

P144, Hot Fuel Examination Facility/North, Facility Safety Report, R.M. Adams, D.C. 

Hampson, K.R. Ferguson, E. Hylsky, February 1975 

P145, EBR-II Reactor Review, NE Reactor Review Team, May 23, 1980 

P146, Hot Fuel Examination Facility South Final Safety Analysis Report, Argonne National 

Laboratory – West, January 1982 

P178, Overview of Idaho National Laboratory’s Hot Fuels Examination Facility-2007 European 

Working Group Hot Laboratories and Remote Handling, A. B. Robinson, R. P. Lind, and D. M. 

Wachs, September 1, 2007 

P186, Revision 3, HFEF Safety Analysis Report, Idaho National Laboratory, January 31, 2008 

P187, Revision 11, FCF Safety Analysis Report, Idaho National Laboratory, October 26, 2006 
 

D-4

P876, Revision 0, The Ceramic Waste Form Process at Idaho National Laboratory, S. Priebe, 

May 2007 

P877, Revision 0, Internal Report, Production and Sampling Plan for Ceramic Waste Form 

Process Qualification, S.M. Frank, K. Bateman, T.P. O’Holleran, M.F. Simpson, September 

2008 

P878, Test Requirements for Sodium Loop Safety Facility In-Reactor Experiment T6 (P4), 

P4024, Analysis of Spent Fuel Treatment Demonstration Operations, Garcia et al., July 1999 

P4025, Environmental Assessment, Electrometallurgical Treatment Research and Demonstration 

Project in the Fuel Conditioning Facility at Argonne National Laboratory – West, U.S. 

Department of Energy Office of Nuclear Energy, Science and Technology (DOE/EA-1148), May 

15, 1996 

Radiological Drum Survey Lot 5C, October 1, 2013 

Radiological Drum Survey Lot 5C, June 26, 2013 

U025, DRAFT Facility Waste Descriptions Argonne – Waste, December 14, 1973 

U483, HFEF Transuranic Waste Can Log Cards, not dated 

U484, Radioactive Scrap & Waste Storage/Disposal Request and Authorization Forms and 

related documents, not dated 

U541, Shipping Papers Gathered from MFC for ILTSF HFEF-5 Inserts, February 10, 1983 

U551, Compilation of HFEF Process Work Sheets and HFEF Procedure Change Notices; 

includes HFEF PWS Log, various authors, various dates 

U552, Compilation of MFC Liner Documents, various authors, various dates