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

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT 

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

FUEL EXAMINATION WASTE CONTAINERS TO REMOTE-HANDLED DEBRIS 

WASTE STREAM AERHDM AT THE ARGONNE NATIONAL LABORATORY 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Federal Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

November 2010
i

TABLE OF CONTENTS 

Section Page

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

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

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

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

4.0 Scope of This Evaluation .....................................................................................................6

5.0 Technical Evaluation of the Addition of 30-Gallon Containers of Fuel Pin Fuel 

Examination Waste from the Alpha Gamma Hot Cell Facility ...........................................7

5.1 Acceptable Knowledge ........................................................................................... 8

5.2 Radiological Characterization ............................................................................... 17

6.0 Summary of Results ...........................................................................................................23

7.0 Conclusions ........................................................................................................................25

ATTACHMENTS 

Attachment A: Approval Summary for ANL RH Waste Characterization Program 

Attachment B: List of Documents Reviewed by EPA during T1 Evaluation 

Attachment C: Description of the ANL Process Used for Measurement of Surrogate FEW 

Fuel Pins 
ii

ACRONYMS AND ABBREVIATIONS 

AGHCF Alpha Gamma Hot Cell Facility 

AK Acceptable Knowledge 

AKE Acceptable Knowledge Expert 

AKSR Acceptable Knowledge Summary Report 

Am americium 

ANL Argonne National Laboratory 

ANL-E Argonne National Laboratory – East 

ANL-W Argonne National Laboratory – West 

ATR Advanced Test Reactor 

BDR Batch Data Report 

CBFO Carlsbad Field Office 

CCP Central Characterization Project 

CFR Code of Federal Regulations 

CH Contact-Handled 

Ci curie 

CRR Characterization Reconciliation Report 

Cs cesium 

CSSF Correlation and Surrogate Summary Form 

CTP Confirmatory Test Plan 

DOE U.S. Department of Energy 

DQO Data Quality Objective 

DR Discrepancy Resolution 

DTC Dose-to-Curie 

EBR-II Experimental Breeder Reactor-II 

EPA U. S. Environmental Protection Agency 

FEW Fuel Examination Waste 

FFTF Fast Flux Test Facility 

FIMS Fuel Information Management System 

g gram 
iii

HBR H.B. Robinson 

m

3

 cubic meters 

mrem/hr millirem per hour 

NCR Non-Conformance Report 

ORIGEN Oak Ridge Isotopic Generation Computer Program 

PTS Project Tracking System 

Pu plutonium 

R/hr roentgen per hour 

Rem Roentgen Equivalent Man 

RERTR Reduced Enrichment Research and Test Reactor Program 

RH Remote-Handled 

SPM Site Project Manager 

Sr strontium 

T1 Tier 1 

T2 Tier 2 

Th thorium 

TMU Total Measurement Uncertainty 

TREAT Transient Reactor Test Facility 

TRU Transuranic 

U uranium 

UREX Uranium Extraction 

VE Visual Examination 

WCPIP Remote-Handled TRU Waste Characterization Program Implementation Plan 

WIPP Waste Isolation Pilot Plant 

WMC waste matrix code 

WMP Waste Material Parameter 

WSPF Waste Stream Profile Form 

WWIS WIPP Waste Information System 
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 add Fuel Examination Waste (FEW) to the previously-approved remotehandled (RH) transuranic (TRU) debris Waste Stream AERHDM at the U.S. Department of 

Energy’s (DOE’s) Argonne National Laboratory (ANL)1. In January 2007, EPA approved the 

Central Characterization Project (CCP) to characterize RH waste at ANL. Using the EPAapproved waste characterization processes discussed in this report, ANL-CCP can characterize 

FEW from the processing of fuel pins in the Alpha Gamma Hot Cell Facility (AGHCF). This 

AGHCF FEW packaged in 30-gallon containers2 and thus characterized can be added to the 

ANL Waste Stream AERHDM for disposal at 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 drums. 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. Table 1 of 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 added containers to the 

approved AERHDM waste stream as shown in Attachment A. 

On July 29, 2010, the Carlsbad Field Office (CBFO) requested EPA approval of a T1 change to 

include all of the AGHCF FEW packaged in 30-gallon containers in Waste Stream AERHDM. 

ANL-CCP issued a new standing order, CCP-SO-ANLE-003, Revision 0, to formally introduce 

the technique of measuring and recording the length of the AGHCF fuel pin FEW during VE. 

The AGHCF fuel pin FEW were characterized by the method of dimensional analysis, as 

described in Appendix C of CCP-AK-ANLE-501, Revision 3. 

Prior to the formal T1 request in July, EPA visited ANL in May and observed and approved this 

new procedure in use at ANL. Because there were no new equipment or additional new 

processes on site at ANL as part of the T1 request, EPA conducted a desktop review of this 

change, concluding that the ANL-CCP plan to use the EPA-approved system of controls to 

characterize the 30-gallon containers of fuel pin FEW from the AGHCF was acceptable. EPA 

did not identify any findings or concerns during this evaluation. As a result, EPA approves the 

T1 change request to add 30-gallon containers of the AGHCF fuel pin FEW to ANL-CCP’s 

previously approved AERHDM waste stream. This approval is limited to the AGHCF fuel pin 

FEW. Inclusion of additional FEW containers from the AGHCF in Waste Stream AERHDM is a 

Tier 2 (T2) change if those containers have the same pedigree and are characterized using the 

 

1

 ANL was initially designated ANL-E to distinguish it from ANL-West. Since 2009, ANL-W was renamed the

Materials and Fuel Complex and ANL-E is ANL. Both designations are found in the documents EPA reviewed for 

this evaluation and these terms are interchangeable in this report. 

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

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

same dimensional analysis as the FEW discussed in this report as shown in Table 1 below. For 

this T2 change, ANL-CCP must: 

• Notify EPA of their intention to add containers of FEW debris from the AGHCF, including 

the approximate number of additional containers and the approximate additional volume of 

waste, and provide the timeframe for waste 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 Report (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 AGHCF FEW other than the fuel pin FEW discussed in this report, 

specifically characterization of the Reduced Enrichment Research and Test Reactor Program 

(RERTR) plates FEW and crucibles and melts FEW, is a T1 change, as shown in Table 1. Table 

1 also shows new T1 changes or specific additions to existing T1s in bold text. There are several 

T2 changes that were established during the baseline approval that remain in effect, and these are 

listed as applicable in Section 5.1. In addition, there are minor changes in Table 1 to incorporate 

recent T1 approvals and ensure consistency. 

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

evaluation. This information will be provided 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 No

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)*** that have the potential to affect the characterization process to CCP-AK-ANLE-500, CCP-AK-ANLE-501 or CCP-AK-ANLE-502 Implementation of load management for any RH waste stream 

Characterization of any AGHCF FEW other than the fuel pins 

discussed in this report, specifically AGHCF RERTR plates FEW and crucibles and melts FEW

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 modificationand AK Summary 

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

Notification to EPA of the intention AERHDM including the approximatvolume(s) of waste, the timeframe focharacterization, and disposal and sudocumenting that the pedigree of the as those covered by the baseline and/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 

substantive modification thereof*** Any new waste stream not approved under this baseline or addition 

of containers to Waste Stream AERHDM that require changing the 

Notification to EPA that revisions of C

that require CBFO approval** are comSubmission of an updated CCP-AK-ANradiological characterization process(s) the same as those covered by the basel
4 

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 No

RH Waste Characterization 

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

established radionuclide scaling factors Application of new scaling factors for isotopic determination other than those documented in CCP-AK-ANLE-501 Application of any new characterization technique other than the dimensional analysis described in this report for AGHCF fuel pin FEW

Submission of DTC BDRs or calculat

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 contain

list of fully characterized containers pr

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

New T1 changes or specific additions to existing T1s in bold text 

* 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 EVALUATIONS 

Any changes to the waste characterization activities from the date of the baseline inspection must 

be reported to, and, if applicable, approved by EPA, according to the tiering requirements set 

forth in the ANL 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. The purpose of a baseline inspection is to approve the site’s waste 

characterization program based on the demonstration that the program’s components, with 

applicable conditions and limitations, can adequately characterize TRU wastes and comply with 

the regulatory requirements imposed on TRU wastes destined for disposal at the WIPP. An EPA 

inspection team conducts the baseline inspection to verify that the site’s system of controls is 

technically adequate and properly implemented. 

Following the EPA’s approval of waste characterization processes evaluated during the baseline 

inspection, EPA is authorized to evaluate and approve, if necessary, changes to the site’s 

approved waste characterization program by conducting additional inspections under the 

authority of 40 CFR 194.24(h). Under 40 CFR 194.24, EPA has the authority to conduct 

continued compliance inspections to verify that the site continues to use only the approved waste 

characterization processes to characterize the waste and remains in compliance with all the 

regulatory requirements. Based on the adequacies of the waste characterization processes 

demonstrated during the baseline inspection, including all conditions and limitations, EPA 

specified which subsequent waste characterization program changes or modifications must 

undergo further EPA inspection or approval under 40 CFR 194.24. This was accomplished by 

assigning a tier level to each aspect of the ANL-CCP’s characterization program. T1 activities 

have more stringent reporting requirements and require that DOE notify EPA, and that EPA 

provide approval prior to implementation. The rule under which baseline inspections are 

conducted can be found in the Federal Register (Vol. 69, No. 136, pages 42571-42583 of 

July 16, 2004). 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation of a T1 change to include the FEW fuel pin 

wastes from the AGHCF packaged in 30-gallon containers in Waste Stream AERHDM, as 

described in CCP-AK-ANLE-500, Revision 5 and Discrepancy Resolution (DR) form DR023. 

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

decision regarding the inclusion of the AGHCF fuel pin FEW has been conveyed to DOE 

separately by letter. As discussed previously, EPA will also announce the decision on its website 

at www.epa.gov/radiation/WIPP, in accordance with 40 CFR 194.8(b)(3). 

The DOE documents that EPA reviewed for this 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: 
6 

Manager, National TRU Program 

Carlsbad Field Office 

U.S. Department of Energy 

P O Box 3090 

Carlsbad, NM 88221-3090 

4.0 SCOPE OF THIS EVALUATION 

The scope of this evaluation covers inclusion of 30-gallon containers of the AGHCF fuel pin 

FEW as described in CCP-AK-ANLE-500, Revision 5 in Waste Stream AERHDM. The 

evaluation was performed by comparing elements assessed in the previous EPA approvals with 

information about the new waste containers that was provided by ANL-CCP/CBFO to ensure 

that they fit within the approvals issued by EPA previously. Because 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, inspection checklists were not used. 

A DR form that was provided by ANL-CCP for incorporation into the AK Summary Report 

(AKSR) corrects the number of drums and waste volume described in Revision 5 of the AKSR 

(DR023). The DR form describes Waste Stream AERHDM as containing (a) 15.6 cubic meters 

(m3) of debris waste from the K-Wing in Building 205 and (b) 37.4 m3 of debris waste from the 

AGHCF in Building 225, including the 30-gallon containers of the AGHCF fuel pin FEW that 

are the subject of this T1 evaluation 

As part of this evaluation, EPA examined the updated AK information to verify that the 

additional waste containers had the same pedigree as that of the approved AERHDM debris 

waste stream and were characterized using an appropriate radiological characterization process. 

This examination applies to the AGHCF fuel pin FEW packaged in 30-gallon drums with the 

same pedigree as that of the previously approved Waste Stream AERHDM that were 

characterized using the dimensional analysis method, as discussed in Section 5.0 of this report. 

Personnel who participated in the T1 evaluation are listed in Table 2, along with each person’s 

affiliation and function during the evaluation. 

Table 2. T1 Evaluation Participants 

Name Affiliation & Function 

Rajani Joglekar Lead Inspector, U.S. EPA 

Ed Feltcorn Inspector, U.S. EPA 

Connie Walker Technical Evaluator – Acceptable Knowledge, SC&A 

Kira Darlow Technical Evaluator – Acceptable Knowledge, SC&A 

Patrick Kelly Technical Evaluator – Radiological Characterization, SC&A 

Amir Mobasheran Technical Evaluator – Radiological Characterization, SC&A 

Kevin Peters Acceptable Knowledge Expert, ANL-CCP 

Irene Quintana Site Project Manager, ANL-CCP 

Jene Vance Radiological Characterization Subject Matter Expert, ANL-CCP 
7 

5.0 TECHNICAL EVALUATION OF THE ADDITION OF 30-GALLON 

CONTAINERS OF FUEL PIN FUEL EXAMINATION WASTE FROM THE 

ALPHA GAMMA HOT CELL FACILITY 

The population of waste approved during the Baseline Inspection consisted of 45 30-gallon 

drums of RH TRU debris waste generated in the AGHCF. Revision 5 of the AKSR and DR023 

incorporate and explain the addition of the AGHCF FEW packaged in 30-gallon containers to the 

previously approved RH debris Waste Stream AERHDM. The AGHCF FEW, historically 

designated as “sweeps,” “high-level scrap,” or “recoverable material,” was originally segregated 

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

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

There are over 3,000 samples containing fuel-bearing material within the AGHCF. This material 

consists of nuclear irradiated fuel specimens (fuel pins), metallography mounts, and other fuelbearing materials (RERTR plates and crucibles and melts). This material, principally light water 

reactor fuels with some mixed-oxide fuel, RERTR carbide, and thorium (Th) fuels, was 

generated by research and experimental activities conducted at U.S. Nuclear Regulatory 

Commission (NRC) and DOE facilities. The activities conducted involved sectioning, grinding, 

and polishing for metallography, gamma spectrometry, high temperature examination, fission 

gas collection and analysis, macrophotography, and profilometry. The NRC facilities included 

the Dresden, Limerick, H.B. Robinson (HBR), Saxton, Quad Cities, Big Rock Point, Surry, and 

Three Mile Island commercial nuclear power plants. The DOE sites that provided fuel-bearing 

material were the Advanced Test Reactor (ATR), Chicago Pile, Experimental Breeder Reactor-II 

(EBR-II), Engineering Test Reactor, Fast Flux Test Facility (FFTF), Material Test Reactor, NReactor, Oak Ridge Research Reactor, Savannah River Reactor, and Transient Reactor Test 

Facility (TREAT). Additionally, fuel examination material came from a CANada Deuterium 

Uranium (CANDU) reactor and the Belgonair Reactor-3, and some was in the form of Intense 

Pulsed Neutron Source targets and other target disks (P2032, U076). Sodium-bonded fuel 

examination materials stored in the AGHCF will be packaged and transferred to Idaho National 

Laboratory and are not included in Waste Stream AERHDM (C2025, P2032, U076). 

EPA examined the AK and radiological characterization processes and associated information to 

determine whether ANL-CCP demonstrated compliance with 40 CFR 194.8 for a T1 change to 

add containers to Waste Stream AERHDM. EPA concluded that ANL-CCP continues to 

appropriately apply the system of controls approved by EPA during the Baseline Inspection. 

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

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

AGHCF fuel pin FEW in Waste Stream AERHDM. ANL-CCP provided CCP-AK-ANLE-500, 

Revision 5 and CCP-AK-ANLE-501, Revision 3 to EPA for review of the AGHCF fuel pin FEW 

being packaged in 30-gallon containers. As a result of EPA’s initial review, several technical 

issues were identified that necessitated the revision of two calculation packages and Revision 3 

of CCP-AK-ANLE-501, Appendix C. Additionally, a new calculation package was created. The 

revised documents and new calculation packages were provided to EPA and were included in 

this T1 evaluation along with attachments, source documents, required forms and other data that 
8 

were provided to EPA. The listing of all documentation reviewed is in Attachment B, and the list 

of VE batch data reports (BDRs) and radiological characterization calculation packages 

examined is presented in Table 3. Because the radiological characterization process for the 

AGHCF fuel pin FEW waste does not involve the generation of BDRs, the characterization for 

each drum is documented in a separate calculation package, as shown in Table 3. 

Table 3. Batch Data Reports and Calculation Packages Examined 

Drum Number VE BDR Number Calculation Package Number 

952 RHANLVE100008 ANLE-RH-27, Revision 1 

953 RHANLVE100008 ANLE-RH-35, Revision 1 

954 RHANLVE100008 ANLE-RH-36, Revision 0* 

955 RHANLVE100008 ANLE-RH-37, Revision 0* 

956 RHANLVE100008 ANLE-RH-38, Revision 0* 

*The calculation packages for these drums were provided initially but upon examination were found to 

require revision and the Revision 0 packages were not used for this T1 evaluation. 

5.1 Acceptable Knowledge 

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

waste characterization program demonstrated compliance with the requirements of 40 CFR 194.8 

for the inclusion of the AGHCF fuel pin FEW in Waste Stream AERHDM. 

Waste Characterization Element Description

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

characterization as impacted by addition of new containers: 

• Waste stream identification and definition 

• Radionuclide content of additional waste 

• Physical composition of additional waste 

• Sufficiency of modified AKSR to include the additional waste 

• Drum data traceability and modifications to the Waste Stream Profile Form (WSPF) and 

Characterization Reconciliation Report (CRR) 

• Defense origin of additional waste 

• Identification of high-level waste and spent nuclear fuel 

• AK source document sufficiency 

• Modifications to the Confirmatory Test Plan (CTP) 

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

correlation 

• Personnel training 

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

• AK accuracy 

• Load management 

• Identification and attainment of Data Quality Objectives (DQOs)
9 

Technical Evaluation

To assess the appropriateness of inclusion of the AGHCF fuel pin FEW packaged in 30-gallon 

containers based on its radiological and physical characteristics, EPA evaluated the AK-based 

radiological and physical characteristics information. EPA evaluated the following: how these 

data had been integrated, impacts of the information on the waste stream, changes to the 

radiological and physical characteristics of the waste and other elements that could affect 

pertinent characteristics of Waste Stream AERHDM. Results of the analysis are presented below. 

When information presented in the text is supported directly by an AK reference, the reference is 

cited in parentheses. 

(1) The definition of Waste Stream AERHDM was examined with respect to the addition of 

the Alpha Gamma Hot Cell Facility fuel pin fuel examination waste and found to be 

adequate. 

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

AGHCF and the K-Wing.3

 As part of the baseline approval, EPA concluded that the waste 

stream was adequately defined, but the waste stream did not at that time include the AGHCF fuel 

pin FEW. After reviewing the provided documentation, EPA concluded that inclusion of the 

AGHCF fuel pin FEW in Waste Stream AERHDM is adequately supported. 

The AGHCF fuel pin FEW containers were generated as a result of the same hot cell activities 

that generated the previously approved AGHCF debris waste containers (see see EPA Docket 

No. A-98-49; II-A4-73). As indicated in the AKSR, the AGHCF fuel pin FEW containers under 

evaluation for addition to Waste Stream AERHDM contain “similar debris [to the previously 

approved waste containers] including irradiated fuel test materials and residues (debris, fuel pin 

fragments, samples, capsules, and swarf) previously stored as accountable materials4

 in the 

AGHCF. This waste has been generated at the AGHCF during the examination of irradiated and 

un-irradiated fuel pins and other reactor materials from various reactor programs at ANL-W5 and 

other DOE reactors.” 

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

measurements of the AGHCF fuel pin FEW are documented on CCP-SO-ANLE-003, Revision 

0, Attachment A. The VE operators creating the VE data sheets (contained in the VE BDR 

described in Table 3, above) assigned Waste Matrix Code (WMC) S5400, Heterogeneous Debris 

to the examined AGHCF fuel pin FEW containers. This is the same WMC as is assigned to the 

previously approved containers in Waste Stream AERHDM, which is one indication that the 

AGHCF fuel pin FEW containers have the same physical characteristics as those in the approved 

waste stream. See Item (3), below, for additional discussion on the physical characteristics of the 

AGHCF fuel pin FEW. 

 

3

 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. 

4 Accountable materials are items that are tracked and controlled in accordance with DOE M 435.1-1 because of 

their special nuclear material content. 

5

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

The AGHCF fuel pin FEW is residual fuel materials from the fuel examination activities that 

contaminated the previously approved AGHCF debris waste containers. The same AK source 

documents (including P808, P828, U1003) were used to determine the ORIGEN2.2 inputs for 

both the AGHCF fuel pin FEW containers and the previously approved AGHCF debris waste 

containers. However, as indicated in the sampling plan (CCP-AK-ANLE-502, Revision 2, Draft 

A), the same scaling factors were not applied to the AGHCF fuel pin FEW containers because 

the radionuclide activity and mass for each container were more accurately calculated based on 

the mass of the discrete fuel specimens loaded into the individual drums. See Item (2), below, for 

additional discussion on the radiological characteristics of the AGHCF fuel pin FEW. 

Characterization of any AGHCF FEW other than the fuel pins discussed in this report is a T1 

change. Specifically, this limitation is directed at the AGHCF RERTR plates FEW and crucibles 

and melts FEW. 

(2) Radiological characteristics of the Alpha Gamma Hot Cell Facility fuel pin fuel 

examination waste were assessed with respect to their similarity to Waste Stream 

AERHDM and found to be adequate. 

ANL-CCP developed a radiological characterization process using dimensional analysis that 

fully utilizes the available AK source documentation. As mentioned in Item (1) above, the same 

AK source documents (including P808, P828, U1003) were used to determine the ORIGEN2.2 

inputs for both the AGHCF fuel pin FEW containers and the previously approved AGHCF debris 

waste containers. The modeling produced the activities and masses of the individual 

radionuclides on a per mass unit basis of the fuel material. These radionuclide activities and 

masses were then multiplied by the total mass for each discrete fuel type within a container (as 

recorded in VE documentation) and summed to derive the total radionuclide activity and mass of 

the drum. This process resulted in more accurate radionuclide activity and mass calculations for 

each container than could be calculated using the DTC process. 

The AKSR provided to EPA did not originally include sufficient discussion of the radiological 

characterization process to be implemented for the AGHCF fuel pin FEW containers. After 

discussing this with ANL-CCP representatives, ANL-CCP provided a Freeze File6

 version of the 

draft AKSR, Revision 6 (U911) that incorporates the radiological characterization process 

described above, as implemented for all of the AGHCF FEW containers. EPA finds these 

revisions to be adequate for the purposes of reviewing the inclusion of AGHCF fuel pin FEW in 

Waste Stream AERHDM and expects a formal revision of the AKSR to be completed prior to the 

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

(3) Physical characteristics of the Alpha Gamma Hot Cell Facility fuel pin fuel examination 

waste were assessed with respect to the physical characteristics of Waste Stream 

AERHDM and were found to be adequate. 

 

6

 Freeze File: As a result of EPA inspections, if CCP must revise documents to address EPA issues, CCP makes 

those changes and provides a copy to EPA as objective evidence for the changes made. These revisions are then 

processed by CCP’s document control process to generate an official version as the most current revision. 
11 

ANL-CCP evaluated the impact inclusion of the AGHCF fuel pin FEW, consisting of primarily 

metal debris, would have on the Waste Material Parameters (WMPs) previously calculated for 

Waste Stream AERHDM. They found that the additional fuel weight in the AGHCF fuel pin 

FEW-containing containers would contribute less than one percent to the total waste weight of 

the container (C2026, U2013). Therefore, the impact to the WMPs is considered to be negligible. 

Based on the results of this evaluation, ANL-CCP concluded that the AGHCF fuel pin FEW is 

physically similar to the AGHCF debris waste, and that the WMPs published in the AKSR for 

the AGHCF debris waste are comparable and bounding. VE will be performed at the time of 

packaging to confirm the absence of prohibited items. 

EPA reviewed ANL-CCP’s evaluation as presented in the AKSR and found the logic to be sound 

and acceptable; however, ANL-CCP’s evaluation is based on the assumption that the 

configuration of each AGHCF fuel pin FEW-containing 30-gallon container would be one 7-

gallon container containing the AGHCF fuel pin FEW in the bottom half of the 30-gallon 

container and one 7-gallon container containing AGHCF debris in the upper half (C2026, 

U2013). The VE records provided to EPA indicate that each 30-gallon AGHCF fuel pin FEW 

container contains two 7-gallon containers of the AGHCF fuel pin FEW and no additional 

AGHCF debris waste. ANL-CCP explained that the packaging configuration described in the 

AKSR and source document U2013 was just one example of how the AGHCF fuel pin FEW 

could be packaged. It was determined that the radiological characteristics of the container could 

be determined more accurately if all of the radionuclide-contributing debris in a container are 

FEW fuel pins. Therefore, all AGHCF fuel pin FEW containers are likely to contain two 7-

gallon cans of the AGHCF fuel pin FEW. ANL-CCP explained that this does not impact the 

WMPs assigned to the containers in Waste Stream AERHDM because the WMP estimates are 

sufficiently broad to account for all possibilities, including the increased quantity of metal debris 

associated with the AGHCF fuel pin FEW. The AGHCF fuel pin FEW containers are expected to 

primarily contain iron-based, aluminum-based, and other metals in combinations such that the 

expected WMP weight percent ranges are not exceeded in any container.

The Freeze File AKSR clarified that the packaging configuration implemented for all of the 

AGHCF FEW containers, including the AGHCF fuel pin FEW that is the subject of this T1 

review, includes two AGHCF FEW 7-gallon containers and no AGHCF debris, and that the 

different packaging configuration will not affect the overall contribution of the AGHCF FEW to 

the WMPs of Waste Stream AERHDM as a whole. The Freeze File also adds language defining 

the AGHCF FEW as debris consisting primarily of metal items. EPA finds these revisions to be 

adequate and expects a formal revision of the AKSR to be completed prior to the CCP’s 2011 1st

quarter submission of T2 changes to EPA for review and concurrence. 

(4) The Acceptable Knowledge Summary Report and implementation of acceptable 

knowledge as required in Attachment A of the Waste Characterization Program 

Implementation Plan were evaluated and were found to be adequate. 

EPA examined Revision 5 of the AKSR and found that the document contained all the necessary 

pieces, but that various sections of the document did not adequately support inclusion of the 

AGHCF fuel pin FEW, as summarized by the three issues described below: 
12 

Issue No. 1: The radionuclide characterization section did not adequately describe the 

radiological characterization process as applied to the AGHCF fuel pin FEW. See item (2), 

above, for additional description and resolution of this issue. 

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

on Waste Stream AERHDM WMPs and the source documents supporting this discussion 

were not consistent with the physical characteristics identified in the VE BDR. See item (3), 

above, for additional description and resolution of this issue. 

Issue No. 3: The argument that the AGHCF fuel pin FEW is not spent nuclear fuel or high 

level waste was not adequately supported in the AKSR text by references to source 

documentation. See item (7), below, for additional description and resolution of this issue. 

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

addressed all three issues. The revised AKSR more clearly explains the radiological 

characterization process of the AGHCF fuel pin FEW containers, more clearly describes the 

AGHCF fuel pin FEW container packaging configuration and WMPs, and lists the source 

documents used by ANL-CCP to develop the spent nuclear fuel/high level waste arguments. 

EPA finds that the AKSR will be sufficient upon inclusion of the revisions as demonstrated in 

the draft Revision 6, and expects a formal revision of the AKSR to be completed prior to the 

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

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

modifications of the Waste Stream Profile Form and related Characterization 

Reconciliation Report were examined and were found to be adequate. 

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

processing, transport, and characterization processes up to and including that performed by 

ANL-CCP. Data management in the Project Tracking System (PTS) data system used by ANLCCP was also assessed, as well as presentation and general contents of the ANL-CCP waste 

characterization data. 

The AGHCF fuel pin FEW containers are newly generated, so there are no original data 

packaging sheets or other generator documentation associated with individual containers. The 

AGHCF fuel pin FEW packaged in the containers, however, has been stored in the AGHCF as 

accountable materials7

; therefore, there are historic records for the contents of the individual 

containers. ANL-CCP indicated that five containers have been generated and undergone ANLCCP VE and radiological characterization. EPA was provided VE BDR RHANLVE100008 that 

included all five AGHCF fuel pin FEW containers – 952, 953, 954, 955 and 956. Examination of 

these data indicated that each drum contained two 7-gallon containers with a shield pot, each of 

which held nine to ten fuel specimens. Calculation packages ANLE-RH-27 and ANLE-RH-35 – 

38 were provided and included measurements for Drum Nos. 952 – 956, respectively. Using 

these packages, EPA traced the accountable materials identified in drum Nos. 953 and 956 

backwards from the PTS screenshots through VE documentation and the 7-gallon container 

 

7

 See Footnote 4 above. 
13 

packaging records to the Fuel Information Management System (FIMS) that identified the host 

reactor and acquisition date for each specimen. Documentation included data and the 

radiological characterization calculations for each container. The documents associated with 

each drum and 7-gallon can are summarized in Table 4, below. 

Table 4. Alpha Gamma Hot Cell Facility Fuel Examination 

Waste Fuel Pin Data Tracking References 

Drum Can Shield 

Pot Fuel Elements FEW Tracking Form Record 

FIMS Inventory 

(U076) 

Calculation 

Package 

953 597 7021 604D1-604D9 953-597-7021.pdf Page 14 ANLE-RH-35 

953 604 7020 604A1-604A5 953-604-7020.pdf Page 13 ANLE-RH-35 

953 604 7020 606A1-606A5 953-604-7020.pdf Page 13 ANLE-RH-35 

956 909 7034 604E1-604E9 956-909-7034.pdf Page 14 ANLE-RH-38* 

956 570 7033 604C1-604C9 956-570-7033.pdf Page 14 ANLE-RH-38* 

*Revision 0 of calculation package Nos. ANLE-RH-36, ANLE-RH-37 and ANLE-RH-38 were not technically 

acceptable for radiological characterization, and were revised. However, they contained sufficient information to 

support the traceability analysis. 

A copy of the Attachment 8 container list was provided, but it was dated 2007 and did not 

include the AGHCF fuel pin FEW containers. However, the July 22, 2010 Add Container Memo 

(provided separately) requested the inclusion of the five AGHCF fuel pin FEW containers in the 

waste stream. EPA expects that Attachment 8 will eventually be formally updated to include the 

AGHCF fuel pin FEW containers. As required in EPA’s baseline approval, notification to EPA 

of the availability of an updated Attachment 8 remains a T2 change. 

ANL-CCP did not originally provide documentation pertaining to the management of drum data 

in the CCP PTS system, nor did they provide Site Project Manager (SPM) review 

documentation, or a CRR that addressed the AGHCF fuel pin FEW. Also, the five AGHCF fuel 

pin FEW containers mentioned above had not been entered into the WDS. EPA requested a CRR 

that addressed the AGHCF FEW, as well as modifications (change requests) to the WSPF related 

to the AGHCF fuel pin FEW and print-outs of each drum as currently documented in the PTS 

and AK Tracking Spreadsheet. ANL-CCP provided all of the requested information, except for 

the revised WSPF, which will be completed once EPA approves the waste stream and it is 

subsequently certified by CBFO. The CRR was provided in draft form solely for the purpose of 

EPA’s T1 review. EPA evaluated the draft CRR and found it to be adequate. As required in 

EPA’s baseline approval, revision of the WSPF and related attachments including the CRR 

remains a T2 change, and EPA requires notification of these changes when they are made. 

Providing these data demonstrated that ANL-CCP is able to generate the required documentation 

for the AGHCF fuel pin FEW containers. 

 

(6) The identification of the Alpha Gamma Hot Cell Facility fuel pin fuel examination waste 

as defense waste was examined and found to be adequate. 

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

AERHDM for the AGHCF waste during the baseline inspection (No. EPA-ANL-CCP-RH-9.06-

8). EPA determined that the AK record contains sufficient evidence to demonstrate that all of the 
14 

TRU wastes generated by AGHCF operations are contaminated with materials from atomic 

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

safeguards, and defense research and development activities. ANL has also played an integral 

role supporting the underlying historical and ongoing defense missions associated with DOE test 

and research reactor programs, including the ANL-W EBR-II, Zero Power Plutonium (Physics) 

Reactor, ATR, TREAT, and Hanford FFTF (C124, C330, P002, P585, U009, U076). The 

AGHCF fuel pin FEW wastes are a subset of the materials processed in the AGHCF and, as 

stated in Item (1) above, the AGHCF fuel pin FEW was generated as a result of defense-related 

hot cell activities. Therefore, the AGHCF fuel pin FEW containers that are added to Waste 

Stream AERHDM meet the WIPP requirement of defense-related waste. 

(7) Rationale for why the Alpha Gamma Hot Cell Facility fuel pin fuel examination waste is 

not high-level waste or spent nuclear fuel was examined and found to be adequate. 

The AKSR, Revision 5, as presented to EPA for this T1 evaluation did not reference any of the 

AGHCF FEW materials or any AK source documents in the statement regarding spent nuclear 

fuel and high-level waste. EPA discussed this issue with ANL-CCP representatives who then 

provided EPA with a Freeze File containing the draft revised AKSR (U911). EPA finds the 

discussion presented in U911 and summarized below to be adequate and expects a formal 

revision of the AKSR to be completed prior to the CCP’s 2011 1st quarter submission of T2 

changes to EPA for review and concurrence. 

According to the Nuclear Waste Policy Act (NWPA), spent nuclear fuel is fuel that has been 

withdrawn from a nuclear reactor following irradiation, the constituent elements of which have 

not been separated by reprocessing. DOE’s M 435.1-1, DOE Radioactive Waste Management 

Manual expands on this definition to clarify that test specimens of fissionable material irradiated 

for research and development only may be classified as TRU waste, as appropriate. ANL-CCP 

determined that the waste containers in Waste Stream AERHDM, including the AGHCF fuel pin 

FEW containers, “contain test residues, test materials, and the resultant test fragments from the 

fuel pin test specimens, including irradiated pin fragments and dispersed particulate (fines and 

dust).” ANL-CCP reviewed the AGHCF accountable materials inventories to verify that the 

materials to be packaged did not contain intact irradiated fuel pins (U076). EPA inspected the 

AGHCF fuel information management system (FIMS) database documentation and agrees that 

the radiological materials managed in the AGHCF were primarily fuel samples and swarf, as 

indicated by the size of the material and the segment/sample identification record (U076). ANLCCP also states that the intact irradiated fuel pin test specimens were managed separately and are 

not included in this waste stream. As a result, the AGHCF fuel pin FEW is not considered spent 

nuclear fuel. 

High-level waste is defined by the NWPA as the 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 

AGHCF fuel pin FEW is not spent nuclear fuel, so by definition the waste could not contain 

high-level waste. Also, the waste produced at the AGHCF, including the fuel pin FEW, 
15 

originated from laboratory operations associated primarily with the examination of irradiated 

materials and research and development of laboratory-scale technology (P004 and P380). ANLCCP concluded that the waste is not a spent nuclear fuel or high-level waste, and EPA accepts 

these arguments. 

(8) Sufficiency of Acceptable Knowledge support documents and related document tracking 

with respect to the addition of the Alpha Gamma Hot Cell Facility fuel pin fuel 

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

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

document types, following the format typically used by ANL-CCP for RH wastes. The listing is 

complete, and is easy to understand. ANL-CCP identified several references specific to the 

AGHCF FEW, including the AGHCF fuel pin FEW. As discussed elsewhere in this T1 

evaluation [items (2), (3), and (7)] EPA identified several places in the AKSR that required 

revision, including places where statements were made about the AGHCF fuel pin FEW without 

listing associated source documents to support the statements. EPA discussed this with ANLCCP representatives, and source document references were added to the text in a draft revision of 

the AKSR (U911). No additional source documents were added to the AK Source Document 

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

to the technical elements discussed in the AKSR and not the individual source documents used 

by the AK Expert (AKE) to prepare the AK basis for the waste stream in question (see 

Attachment B for a list of reviewed references). 

(9) Evaluation of the Certification Plan and Confirmatory Testing Plan was found to be 

satisfactory. 

RH sites must generate a Certification Plan that explains how RH waste characterization will 

take place at each site, as well as a CTP when this plan is required as part of AK Qualification. 

ANL-CCP provided a combined Certification Plan and CTP for EPA review and EPA reviewed 

its compatibility with the Waste Characterization Program Implementation Plan (WCPIP) 

requirements. ANL-CCP’s characterization program for the AGHCF fuel pin FEW includes the 

use of fuel specimen dimensional analysis in combination with ORIGEN2.2 modeling output to 

quantify the WIPP-tracked radionuclides, and VE during packaging to identify the physical 

WMPs. The length of each fuel specimen will be measured and documented during VE (EPA 

observed this operation at ANL, in May 2010, as discussed later in this report under Section 5.2 

below). The measured length will be multiplied by the fuel mass per unit length value derived 

from fuel specimen design information in the AK record. ORIGEN2.2 modeling resulted in the 

activities of the individual radionuclides on a per mass unit basis of the fuel material, which 

when multiplied by the total mass of the discrete fuel specimens will determine the activity 

values for each quantity of fuel specimen. The activity values for each fuel specimen loaded into 

a container will be summed to derive the total activity for any given container of the AGHCF 

fuel pin FEW. 

Review of the CTP showed that all of the required characterization elements were adequately 

addressed. Based on the information above, EPA determined that ANL-CCP adequately used a 

combination of approaches to characterize and qualify AK data as required in 40 CFR 194.24/22. 
16 

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

Training records for Kevin Peters (AKE), Steve Schafer (AKE), and Irene Quintana (SPM) were 

examined. Records were provided on July 21, 2010. It should be noted that the documentation 

examined did not indicate that ANL-CCP individuals are trained to EPA requirements, nor are 

they trained with respect to radiological characterization aspects, both of which are required in 

the WCPIP. Since the WCPIP is currently under revision, EPA will examine future training 

against the modified WCPIP. 

(11) Non-Conformance Reports and Discrepancy Resolution Forms were examined and were 

found to be adequate. 

EPA examined Non-Conformance Reports (NCRs) and Discrepancy Resolution (DR) forms 

related to Waste Stream AERHDM during Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8 

and found the preparation of these documents to be adequate. No NCRs are available for the 

AGHCF fuel pin FEW as only five drums have been fully characterized at this time8

. One DR 

form (DR023) addresses the change in the estimated volume of the AGHCF FEW as a whole. 

Based on this single DR, and NCRs and DR forms evaluated during previous reviews, EPA 

understands and expects that the process EPA evaluated in the past would be used to develop 

these documents when necessary. 

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

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

completed on May 13, 2010, but does not include evaluation of the AK accuracy for any 

AGHCF fuel pin FEW containers. EPA’s baseline approval includes changes or updates to the 

AK Accuracy Report as a T2 change. Therefore, ANL-CCP/CBFO would automatically notify 

EPA when the next AK Accuracy Report specific to this waste stream is available. 

(13) Use of a Correlation and Surrogate Summary Form and Load Management were 

evaluated and were determined to not apply to these wastes. 

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

information from a related CH waste stream is used in the RH waste characterization process. 

During Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8, ANL-CCP indicated that CH data 

was not used in this manner. Inclusion of the AGHCF fuel pin FEW in Waste Stream AERHDM 

also did not require completion of a CSSF. 

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

AERHDM and this will not change with inclusion of the AGHCF fuel pin FEW that was the 

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

of load management is a T1 change requiring EPA prior approval and this is unchanged. 

 

8

 As stated previously, only two of the original five calculation packages were adequate with respect to radiological 

characterization. However, this does necessarily preclude these calculation packages from serving as objective 

evidence for AK or VE. 
17 

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

As a result of the analysis presented in Items 1-13, above, EPA was able to assess how each Data 

Quality Objective (DQO) was addressed. The following DQOs must be addressed as per the 

WCPIP: 

• Defense determination 

• TRU waste determination 

• RH waste determination 

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

• Residual liquids 

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

As indicated in Item (9), above, the DQOs were addressed primarily through AK, radiological 

modeling and VE. When evaluated as a whole, CCP-AK-ANLE-500, Revision 5 and the draft 

Revision 6 prepared by ANL-CCP in September 2010; CCP-AK-ANLE-501, Revision 3; 

CCP-AK-ANLE-502, Revision 2, Draft A; and the reviewed supporting source documents 

indicate that the DQOs, as specified in the WCPIP, have been met. 

Summary of Acceptable Knowledge

Findings or Concerns 

The EPA evaluation team did not identify any findings or concerns relative to the addition of 30-

gallon drums of the AGHCF fuel pin FEW during this T1 change evaluation. 

Tiering Changes 

Based on the results of this T1 evaluation, there is one change to the AK T1 designations and 

there are no changes to the AK T2 designations. Characterization of any AGHCF FEW other 

than the fuel pin FEW discussed in this report, specifically AGHCF RERTR plate FEW and 

crucibles and melts FEW, is a new T1 change. Table 1 shows the new T1 change and specific 

additions to existing T1s in bold text. Some T2 changes that were initiated during the baseline 

approval remain in effect, and these are listed as applicable in Section 5.1. Additionally, there 

are minor changes in Table 1 to incorporate recent T1 approvals and ensure consistency. 

5.2 Radiological Characterization 

RH Waste Overview

Generation of the AGHCF FEW, including the fuel pin FEW, is described above in section 5.0. 

The AGHCF fuel pin FEW is placed into one-gallon, shielded fuel capsules, which, in turn, are 

placed in 7-gallon cans; up to two cans are placed into 30-gallon drums fitted with 140-mil 

polyethylene liners. These 30-gallon drums of the AGHCF fuel pin FEW are the subject of this 

T1 evaluation. 
18 

Radiological Characterization Overview

The overall approach to the radiological characterization of the AGHCF fuel pin FEW containers 

is not the DTC approach that has been used on RH wastes from other sites. Instead, radiological 

characterization is based on the determination of the total mass of discrete fuel specimen(s) 

loaded into the individual drums. The fuel pin specimens are measured and their mass 

determined by multiplying the measured length and the fuel mass per unit length provided by 

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

allow the direct determination of each container’s radionuclides, specifically cesium-137 (137Cs), 

americium-241 (241Am), plutonium-238 (238Pu), 239Pu, 240Pu, 242Pu, strontium-90 (90Sr), uranium233 (233U), 234U, 238U, and other radionuclides, as applicable. Accordingly, scaling factors and 

the relationship between the loaded-waste density and DTC conversion factor are not needed. 

Compared to the DTC approach, the total mass determination approach should be more accurate, 

because the uncertainties associated with the DTC conversion will be eliminated. 

The pre-irradiation composition, burnup, reactor discharge date, and decay time of the fuel 

specimens examined in the AGHCF hot cells, as obtained from AK records, were the input data 

for the ORIGEN2.2 analyses. The activities of individual radionuclides on a per-mass unit basis 

obtained from ORIGEN2.2 are applied to the quantities contained in each AGHCF fuel pin FEW 

container, allowing the determination of the container’s total activity. As described above, 

following measurement each specimen is placed into one-gallon, shielded fuel capsules, which 

are then placed in a 7-gallon can and up to two cans are placed into a 30-gallon drum. Each 

waste drum is unique and a calculation package will be developed to document the 

characterization process for each drum. There will be no radiological characterization BDRs 

associated with the AGHCF fuel pin FEW and instead there will be one calculation package per 

waste drum. For this T1 evaluation five calculation packages were provided for Drum Nos. 952 – 

956, all of which were reviewed. Upon initial review, EPA noted that these packages incorrectly 

included the mass of the shielded pots containing the fuel pins in the calculated sample mass. 

Shielding included for the purpose of reducing the external radiation (dose rate) is not considered 

part of the sample. EPA raised this concern and two of these packages were revised by ANLCCP. This evaluation is based on a review of the revised calculation packages for Drum Nos. 

952 and 953. EPA expects that the format and technical approach embodied in ANL-RH-27 

(Drum No. 952) and referenced in ANL-RH-35 will be employed for all of the AGHCF fuel pin 

FEW. An overview of the radiological characterization process used for the AGHCF fuel pin 

FEW and depicted in Figure C2-1 of CCP-AK-ANLE-501, Revision 3, is provided in Figure 1, 

below. 

EPA evaluated the characterization methods used for the AGHCF fuel pin FEW in terms of the 

technical adequacy of the approach, as supported by the program’s documents, procedures, and 

controls, and the knowledge and understanding of the personnel involved in the RH waste 

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

elements at ANL, as described below. 
19 

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

Documents Reviewed

As described above in section 5.0, Attachment B includes all documents related to the INL-CCP 

RH TRU radiological characterization program that were examined to support this T1 evaluation 

Model drum 

unshielded dose rate 

Measure drum 

shielded dose rate 

(RH determination) 

Collect relevant AK on the 

Waste Stream 

Develop Certification Plan 

Locate and retrieve relevant ANL-E records 

and literature sources on fuel compositions, 

burnups, reactor discharge dates, and fuel pin 

physical parameters 

Make ORIGEN2.2 runs for fuel 

pins involved in AGHCF 

activities 

Calculate fuel mass loading per 

unit length of each fuel pin 

Calculate the activity and mass content of 

the drums for the reportable 

radionuclides (TRU determination) 

Conduct dimensional 

analysis of fuel pins loaded 

into drums and recorded in 

VE logbook

Determine uncertainties in the 

reported activities and masses of the 

radionuclides 
20 

Technical Evaluation

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

characterize the Alpha Gamma Hot Cell Facility fuel pin fuel examination waste and 

determined that it was technically adequate. 

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

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

Revision 3, and the supporting calculation packages were reviewed. The following aspects of the 

characterization process were evaluated: 

• The methodology and the technical approach of the dimensional measurement 

• Information on fuel pin lengths extracted from VE records 

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

• Utilization of FIMS 

• Determination of reportable radionuclide and the bounding analysis performed 

• Retrieval of records and information from the AGHCF programs 

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

total activity content of drums 

• Utilization of pre-irradiation fuel composition (including enrichment), fuel burnup, date of 

discharge from reactor (end-of-irradiation date), and decay duration as input data for 

ORIGEN2.2 analyses 

• Activity in curies (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) 

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

pins in the AGHCF 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 

The constants and other values required for these calculations were taken from the appropriate 

sources (TRAMPAC) and were spot-checked for accuracy. Calculations are performed using an 

Excel spreadsheet, as shown, as an Example, in Figure C4-6 of CCP-AK-ANLE-501, Revision 3, 

where the input includes:

• Container number 

• Estimated fill percentage 

• Container gross weight 
21 

• Container net weight 

• Waste material type 

• Radionuclides and their activities 

There were no concerns regarding the methodology and the technical approach used for 

radiological characterization of the AGHCF fuel pin FEW. 

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

evaluated and found to be acceptable. 

The Technical Report CCP-AK-ANLE-501 is the main document that describes the radiological 

characterization process that ANL-CCP used for the AGHFC FEW fuel pins. This document is 

supported by a series of calculation packages that were reviewed. Additionally, the 

characterization for each drum is documented in a single calculation package, five of which were 

initially provided to EPA. These packages were prepared and reviewed by Jene Vance and Jim 

Holderness. Upon initial review these were found to be in error in that the weight of the shielded 

containers was included in the weight of the samples’ TRU-bearing nuclear material, e.g., 239Pu. 

This was corrected in Revision 1 of calculation packages ANL-RH-27 and ANL-RH-35, Drum 

Nos. 952 and 953, respectively. 

Revision 3 of CCP-AK-ANLE-501 also required revision to address the RH determination, 

which was not addressed in calculation packages or Revision 3 of CCP-AK-ANLE-501. This is 

typically performed in conjunction with DTC, which is not applicable to the AGHCF fuel pin 

FEW containers. ANL-CCP provided calculation package ANL-RH-31, Surface Dose Rate 

Multiplier for AGHCF FEW Drums, Revision 0 to address this and added language to CCP-AKANLE-501, Appendix C, Section 4 that summarized ANL-RH-31. Essentially, ANL-CCP 

proposed to determine a multiplication factor (the inverse of a dose reduction factor) to be 

applied to the measured dose rate of the shielded pots to correct the readings to represent the 

unshielded 137Cs which must be measured to determine the drum’s status relative to the RH 

criterion of a surface dose rate equal to or greater than 200 millirem per hour (mrem/hr) and less 

than 1,000 rem/hr. The multiplication factor will be determined using the radiation transport 

computer code MCNP5 and would allow conversion of the measured (shielded) dose rate to an 

unshielded dose rate. EPA reviewed this approach and found that it was technically acceptable 

and appropriately documented although ANL-CCP did not provide objective evidence of the RH 

determination for actual AGHCF fuel pin FEW containers.

The EPA evaluation team determined that upon modification CCP-AK-ANLE-501 adequately 

documented the radiological characterization process for the RH TRU AGHCF fuel pin FEW, 

and the revised calculation packages cited above adequately supported the activities upon which 

the radiological characterization of the RH TRU AGHCF fuel pin FEW containers is based. EPA 

may request copies of the records that document the RH determination for the AGHCF fuel pin 

FEW containers for their review at a later date. There were no issues related to the 

documentation of technical aspects of the ANL-CCP radiological characterization approach for 

the AGHCF fuel pin FEW. 
22 

(3) Measurements of the Alpha Gamma Hot Cell Facility fuel pin fuel examination waste at 

Argonne National Laboratory were observed and were found to be adequate. 

On May 4, 2010, EPA inspectors observed ANL personnel measuring the length and diameter of 

surrogate fuel pins in a glove box as part of a demonstration. ANL personnel followed ANL 

Procedures (included as Attachment C to this report) while performing this task. The purpose of 

the demonstration was to show how accurately a single FEW sample can be measured to support 

the confirmation of the physical description in AK, as well as the data gathered during the ANLCCP VE process. The ability to accurately perform these measurements has a direct impact on 

the radiological characterization process performed by ANL-CCP. The successful demonstration 

of this process allows ANL-CCP to use the ORIGEN-generated data to characterize the RH TRU 

material in each container, providing a significant improvement in accuracy over the DTC 

method used for other RH TRU waste forms. The measurements matched the known dimensions 

of the surrogate fuel pins used for demonstration purposes. The ANL-CCP staff stated they 

would follow this same procedure used for the surrogate fuel pins to measure actual fuel pins 

before packing them in the shielded pots. EPA determined that the performance of ANL-CCP 

sampling personnel was technically adequate. 

 

(4) 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. However, for the AGHCF fuel pin 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, and ORIGEN2.2 analysis uncertainty 

(benchmark uncertainty) 

• ORIGEN2.2 inputs 

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

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

AERHDM containing the AGHCF fuel pin FEW. 

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

The determinations that these containers meet the definition of TRU waste were examined 

during the baseline inspection based on a DTC BDR. However, DTC was not used for the 

AGHCF fuel pin FEW and this determination had to be evaluated based on the five calculation 
23 

packages provided for Drums Nos. 952 – 956, all of which were examined. As stated previously, 

these were in error and the calculation packages for Drum No. 952 and 953 were revised and 

resubmitted to EPA. Based on the two calculation packages, both containers were clearly TRU, 

i.e., contained more than 100 nanoCuries per gram of transuranic radionuclides. There were no 

technical or documentation-related concerns regarding the TRU determinations for the two 

containers of AGHFC FEW fuel pin wastes. 

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

EPA evaluated ANL-CCP’s process to determine that the containers were RH, i.e., had contact 

dose-rates greater than 200 mR/hr. Since these samples are packed in shielded pots an unshielded 

contact dose rate is not obtainable by direct measurement. To address this, ANL-CCP prepared 

calculation package ANLE-RH-31, Surface Dose Rate Multiplier AGHCF FEW Drums, which 

describes the technical basis for modeling the sample’s shielded dose rate and deriving the 

multiplier to convert this to an unshielded dose rate. ANL-CCP provided a copy of the 

“SURFACE DOSE RATE CALCULATION WORKSHEET FOR 30 GALLON RH FEW 

DRUMS” for 30-gallon container Nos. 952 and 953, both dated October 28, 2010. These copies 

documented that both containers were clearly RH with contact dose rates of 474.30 and 770.04 

R/hr, respectively9. EPA had no concerns regarding the RH determination for the AGHFC FEW 

fuel pins. 

Summary of Radiological Characterization

Findings or Concerns 

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

characterization. There are no open concerns related to radiological characterization resulting 

from this T1 evaluation. 

Tiering Changes 

Based on the results of this T1 evaluation, there are no changes to the T1 and T2 designations 

that were assigned to radiological characterization for ANL-CCP during the baseline approval. 

6.0 SUMMARY OF RESULTS 

Findings and Concerns 

The EPA Inspection Team did not identify any findings or concerns relative to the addition of 

30-gallon drums of the AGHCF fuel pin FEW to Waste Stream AERHDM during this T1 change 

evaluation. 

 

9

 Roentgens (R) and Rems (rem) are units of radiation exposure and dose equivalent, respectively. Although they 

represent different quantities, by convention they are often considered equivalent. In this report, these terms are used 

interchangeably, which is a conservative approach to assigning dose equivalent in rem. 
24 

Tiering Changes 

While the baseline and previous T1 changes adding RH waste to Waste Stream AERHDM have 

been container-limited, this approval is not limited to the addition of a specific number of 

AGHCF fuel pin FEW containers to Waste Stream AERHDM. ANL-CCP may add containers to 

the approved ANL RH waste stream if the following conditions apply: 

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

• ANL-CCP can demonstrate that the radiological characterization processes, including any 

radionuclide scaling factors, used for the RH waste stream are technically appropriate for 

use in the DTC determination or other approved method of radiological characterization 

of the additional containers 

Any addition of new containers to the approved waste stream must meet the revised ANL-CCP 

tiering table (Table 1), including the following T2 changes: 

• Notification to EPA of the intention to add containers of FEW debris from the AGHCF 

including the approximate number of additional containers and the approximate additional 

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

disposal. 

• Providing an updated 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 unchanged. 

• Acknowledging 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 BDRs, ANL-CCP must initiate another T2 change. ANL-CCP must 

provide the list of fully characterized containers. From this list, EPA may select a few containers 

to review the characterization information included in the respective VE and DTC BDRs or 

calculation packages and to verify that the additional containers belong to the approved waste 

stream. 

Additionally, there is one new T1 change. This approval is limited to the AGHCF fuel pin FEW 

and characterization of any AGHCF FEW other than the fuel pin FEW discussed in this report is 

a T1 change. Specifically, this limitation is directed at the AGHCF RERTR plate FEW, and 

crucibles and melts FEW. 
25 

7.0 CONCLUSIONS 

During this T1 change evaluation, EPA examined the addition of 30-gallon containers of the 

AGHCF fuel pin FEW to Waste Stream AERHDM. Based on the results of this evaluation, EPA 

is approving addition of 30-gallon containers of the AGHCF fuel pin FEW, characterized using 

dimensional analysis, to Waste Stream AERHDM with the limitations discussed above. 

Inclusion of the AGHCF RERTR plates FEW and/or the AGHCF crucibles and melts FEW in 

Waste Stream AERHDM will require separate T1 evaluations. 
A-1

ATTACHMENT A 

APPROVAL SUMMARY FOR ANL RH WASTE CHARACTERIZATION 

PROGRAM 

Specific ANL RH Approval Date EPA Docket Number 

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

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

Tier 1 Change – Approval of Visual Examination for Newly 

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

Approval of 100 additional drums of AGHCF debris 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 
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 5, January 14, 

2010 

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 3, July 23, 2010 

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, Draft A, 2010 

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

2010 

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

2010 

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

2010 

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

2010 

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

2010 

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

2010 

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

2010 

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

2010 

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

2010 

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

TRU Solutions, LLC 
B-2 

CCP-TP-005, Revision 18, CCP Acceptable Knowledge Documentation, Attachment 8 – Waste 

Containers, Waste Stream AERHDM, August 8, 2007 

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

August 20, 2010 

Inter-Office Correspondence from I. S. Quintana to CCP Records Custodian, RE: Transmittal of 

Waste Stream Profile Form, Attachment 4, for Remote-Handled Waste Stream AEHRDM at the 

Argonne National Laboratory, July 23, 2008 

Inter-Office Correspondence, from C. M. Gomez to M. Sensibaugh, Acceptable Knowledge 

Accuracy Report, Argonne National Laboratory, Waste Stream Number AERHDM, Lots 1-5, 

May 13, 2010 

Memorandum to Irene Quintana, CCP SPM, from Kevin Peters, CCP AKE, RE: Addition of 16 

Containers to Waste Stream AERHDM, July 22, 2010 

PTS Screenshots/Traceability Information for Drums 952, 953, 954, 955 and 956, Provided to 

EPA on August 20, 2010 

RH ANLE AK Container Tracking Spreadsheet, July 26, 2010 

RH Tiering of TRU Waste Characterization Processes Implemented by CCP at ANL (Based on 

EPA Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8 and updated during T1 evaluation to 

add K-Wing debris waste to Waste Stream AERHDM) Docket No. A-98-49; II-A4-132, 

September 2010 

Training documentation, Qualification Cards and Site-Specific RH Training for K. Peters, S. 

Schafer and I. Quintana, provided July 21, 2010 

C124, Fax to Mark Wyco and Larry Neimark, ANL-E re: Request for ANL-E to Identify Items 

of ANL-W Origin, Julia Whitworth, IT Corporation, February 21, 2002 

C330, Memorandum to Ines Triay, Acting Manager, CBFO: Determination and Findings, 

Defense Origin of Nuclear Waste, Kerr-McGee Waste, F. Marcinowski, April 15, 2005 

C2025, Communication with Dan Pancake: Inventory Update and the Management of Potentially 

Reactive and Pyrophoric Materials, K. Peters, December 1, 2009 

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

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

P002, Central Characterization Project Acceptable Knowledge Summary Report for Argonne 

National Laboratory-East Contact-Handled TRU Waste Facility Maintenance and Laboratory 
B-3 

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

December 31, 2003 

P004, Safety Analysis Report for the Alpha-Gamma Hot Cell Facility, M4000-0025-SA-01, 

W.D. Jackson, December 6, 1982 

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

October 2001 

P585, Safety issues at the DOE Test and Research Reactors, A Report to the U.S. Department of 

Energy, National Academy Press, 1988 

P808, Memo from Garkisch to Kazuya Yamamoto transmitting the SPA-1A Data Report, Data 

Report, SPA-1A Test Irradiation in EBR-II, NDP-94-028 Doc ID: WCAP-14154, WAES-TR94-001, H.D. Garkisch and K. Yamamoto, September 1994 

P828, Design, Operation, and Performance Data for High Burnup PWR Fuel from the H.B. 

Robinson Plant for Use in the NRC Experimental Program at ANL, EPRI 1001558, E.J. 

Ruzauskas and K.N. Fardell, April 2001 

P2032, Building 212 Alpha Gamma Hot Cell Facility Deactivation Project Plan with Appendix 

1: Alpha-Gamma Hot Cell Facility Excess Materials and Waste Disposition Campaign Baseline; 

Appendix 2: Next Phase TRU Waste Campaign Baseline; and Appendix 3: Alpha-Gamma Hot 

Cell Facility Decontamination Project, NOD-190-00-00, NOD-192-00-00, NOD-191-00-00, 

NOD-194-00-00, D. Pancake, M. Sodaro, D. Hodge, August 26, 2009, August 14, 2009, August 

21, 2009 

U009, Transuranic Waste at Argonne National Laboratory-West: Meeting the Waste Acceptance 

Criteria for the TRU Repository, August 10, 2001 

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

2009 

U911, Freeze File of Draft CCP-AK-ANLE-500, Revision 6, K. Peters, Provided to EPA 

September 7, 2010 

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

Various Authors, 1964-1997 

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

ANLE-RH-20, AGHCF Fuel Information Input Check, U903, Revision 0, Jene Vance, July 8, 

2010 

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

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

July 8, 2010 

ANLE-RH-23, ORIGEN2.2 Analysis of HBR High Burnup Fuel, U906, Revision 0, James 

Holderness, July 8, 2010 

ANLE-RH-24, ORIGEN2.2 Analysis of Thorium Fuel, U907, Revision 0, James Holderness, 

July 8, 2010 

ANLE-RH-25, Determination of Reportable Radionuclides, U908, Revision 0, James 

Holderness, July 8, 2010 

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

ANLE-RH-27, Radiological Characterization for Drum 952, U910, Revision 0, James 

Holderness, July 8, 2010 

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

September 22, 2010 

ANLE-RH-31, Surface Dose Rate Multiplier AGHCF FEW Drums, Revision 0, James 

Holderness, October 7, 2010 

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

22, 2010 

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

October 2, 2010 

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

22, 2010 

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

22, 2010 

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

22, 2010 

Handouts provided following the demonstration of dimensional measurements of surrogate fuel 

pins on May 4, 2010.
C-1 

ATTACHMENT C 

DESCRIPTION OF ANL PROCESS USED FOR THE MEASUREMENT

OF SURROGATE FEW FUEL PINS 
C-2 

ATTACHMENT C-1 

FEW Surrogate Sample Measurement Exercise 

At the ANL Alpha Gamma Hot Cell Facility, May 4, 2010 

The purpose of this exercise was for ANL-CCP to demonstrate the ability to measure, confirm, 

and document the length and diameter of FEW samples inside the AGHCF. Surrogate samples 

were used for this demonstration that took place at ANL in the AGHCF on May 4, 2010. 

The length and diameter of each sample was measured outside the cell (Initial), and the 

dimensions recorded. These samples were then transferred into the hot cell, and the length and 

diameter were measured on the samples inside the cell (Observed) using the same measurement 

devices. The Initial and Observed measurements were compared. 

FEW Surrogate 

Specimen Number 

Initial Sample 

Length* 

(inches) 

Observed Sample 

Length** 

(inches) 

Initial Sample 

Diameter* 

(millimeters) 

Observed Sample 

Diameter** 

(millimeters) 

Surrogate #001 3 3 12.5 13 

Surrogate #002 2 2 12.5 13 

Surrogate #003 2-1/2 2-1/2 10 10 

Surrogate #004 1-3/4 1-3/4 10 10 

Surrogate #005 3 3 8.5 9 

Surrogate #006 1-3/4 1-3/4 8.5 9 

Surrogate #007 1-3/4 1-3/4 4.5 5 

Surrogate #008 1-1/4 1-1/4 4.5 5 

 *Measured outside the hot cell (Initial Measurement) 

 **Measured inside the hot cell (Observed Measurement) 

The ruler used for the Initial measurements of the samples is divided into units of 1/16 inch (in.). 

The observed lengths were visible at this increment during the Initial measurement. The Initial 

diameters could be quantified to a tolerance of +/- 0.5 millimeters (mm), however, Observed 

measurements were visible only at 1 mm increments. Rulers used to collect data are certified and 

calibrated, and ANL-CCP provided the appropriate certificates to document this. 
C-3 

ATTACHMENT C-2 

FEW Confirmatory Measurement Demonstration 

At the ANL Alpha Gamma Hot Cell Facility, May 4, 2010 

This summary describes results obtained from the confirmatory measurement exercise of 

AGHCF FEW conducted in the AGHCF at ANL on May 4, 2010. Representatives from the US 

EPA, ANL-CCP, and the Next Phase TRU Waste Campaign were present to observe the 

demonstration. The purpose of the exercise was for ANL-CCP to demonstrate how accurately a 

single FEW sample can be measured to support confirmation of the physical description in AK, 

as well as the data gathered during the ANL-CCP VE process. The ability to accurately obtain 

these measurements has a direct impact on the radiological characterization process performed 

by ANL-CCP. The successful demonstration of this process allows ANL-CCP to use the 

ORIGEN-generated data to characterize the RH TRU material in each container, providing a 

significant improvement in accuracy over the DTC method used for other RH TRU waste forms. 

The FEW surrogate samples and measurement devices are shown in Figure C.1, below. 

Figure C.1. FEW Surrogate Samples and Measurement Tools 

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

measured to +/- 0.25 in. (length), and +/- 2 mm (diameter). The diameter measurement is 

performed solely to provide confirmation of ANL-CCP AK data, where the length measurement 

is used both to confirm AK data and to provide the mass for radiological characterization using 

the known densities for each specimen. The demonstration was conducted in the AGHCF under 

the same conditions and using the same equipment that will be used for actual FEW packaging 

evolutions. 
C-4 

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

The FEW measurement confirmation demonstration took place at ANL in the AGHCF Work 

Station No.4, shown in Figure C.2, above. The specimens used for this demonstration were 

surrogate FEW samples that were designed to be representative of the AGHCF FEW sample 

inventory. Each specimen was removed from its clear polyethylene container and was measured 

on a ruler for length, and on a gauge for diameter. There were eight samples measured during 

this demonstration, each having different dimensions. In every case, the length measurements 

were accurate to +/-1/8 in. (0.125 in.), and the diameters accurate to +/- 1 mm. The rulers that are 

used to measure sample length in the AGHCF are certified and calibrated and the appropriate 

certificates documenting this are maintained by both ANL and ANL-CCP. These in-cell rulers 

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

all length measurements are now accurate to +/- 0.1 in.