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 P ROGRAM

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 2014i 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 Diagra m for Lot 5C ...................................... ....... 13

ATTACHMENTS Attachment A: Approval Summary for INL-CCP RH Wast e Characterization Program Attachment B: List of DOE Personnel Present at Eval uation Attachment C: Lot 5C Population of Liners and Drums : Identification of Drums within

Approved Subpopulation Attachment D: List of Documents Reviewed by EPA du ring T1 Evaluationii ABBREVIATIONS AND ACRONYMS AK acceptable knowledge AKE Acceptable Knowledge Expert AKSR acceptable knowledge summary report Am americium AMWTP ACL Advanced Mixed Waste Treatment Project An alytical 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 Facili ty INL Idaho National Laboratory INTEC Idaho Nuclear Technology and Engineering Cent er L&O Laboratory and Office LANL-CO Los Alamos National Laboratory-Carlsbad Off ice
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 Partnershipiii

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 Plant4

1.0 INTRODUCTION This report supports the U.S. Environmental Protect ion Agency’s (EPA’s) approval of a Tier 1 (T1) change to add Lot 5C remote-handled (RH) trans uranic (TRU) debris waste to the previously-approved Waste Stream ID-HFEF-S5400-RH a t the U.S. Department of Energy’s (DOE’s) Idaho National Laboratory (INL). In Februar y 2010, EPA approved the Central Characterization Program (CCP) 1 to characterize Waste Stream ID-HFEF-S5400-RH at I NL (see EPA Docket No. A-98-49; II-A4-122). Using the EPA-a pproved waste characterization processes discussed in this report, INL-CCP may cha racterize Lot 5C debris waste for disposal at the Waste Isolation Pilot Plant (WIPP) as part of W aste Stream ID-HFEF-S5400-RH. EPA conducted continued compliance inspections of I NL-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 eq uipment at INL that EPA approved in the January 2007 baseline approval and in subsequent ti ering 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 Stre am ID-HFEF-S5400-RH. EPA limited the scope of this T1 evaluation to the components of ac ceptable 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 addition al new processes on site at INL as part of the T1 request, EPA conducted a desktop review of t his change and then met with INL-CCP personnel in Denver, Colorado, on December 3–5, 201 3. During the Denver meeting, EPA identified and CBFO agreed that the initial evaluation scope required modification. Specifically, INL-CCP remove d all drums whose external dose rates were attributable to radionuclides other than cesium-137 ( 137 Cs), as detailed in section 4.0 of this report. CBFO provided to EPA a revised T1 request o n February 26, 2014, limiting the T1 scope to a subpopulation of drums, where at least 95% of the dose rate was attributable to 137 Cs. EPA evaluated the T1 change to add Lot 5C container s with at least 95% of the dose rate attributable to 137 Cs to Waste Stream ID-HFEF-S5400-RH. However, prior to issuance of EPA’s T1 approval, CBFO submitted another revised T1 requ est on April 15, 2014. The April revision of the T1 request reincorporated the previously exc luded containers, effectively returning the T1 change to its original scope. CBFO requested that E PA delay issuance of the T1 decision so that all Lot 5C containers would be evaluated at one tim e. EPA completed the T1 evaluation upon receiving revised radiological characterization doc uments. EPA did not identify any findings or concerns durin g 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 re viewed, including batch data reports (BDRs) and calculation packages. As a result of this evaluation, EPA did not make an y 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 f or 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) remai n 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 dru ms from 13 liners that currently make up Lot 5C. 2 These 60 drums of TRU waste are the subject of thi s T1 report, but EPA’s approval also includes any additional liners or progeny drums tha t 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 throu gh the EPA website and by emails to the WIPPNEWS list, in accordance with Title 40 of the C ode of Federal Regulations [40 CFR 194.8(b)(3)].

2.0 PURPOSE OF TIER 1 EVALUATIONS Certain changes to the waste characterization activ ities 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 th e July 16, 2004, Federal Register notice (Vol. 69, No. 136, pages 42571–42583), EPA must per form a single baseline inspection of a TRU waste generator site’s waste characterization p rogram. The purpose of EPA’s baseline inspection is to approve the site’s waste character ization program, based on the demonstration that the program’s components, with applicable cond itions and limitations, can adequately characterize TRU wastes and comply with the regulat ory requirements imposed on TRU wastes destined for disposal at the WIPP. Following EPA’s baseline approval, EPA is authorize d to evaluate and approve changes, if necessary, to the site’s approved waste characteriz ation 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 req uiring post-implementation notification (T2) are identified in the site-specific baseline inspec tion reports and subsequent T1 evaluation reports. When evaluating proposed T1 changes for ap proval, 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 ch aracterize and dispose of any previously approved TRU waste using processes, procedures or e quipment implemented as T2 changes at risk of subsequent EPA disapproval.

2 Lot 5C is currently defined as waste from 13 liner s, as discussed in this report. The exact number of 55- gallon drums that will be created upon completion o f repackaging the wastes in these liners has not ye t been determined. INL-CCP documents present this number a s 59 or 60. This report presents the number of drum s as 60, with the understanding that it may change.6

3.0 PURPOSE OF THIS REPORT This report presents the results of EPA’s evaluatio n of a T1 change to add Lot 5C RH TRU debris waste to Waste Stream ID-HFEF-S5400-RH, as d escribed 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 re sults 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 b y 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 foraddition to Waste Stream ID-HFEFS5400-RH. Sections 6.1 and 6.2 of this report detai l 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 pe rsonnel 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 Know ledge, SC&A Rose Gogliotti Technical Evaluator – Radiological C haracterization, SC&A Patrick Kelly Technical Evaluator – Radiological C haracterization, SC&A Amir Mobasheran* Technical Evaluator – Radiologica l 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 Ta ble 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 rev isions and other technical details. All DOE personnel present at the evaluation are listed in Attachment B.7 Table 2. DOE Tier 1 Evaluation Personnel

Name Affiliation & Function Scott Smith INL-CCP, AK Expert Derek Ott URS, Radiological Characterization Techni cal 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 ge nerated by hot cell and analytical laboratory activities at the Materials and Fuels Co mplex (MFC) and specifically in Building 785 - the Hot Fuel Examination Facility (HFEF, formerly HFEF-north), Building 765 - Fuel Conditioning Facility (FCF, formerly HFEF-south), a nd Building 752 - Laboratory and Office (L&O) Building. INL generated the waste in Waste St ream ID-HFEF-S5400-RH in support of analyses and examination of Experimental Breeder Re actor-II (EBR-II) irradiated fuel, and it consists predominantly of organic and inorganic deb ris. These wastes are currently stored at the Idaho Nuclear Technology and Engineering Center (IN TEC) and the MFC Radioactive Scrap and Waste Facility (RSWF), pending transfer to INTE C. CCP-RC-INL-581, Revision 1, describes this waste as follows: “The debris primar ily consists of waste generated at the HFEF during the handling and examination of irradiated f uel pins and other reactor materials from various reactor programs. These canister liners con tain 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, cer ium ion-exchange resins, South Bank and North Bank Filters from the HFEF, and process and c asting crucibles.”

RH Waste Overview

Waste Stream ID-HFEF-S5400-RH consists of 98 canist ers or liners of RH TRU debris wastes generated by hot cell and analytical chemistry oper ations conducted in the HFEF, FCF, and the L&O Building Analytical Laboratory hot cells from J une 1970 to November 2007. INL-CCP has divided this waste stream into four lots, and the s ubject of this T1 evaluation is exclusively the 13 liners designated as Lot 5C, which were generate d 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 i nitially packaged in 86 HFEF cans (or inserts), eight Sodium Loop Safety Facility cans (s ix of which contained three 45-gallon drums), and four paints cans in 16-inch RSWF liners. INL-CC P repackaged these wastes into 30- or 45- gallon drums, and over-packed them into 55-gallon d rums 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 additional8

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 Packa ges Provided EPA evaluated the INL-CCP documentation that suppor ted inclusion of Lot 5C debris waste in Waste Stream ID-HFEF-S5400-RH. EPA’s review identif ied several technical issues that necessitated the revision of several documents. Pro posed modifications to these documents were discussed with EPA during the meeting in Denver, Co lorado, and approved revised documents incorporating necessary changes were provided to EP A before the conclusion of this T1 evaluation.

The DOE documents that EPA reviewed for this evalua tion, including BDRs and calculation packages, are cited in different sections throughou t the report and are listed in Attachment D. Any of these documents can be requested from the fo llowing 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 p rocess and associated information during the continued compliance inspection in May 2 013. Therefore, EPA limited the scope of this AK evaluation to those elements necessary to a ssess the technical adequacy of the information supporting inclusion of Lot 5C RH TRU d ebris waste in Waste Stream ID-HFEFS5400-RH. Waste Characterization Element Description

EPA limited this T1 evaluation to the technical ele ments 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 o rigin and is not high-level waste (HLW) or spent nuclear fuel (SNF).

Technical Evaluation EPA evaluated the adequacy of AK information specif ic 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 attachme nts and supporting source documents.9

(1) EPA examined the waste stream determination for Was te 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 hazardou s constituents (similar radiological properties for WCPIP compliance), and that are gene rated from a single process or activity. This definition will be used to obtain information for t he waste stream specific description to be written in step 4.4.34.” CCP-TP-005, Revision 26, a lso 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 informatio n for each drum:

• Waste generation location and process.

• Time period of generation.

• Physical form compared to the assigned Waste Materi al 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 inade quate in several ways. INL-CCP revised this document to include accurate and consistent wa ste generation locations, processes and time period of generation, as well as more information a bout 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 docu ment to be adequate. EPA examined Revision 3 of the AK summary report (A KSR; CCP-AK-INL-580) to determine whether it contained sufficient information to just ify inclusion of Lot 5C in the waste stream. EPA found the AKSR to be inadequate and INL-CCP pro vided a marked-up version of Revision 3, which also required modification. INL-CCP provid ed Revision 4 of the AKSR, which EPA found to be adequate.

There are no issues relative to the waste stream de finition for Waste Stream ID-HFEF-S5400, Lot 5C. (2) EPA examined the waste stream information that supp orts the absence of spent nuclear fuel or high-level waste in this waste stream and f ound it to be adequate. The WIPP Land Withdrawal Act prohibits WIPP disposa l of SNF and HLW as defined by the Nuclear Waste Policy Act (NWPA). INL-CCP asserts th at Waste Stream ID-HFEF-S5400-RH includes fragments generated by segmentation of tes t specimens, residues, and dust/fines from sectioning and testing of SNF; the waste does not c ontain complete fuel rods. Process and waste management documents do not indicate that Waste Str eam ID-HFEF-S5400-RH includes intact fuel rods or waste from reprocessing of SNF; any wa ste associated with SNF or HLW is incidental to reprocessing and the waste stream inc ludes only minimal solidified liquid10

associated with chemical tests (References C214, C4 65, C4100, P4024, P4025, U483, U484, U541, U551 and U552). Additionally, EPA examined th e 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 wa ste stream is defense in origin and found it to be adequate. TRU waste is eligible for disposal at the WIPP if i t has been generated in whole or in part by one of the atomic energy defense activities listed in t he 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 operat ions are contaminated with materials from atomic energy defense activities associated wi th naval reactors development, defense nuclear materials productions, defense nuclear wast e and materials by-products management, and defense research and development activities” (R eferences 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, includ ing supporting the Bettis Atomic Power Laboratory and the Naval Nuclear Propulsion Program , Los Alamos National Laboratory, Lawrence Livermore National Laboratory, the Star Wa rs Program, and plutonium experiments in support of waste disposal. The integrated use of HF EF, FCF and L&O facilities resulted in incidental commingling of waste from various progra ms, thus mixing defense and non-defense waste (References C002, C003, C465, P001, P047, P11 6, 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 w as generated in the same buildings using the same processes that include defense waste. Addition ally, MFC personnel did not segregate waste as defense or non-defense at generation, and have n ot packaged or repacked waste postgeneration with respect to defense/non-defense orig in. The presence of defense-related material in each liner means that it could have contacted de fense-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 t o 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 analyti cal laboratory and has a radiological composition different enough from the Lot 5C popula tion to warrant its own scaling factor. Given the discrepancies pertaining to the origin of Liner R-8, EPA examined the traceability11

documentation to support inclusion in Lot 5C and th is waste stream, as documented in Reference U522, the Sea Lion database. EPA determined that Re ference U552 adequately explains the apparent discrepancy between the origin of Lot 5C a nd 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 belong ing in Waste Stream ID-HFEF-S5400, Lot 5C. Summary of Acceptable Knowledge Findings and Concer ns The EPA evaluation team did not identify any AK-rel ated findings or concerns relative to the addition of Lot 5C RH TRU debris waste to Waste Str eam ID-HFEF-S5400-RH during this T1 change evaluation. Acceptable Knowledge Approval Based on the results of this evaluation, EPA approv es the addition of Lot 5C RH TRU debris waste to Waste Stream ID-HFEF-S5400-RH and finds th at all AK requirements have been met. Based on this evaluation, there are no changes to t he AK T1 or T2 designations. Characterization of any new waste stream not approved under the base line 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. T 1 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 as sociated information during the continued compliance inspection in May 2013. Therefore, EPA l imited the scope of this radiological characterization evaluation to those elements neces sary to assess the technical adequacy of the information supporting inclusion of Lot 5C RH TRU d ebris 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 contr ols, and the knowledge and understanding of the personnel involved in the RH waste character ization program. During this RH evaluation, EPA evaluated the following elements of the INL-CCP radiological characterization program:

• Overall radiological characterization.

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

• Representativeness and technical adequacy of the an alytical data used to support the scaling factors.

• OSPREY measurements to determine the relative contr ibutions of 137 Cs, cobalt-60 ( 60 Co), and europium-154 ( 154 Eu) to each container’s external dose.12

• Development of three independent DTC correlations f or each of the four packaging configurations within 55-gallon drums, based on Mon te Carlo N-Particle Transport Code (MCNP5 ® ) modeling of the drum’s gamma dose rate using a 1- curie (Ci) source of 137 Cs, a 1-Ci source of 60 Co and a 1-Ci source of 154 Eu for each configuration.

• Uncertainty analysis.

Each of these is discussed in the sections that fol low.

Technical Evaluation The EPA evaluation team evaluated the following asp ects: (1) EPA evaluated the overall radiological characteriza tion process and its documentation and found them to be adequate. The radiological characterization process for HFEF Lot 5C uses DTC correlations for four 3 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 137 Cs, correlating a drum’s dose rate, 4 packaging configuration and WIPPtracked radionuclides. The EPA inspection team prep ared a flow diagram to accurately reflect this process, shown in Figure 1 below. During the course of this T1 evaluation, INL-CCP re vised the documents supporting radiological characterization. EPA determined that the radiologi cal characterization process for Lot 5C was technically adequate and appropriately documented i n 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, t he revised T1 scope included a distinct waste group called Separate (or Special) Resin Waste, which used the s caling factors developed for the General Debris gro up.

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 criteri on for RH determination is expressed in terms of a dose rate in rem, which, while technically incorrect, is commonl y used. In this report, the terms dose and dose rat e are used in place of the technically correct terms “dose equiva lent” or “dose equivalent rate.” The actual differe nce among these values for the purpose of this report is negligible

.13Figure 1. Radiological Characterization Flow Diagram for Lot 5CModel the 1 m dose usingMCNP5 as a function of wastedensity to relate137Cs,154Eu,and60Co to the dose rate foreach packaging configurationUse OSPREY to determine therelative gamma dosecontributions from137Cs,154Eu, and60CoMeasure 1 m dose rate at 0 ̊,90 ̊, 180 ̊ and 270 ̊ from eachdrum in the waste streamDetermine137Csactivity contentin each drumUse DTC factors (mR/hr/Ci)-density relationships for137Cs,154Eu, and60Co to determinerespective activitiesSample waste using samplingplanDevelop sampling plan toensure various waste types arerepresentedSamples are analyzed by theAMWTP ACL to determineradionuclide compositionReview AK records to identifypossible waste types that mayrequire unique scaling factorsRemove grouping of wastecontaining fuel rods, i.e., Fueland Hardware GroupingModel Fuel and HardwareGroup wastes in ORIGENusing AK recordsReview analytical results todetermine if any sampledcontainers are sufficientlydifferent from the other resultsto require unique SFsDevelop SFsunique to eachgroupingDevelop SFs unique to theFuel and Hardware groupingApply relevant SFto each drum todetermineradionuclides ofinterest for drums14

(2) EPA evaluated the collection and analysis of sample s 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 select ed liners or drums within the liners for each of the four waste types, as follows: debris (six sa mples), 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 f rom the sampling plan. The Advanced Mixed Waste Treatment Project Analytic al Chemistry Laboratory (AMWTP ACL) 5 performed radiometric and spectrophotometric analy ses on the samples to quantify uranium-233 ( 233 U)/ 234 U, 235 U/ 236 U, 238 U, americium-241 ( 241 Am), plutonium-238 ( 238 Pu), 239 Pu/ 240 Pu, 241 Pu, 242 Pu, 137 Cs, strontium-90 ( 90 Sr), 60 Co, 154 Eu and 134 Cs. The AMWTP ACL documented the analyses in analysis-specific BDRs. INL-CCP documented their evaluation of the analytical results in a post-sampling memorandu m that presented the results relative to the Quality Assurance Objectives to support the develop ment of scaling factors. EPA determined that the analytical data were repres entative and technically adequate to support the development of radionuclide scaling factors. Th ere were no issues regarding the collection and analysis of samples from Waste Stream ID-HFEF-S 5400, Lot 5C. (3) EPA found that INL-CCP correctly derived and approp riately documented cesium-137- based radionuclide scaling factors for four waste g roups. INL-CCP described the development of scaling factor s 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 devel oped 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 gro up based on dose rate measurements.

• Separate resin waste: based on the attributes of dr um 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 develo pment approaches for all four waste groups were technically adequate. EPA did not ident ify any concerns regarding the technical adequacy of INL-CCP’s development of radionuclide s caling factors for Waste Stream IDHFEF-S5400, Lot 5C.

5 The AMWTP ACL is located on site at INL and was pr eviously called the INTEC laboratory. EPA inspected and approved the laboratory for the analy sis 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 a nd hardware waste using ORIGEN2.2 and appropriately developed radionuclide scaling factors using the results. Canister liners PP-15 and QQ-9 contained fuel and h ardware components. The burnup and composite information for these wastes is known suc h that the radiological properties can be modeled using ORIGEN2.2. INL-CCP used information f rom an ANL memorandum as input and extracted and summarized the results of the mod eling in the “Lot 5C Scaling Factors” Spreadsheet. INL-CCP converted radionuclide mass va lues to activities and generated 137 Csbased scaling factors. EPA found the scaling factor s to reasonably represent the wastes’ radionuclide composition. EPA did not identify any concerns regarding the tec hnical adequacy of INL-CCP’s modeling to support the development of radionuclide scaling fac tors 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 fo r a 55-gallon drum of Lot 5C waste for four different packaging config urations and three gamma sources. The four packaging configurations consider the presence or a bsence of a drum liner and the size of the inner container. INL-CCP developed 12 DTC relations hips for waste density from 0.1 to 2.0 grams per cubic centimeter. INL-CCP based the modeling on the assumption that i ndependent 1-Ci sources of 137 Cs, 60 Co and 154 Eu were uniformly distributed within the drum. Usin g waste density and the DTC correlation allows calculation of the activity attr ibutable to 137 Cs, which is then used with decaycorrected scaling factors (excluding 60 Co and 154 Eu) to determine the activities of the radionuclides of interest. The activities for 137 Cs, 60 Co and 154 Eu, are calculated directly from their corresponding DTC correlations. INL-CCP descr ibed 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 o f MCNP5 ® to support the DTC correlation for Waste Stream ID-HFEF-S5400, Lot 5C. Consistent with the T1 and T2 designations that wer e 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, INLRHD TC13004, INLRHDTC13007 and INLRHDTC13008. INL-CCP generated the DTC BDRs using procedure CCP-TP-504, Revision 14, which was the current revi sion at the time of DTC assay. For logistical reasons, some containers had Waste Conta iner DTC Conversion Records that had been superseded. All containers used the initial DTC mea surement event as the basis for the16

radionuclide calculations, often in conjunction wit h 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 drum s in June and September 2013, and all drums were found to have contact dose rates in exce ss of 200 millirem per hour. EPA did not identify any concerns regarding INL-CCP’s RH determ ination 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 liste d 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 acti vity 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 (T MU) for Lot 5C is based on the propagation of uncertainties present in the determi nation of the waste stream’s radiological constituents. These aspects are assumed to be indep endent, which allows them to be added in quadrature. 6 The TMU determination included contributions of th e following:

• 137 Cs DTC correlation—uncertainties due to MCNP5 ® code, waste mass and source distribution within drum, and waste density.

• 137 Cs activity measurement—dose rate measurement uncer tainty and uncertainty due to the contribution of other gamma-emitting radionucli des (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 o verall uncertainties are consistent with what

6 Adding in quadrature is a standard statistical tec hnique that allows one to combine the square root o f the sum of each contributor to uncertainty squared, res ulting in a lower value than what would be obtained if the values were simply added. For example, the TMU for 137 Cs 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%), a s shown in INL-RH-145 for a hypothetical drum of ge neral 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 grou p. 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 a nd Concerns The EPA evaluation team did not identify any radiol ogical 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 approv es the addition of Lot 5C RH TRU debris waste to Waste Stream ID-HFEF-S5400-RH consistent w ith the limitations specified in this report. Based on this evaluation, there are no changes to t he radiological characterization T1 or T2 designations. Characterization of any new waste str eam 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 facto rs remains a T1 change. T1 and T2 changes that were initiated during the baseline approval re main in effect.

7.0 FINDINGS AND CONCERNS Summary of Findings and Concerns The EPA inspection team did not identify any findin gs or concerns relative to the addition of Lot 5C RH TRU debris waste to Waste Stream ID-HFEF-S540 0-RH during this T1 change evaluation.

8.0 CONCLUSIONS Changes to Tiering As a result of this evaluation, EPA did not make an y changes to the INL-CCP RH T1 and T2 designations that were established during the basel ine 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 continue d compliance inspection of INL-CCP (see EPA Docket No. A-98-49; II-A4-190; July 15, 2014) remai n in effect and are listed as applicable in sections 6.1 and 6.2. Approval EPA concluded that the waste characterization proce sses of AK and radiological characterization used to characterize Lot 5C RH TRU debris waste as part of Waste Stream ID-HFEF-S5400-RH18

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 approv es 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 additiona l 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 Febru ary 12, 2007 A-98-49; II-A4-80 T1 Change – Approval of K Cell Wastes January 1, 20 08 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 A pril 16, 2014 A-98-49; II-A4-183 2014 Continued Compliance Inspection July 15, 2014 A-98-49; II-A4-190B-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 Technic al 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 ObserverC-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-1C-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 SL18AD-1 ATTACHMENT D

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUAT ION AK Info on Blanket Pins A794 and A795, F.S. Kirn, J une 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. Sm ith, August 31, 2005 C214, Telephone Interview Conducted Between CCP Per sonnel 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 Manageme nt Information, S. Smith and C. Johnson, April 15, 2008 C465, Evaluation and Summary of the Process Work Sh eets (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 Stor ed 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 Addit ion 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 Ac ceptable Knowledge Summary Report for Remote-Handled Transuranic Debris Waste from Ma terials and Fuel complex Hot Fuel Examination Facility at the Idaho National Laborato ry, Waste Stream: ID-HFEF-S5400-RH, Revisions 3, January 27, 2011; Draft Revision 4, Ja nuary 22, 2014; Final Revision 4, March 24, 2014 CCP-RC-INL-581, Central Characterization Project Re mote-Handled Transuranic Radiological Characterization Technical Report for Remote-Handle d Transuranic Debris Waste from Materials and Fuel Complex Hot Fuel Examination Fac ility at the Idaho National Laboratory, Waste Stream: ID-HFEF-S5400-RH, Revision 0, Septemb er 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, 2011D-2

CCP-AK-INL-585, Central Characterization Program Sa mpling and Analysis Plan for the Remote-Handled Transuranic (RH-TRU) Debris Waste fr om Materials and Fuel Complex Hot Fuel Examination Facility (HFEF) at the Idaho Natio nal Laboratory (INL), Waste Stream: IDHFEF-S5400-RH, Revision 1, December 13, 2012 CCP-TP-005, Revision 22, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste Containers, Waste Stream ID-HFEF-S5400-RH (CCP-AK-I NL-580), May 17, 2011 CCP-TP-005, Revision 22, CCP Acceptable Knowledge D ocumentation, Attachment 1 – Acceptable Knowledge Document Checklist, HFEF Remot e-Handled TRU Debris, June 8, 2011 CCP-TP-005, Revision 22, CCP Acceptable Knowledge D ocumentation, Attachment 4 – Acceptable Knowledge Source Document Information Li st, HFEF Remote-Handled TRU Debris, June 8, 2011 CCP-TP-005, Revision 22, CCP Acceptable Knowledge D ocumentation, Attachment 6 – Waste Form, Waste Material Parameters, Prohibited Items, and Packaging, Waste Stream Remote Handled Debris Waste CCP-AK-INL-580 and attached me morandum, 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 Fac tor Development, Revision 0 and associated spreadsheet, July 8, 2013; Revision 1, a nd associated spreadsheet, March 15, 2014D-3

INL-RH-143, Calculations for Determination of Repor table Radionuclides, Revision 0 and associated spreadsheet, July 8, 2013; Revision 1, M arch 15, 2014 INL-RH-144, Calculations for Lot 5C DTC Correlation and Sensitivity Studies, Revision 0 and associated spreadsheet, July 8, 2013; Revision 1 an d 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 associat ed spreadsheet, March 15, 2014 INL-RH-146, DTC and Related Calculations for ID-HFE F-S5400-RH, Revision 0, and associated spreadsheet, September 24, 2013; Revisio n 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 Memor andum from D. Ott to I. Joo, dated 12/20/2013 P001, The Defense Programs Origin of Transuranic Wa ste at Argonne National Laboratory – West, H.F. McFarlane, November 2001 P042, Revision 4, Analytical Laboratory Safety Anal ysis Report, Idaho National Laboratory, April 6, 2006 P047, Argonne National Laboratory Description and P roposed Operation of the Fuel Cycle Facility for the Second Experimental Breeder Reacto r (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 Silici de 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 Saf ety Analysis Report, Argonne National Laboratory – West, January 1982 P178, Overview of Idaho National Laboratory’s Hot F uels 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, Idah o National Laboratory, January 31, 2008 P187, Revision 11, FCF Safety Analysis Report, Idah o National Laboratory, October 26, 2006D-4

P876, Revision 0, The Ceramic Waste Form Process at Idaho National Laboratory, S. Priebe, May 2007 P877, Revision 0, Internal Report, Production and S ampling 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 Faci lity In-Reactor Experiment T6 (P4), P4024, Analysis of Spent Fuel Treatment Demonstrati on Operations, Garcia et al., July 1999 P4025, Environmental Assessment, Electrometallurgic al Treatment Research and Demonstration Project in the Fuel Conditioning Facility at Argonn e National Laboratory – West, U.S. Department of Energy Office of Nuclear Energy, Scie nce 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 – W aste, December 14, 1973 U483, HFEF Transuranic Waste Can Log Cards, not dat ed U484, Radioactive Scrap & Waste Storage/Disposal Re quest and Authorization Forms and related documents, not dated U541, Shipping Papers Gathered from MFC for ILTSF H FEF-5 Inserts, February 10, 1983 U551, Compilation of HFEF Process Work Sheets and H FEF Procedure Change Notices; includes HFEF PWS Log, various authors, various dat es U552, Compilation of MFC Liner Documents, various a uthors, various dates