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

WASTE CHARACTERIZATION REPORT

EPA TIER 1 EVALUATION
OF THE CENTRAL CHARACTERIZATION PROJECT
REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION P ROGRAM:
ADDITION OF 8 55-GALLON K-WING FUEL EXAMINATION WAS TE
CONTAINERS TO THE REMOTE-HANDLED DEBRIS WASTE STREA M AERHDM

AT THE ARGONNE NATIONAL LABORATORY

September 2011

U.S. Environmental Protection Agency
Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

February 2012i TABLE OF CONTENTS

Section Page

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

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

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

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

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

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

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

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

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

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

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

................................................... ......................... 7

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

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

................................................... ....... 20

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

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

8.0 Conclusions .......................................

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

TABLE OF TABLES

Table 1. Tiering of RH TRU Waste Characterization P rocess Implemented by ANL-CCP .......3
Table 2. T1 Evaluation Personnel ..................

................................................... ...........................6 Table 3. Batch Data Reports and Calculation Package s Examined ........................................ .....8 Table 4. K-Wing Fuel Examination Waste Data Trackin g Summary .......................................17 Table 5. Summary of Training Records for ANL-CCP AK Es ................................................ ..19

ATTACHMENTS

Attachment A: ANL-CCP Approval Summary Table
Attachment B: ANL-CCP Document Reference List Attachment C: Observation of ANL Fuel Weight Confir mation Test Program for Argonne Remote-Handled K-Wing Fuel Examination Wasteii ACRONYMS AND ABBREVIATIONS

AERHDM ANL-East Remote Handled Debris Material

AGHCF Alpha Gamma Hot Cell Facility

AK acceptable knowledge

AKE acceptable knowledge expert

AKSR Acceptable Knowledge Summary Report

Am americium

ANL Argonne National Laboratory

BDR batch data report

CBFO Carlsbad Area Field Office

CCP Central Characterization Project

CFR Code of Federal Regulations

CH contact-handled

Ci curie

CRR Characterization Reconciliation Report

Cs cesium

CSSF Correlation and Surrogate Summary Form

DOE U.S. Department of Energy

DQO data quality objective

DR discrepancy resolution

DU depleted uranium

DTC dose-to-curie

EBR-II Experimental Breeder Reactor II

EPA U.S. Environmental Protection Agency

FEW fuel examination waste

FIMS fissionable isotopes mass standards

g gram
HBR H.B. Robinson – high burnup fuel

HLW high-level waste

IPNS Intense Pulsed Neutron Source

LWA Land Withdrawal Act

LWBR light-water breeder reactoriii

MCNPX Monte Carlo N-Particle eXtended

mrem/hr millirem per hour

NCR nonconformance report

NTP National TRU Program

NWPA Nuclear Waste Policy Act

ORIA Office of Radiation and Indoor Air

ORIGEN Oak Ridge Isotope Generation and Depletion C ode

Pu plutonium

R/hr Roentgen per hour

RERTR Reduced Enrichment Research and Test Reactor

RH remote-handled

RTR real-time radiography

SNF spent nuclear fuel

Sr strontium

T1 Tier 1

T2 Tier 2

TMI Three Mile Island

TMU total measurement uncertainty

TRU transuranic

TRUCON TRU Content

U uranium

UREX Uranium extraction

VE visual examination

WCPIP Waste Characterization Program Implementation Plan

WDS WIPP Waste Data System

WIPP Waste Isolation Pilot Plant

WMC waste matrix code

WMP waste material parameter

WSPF Waste Stream Profile Form

WTS Washington TRU Solutions1

1.0 EXECUTIVE SUMMARY

This report supports the U.S. Environmental Protect ion Agency’s (EPA’s) decision to approve a Tier 1 (T1) change to implement the radiological ch aracterization process for the K-Wing Fuel Examination Waste (FEW). These wastes are added to the previously approved remote-handled (RH) transuranic (TRU) debris Waste Stream AERHDM 1 at the U.S. Department of Energy’s (DOE’s) Argonne National Laboratory (ANL). 2 In January 2007, EPA approved the Central Characterization Project (CCP) to characterize RH w aste at ANL. Based on EPA’s evaluation of ANL-CCP’s application of the EPA-approved waste cha racterization processes, EPA concludes that ANL-CCP can adequately characterize FEW from t he processing of fuel pins in the K-Wing of Building 205 at ANL. As a result, the K-Wing FEW packaged in 55-gallon containers 3 can be added to ANL Waste Stream AERHDM for emplacement in the Waste Isolation Pilot Plant (WIPP).

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

On July 11, 2011, the Carlsbad Field Office (CBFO) requested EPA approval of a T1 change to implement the radiological characterization process for the K-Wing FEW as part of ANL Waste Stream AERHDM. For all available FEW specimens with intact fuel pin cladding, ANL-CCP measured and recorded the length of the K-Wing FEW during VE, as described in Standing Order CCP-SO-ANLE-003, Revision 0. For all FEW test specimens with intact cladding but unavailable for measurement during VE and for all o ther FEW test specimens, ANL-CCP extracted the lengths and weights, respectively, fr om scientific notebooks. The K-Wing FEW were characterized by the method of dimensional ana lysis, as described in Appendix B of CCPAK-ANLE-501, Revision 5. EPA approved the use of di mensional analysis in November 2010 (see EPA Docket No. A-98-49: II-A4-140).

On May 18, 2010, EPA observed a method using surrog ate samples to weigh fuel pin specimens as part of a confirmation test program to qualify t he fuel specimen weights extracted from AK

1 AERHDM stands for ANL-E Remote Handled Debris Mate rial.

2 ANL was initially designated ANL-E to distinguish it from ANL-West. Since 2009, ANL-W was renamed the Materials and Fuel Complex and ANL-E is simply ANL. Both designations are found in the doc uments EPA reviewed for this evaluation and these terms ar e interchangeable in this report.

3 Containers is a generic term which applies to cans, canisters , drums, and any other types of waste packaging units that may be characterized individua lly for their radiological and physical contents.2

(see Appendix C of this report). This approval conf irms the adequacy of this process. Implementation of gravimetric analysis for waste ot her than debris will require EPA approval as a T1 change. Because this T1 request did not includ e any new equipment or additional new processes at ANL, EPA conducted a desktop review of this change. EPA did not identify any findings or concerns during this evaluation. As a r esult, EPA approves the T1 change request to implement the radiological characterization process for the K-Wing FEW as part of ANL-CCP’s previously approved AERHDM waste stream.

This approval is limited to K-Wing FEW, but does no t limit the number of containers of K-Wing FEW that can be characterized using the radiologica l process described in CCP-AK-ANLE-501, Revision 5, Appendix B. Inclusion of additional FEW containers from the K-Wing in Waste Stream AERHDM is a Tier 2 (T2) change if those cont ainers have the same pedigree and are characterized using the same dimensional analysis a s the FEW discussed in this report, as shown in Table 1 below. For such a T2 change, ANL-CCP mus t:

• Notify EPA of their intention to add containers of FEW debris from the K-Wing, including the approximate number of additional cont ainers and the approximate additional volume of waste, and provide the timefra me for waste generation, characterization, and disposal.

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

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

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

Characterization of any K-Wing FEW other than the f uel pin FEW discussed in this report is a T1 change, as shown in Table 1. Table 1 also shows new T1 or T2 changes or specific additions to existing T1s and T2s in bold text. There are several T1 and T2 changes that wer e established during the baseline approval that remain in effect, and these are listed as applicable in Sections
6.1 and 6.2.

This report serves as EPA’s public notification of the results of the proposed T1 change and its evaluation. This information will be provided throu gh the EPA website and by sending e-mails to the WIPPNEWS list, in accordance with 40 CFR 194 .8(b)(3).3Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by ANL-CCP(Based on September 12–14, 2006, Baseline Inspection and Subsequent T1 Evaluations, Updated February 2012)RH Waste CharacterizationProcess ElementsANL-CCP RH Waste Characterization Process - T1 ChangesANL-CCP RH Waste Characterization Process - T2 Changes*Acceptable Knowledge (AK)Any new waste streams not approved under this baselineModification of the approved Waste Stream AERHDM toincludeadditional containers beyond the approximately 45 included inCCP-AK-ANLE-500, Revision 1, if new or different radionuclidescaling factors are requiredSubstantive modification(s)*** to CCP-AK-ANLE-500,CCP-AK-ANLE-501 or CCP-AK-ANLE-502 that have the potentialto affect the characterization processImplementation of load management for any RH wastestreamCharacterization of any AGHCFor K-Wing FEWother thanthefuel pins, specifically AGHCF RERTR plates FEW andcruciblesand melts FEW(AK 1)Notification to EPA that the final DTC determination is complete for RHcontainers in the approved waste streamNotification to EPA when updates are made to AK documentation as aresult of WCPIP revisions**Notification that updates have been completed to the following documents:•All future revisions of CCP-AK-ANLE-500, CCP-AK-ANLE-501,and CCP-AK-ANLE-502, including freeze file changes•Listing of the references that document the assembly of fuel pin dataand review processNotification to EPA that the data package for thisdebris waste stream iscompleted, including any modificationsor change notificationsto theWSPF, including the CRR and AK Summary(AK 10)Notification to EPA when AK accuracy reports are completed, preparedannually at a minimumNotification to EPA when Attachment 4 of CCP-TP-005is generated toreflect the updated AKSR Source Document ReferenceListNotification to EPA when Attachment 8 of CCP-TP-005has been formallyupdatedor when Add Container Memoranda have been added toSource Document C2029 (AK 5)Notification to EPA of the intention to add containers to Waste StreamAERHDM, including the approximate number of containers and volume(s)of waste, the timeframe for waste generation, characterization, and disposaland submission of an updated AKSR documenting thatthe pedigree of theadditional containers is the same as those coveredby the baseline and/orsubsequent T1 approvals†Submission of a list of fully characterized containers from a population ofadditional containers proposed as a T2 change, above†Radiological Characterization,including Dose-To-Curie (DTC)Use of any alternate radiological characterizationprocedure otherthan DTC with established scaling factors as documented in CCPTP-504 and CCP-AK-ANLE-501, Revision 0, respectively, orNotification to EPA that revisions of CCP-AK-ANLE-501 or CCP-TP-504that require CBFO approval** are completeSubmission of an updated CCP-AK-ANLE-501 documenting that the4RH Waste CharacterizationProcess ElementsANL-CCP RH Waste Characterization Process - T1 ChangesANL-CCP RH Waste Characterization Process - T2 Changes*substantive modification thereof***Any new waste stream not approved under this baseline or additionof containers to Waste Stream AERHDM that require changing theestablished radionuclide scaling factorsApplication of new scaling factors for isotopic determination otherthan those documented in CCP-AK-ANLE-501Implementation of gravimetric analysis for waste other thandebris will require EPA approval as a T1 change.(RC 1)radiological characterization process(s) used for the additional containers isthe same as those covered by the baseline and/or subsequent T1 approvals†Submission of DTC BDRs or calculation packagesfor containers selectedby EPA from a list of fully characterized containers provided by ANLCCP†Visual Examination (VE) VE by reviewing existing audio/visual recordings for any wasteSummary Category Group not covered by this approvalVE by any new process for S5000 debris wastesSubmission of VE BDRs for containers selected by EPA from a list of fullycharacterized containers provided by ANL-CCP†Notification to EPA that revisions of any VE procedure that require CBFOapproval are completeAddition of new S5000 debris waste streamsReal Time Radiography (RTR) Any use of RTR requiresEPA approval Submission of RTR BDRs for containersselected by EPA from alist of fully characterized containers provided byANL-CCP†WIPP Waste Data System (WDS) NoneChanges made to WDS procedure(s) that require CBFOapprovalNew T1 or T2 changes or specific additions to existing T1s or T2 are inboldtext; references to specific sections in this report are provided only for these revised changes.* 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. Newreferences that are included as part of the document revision may berequested by EPA.***Substantive modificationrefers to a change with the potential to affect ANL’s RH waste characterization process, e.g., the useof an inherently different type of measurementinstrument or the use of the high-range probe as described for CCP-TP-504 for radiological characterization.† ANL-CCP will report this T2 change immediately.5

2.0 PURPOSE OF TIER 1 EVALUATION

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 in the ANL-CCP RH Baseline Final Report cited above.

Under the changes to 40 CFR 194.8 promulgated in th e July 16, 2004, Federal Register notice, EPA must perform a single baseline inspection of a TRU waste generator site’s waste characterization program (Vol. 69, No. 136, pages 4 2571–42583, July 16, 2004). The purpose of EPA’s baseline inspection is to approve the site’s waste characterization program, based on the demonstration that the program’s components, with a pplicable conditions and limitations, can adequately characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes destined for disposal at the WIPP.

Following EPA’s baseline approval, EPA is 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 re quiring post-implementation (T2) notification, are identified in the site-specific b aseline inspection reports. When evaluating proposed T1 changes for approval, EPA may conduct a site inspection to observe first-hand the implementation of the change, or can opt to conduct a “desktop” review of information provided specific to a change. DOE may choose to characteriz e and dispose of any previously approved TRU waste using processes/procedures/equipment impl emented as T2 changes at risk of subsequent EPA disapproval. EPA reviews T2 changes on a quarterly basis and EPA may conduct continued compliance inspections to evaluat e implemented T2 changes to verify adequacy.

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluatio n of a T1 change to implement the radiological characterization process for the K-Wing FEW package d in 55-gallon containers in Waste Stream AERHDM, as described in CCP-AK-ANLE-501, Revision 5 . This report presents the technical basis and results of EPA’s approval decision. EPA’s approval decision regarding implementation of the radiological characterization process for th e K-Wing FEW has been conveyed to DOE separately by letter. As discussed previously, EPA will also announce the decision on its website

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

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

Manager, National TRU Program
Carlsbad Field Office U. S. Department of Energy

P O Box 3090 Carlsbad, NM 88221-30906

4.0 SCOPE OF THE TIER 1 EVALUATION

The scope of this evaluation is the radiological ch aracterization of 55-gallon containers of KWing FEW in Waste Stream AERHDM. CBFO/ANL-CCP deter mined that the drums containing K-Wing FEW are of the same pedigree as the previous ly approved K-Wing debris containers. Based on criteria set forth by EPA during Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8 (Docket No. A-98-49; II-A4-73, January 2007) and th e subsequent T1 evaluation (Docket No. A98-49; II-A4-140, November 22, 2010), a T1 request is required for characterization of any FEW other than the Alpha Gamma Hot Cell Facility (AGHCF ) fuel pin FEW. Therefore, the scope of this T1 request is evaluation of the radiological c haracterization approach for the K-Wing FEW in Waste Stream AERHDM, as specified in CCP-AK-ANLE -501, Revision 5, Appendix B.

Waste Stream AERHDM has been evaluated several time s; however, this is the first EPA T1 evaluation since implementation of Revision 2 of th e Waste Characterization Program Implementation Plan (WCPIP). Several documents subm itted along with the original July 2010 T1 request were not compliant with the new WCPIP. E PA asked that CBFO/ANL-CCP revise
relevant waste stream documentation to reflect the requirements of Revision 2 of the WCPIP. All reference to the WCPIP in this report means Revisio n 2, unless specified otherwise. As part of the review, EPA also evaluated AK to confirm that t he K-Wing FEW, as described in CCP-AKANLE-500, Revision 7 (AK Summary Report or AKSR), i s of the same pedigree as the previously approved K-Wing debris waste.

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

• Programmatic Requirements and AK, including VE

• Radiological Characterization

This evaluation involved expanding an existing wast e stream to incorporate new containers and not the addition of a new Summary Category Group or waste stream; therefore inspection
checklists were not used.

5.0 EVALUATION PERSONNEL

EPA and its support personnel conducted interviews with ANL-CCP personnel in several disciplines by telephone. The EPA evaluation team m embers and the personnel contacted are
listed in Table 2 with their affiliations and techn ical areas of expertise. This listing includes personnel present at meetings conducted as part of this evaluation.

Table 2. T1 Evaluation Personnel

Personnel Name Affiliation Area of Expertise, Function

Rajani Joglekar EPA ORIA Tier 1 Evaluation Lead Ins pector Ed Feltcorn EPA ORIA Tier 1 Evaluation Inspector Connie Walker SC&A Acceptable Knowledge, Inspector Kira Darlow SC&A Acceptable Knowledge, Inspector Amir Mobasheran SC&A Radiological Characterization, Inspector Patrick Kelly SC&A Radiological Characterization, I nspector7 Table 2. T1 Evaluation Personnel

Personnel Name Affiliation Area of Expertise, Function

Kevin Peters CCP-TechSpecs Acceptable Knowledge Exp ert Mark Doherty CCP-TechSpecs Acceptable Knowledge Exp ert Jene Vance WTS-CCP Radiological Characterization, T echnical Expert Jim Holderness WTS-CCP Radiological Characterizatio n, Technical Expert Irene Quintana WTS-CCP Site Project Manager Mike Sensibaugh WTS-CCP Observer

Marcus Pinzel CBFO NTP Observer

6.0 TECHNICAL EVALUATION

Waste Generating Activities

The K-Wing FEW consists of residual fuel specimens and remnants from irradiated materials used in research conducted in K-Wing hot cells. The activities that resulted in the residual fuel specimens were: sample preparation for subsequent t esting, including development of pyroprocessing techniques and aqueous biphasic extracti on studies; leaching, degradation, and
corrosion studies of reactor fuels intended to be d isposed into the proposed Yucca Mountain repository; and small-scale demonstration experimen ts for the chemical separation of fission products, plutonium (Pu) and uranium (U) in the ura nium extraction (UREX) process (References C2002, C2004, C2005, C2006, P344, P1001 , P2011, P2018). The K-Wing FEW inventory identifies 119 discrete quantities of res idual fuel pin specimens originating from 30 fuel pin specimens (Reference U2004). These RH TRU FEW had been placed in two-liter shielded fuel capsules, which were subsequently pla ced in 55-gallon drums fitted with 140 mil fiberboard liners. Other non-FEW debris, including the Intense Pulsed Neutron Sources (IPNS) targets, was loaded in the drums with the fuel caps ules (References P2038 and U2020, and VE BDR ANLRHVE11010). A total of eight 55-gallon drums containing K-Wing FEW have been generated.

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

EPA evaluated the documentation that ANL-CCP had pr epared to support the inclusion of the KWing FEW in Waste Stream AERHDM. ANL-CCP provided C CP-AK-ANLE-500, Revision 7, CCP-AK-ANLE-502, Revision 4, and CCP-AK-ANLE-501, R evision 5 to EPA for review. As a result of EPA’s review, several technical issues we re identified that necessitated the revision of CCP-AK-ANLE-500, Revision 7, CCP-AK-ANLE-502, Revis ion 4, some of the associated AK documentation (see Section 6.1), and Revision 5 of CCP-AK-ANLE-501, Appendix B. The revised documents were provided to EPA prior to the conclusion of this T1 evaluation. The listing of all documentation reviewed is in Attachm ent B, and the list of VE BDRs and radiological characterization calculation packages examined is presented in Table 3. Because the radiological characterization process for the K-Win g FEW waste does not involve the generation of batch data reports, the characterization for eac h drum is documented in a separate calculation package, as shown in Table 3.8 Table 3. Batch Data Reports and Calculation Package s Examined

Drum Number VE BDR Number Calculation Package Number

RW18875 RHANLVE11010 ANLE-RH-15-2

RW18876 RHANLVE11010 ANLE-RH-15-1

RW18877 RHANLVE11010 ANLE-RH-15-3

RW18878 RHANLVE11010 ANLE-RH-15-4

RW18879 RHANLVE11010 ANLE-RH-15-5

RW18880 RHANLVE11010 ANLE-RH-15-6

RW18881 RHANLVE11010 ANLE-RH-15-7

RW18904 RHANLVE11010 ANLE-RH-15-8

6.1 Programmatic Requirements and Acceptable Knowledge

EPA examined the programmatic requirements and AK p rocess and associated information to assess the technical adequacy of the information to support the inclusion of the K-Wing FEW in

ANL RH Waste Stream AERHDM.

Waste Characterization Element Description

As part of this evaluation, EPA reviewed the follow ing with respect to programmatic requirements and the use of AK for RH waste charact erization:

• Evaluation scope and waste stream identification

• Identification of the WCPIP waste characterization process

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

• Adequacy of data management reviews, validation act ivities, data reporting and records
retention

• Adequacy of personnel training

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

• Adequacy of Nonconformance and Discrepancy Resoluti on documentation (NCRs and DRs, respectively)

• Waste stream definition including radiological and physical characteristics

• Verification that the subject waste is of defense o rigin and is not high-level waste (HLW) or spent nuclear fuel (SNF)

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

• Adequacy of AK procedure and its implementation, in cluding Attachments, AK Accuracy Reports, Characterization Reconciliation R eports (CRRs), and Correlation and Surrogate Summary Forms (CSSFs)

• Adequacy of the AKSR and associated source document s9

• AK data traceability

• Attainment of Data Quality Objectives (DQOs)

Technical Evaluation

EPA evaluated the adequacy of AK information specif ic to adding K-Wing FEW to Waste Stream AERHDM, as described in CCP-AK-ANL-500 (AKSR ), Revision 7, CCP-AK-ANL501, Revision 5, and CCP-AK-ANL-502, Revision 4. EP A also evaluated the records relative to the WCPIP programmatic requirements. The specific W CPIP citation that addresses EPA requirements for AK is included parenthetically at the end of each component heading.

(1) The scope of the Tier 1 request and the waste strea m determination were examined for Waste Stream AERHDM, including the additional K-Win g fuel examination waste containers, and found to be adequate (WCPIP, Sectio n 3.0, p. 13) 4

.

This T1 requests approval of the radiological chara cterization approach for the 55-gallon containers of K-Wing FEW in Waste Stream AERHDM, as specified in CCP-AK-ANLE-501, Revision 5, Appendix B. ANL-CCP representatives sta ted that eight containers of K-Wing FEW had been characterized at the time of the T1 reques t and no additional containers are expected. The scope of the T1 request is well-defined and con fined to the radiological characterization process for the eight 55-gallon containers of K-Win g FEW. In conjunction with evaluating the T1 request, EPA is evaluating the AK documentation for WCPIP compliance and to confirm that the K-Wing FEW is of the same pedigree as Waste Str eam AERHDM.

The WCPIP defines a waste stream as “waste material that is (1) generated from a single process/activity and (2) similar in material, physi cal form, and radiological properties.” Waste Stream AERHDM is a debris waste stream generated by ANL in two locations – the AGHCF and the K-Wing. 5 As part of the baseline and subsequent T1 approval s, EPA concluded that the waste stream was adequately defined but it did not at that time include K-Wing FEW. After reviewing the provided documentation, EPA concluded that the K-Wing FEW is of the same pedigree as Waste Stream AERHDM.

The K-Wing FEW containers were generated as a resul t of the same hot cell activities that generated the previously approved K-Wing debris was te containers (see EPA Docket No. A-98- 49; II-A4-132). As indicated in the AKSR, these K-W ing FEW drums contain “fuel sections and fragments left over from previous experiments” and additional non-FEW debris from the same experiments (demonstration of the UREX process and sampling of irradiated target material). This non-FEW debris is from the same population of debris packaged in the previously approved K-Wing debris waste containers.

4 The WCPIP references are examples and are not mean t to be an exhaustive list. Many of these requirements are discussed in several places within the WCPIP.

5 The AGHFC and the K-Wing Hot Cell Facility are dis tinct facilities located in the 200 Area of ANL-E that were used for similar purposes.10

Based on this information, the processes that gener ated the source material within the waste and the waste itself are well understood and represent a single process or waste stream. The radiological and physical compositions of the waste stream are addressed in Item (7). This approval is limited to fuel pin FEW. (See Table 1.)

(2) The Certification Plan, including description of th e waste characterization process, was examined and found to be complete and technically a dequate (WCPIP, Section 3, pp. 14- 15).

CCP-AK-ANL-502, Revision 4 (Certification Plan) sta tes that a combination of characterization
methods from WCPIP Sections 4.2 and 4.3 has been em ployed to characterize Waste Stream AERHDM, specifically the K-Wing FEW. These methods include AK, VE, and radiological
characterization. AK is used to determine and descr ibe the waste stream, and to define Land
Withdrawal Act

(LWA) DQOs such as the defense status of the waste [Item (9)] and absence of HLW and SNF [Item (8)]. VE is used to verify the ph ysical composition of the waste stream [Item (7)], and modeling and AK in combination with dimensional analysis were used to determine the radiological composition (Section 6.2 ). The characterization process is adequately
described in the Certification Plan.

The WCPIP requires that the Certification Plan desc ribe the process for certification of the waste stream, including a description of the following:

• AK qualification and/or characterization methods se lected to meet the DQOs, including the justification for the selection of the methods

• Quality Assurance Objectives for the selected metho ds

• Characterization and testing methods not included i n the WCPIP in sufficient detail to allow for CBFO approval prior to implementation

• Summary of the program documents to be prepared dur ing the characterization and/or qualification methods

EPA examined the Certification Plan and found that the document contained most of the fundamental information cited above plus additional information describing how AK accuracy is to be evaluated. The AK accuracy discussion is not a required component of the Certification
Plan. EPA has determined that while it is not techn ically incorrect to include an AK accuracy discussion in the Certification Plan, it is accepta ble if the discussion implies that AK is to be used to meet all of the DQOs. CCP-AK-ANLE-502, Revi sion 4, needed to be revised to clarify the relationship among AK, AK accuracy, and the DQO s.

Additionally, the Certification Plan did not includ e any description of the methods implemented to qualify and confirm the AK-based FEW specimen we ight and length measurements that were used in the radiological characterization process [ see Item (3), below]. The Certification Plan must include a description of any qualification or confirmation as part of the description of the characterization methods used to meet the DQOs. EPA raised the issue that AK-based FEW specimen weight data were used for a few fuel pins, which required qualification of those data.
ANL-CCP revised the Certification Plan to include a discussion of the AK confirmations and to11

remove the initialization “DQO” from the AK accurac y discussion. The revised Certification Plan is technically adequate but it is in need of f urther editorial revision, noting that future certification plans developed using the text of thi s certification plan as a template must be modified to more clearly address the current WCPIP requirements. EPA may revisit this during a future evaluation to maintain consistency with othe r ANL-CCP documentation. Notification to
EPA when formal revisions of the Certification Plan are available remains a T2 change. (See Table 1.) Substantive modification of CCP-AK-ANLE-5 02 that has the potential to affect the characterization process remains a T1 change. (See Table 1.)

(3) The waste characterization methods were identified and the selected approach and documentation were adequate (WCPIP, Section 5, p. 1 3).

Based on information presented in the Certification Plan, the physical and radiological compositions of the waste stream are determined thr ough measurement, modeling, and VE. While some K-Wing FEW specimens were measured, the weights and lengths from the historic AK record are used for the following: K-Wing FEW sp ecimens that are not contained within intact cladding; are contained within intact claddi ng but are too short to be accurately measured during VE (less than 0.5 inches); or, are within in tact cladding but otherwise unable to be measured. ANL-CCP executed a Confirmation Test Prog ram (CCP-AK-ANLE-505C, Fuel Weight Confirmation Test Program for Argonne Remote -Handled K-Wing Fuel Examination Waste) to confirm the AK-based weights and validate the AK for use in radiological characterization. This confirmation was correctly i mplemented. However, ANL-CCP did not confirm the AK length measurements prior to the EPA inspection. EPA discussed this with ANL-CCP, and a comparison of available length measu rements in VE records and the corresponding AK was performed, as documented in Re ference C3000. This comparison confirmed the AK length measurements for use in cha racterizing K-Wing FEW containers. After revision of the Certification Plan, EPA concl uded that the AK-based data were qualified, and the characterization methods were adequately id entified and were appropriate for this waste

stream.

(4) Example Nonconformance Documentation and Discrepanc y Resolution forms were examined and found to be adequate (WCPIP, Section 3 .4.2.3, p. 24).

There have not been any NCRs or DRs generated durin g characterization of the K-Wing FEW
containers. EPA examined NCRs and DR forms related to Waste Stream AERHDM during the ANL-CCP RH baseline inspection and subsequent T1 ev aluations and found the preparation of these documents to be adequate. Based on EPA’s prev ious evaluations, EPA expects that ANLCCP would develop appropriate NCRs and DRs when nec essary.

(5) The Acceptable Knowledge procedure was examined and found to be adequate and appropriately implemented (WCPIP, Section 4.1, pp. 32-33).

CCP-TP-005, Revision 23 became effective June 30, 2 011. The preparation dates for the AKSR, Certification Plan, Radiological Characterization R eport, and all revised supporting documentation postdate CCP-TP-005, Revision 23. The refore, CCP-TP-005, Revision 23 is the appropriate revision for preparation of CCP-TP-005 attachments, noting that future changes to12

any attachments should reflect the version of CCP-T P-005 in place at the time the changes are
made.

CCP-TP-005, Revision 23 includes 15 attachments and also requires development and maintenance of an AK tracking spreadsheet that pres ents a running compilation of drums within
each waste stream at a site. ANL-CCP modified Attac hments 1, 4, 8, and 13 to include the KWing FEW in Waste Stream AERHDM. Attachments 1, 8, and 13 were adequate as presented to EPA. See Item (6), below for discussion about Attac hment 4.

Attachment 8 is the waste stream container list use d to develop the SWSPF. The Attachment 8 provided for this T1 evaluation was revised July 12 , 2011, and includes all containers added to
Waste Stream AERHDM as of that date. CCP has recent ly implemented a new approach to tracking the addition of containers to approved was te streams. For all waste streams, the Attachment 8 will no longer be updated after approv al of the AKSR; instead, it will be updated either after the first approval or, as for Waste St ream AERHDM, after the first approval following this change in CCP policy. Add Container Memoranda will be filed in single source
documents and will serve as the official record for additional containers.

As this change was recently implemented, EPA has no t had a chance to evaluate the entire process. EPA confirmed that the “Waste Container Ev aluation Memorandum for Waste Stream AERHDM” file contains all Add Container Memoranda g enerated since the initial AKSR approval (Reference C2029). ANL-CCP representatives indicated that Source Document C2029 will be updated continuously as additional containe rs are added to the waste stream and that the AK Tracking Spreadsheet will continue to be updated , as in the past. EPA finds that this new process is acceptable for Waste Stream AERHDM based on review of Attachment 8, Source Document C2029, and the AK Tracking Spreadsheet. EP A will continue to review implementation of this process during future evalua tions. Notification to EPA when Add
Container Memoranda have been added to Source Docum ent C2029 is a new T2 change. (See Table 1.)

(6) The Acceptable Knowledge Summary Report was examine d, along with the reference list and associated source documents, and found to be ad equate (WCPIP, Section 4.1, p. 31).

EPA examined Revision 7 of the AKSR and found that the document did not clearly quantify the impact that the K-Wing FEW would have on the waste material parameter (WMP) calculations and included incorrect information describing the r adiological characterization process. Section
6.0 of the AKSR also needed to be revised to correc t a typographical error and to update the text to be WCPIP compliant and consistent with CCP-AK-AN LE-502. ANL-CCP revised the AKSR to correct Section 6.0 and to explicitly account fo r the K-Wing FEW in the WMP calculations. EPA finds the revised AKSR to be adequate.

EPA also examined the source document reference lis t (CCP-TP-005, Revision 23, Attachment 4) as provided July 11, 2011, and found that this d ocument did not contain a record of the memorandum that ANL provided to the ANL-CCP radiolo gical characterization personnel that
described the radionuclide activities of the IPNS T argets [see Item (7), below]. ANL-CCP13

revised the source document reference list to inclu de this memorandum. EPA finds the revised Attachment 4 to be adequate.

Any substantive modifications to the AKSR that have the potential to affect the characterization process continue to be T1 changes. Notification to EPA upon minor revisions of the AKSR continues to be a T2 change. (See Table 1.)

(7) The radiological and physical properties of the was te stream were examined and found to be adequately described for the K-Wing fuel examina tion waste based on acceptable knowledge (WCPIP, Section 3.0, p. 13).

The K-Wing FEW is residual material from fuel exami nations that contaminated the previously approved K-Wing debris waste containers, plus four IPNS Targets. The same AK source documents were used to determine the ORIGEN2.2 inpu ts for both the K-Wing FEW containers and the previously approved K-Wing debris waste con tainers. However, as indicated in the Certification Plan, the same scaling factors were n ot applied to this set of the K-Wing FEW containers because the radionuclide activity and ma ss for each container were more accurately
calculated based on the masses of the discrete fuel test specimens in the individual drums. The mass of each test specimen was determined using mea surements taken during VE or using qualified AK-based data [see Item (3), above]. ANL- CCP calculated the radionuclide activities for the IPNS targets using the computer code MCNPX (see Section 6.2). The radiological contribution of the debris packaged with the K-Wing FEW is expected to be minimal and is
therefore excluded.

The physical characteristics of each container are recorded on VE data sheets and the physical measurements of FEW specimens in Container Nos. RW1 8876 (weight), RW18877 (weight and length), and RW18878 (weight) are documented in VE Logbook RH-ANLE-VE-009. The VE operators who created the VE data sheets (in VE BDR RHANLVE11010 in Table 3, above) assigned Waste Matrix Code (WMC) S5400, Heterogeneo us Debris to the examined K-Wing FEW containers. This is the same WMC as was assigne d to the previously approved K-Wing debris containers in Waste Stream AERHDM, which is one indication that the K-Wing FEW containers have the same physical characteristics a s those in the approved waste stream.

The K-Wing FEW is placed in shielded fuel capsules (approximately 2 liters in size) and then packaged in 55-gallon containers along with other K -Wing debris waste. Therefore, ANL-CCP considers that the K-Wing FEW will have a minor imp act on the WMPs previously calculated for Waste Stream AERHDM (Reference U2020 and CCP-TP -005, Revision 19, Attachment 6). Revision 7 of the AKSR did not explicitly state tha t the K-Wing FEW would have minimal impact on the WMPs [see Item (6), above]. The AKSR was revised to include the expected impact of K-Wing FEW on the WMPs and a memorandum w as added to CCP-TP-005 Attachment 6 to provide additional information. VE performed at the time of packaging confirmed the absence of prohibited items. EPA’s re view confirmed that neither prohibited items nor liquids were observed, and the VE BDR was adequ ate.14

(8) The waste stream information was examined and indic ates that the waste stream does not contain spent nuclear fuel or high-level waste (WCP IP, Section 2.2.7, p. 12).

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

(NWPA). The NWPA states SNF is “fuel that has been withdrawn from a nuclear reactor following irradiation, the constitu ent elements of which have not been separated by reprocessing.” DOE M435.1-1 6 expands on this definition and states that, “test s pecimens of
fissionable material irradiated for research and de velopment only, and not production of power or plutonium, may be classified as waste, and manag ed in accordance with the requirements of this Order when it is technically infeasible, cost prohibitive, or would increase worker exposure to separate the remaining test specimens from other contaminated material.” The NWPA defines HLW as “the highly radioactive material resulting f rom the reprocessing of spent nuclear fuel, including liquid waste produced directly in reproce ssing and any solid material derived from such liquid waste that contains fission products in sufficient concentrations, and other highly radioactive material that the Commission, consisten t with existing law, determines by rule requires permanent isolation.”

ANL-CCP determined that the debris wastes generated during deactivation, decommissioning and demolition activities of the K-Wing facility co ntain residual radiological contamination from operations conducted from 1996 until 2007, and do n ot contain irradiated fuel elements withdrawn from a reactor. The FEW component of the K-Wing debris includes test residues and specimens, and the resultant test fragments from th e fuel pin test specimens, including irradiated pin fragments, fines and dust. EPA inspected the K- Wing inventory documentation and agrees that the radiological materials managed in the K-Wi ng were primarily fuel samples and swarf 7

, as indicated by the size of the material in the K-W ing inventory (Reference U2004). ANL-CCP also states that the intact irradiated fuel pins we re managed separately and are not included in the waste stream. As a result, the K-Wing FEW is not co nsidered SNF.

Because ANL-CCP determined that the K-Wing FEW is n ot SNF, the waste could not contain HLW, by definition. While the K-Wing UREX process d emonstrations included reprocessing research, by virtue of taking place within a hot ce ll, these research and development laboratory operations were not production operations involving the separation or reprocessing of constituent elements from reactor fuels. Therefore, ANL-CCP con cluded that HLW was not generated (References P2019, P2023, and P2024); thus the wast e is not SNF or HLW and EPA accepts these arguments as reasonable. Note that ANL-CCP is not including any of the vitrified samples of HLW or waste surrogates from West Valley and Sav annah River Site used during Yucca Mountain corrosion studies that are part of Waste S tream AERHDM and are stored in the KWing, pending further evaluation. This type of wast e can only be sent to WIPP with TRU waste if statutory changes to the LWA occur.

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

.

7 Swarf is material produced by a cutting or grinding proc ess.15

(9) The waste stream information was examined and indic ates the waste stream has a defense pedigree (WCPIP, Section 2.2.7, p. 12).

EPA previously evaluated and approved the defense w aste determination of Waste Stream AERHDM for the K-Wing waste during a T1 evaluation (see EPA Docket No. A-98-49; II-A4-132). EPA determined that the AK record conta ins sufficient evidence to demonstrate that all of the TRU wastes generated by K-Wing operation s contain materials from atomic energy
defense activities associated with naval reactor de velopment, materials security and safeguards, and defense research and development activities. De fense-related spent fuels managed in KWing after 1995 included those obtained from the Ex perimental Breeder Reactor II, Hanford N reactor, Shippingport Light Water Breeder Reactor a nd Reduced Enrichment Research and Test Reactor Program (RERTR), which were also used in Yu cca Mountain corrosion studies and high-burnup characterization studies (References C0 06, C2004, C2007, and U001). ANL-CCP representatives also indicate that because the K-Wi ng continues to “store, manage, and utilize research materials... accumulated throughout the... ope rational history” and the impossibility of “separation of contamination from destructively exa mined specimens,” all RH TRU debris waste from the K-Wing meets the WIPP requirement of defen se-related waste (Reference C2027). The K-Wing FEW is a subset of the materials processed i n the K-Wing. Therefore, the K-Wing FEW
containers that are added to Waste Stream AERHDM me et the WIPP requirement of defenserelated waste.

(10) The Waste Stream Profile Form and attached Characte rization Reconciliation Report were examined and found to be adequate (WCPIP, Sect ion 3.4.2.1, p. 22).

The WCPIP includes specific requirements for the co ntents of the WSPF and the CRR. The
WSPF for Waste Stream AERHDM does not meet the WCPI P requirements because it has not been revised since the WCPIP revision was approved. EPA’s policy with respect to revision of documents to meet requirements in Revision 2 of the WCPIP is that documents such as the WSPF do not need to be revised just to meet the new requirements, but if the document has to be revised for other reasons, it must also be brought into compliance with the revised WCPIP, and EPA notification of this revision is necessary.

ANL-CCP personnel stated that change notices to WSP Fs are initiated if: the addition of material parameter weight estimates per unit of waste is req uired; the TRU Content (TRUCON) Codes change; or, if the waste stream volume changes. The AERHDM WSPF was approved in May 2008, and a Change Notice was approved in September 2010 in response to the addition of a
TRUCON Code and an increase in waste stream volume. ANL-CCP personnel stated that waste stream volume increase included in the September 20 10 Change Notice accounted for the KWing FEW and, therefore, a Change Notice will not b e initiated as a result of this T1 evaluation. EPA agrees that the WSPF does not need to be revise d for WCPIP compliance. The WSPF for Waste Stream AERHDM is adequate.

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

• Specification of applicable site and waste stream

• Listing of each DQO16

• Data from the AK record that addresses each DQO

• AK source document references that support/provide the data

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

• Documentation, including specific references, of ho w the AK data for each DQO were qualified, such as BDRs, corroborative data, procee dings of a peer review

• Radiography and/or VE summary to document that proh ibited liquids are absent from the waste and to confirm the physical properties of the waste

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

• Complete AK summary (unless previously submitted)

• Complete listing of all container identification nu mbers used to generate the WSPF,
cross-referenced to each BDR

• Signature of the Site Project Manager

ANL-CCP representatives provided a draft CRR on Jul y 11, 2011, that EPA evaluated and found was adequate, in spite of typographical errors. As required in EPA’s baseline approval, revision of the WSPF and related attachments, including the CRR, remains a T2 change, and EPA will receive notification of these changes when they are made. Notification to EPA upon availability of WSPF Change Notices is a new T2 change. (See Tab le 1.)

(11) The AK Accuracy Report was examined and found to be adequate; a Correlation or Surrogate Summary Form was not required (WCPIP, Sec tion 3.2.2, pp. 17-19, and Section 4.1, p. 30).

Completion of a CSSF is required when AK from a rel ated contact-handled (CH) waste stream is used in the RH waste characterization process. Duri ng the ANL-CCP baseline inspection, an ANL-CCP representative indicated that CH data were not used in this manner. Inclusion of KWing FEW waste in Waste Stream AERHDM also did not require completion of a CSSF.

EPA examined the draft AK Accuracy Report provided July 11, 2011, and found that it did not adequately address evaluation of the expected radio nuclide distribution. Also, this report implies that AK accuracy is used to evaluate whether the DQ Os were met and that ANL-CCP used qualified AK information to meet all of the DQOs. A NL-CCP revised the AK Accuracy Report to address these issues and, while the revised draf t AK Accuracy Report is in need of further editorial revision, it is technically adequate. Sin ce ANL-CCP uses the same AK Accuracy Report template for all of the lots in a waste stream, EPA may suggest further clarification edits during a future review. Notification to EPA when AK accuracy reports are completed remains a T2 change. (See Table 1.)17

(12) Drum data are adequately traceable and are in the A cceptable Knowledge record (WCPIP, Section 3.4.4.1, p. 20; Section 3.4.2.2, p. 23, and Section 4.1, pp. 29-34).

EPA examined traceability of AK data to understand the waste generation, packaging, processing, transport, and characterization process es up to and including the characterization activities performed by ANL-CCP. The K-Wing FEW con tainers are newly generated, so there are no original data packaging sheets or other gene rator documentation associated with individual containers. The K-Wing FEW packaged in t he containers, however, has been stored in the K-Wing as accountable materials. 8 Therefore, there are historic records for the FEW contents of the individual containers. ANL-CCP indicated tha t eight containers have been generated and undergone ANL-CCP VE and radiological characterizat ion. EPA was provided VE BDR ANLRHVE11010 that included all eight K-Wing FEW con tainers, Nos. RW18875-RW18881
and RW18904. Examination of these data indicated th at each drum contained one or two shielded containers containing FEW along with other K-Wing trash debris. The VE BDR also identifies the specific FEW test specimens in each container. This information links the FEW contents to specific line items in the K-Wing inven tory containing the historic weight and length measurements. The length measurements for the FEW t est specimens that could be measured are recorded in various VE logbooks. A few of the K-Win g FEW test specimens are also traceable to the AGHCF inventory of accountable materials. EPA’s traceability analysis of four of these containers is summarized in Table 4, below.

Table 4. K-Wing Fuel Examination Waste Data Trackin g Summary

Drum FEW

Specimens VE Length

Measurement Historic

Length/ Weight

Information Calculation

Package AGHCF Record

(information from C2027)

RW18875 ANL #6 N/A Weight from

U2004 ANLE-RH-15-2

RW18878 HBR

(A/G611C4, c22) N/A Weight from

U2004 ANLE-RH-15-4 U303 (PDF p. 56): Samples from AGHCF to K-Wing June 2003. U304 (PDF p. 4): Sectioning of samples in AGHCF, subsequent analysis in K-Wing.

RW18881 18 from:

Limerick (A/G574B2); Shippingport

LWBR(A/G340); NReactor (A/G562); ATM-103,

109 N/A 9 lengths, 9 weights from

U2004 ANLE-RH-15-7 U1003: Receipt of A/G 340 fuel specimens from Idaho in AGHCF
from1986–1988. Identifies ongoing management of met mounts and samples from Sections 340A, C, E, G, H, J and transfer of samples to K-Wing in 2001.

P344: Discusses excising and analysis of Limerick fuel rod sample 574B2 in AGHCF, followed by preparation of specimen for analysis in K-Wing.

8 Accountable materials are nuclear items and related materials that must be controlled as specified in DOE Order 410.2, Management of Nuclear Materials , and generally include fissile materials, source m aterials used to produce fissile materials and other materials of sp ecial interest.18

Drum FEW

Specimens VE Length

Measurement Historic

Length/ Weight

Information Calculation

Package AGHCF Record

(information from C2027)

P519: Describes preparation of
574B in AGHCF

RW18904 53 from:

ATM-103, 106, 109;

EBR-II MOX (A/G498);

TMI (A/G536);

Limerick (A/G574B2);

N-Reactor (A/G562);

LWBR (A/G340J);

IPNS 5 lengths in

logbook: RHANLE-VE007 2 lengths, 46

weights from U2004; IPNS

data in C2032 ANLE-RH-15-8 See A/G340J, A/G574B2, and A/G562 references above;

U1003: Specimens 498A and 498B transferred in AGHCF early 1995. P515, P518, P523: Sectioning and testing TMI fuel 536, including AGHCF test plans.

During the initial traceability analysis, EPA deter mined that the K-Wing FEW inventory in Source Document U2004 did not clearly match the FEW test specimens identified in the VE BDR. ANL-CCP representatives explained that the wei ghts and lengths for radiological characterization had been gleaned from a different K-Wing inventory document provided directly to the radiological characterization perso nnel. This new K-Wing inventory document is AK and, as such, must be identified as a source doc ument and filed with CCP Records. ANLCCP AK personnel added the new K-Wing inventory to Source Document U2004 and updated the Attachment 3, Source Document Summary Sheet to include the additional record.

EPA repeated the traceability analysis using the ne w K-Wing inventory and additional logbook information and found that the drum data are adequa tely traceable in the AK record.

(13) Acceptable Knowledge Training was examined and foun d to be adequate (WCPIP, Section 4.1, p. 32).

The WCPIP indicates that characterization program p ersonnel responsible for compiling AK, characterizing RH TRU waste streams using the AK pr ocess, and assessing the AK characterization shall be qualified and trained in the following:

• The WCPIP

• Characterization program NCR and corrective action processes

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

• Determination of radiological contents of individua l containers

Mr. Kevin Peters wrote the AKSR and Ms. Lisa Watson signed several of the AK attachments revised in association with the K-Wing FEW T1. Tabl e 5, below, summarizes the objective evidence provided demonstrating Mr. Peters’ and Ms. Watson’s training. The current qualification card for Ms. Sherry Aukland was also reviewed because she signed some of the19

revised AK attachments for Mr. Peters. Ms. Aukland did not collect AK for this waste stream and only fulfilled the role of a clerk to expedite the revision process. Therefore, EPA agreed that only a review of her qualification card was necessa ry.

Table 5. Summary of Training Records for ANL-CCP AK Es

Name WCPIP Nonconformance
and Corrective
Action Process (CCP-QP-005) Site-Specific

Training Determining

Radiological
Contents of
Containers Current Revision of

CCP-TP-005

Kevin Peters Qual Card Qual Card CCP Document
Control
Screenshot Briefing R23: Briefing and Att 8, 3s, 13

Lisa Watson Qual Card Qual Card E-Mail

Statement Briefing R23: Briefing and Att 1, 4

Through interviews and the above-mentioned document ation, EPA finds training for AK personnel to be adequate. EPA notes that providing the IPNS Targets memorandum and the KWing inventory directly to ANL-CPP radiological per sonnel [See Items (6) and (12), respectively] may indicate that the radiological pe rsonnel also collect AK information and should therefore be subject to the same training requireme nts as the AK Experts (AKE). EPA will revisit this matter at a later date with upcoming T1 approv als, if this pattern of sharing source documents with the radiological personnel continues

.

(14) Data Quality Objectives were evaluated and found to be adequately met (WCPIP, Section 3.4.2, p. 22).

The WCPIP identifies the following DQOs that must b e addressed:

Defense Waste, High-Level Waste, and Spent Nuclear Fuel Determination (Regulatory Basis: LWA) : This is required to ensure that the waste stream was generated by atomic energy defense activities, is not HLW, and is not SNF. These are a ddressed in CCP-AK-ANLE-500, Revision 8, and CCP-AK-ANLE-502, Revision 5, as discussed in It ems (9) and (8), above.

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

• TRU Waste Determination: Waste must contain more than 100 nanocuries of TRU isotopes per gram of waste

• RH Waste Determination: Surface dose rate must be equal to or greater than 200 millirem per hour (mrem/hr) and less than 1,000 rem per hour

• Activity Determination: The total waste inventory can be no more than 5.1 m illion curies (Ci) of RH TRU; activity limit per canister is 23 C i per liter; and all radionuclides important to release calculations must be tracked

These three DQOs are addressed in CCP-AK-ANLE-501, Revision 7, as discussed in Section 6.2, below.20

Physical Properties (Regulatory Basis: EPA Certific ation of the WIPP) :

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

• Physical Form: The physical form of the waste to delineate the wa ste stream as required by the final certification rule must be determined

These two DQOs are addressed in VE BDR No. ANLRHVE1 1010, as discussed in Items (7) and (12), above.

EPA determined that the documents cited above suppo rt that all DQOs were achieved and that AK data used to quantify parameters were adequately qualified.

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

Acceptable Knowledge Approval

Based on the results of this evaluation, EPA concur s that the K-Wing FEW is of the same pedigree as waste already approved for inclusion in Waste Stream AERHDM and finds that all procedural requirements have been met. Based on thi s evaluation, EPA has added new T1 and T2 change requirements (see bold text inserts in Table 1).

6.2 Radiological Characterization

Radiological Characterization Overview

Radiological characterization of the K-Wing FEW is based on determining the total mass of discrete fuel specimens in individual drums and ass igning a radionuclide activity distribution per unit mass of the loaded specimens. The form of the fuel materials and availability of information allow the direct determination of a container-speci fic value for the 10 WIPP-tracked radionuclides, specifically cesium-137 ( 137 Cs), americium-241 ( 241 Am), plutonium-238 ( 238 Pu), plutonium-239 ( 239 Pu), plutonium-240 ( 240 Pu), plutonium-242 ( 242 Pu), strontium-90 ( 90 Sr), uranium-233 ( 233 U), uranium-234 ( 234 U), uranium-238 ( 238 U), and other radionuclides, as applicable.

The K-Wing FEW includes 30 fuel specimens, some of which are contained in intact fuel cladding while others are powders and irregular pie ces. The fuel-pin specimens were measured for length and weight, as needed, and their masses were determined by multiplying the measured length and the fuel mass per unit length provided b y AK. For fuel pin specimens that could not be measured, the mass and length values were taken from historic AK data, which were qualified using VE on a subset as part of a confirmation test program.21 Figure 1. Radiological Characterization Process for FEW Retrieve records on fuel compositions, burnups, reactor discharge dates, fuel pin physical parameters,

and characterization date

Obtain from the VE records the length of intact fuel pins

loaded into the drum and

calculate the fuel mass Develop and execute Test Program to confirm historical weight

measurement data on nonclad fuel specimens

Retrieve historical weight

measurement data on nonclad fuel specimens

From VE records, confirm

containers and masses of non-clad fuel specimens

loaded into the drum Calculate fuel mass loading
per unit length of each fuel
pin Make ORIGEN2.2 runs for 30 fuel pins involved in K-Wing hot cell

activities to determine mass and/or activity of

radionuclides of interest per-unit-mass Collect relevant AK on
K-Wing FEW

Develop and execute

Waste Certification Plan

Calculate activity and mass for reportable

radionuclides

Determine uncertainties in

the recorded activities and

masses of the radionuclides Using MCNPX, determine
the activity of any DU
target from IPNS if loaded

into the drum22

The activity distribution of the radionuclides was determined with ORIGEN2.2 using preirradiation composition ( 235 U enrichment, U/Pu ratio, 240 Pu enrichment), burnup, and decay time of the K-Wing fuel specimens obtained from AK as in put. The decay time is the time difference between the reactor discharge date and the shipment date, assumed to be the date that the drum is
characterized. The activities of individual radionu clides obtained from ORIGEN2.2 are applied to the quantities in each container, allowing the d etermination of the container’s total activity.

As described above, following measurement the speci mens were placed into shielded fuel capsules, which were then placed into eight 55-gall on drums, Nos. 18875-18881, and 18904. Each drum is unique and there is one calculation pa ckage per waste drum. EPA expects that the format and technical approach embodied in ANLE-RH-1 5-1 and referenced in ANLE-RH-15-2 through ANLE-RH-15-8 will be the same for the other seven K-Wing FEW drums EPA evaluated for this approval. An overview of the rad iological characterization process used for the K-Wing FEW and depicted in Figure B3-1 of CCP-AK-AN LE-501, Revision 5, is provided in Figure 1, above.

EPA evaluated the characterization methods used for the K-Wing FEW in terms of the technical adequacy of the approach, as supported by the progr am’s documents, procedures, and controls, and the knowledge and understanding of the personne l involved in the RH waste characterization program. Additionally, EPA personnel observed the a ctual measurement of fuel elements at ANL, as described in Attachment C.

Documents Reviewed

Attachment B includes all documents related to the INL-CCP RH TRU radiological characterization program that were examined to supp ort this T1 evaluation.

Technical Evaluation

(1) The EPA inspection team evaluated the methodolo gy and the technical approach used to characterize and document the K-Wing FEW and determ ined that they were technically adequate.

The information that formed the basis of the radiol ogical characterization process was reviewed. Specifically, the “direct” method used to replace D TC as documented in CCP-AK-ANLE-501, Revision 5, and the supporting calculation packages were reviewed. The following aspects of the characterization process were evaluated:

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

• Information on fuel pin lengths extracted from VE r ecords

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

• Utilization of fissionable isotopes mass standards (FIMS) data

• Determination of reportable radionuclides and the b ounding analysis performed23

• Retrieval of records and information from the K-Win g programs

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

• Utilization of pre-irradiation fuel composition ( 233 U enrichment, U/Pu ratio, 240 Pu enrichment), fuel burnup, date of discharge from re actor (end-of-irradiation date), and decay duration as input data for ORIGEN2.2 analyses

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

242 Pu, 241 Am, 137 Cs, and 90 Sr), curium-244 ( 244 Cm), curium-245 ( 245 Cm), cesium-134 ( 134 Cs), europium-154, yttrium-90, and barium-137m

• The bounding analysis involving a set of fuel types to represent the population of fuel pins in the K-Wing inventory for Fissile Gram Equiv alent, Pu Equivalent Curies, and decay heat in Watts

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

CCP-AK-ANLE-501, Revision 5, states that the waste stream also includes four targets from the IPNS, and that ANL-E staff determined the radionucl ide content of each target using the MCNPX computer code. The total activities for these drums were obtained by adding the activities of the targets and fuel specimens. EPA w as not provided a calculation package documenting this activity; however, the radiologica l contribution of the IPNS targets is expected
to be minimal and was therefore excluded.

The constants and other values in the calculation p ackages were taken from the appropriate sources and were spot-checked for accuracy. Calcula tions were performed using an Excel spreadsheet, as shown in Figure B4-3 of CCP-AK-ANLE -501, Revision 5, using the following input:

• Date of characterization

• Waste stream designation

• Container number

• Number of steel FEW containers

• Container gross weight

• Container net weight

• Waste material type

• Radionuclides and their activities

There were no concerns regarding the methodology, t echnical approach and documentation used for radiological characterization of the K-Wing FEW . Implementation of gravimetric analysis for waste other than debris will require EPA approval a s a T1 change. (See Table 1.)24

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

CCP-AK-ANLE-501 is the main document that describes the radiological characterization process, supported by a series of calculation packa ges. EPA reviewed Revision 5 of CCP-AKANLE-501 and found it to be adequate, although it r equired minor corrections, e.g., citing the use of MCNP5 for the RH determinations as is typica lly performed in conjunction with DTC but is not applicable to the K-Wing FEW containers. EPA also reviewed 11 calculation packages that had been prepared by Derek Ott and James Holde rness and reviewed by Jene Vance. The
characterization for each drum is documented in a s ingle calculation package that effectively replaces a BDR, in that it documents the specific d etails of each drum, i.e., the activities and
masses of the 10 WIPP-tracked radionulcides and the ir uncertainties. Calculation package ANLE-RH-15-1, Revision 0, Radiological Characterization of K-Wing Drum 18876 , provided detailed calculations for Drum No.18876, which EPA reviewed in detail. The calculations for the other seven drums referenced this package and showe d the changes and the corresponding
results.

The EPA evaluation team determined that CCP-AK-ANLE -501 adequately documented the radiological characterization process for the K-Win g FEW, and the calculation packages adequately supported the activities upon which the radiological characterization is based. The drum-specific calculation packages adequately repla ced BDRs and contained the necessary information to support their characterization. Ther e were no issues related to the documentation of technical aspects of the ANL-CCP radiological ch aracterization approach for the K-Wing

FEW.

(3) The technical basis and derivation of Total Measure ment Uncertainty were evaluated and were found to be adequate.

The development of Total Measurement Uncertainty (T MU) for Waste Stream AERHDM is based on the propagation of uncertainties present i n all aspects of the determination of the radiological constituents. These aspects are assume d to be independent, which allows them to be added in quadrature. 9 However, for the K-Wing FEW there are two sources of uncertainty that are statistically dependent: (1) the specimen mass determination; and (2) a single drum containing multiple fuel specimens from the same fu el pin or subassembly. The TMU
determination included contributions of the followi ng sources of uncertainties:

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

• Specimen mass determination based on weight measure ment involving specimen weight measurement, tare weight determination

9 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.25

• ORIGEN2.2 analysis uncertainty (benchmark uncertain ty, including all sources of uncertainty: uncertainties in code inputs, uncertai nties in the code, and the model uncertainties)

A general treatment of TMU is presented in CCP-AK-A NLE-501, Revision 5. There were no concerns regarding the technical derivation and doc umentation of TMU for ANL Waste Stream AERHDM containing the K-Wing FEW.

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

The determinations that each container in the strea m was RH, i.e., had a contact dose rate in excess of 200 mrem/hr, were based on surveys taken by ANL-E Health Physics personnel, as recorded on Building No. 205 K-Wing survey forms. A ll containers were measured using a Ludlum Model 9-7 portable survey meter, SN 2614, an d had a current calibration for all eight measurements, as documented on the survey forms. Th e contact gamma dose rates were listed in R/hr (Roentgen per hour) and ranged from 11.3 R/hr to 43.3 R/hr. All eight drums had contact
dose rates in excess of the 200 mrem/hr criterion f or RH wastes.

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

Radiological Characterization Approval

Based on the results of this evaluation, EPA approv es the process of determining the radiological content of the K-Wing FEW, as described in this rep ort.

7.0 FINDINGS OR CONCERNS

Summary of Findings and Concerns

The EPA inspection team did not identify any findin gs or concerns related to AK or radiological characterization. EPA worked interactively with the ir ANL-CCP counterparts to answer questions, identify information needs, and acquire necessary data and references; all potential issues were resolved in a timely fashion. There are no open issues related to AK or radiological characterization resulting from this T1 evaluation.

8.0 CONCLUSIONS

EPA concluded that the waste characterization proce sses of AK and radiological characterization used to characterize RH TRU K-Wing FEW as part of A NL Waste Stream AERHDM are adequate, as evidenced by the records evaluated. Th ere are no open issues relative to this T1
evaluation.26

Approval

This T1 change consisted of the radiological charac terization technique for the K-Wing FEW as part of ANL Waste Stream AERHDM. Based on the resul ts of this evaluation, EPA approves this T1 change for Waste Stream AERHDM, consistent with the limitations specified in this
report.A-1 ATTACHMENT A

APPROVAL SUMMARY FOR ANL RH WASTE CHARACTERIZATION PROGRAM

Specific ANL RH Approval Date EPA Docket Number

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

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

Tier 1 Change – Approval of Visual Examination for Newly

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

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

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

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

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

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

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

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

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

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUAT ION

CCP-AK-ANLE-500 Central Characterization Project Ac ceptable Knowledge Summary Report For Argonne Remote-Handled Debris Waste, Waste Stre am: AERHDM, Revision 7, August 12, 2011 and Revision 9, December 21, 2011

CCP-AK-ANLE-501, Central Characterization Project R emote-Handled Transuranic Radiological Characterization Technical Report for Remote-Handled Transuranic Debris Waste From Argonne National Laboratory-East, Revision 5, June 22, 2011 and Revision 7, January 3,

2012

CCP-AK-ANLE-502, Central Characterization Project R H TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation Test Plan for ANL RH Waste Stream: AERHDM, Revision 2, August 3, 2011 and Revision 6, December 28, 2011

CCP-AK-ANLE-505C, Central Characterization Project Fuel Weight Confirmation Test Program for Argonne Remote-Handled K-Wing Fuel Exam ination Waste, Waste Stream: AERHDM, Revision 0, May 17, 2010

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

CCP-TP-005, Revision 19, CCP Acceptable Knowledge D ocumentation, Attachment 6 – Waste Form, Waste Material Parameters, Prohibited Items, and Packaging, Waste Stream AERHDM, August 3, 2010; Memorandum added September 15, 2011

CCP-TP-005, Revision 23, CCP Acceptable Knowledge D ocumentation, Attachment 1 – Acceptable Knowledge Document Checklist, Waste Stre am AERHDM, July 6, 2011

CCP-TP-005, Revision 23, CCP Acceptable Knowledge D ocumentation, Attachment 4 – Acceptable Knowledge Source Document Information Li st, Waste Stream AERHDM, July 6, 2011 and October 20, 2011

CCP-TP-005, Revision 23, CCP Acceptable Knowledge D ocumentation, Attachment 8 – Waste Containers, Waste Stream AERHDM, July 5, 2011

CCP-TP-005, Revision 23, CCP Acceptable Knowledge D ocumentation, Attachment 13 – CCP Waste Stream Characterization Checklist, Waste Stre am AERHDM, Draft, Provided July 11,

2011

Characterization Reconciliation Report for AERHDM, Draft for Audit Purposes, Provided July 11, 2011

Inter-Office Correspondence, from Irene Quintana to CCP Records Custodian, Acceptable Knowledge Accuracy Report: Argonne National Laborat ory Waste Stream Number AERHDM, Lot K-Wing FEW, Audit Purposes Only, July 1, 2011 a nd October 19, 2011B-2

RH ANLE AK Container Tracking Spreadsheet, October 24, 2011

Training documentation: Qualification Cards, Radiol ogical Training, and Site-Specific RH Training for K. Peters and L. Watson; Qualification Card for S. Aukland

Update for WIPP Operating Record (Change Notice #1) Remote Handled Heterogeneous Debris from the Argonne National Laboratory (AERHDM), Sept ember 21, 2010

VE BDR ANLRHVE11010, July 5, 2011

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

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

C006, Interview with L.A. Neimark re: AGHCF samples , applicable programs, defense relationship to materials, and commingling of waste , C. Schultz, Record of Communication: RO C-C6, July 17, 2001

C2002, Memorandum from Timothy S. Crawford to Dr. F rank Y. Fradin regarding the Safety Analysis Report (SAR) Revision 02 and Technical Saf ety Requirements (TSRs) Revision 01 for the Argonne National Laboratory-East (ANL-E) Buildi ng 205 G & K Wing Laboratories, Timothy S. Crawford, 0898-016, August 07, 1998

C2004, Safety Review for Unsaturated Testing of Ura nium Metal Spent Fuel in Bldg. 205 Senior Cave and K-116 Facilities, R. D. Wolson, CMT50-0 US -Draft, Revision 0, March 7, 2009

C2005, Safety Review of Tests with Samples of Spent Fuel in Bldg. 205, K-104 (Senior Cave) and, in K-116, Sampling of Leachate Solutions from the Tests, P. A. Finn, CMTS0-0058-EP, Revision 1, March 13, 2000

C2006, Work Plan for the Preparation of Unirradiate d AI-clad Specimens for GMT, T.S. Bray, IPS-329-00-00, December 02, 1999

C2007, Work Plan for the Preparation of Specimens f rom the Characterization of Pins UW02010 (A/G 498A) and UWOB036 (A/G 4988), L.A. Neimark, IP S-284-00-00, June 17, 1998

C2010, Evaluation of the Physical Waste Composition for K-Wing Waste in Waste Stream AERHDM, Christopher Chancellor, September 24, 2009

C2011, ANL Memorandum to R.J. Page re: Estimating M ass and Radioactivity for EBR-2 Element Segments Stored in Building 212 - More Numb ers, K.N. Grimm, April 22, 2008

C2012, ANL Memorandum to R.J. Page re: Estimating M ass and Radioactivity for HBR Rods Stored in the AGHCF, K.N. Grimm, January 24, 2008

C2013, ANL Memorandum to R.J. Page re: Estimating M ass and Radioactivity for Surry Unit 2 Elements Stored in the AGHCF, K.N. Grimm, March 17, 2008B-3

C2014, ANL Memorandum to R.J. Page re: Limerick Fue l Rod Activity Analysis, K.N. Grimm, March 21, 2006

C2015, ANL Memorandum to R.J. Page re: Estimating A ctivity for Limerick Rods Stored in the AGHCF - More Numbers, K.N. Grimm, January 29, 2008

C2016, ANL Memorandum to R.J. Page re: Quad Cities Unit 1 Fuel Rod Activity Analysis, K.N. Grimm, April 21, 2006

C2017, ANL Memorandum to R.J. Page re: Estimating A ctivity for Quad Cities Rods Stored in the AGHCF - More Numbers, K.N. Grimm, January 30, 2 008

C2018, ANL Memorandum to R.J. Page re: Three Mile I sland Unit 1 Fuel Rod Activity Analysis, K.N. Grimm, April 19, 2006

C2019, ANL Memorandum to R.J. Page re: Estimating A ctivity for TMI Rods Stored in the AGHCF - More Numbers, K.N. Grimm, January 29, 2008

C2020, ANL Memorandum to R.J. Page re: Estimating M ass and Radioactivity for BRP, HBR, and BR3 Rods Stored in the AGHCF, K.N. Grimm, March 1, 2007

C2021, ANL Memorandum to R.J. Page re: Estimating A ctivity for BRP, HBR, and BR3 Rods Stored in the AGHCF - More Numbers, K.N. Grimm, Mar ch 18, 2008

C2027, Waste Stream Delineation Evaluation for Wast e Stream AERHDM to include K-Wing Waste, K. Peters, July 14, 2010

C2029, Waste Container Evaluation Memorandum for Wa ste Stream AERHDM, K. Peters, May 20, 2008

C2032, Memorandum from L.A. Neimark to Distribution , Subject: Revision 1 to the Work Plan for the Preparation of Fuel Rods for Return Shipmen t to Idaho, HFS-01S-00-00, December 8, 2004, L.A. Neimark, HFS-Q1S-00-01, Revision 1, Dece mber 09, 2004

C3000, Comparison of Fuel Rod Length Measurements f rom AK Records and VE Records for K-Wing FEW, J. Vance, November 16, 2011

P1001, From Test Tube to Pilot Plant; A 50 Year His tory of the Chemical Technology Division at Argonne National Laboratory, R.K. Steunenberg an d L. Burris, ANL-00/16, ISBN 0-967168- 1-X, August 1, 2000

P2011, Nuclear Operations Deactivation, Decommissio ning, and Demolition Program: Appendix B: Building 205 K-Wing Hot Cell Deactivation Projec t Plan, D. Hodge, NOD-162-00-01, Revision 1, March 5, 2009

P2018, Safety Analysis Report Building 205 G-Wing a nd K- Wing Laboratories, M.A. Slawecki, R.D. Wolson, J.B. Rajan, F.G. Teats, CMT-30-0470, R evision 2, December 1, 1997B-4

P2019, Test Plan for the Characterization of an App roved Testing Material Mixed Oxide Fuel, L. A. Neimark, SNF-3A-004, Revision 0, April 8, 1998

P2023, Results of the UREX+2 Spent Fuel Demonstrati on, C. Pereira, G.F. Vandegrift, M.C. Regalbuto, A. Bakel, S. Aase, D. Bowers, J.P. Byrne s, M.A. Clark, J.W. Emery, J.A. Falkenberg, A.V. Gelis, A. Leyva, L. Hafenrichter, Y. Tsai, K.J . Quigley, M.H. Vander Pol, and K. Wardle, February 28, 2005

P2024, Results of the 2005 UREX+1a Spent Fuel Demon stration, C. Pereira, L.E. Miller, G.F. Vandegrift, M.C. Regalbuto, A. Bakel, J. Basco, D. Bowers, J. Bruso, J.P. Byrnes, M.A. Clark, J.W. Emery, J.A. Falkenberg, A V. Gelis, L. Hafenri chter, A.A. Leonard, A. Leyva, H. Mayes, T. Robinson, Y. Tsai, K. Quigley, March 31, 2006

P2038, Preparation of Container Shielding Configura tions for Material Transfers From C-Cell, J. Emery, NOD-205K-OPS-301, Revision 2, March 1, 2010

P344, Analysis of Spent Nuclear Fuel Sample A/G 574 B2 (Limerick Reactor) to Determine Selected Isotopes and Estimate Fuel Burnup, D.G. Gr aczyk, April 2003

P515, Work Plan for Determining Hydrogen Contents i n TMI-1 Cladding Memorandum to IPS Document File, H. Tsai, IPS-ET, IPS-331-00-00 and I PS-331-00-01, Revisions 0 and 1, February 3, 2000

P518, Work Plan for the Steam Oxidation Tests at 12 00 degrees on Unirradiated Zry-4 and Irradiated TMI-1 Cladding; Memorandum to NRC Progra m File; Several Supplemental Instructions, Y. Yan, IPS-335-00-00 and IPS-335-01- 00, Revisions 0 and 1, February 11, 2000

P519, Work Plan for cutting Limerick Rod Sections a nd Loading into Shipping Tubes; Memorandum to IPS Document File, H. Tsai, IPS-ET, I PS-336-00-00, January 24, 2000

P523, Work Plan for CMT Samples from TMI Fuel Rod S egments; Memorandum to Distribution, R.V. Strain, IPS-342-00-00, January 3 1, 2000

U001, AGHCF Position Statement Regarding Defense Ve rsus Non-Defense TRU Waste, April 7, 2000

U1003, Argonne Special Material Receipt and Transfe r Documentation by A/G Number (A/G 1 - 535), ANLE, 1964-1997

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

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

U303, Notes for Correction of Fissile Ledger Databa se Regarding H.B. Robinson Fuel Shipment, T. Bray, April 17, 2004

U304, Robinson Report, Unknown DateB-5

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

U898A, CCP Calculation Package for: Radiological Ch aracterization of Drum 18876, J. Vance, ANLE-RH-15-1, Revision 0, June 1, 2011

U898B, CCP Calculation Package for: Radiological Ch aracterization of Drum 18875, J. Holderness, ANLE-RH-15-2, Revision 0, June 6, 2011

U898C, CCP Calculation Package for: Radiological Ch aracterization of Drum 18877, J. Holderness, ANLE-RH-15-3, Revision 0, June 6, 2011

U898D, CCP Calculation Package for: Radiological Ch aracterization of Drum 18878, J. Holderness, ANLE-RH-15-4, Revision 0, June 6, 2011

U898E, CCP Calculation Package for: Radiological Ch aracterization of Drum 18879, J. Holderness, ANLE-RH-15-5, Revision 0, June 6, 2011

U898F, CCP Calculation Package for: Radiological Ch aracterization of Drum 18880, J. Holderness, ANLE-RH-15-6, Revision 0, June 6, 2011

U898G, CCP Calculation Package for: Radiological Ch aracterization of Drum 18881, J. Holderness, ANLE-RH-15-7, Revision 0, June 6, 2011

U898H, CCP Calculation Package for: Radiological Ch aracterization of Drum 18904, J. Holderness, ANLE-RH-15-8, Revision 0, June 06, 2011

U900, CCP Calculation Package for: Determination of Reportable Radionuclides - K-Wing FEW, J. Vance, ANLE-RH-17, Revision 0, June 6, 2011

U902, CCP Calculation Package for: Fuel Rod Loading Calculation, J. Vance, ANLE-RH-19, Revision 0, June 6, 201

Building #205 K-Wing Drum Survey Report, Drum No. 1 8875, December 4, 2009

Building #205 K-Wing Drum Survey Report, Drum No. 1 8876 December 9, 2009

Building #205 K-Wing Drum Survey Report, Drum No. 1 8877, December 15, 2009

Building #205 K-Wing Drum Survey Report, Drum No. 1 8878, December 18, 2009

Building #205 K-Wing Drum Survey Report, Drum No. 1 8879, March 11, 2010

Building #205 K-Wing Drum Survey Report, Drum No. 1 8880, March 23, 2010

Building #205 K-Wing Drum Survey Report, Drum No. 1 8881, April 7, 2010

Building #205 K-Wing Drum Survey Report, Drum No. 1 8904, June 4, 1010B-6

Building #205 K-Wing Drum Survey Report, Drum No. 1 8875, December 4, 2009C-1 ATTACHMENT C:

OBSERVATION OF ANL FUEL WEIGHT CONFIRMATION TEST PR OGRAM FOR
ARGONNE REMOTE-HANDLED K-WING FUEL EXAMINATION WAST E

May 18, 2010

This summary describes results obtained from the co nfirmatory test program for K-Wing FEW conducted in the K-Wing hot cells in Building 205 a t ANL on May 18, 2010. Representatives from the U.S. EPA observed the exercise performed b y ANL-CCP and ANL personnel responsible for operation of the glove box manipula tors. The purpose of this exercise was for ANL-CCP to confirm the weight measurement data in t he AK record and thereby qualify the existing weight measurement data for use in the RH TRU waste characterization program. The testing operations were performed in accordance wit h CCP-AK-ANLE-505C, Revision 0.

Nine FEW specimen containers, which had not yet bee n packaged, had been previously weighed by the Argonne technical staff as part of the suppo rt for the research and experimental activities conducted in the K-Wing hot cells. During the exerc ise, the nine specimen containers were reweighed on a certified balance that was inside the hot cell. During the exercise, the FEW container ID, the existing container weight, and th e scale readout were recorded in ANL Operational Logbook RH-ANLE-WS-001. This informatio n, plus the percent difference in weights, is recorded in Table C-1, below.

Table C-1. K-Wing FEW Confirmation Test Program Wei ghts

FEW Container

ID Number Historic Weight (g) Scale Readout

(g) Percent Difference

in Weights

106V 104.6158 107.4010 2.59%

109CH 106.6658 106.5265 0.13%

103H 105.2735 109.1984 3.59%

103V 103.7844 104.0272 0.23%

106L 103.7891 102.8279 0.93%

109AH 108.1094 108.0222 0.08%

109AV 107.9444 107.9677 0.02%

109BV 107.7386 107.8363 0.09%

109CV 108.3836 108.4857 0.09%

All in-cell weights were obtained using a certified Mettler Toledo Balance, Model XP205-SE, Serial Number 1123421746. The scale calibration exp iration date was March 31, 2011, and the scale tolerance was 0.03 milligram. The goal of the confirmation test program was to determine the acceptability of the existing weight measuremen t data. The existing weight records were considered acceptable if the average percent differ ence between the nine measurements was equal to or less than 20%. The acceptance criterion was determined to ensure a minimal impact on the total uncertainty in the estimated activity in the drums. The average difference of the weights recorded in Table C-1 is 0.86%, which is le ss than 20%. Therefore, the existing historic AK weights are acceptable and the population of wei ght data for FEW specimens packaged in the ANL K-Wing hot cells is qualified for use in th e radiological characterization process.