DOCKET NO: A-98-49; II-A4-188 

 

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT 

EPA TIER 1 EVALUATION 

OF THE CENTRAL CHARACTERIZATION PROGRAM 

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM 

FOR THE IDAHO NATIONAL LABORATORY: 

ADDITION OF WASTE STREAM ID-MFC-SOLID-RH (LOT 5A) 

U.S. Environmental Protection Agency 

Radiation Protection Division 

Center for Waste Management & Regulations 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

September 2014
i 

TABLE OF CONTENTS 

Section Page 

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

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

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

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

4.0 Scope of The Tier 1 Evaluation ...........................................................................................5

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

6.0 Technical Evaluation ...........................................................................................................6

6.1 Acceptable Knowledge ........................................................................................... 7

6.2 Radiological Characterization ............................................................................... 10

7.0 Findings and Concerns .......................................................................................................15

8.0 Conclusions ........................................................................................................................15

 

TABLE OF TABLES 

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

TABLE OF FIGURES 

Figure 1. Radiological Characterization Flow Diagram for Waste Stream ID-MFC-SOLID-RH 

(Lot 5A) ........................................................................................................................................ 12

ATTACHMENTS 

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

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

ABBREVIATIONS AND ACRONYMS 

AK acceptable knowledge 

AKSR acceptable knowledge summary report 

ANL Argonne National Laboratory 

BDR batch data report 

CBFO Carlsbad Field Office 

CCP Central Characterization Program 

CFR Code of Federal Regulations 

Ci curie 

Cm curium 

Cs cesium 

DOE U.S. Department of Energy 

DTC dose-to-curie 

EBR-II Experimental Breeder Reactor-II 

EPA U.S. Environmental Protection Agency 

Eu europium 

HLW high-level waste 

INL Idaho National Laboratory 

INTEC Idaho Nuclear Technology and Engineering Center 

m meter 

MFC Materials and Fuels Complex 

mrem/hr millirem per hour 

Pu plutonium 

R Roentgen 

rem Roentgen equivalent man 

RH remote-handled 

RSWF Radioactive Scrap and Waste Facility 

RTR real-time radiography 

SAP sampling and analysis plan 

SCG summary category group 

SF scaling factor 

SNF spent nuclear fuel 
iii 

T1 Tier 1 

T2 Tier 2 

TMU total measurement uncertainty 

TRU transuranic 

U uranium 

WIPP Waste Isolation Pilot Plant 

WMP waste material parameter 

Zr zirconium 
4 

1.0 INTRODUCTION 

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

(T1) change that adds Waste Stream ID-MFC-SOLID-RH (Lot 5A) to the approved remotehandled (RH) transuranic (TRU) waste characterization program at the U.S. Department of 

Energy’s (DOE’s) Idaho National Laboratory (INL). In January 2007, EPA approved the Central 

Characterization Program (CCP)1

 to characterize RH TRU waste at INL. Using the EPAapproved waste characterization processes discussed in this report, INL-CCP may characterize 

Waste Stream ID-MFC-SOLID-RH debris waste for disposal at the Waste Isolation Pilot Plant 

(WIPP). 

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

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

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

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

November 12, 2013, the Carlsbad Field Office (CBFO) requested EPA approval of a T1 change 

to add Waste Stream ID-MFC-SOLID-RH (Lot 5A) (hereafter referred to as “Waste Stream IDMFC-SOLID-RH”) to the INL-CCP RH waste characterization program. EPA limited the scope 

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

characterization specific to the addition of Waste Stream ID-MFC-SOLID-RH. Because INLCCP did not use new equipment or processes to characterize the subject waste, EPA conducted a 

desktop review of this change in February–June 2014. 

EPA did not identify any findings or concerns during this evaluation. However, EPA raised 

several issues with documentation requiring INL-CCP to revise several reports and various 

calculation packages during the evaluation. EPA reviewed the revised documents and concluded 

that the revisions address EPA’s issues. Attachment B is a list of all documentation reviewed, 

including batch data reports (BDRs) and calculation packages. 

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

(T2) designations established following the baseline approval and modified subsequently as 

needed as a result of EPA’s approval of previous INL-CCP RH T1 change requests and EPA’s 

annual continued compliance inspections. The tiering designations presented in Table 2 of the 

final report for EPA’s 2014 continued compliance inspection of INL-CCP (see EPA Docket No. 

A-98-49; II-A4-190; July 15, 2014) remain in effect and are listed as applicable in sections 6.1 

and 6.2 of this report. 

Based on the information provided, EPA concluded that the INL-CCP’s plan to use the EPAapproved system of controls to characterize the four containers of Waste Stream ID-MFCSOLID-RH was acceptable and appropriate. These four containers of TRU waste in Lot 5A are 

the subject of this T1 report, but EPA’s approval also includes any additional drums that are 

added to Waste Stream ID-MFC-SOLID-RH in the future, provided they are characterized using 

the processes used for characterizing the four containers in Lot 5A as discussed in this report. 

 1

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

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

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

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

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

194.8(b)(3)]. 

2.0 PURPOSE OF TIER 1 EVALUATIONS 

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

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

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

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

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

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

TRU waste generator site’s waste characterization program. The purpose of EPA’s baseline 

inspection is to approve the site’s waste characterization program, based on the demonstration 

that the program’s components, with applicable conditions and limitations, can adequately 

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

destined for disposal at the WIPP. 

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

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

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

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

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

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

to observe implementation of the change or can opt to conduct a desktop review of information 

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

approved TRU waste using processes, procedures or equipment implemented as T2 changes at 

risk of subsequent EPA disapproval. 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation of a T1 change to add Waste Stream IDMFC-SOLID-RH to the EPA-approved waste characterization program. This report presents the 

technical basis for and results of EPA’s approval decision. EPA’s approval decision regarding 

the addition of Waste Stream ID-MFC-SOLID-RH has been conveyed to DOE separately by 

letter. EPA will also announce the decision on its website at www.epa.gov/radiation/wipp, in 

accordance with 40 CFR 194.8(b)(3). 

4.0 SCOPE OF THE TIER 1 EVALUATION 

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

used to characterize Waste Stream ID-MFC-SOLID-RH. Sections 6.1–6.2 of this report detail 

the technical elements assessed during this evaluation. 
6 

5.0 EVALUATION PERSONNEL 

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

affiliations and functions. EPA relied primarily on reviews of documents and information 

provided by INL-CCP. When additional information or clarifications were needed, EPA had 

discussions with Irene Joo, the CCP RH Project Manager, who served as the point of contact for 

this T1 evaluation. 

Table 1. EPA Tier 1 Evaluation Team Members 

6.0 TECHNICAL EVALUATION 

Waste-Generating Activities and Waste Overview

Waste Stream ID-MFC-SOLID-RH is composed of debris and solidified Materials and Fuels 

Complex (MFC) Analytical Laboratory sample solutions generated by radiochemical analysis of 

irradiated fuel and test materials that were created during separation, purification and preparation 

of sample solutions for mass spectroscopic analysis and wet chemical analysis (References 

C002, C092, C214, C4109, P060, P075, P4071, U552, U140, U218, and U223–U240). MFC 

generated the waste between May 1972 and August 1977, and transferred it to the Idaho Nuclear 

Technology and Engineering Center (INTEC) in 2010. 

Waste Stream ID-MFC-SOLID-RH is primarily composed of the contents of the original sample 

bottles, the solidified sample solutions absorbed on Oil-Dri absorbent material, aluminum liners, 

and secondary waste from radiological sampling operations, as well as the 30-gallon drum, metal 

sling and hook, and drum lifting bag from repackaging operations. The waste contains fissile 

materials and mixed fission products from fuel assemblies that were primarily irradiated in the 

Experimental Breeder Reactor-II (EBR-II) that consisted of uranium (U)-zirconium (Zr)-

plutonium (Pu) or U-Zr alloy fuels, U-Fissium fuels, and blanket fuels (References C465, C503, 

U483, U484, U541, U551 and U552). 

Packaging Configuration 

INL personnel originally packaged Waste Stream ID-MFC-SOLID-RH as solidified sample 

solutions absorbed on Oil-Dri absorbent material plus laboratory debris in 1-liter bottles, and 

placed the bottles in aluminum liners (solidified solutions) or cardboard liners (debris). INL 

packaged each open-top, cardboard or aluminum liner in a 16-inch diameter, 148-inch long 

carbon steel liner and stored the 16-inch liners in 24-inch liners at the Radioactive Scrap and 

Waste Facility (RSWF). INL-CCP retrieved the 16-inch liners from the RSWF in 2010 and 

transferred them to INTEC. At INTEC, INL-CCP personnel emptied each of the bottles from the 

various liners onto sampling trays, sampled the waste, and repackaged each liner into four 30-

Name Affiliation & Function 

Rajani Joglekar Lead Inspector, U.S. EPA 

Ed Feltcorn Inspector, U.S. EPA 

Connie Walker Technical Evaluator – Acceptable Knowledge, SC&A 

Rose Gogliotti Technical Evaluator – Radiological Characterization, SC&A 

Patrick Kelly Technical Evaluator – Radiological Characterization, SC&A 

Amir Mobasheran Technical Evaluator – Radiological Characterization, SC&A 
7 

gallon drums. INL-CCP did not comingle the contents of each liner and placed the sampling 

debris, including the metal sampling tray, in the corresponding 30-gallon drum. 

Radiography verified that the 30-gallon drum contents do not include bracing and that INL-CCP 

placed the waste in the drum without special packaging considerations. INL-CCP overpacked the 

30-gallon drums into 55-gallon drums. Final waste drum numbers are QQ-36A-1, OO-25A-1, 

FF-32A-1 and DD-51A-1. 

Documents Provided 

EPA evaluated the INL-CCP documentation that supported the addition of Waste Stream IDMFC-SOLID-RH. INL-CCP provided CCP-AK-INL-540, Revisions 3 and 4; CCP-RC-INL-541, 

Revisions 0 and 1; CCP-AK-INL-542, Revision 1; and CCP-AK-INL-545D, Revision 1, to EPA 

for review. EPA’s review identified several technical issues that necessitated the revision of 

several reports and documents. INL-CCP provided revised documentation during the T1 

evaluation. 

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

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

Any of these documents can be requested from the following address: 

Manager, National TRU Program 

Carlsbad Field Office 

U.S. Department of Energy 

P O Box 3090 

Carlsbad, NM 88221-3090 

6.1 Acceptable Knowledge 

EPA examined the programmatic requirements and AK process and associated information 

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

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

information supporting the addition of Waste Stream ID-MFC-SOLID-RH. 

Waste Characterization Element Description 

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

 Identification of the waste characterization process. 

 Identification of appropriate summary category group (SCG). 

 Waste stream definition, including waste generation and radiological and physical 

characteristics. 

 Role of AK in the characterization methodology, including scaling factors. 

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

or spent nuclear fuel (SNF).
8 

Technical Evaluation 

EPA evaluated the adequacy of AK information specific to Waste Stream ID-MFC-SOLID-RH, 

as described in the AK Summary Report (AKSR) (CCP-AK-INL-540, Revision 3), certification 

plan (CCP-AK-INL-542, Revision 1), and associated source documents. EPA identified several 

areas of the AKSR that required clarification or correction. INL-CCP revised the AKSR to 

include the correct waste stream definition and clarify the SNF and HLW exclusion 

demonstration. EPA’s approval decision is based on Revision 4 of the AKSR. 

(1) EPA determined that INL-CCP appropriately identified the waste summary category 

group to be S5000 debris. 

Original packaging documentation for Waste Stream ID-MFC-SOLID-RH indicated that the 

waste contained primarily solidified material (Reference U552), which prompted INL-CCP to 

assign the waste to the S3000 SCG. Reference C4112, Revision 0, with attached August 13, 

2010, memorandum provides original pre-repackaging waste material parameter (WMP) 

estimates for the waste in the 16-inch liners, and concludes that approximately 55% of the waste 

was composed of inorganic solidified material (by weight). However, INL-CCP later modified 

the waste stream’s SCG after repackaging the liners into drums. Reference DR011 states that 

“the waste stream was assumed to be Summary Category Group S3000...Repackaging of the 

RSWF liners was necessary to characterize and certify the waste for WIPP. However, following 

repackaging (Reference U288) and real-time radiography (RTR) fast scan (References U998 and 

U4059), and with the addition of secondary waste expected from sampling operations (see CCPAK-INL-545D), the waste stream will be predominantly (more than 50 percent by volume) 

Summary Category Group S5000, Debris.” References DR011 and C4112, Revision 1 with 

modified memorandum dated January 2013, provide recalculated WMPs and show the inclusion 

of the 30-gallon drums as waste rather than packaging. SCG S5000 is correctly assigned when 

the 30-gallon drum is considered waste. 

EPA reviewed RTR BDR No. INLRHRTR13005 to verify the identification of the waste as 

debris (S5000). The drums currently contain items such as wire rope, metal hooks, a 30-gallon 

steel drum, a metal tray, scrap metal, metal tube, wire, knives, glass bottles, rubber stoppers, 

scrap plastic, plastic bottles and absorbent. 

(2) EPA examined the waste stream determination for Waste Stream ID-MFC-SOLID-RH 

and found it to be adequate.

A waste stream is defined as waste material that is generated from a single process/activity and is 

similar in material, physical form, and radiological properties. As described in the overview 

portion of section 6.0, above, INL generated the waste in Waste Stream ID-MFC-SOLID-RH 

during radiochemical analyses at the MFC Analytical Laboratory from 1972 to 1977. The 

physical composition of the waste includes debris and solidified MFC Analytical Laboratory 

sample solutions. The waste contents also include debris generated during the 2010 waste 

sampling and repackaging operations (References C758, DR011, U998 and U4059). The 

radiological composition of the waste is well documented in AK records, and INL-CCP obtained 

drum-specific information during its radiochemistry sampling program as documented in section 
9 

6.2, below. The commonality of waste generation process and physical/radiological waste 

characteristics is adequately demonstrated. 

(3) EPA determined that INL-CCP identified the waste characterization pathway, and that 

documentation of the approach was adequate. 

INL-CCP characterized Waste Stream ID-MFC-SOLID-RH through radiological sampling and 

analysis, dose-to-curie (DTC), and radiography, as described in CCP-AK-INL-542, Revision 1, 

CCP-AK-INL-545D, Revision 1, and CCP-RC-INL-541, Revisions 0 and 1. INL-CCP 

adequately described the waste characterization process. EPA’s evaluation of the sampling and 

analysis and DTC are discussed in section 6.2 of this report. 

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

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

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

Nuclear Waste Policy Act at the WIPP. Waste stream ID-MFC-SOLID-RH includes debris and 

solidified sample solutions from Analytical Laboratory hot cell operations, and may contain test 

residues, test materials, and the resultant test fragments from fuel pin test specimens, including 

irradiated pin fragments. Analytical Laboratory operations consisted of destructive analysis and 

examination of irradiated fuel and sample materials that did not involve reprocessing of 

constituent elements from reactor fuel (References C092, C214, DR011, P055, P4071, U552 and 

U4059). Therefore, Waste Stream ID-MFC-SOLID-RH does not contain intact SNF or HLW. 

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

found it to be adequate. 

AK indicates that while MFC personnel managed non-defense material in the Analytical 

Laboratory, TRU wastes generated by MFC operations are contaminated with materials from 

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

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

defense research and development activities (References C002, P001 and P042). For example, 

MFC examined fuel specimens that were primarily irradiated in the EBR-II, which supported 

ongoing defense experiments conducted throughout the 30-year operating life of the reactor 

(1964–1994) (References P001, P071 and P144). The defense origin of the waste is adequately 

demonstrated based on waste comingling. 

Summary of Acceptable Knowledge Findings and Concerns

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

addition of Waste Stream ID-MFC-SOLID-RH during this T1 change evaluation. 

Acceptable Knowledge Approval

Based on the results of this evaluation, EPA approves the addition of Waste Stream ID-MFCSOLID-RH and finds that all requirements have been met. There are no changes to the AK T1 or 

T2 designations. Characterization of any new waste stream not approved under the baseline or 

subsequent T1 evaluations or addition of containers to an approved waste stream that requires 
10 

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

that were initiated during the baseline approval remain in effect. 

6.2 Radiological Characterization 

EPA examined the radiological process to assess the technical adequacy to support the addition 

of Waste Stream ID-MFC-SOLID-RH. 

Waste Characterization Element Description 

EPA evaluated the radiological characterization of INL-CCP RH Waste Stream ID-MFCSOLID-RH in terms of its technical adequacy, as supported by the program’s documents, 

procedures and controls, and the knowledge and understanding of the personnel involved in the 

RH waste characterization program. During this RH evaluation, the EPA team evaluated the 

following elements of the INL-CCP radiological characterization program: 

 Overall radiological characterization. 

 Collection and analysis of swipe samples. 

 Evaluation of measurement data to support the scaling factor development. 

 Development of DTC correlation and determination of radionuclides within each drum. 

 Adequacy of modeling 

 TRU and RH determinations. 

 Uncertainty analysis. 

Each of these is discussed in the sections that follow. 

Technical Evaluation 

EPA evaluated the adequacy of the radiological characterization process specific to Waste 

Stream ID-MFC-SOLID-RH, as described in CCP-RC-INL-541, Revisions 0 and 1, and 

supporting calculation packages. The EPA evaluation team evaluated the following aspects: 

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

and found them to be adequate. 

The radiological characterization process for Waste Stream ID-MFC-SOLID-RH uses sampling 

and analysis to derive cesium-137 (137Cs)-based scaling factors for each drum. INL-CCP 

developed a DTC correlation that allowed the determination of the radionuclides of interest 

based on gamma measurements of 137Cs. The EPA evaluation team prepared a flow diagram to 

accurately reflect this process, shown in Figure 1 below. EPA determined that the radiological 

characterization process for Waste Stream ID-MFC-SOLID-RH was technically adequate and 

appropriately documented. There were no concerns regarding the technical adequacy and 

documentation of the radiological characterization process for Waste Stream ID-MFC-SOLIDRH. 
11 

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

any new RH waste stream not approved to date or the addition of containers to Waste Stream IDMFC-SOLID-RH that requires a radiological characterization process different from what is 

documented in CCP-RC-INL-541, Revision 1, remains a T1 change. Similarly, any change to 

CCP-RC-INL-541 that requires CBFO approval remains a T2 change. 

(2) EPA found the sampling of this waste stream to be representative, technically adequate 

and appropriately documented. 

INL-CCP developed a sampling and analysis plan (SAP) (CCP-AK-INL-545D) to collect 

representative samples from the liners. All four liners were sampled because the waste had 

originated from fuel specimens that represented a variety of fuel types. 

A set of three composite swab samples was collected for each of the four liners. For the drum 

DD-51A, each of the three composite swab samples was obtained from the combination of three 

swab samples: one from the exposed interior surface of each of the drum’s bottles and one from 

the liner contents after they were emptied onto a sample tray. For drums QQ-36A, FF-32A and 

OO-25A, each of the three composite swab samples was obtained from the combination of four 

swab samples: one from the exposed interior surface of each of the drums’ bottles and one from 

the liner contents after they were emptied onto a sample tray. A total of 12 composite swab 

samples were collected. INL-CCP generated sampling BDRs to document the sampling activity 

and EPA evaluated these. EPA found that the sampling met the SAP’s overall objective of 

obtaining representative samples. There were no concerns regarding the representativeness of the 

sampling of containers in Waste Stream ID-MFC-SOLID-RH. EPA found that the analytical data 

to support the development of scaling factors were adequate for their intended use. 

The SAP for Waste Stream ID-MFC-SOLID-RH provided specific sampling guidelines, as 

discussed above. The three composite samples for each drum were submitted to Advanced 

Mixed Waste Treatment Project’s Analytical Chemistry Laboratory located at INL. The 

radiometric analyses included alpha spectrometry, gamma spectrometry, gas-flow proportional 

counting and liquid scintillation counting; spectrometric analysis (inductively-coupled plasma 

mass spectrometry) was also performed. INL-CCP generated analytical BDRs for each analytical 

technique and EPA reviewed them. 

INL-CCP examined the activities of the radionuclides measured and removed some from 

consideration. Specifically, INL-CCP determined that curium-242 (242Cm), 244Cm, and 245Cm 

were not reportable and the contributions of cobalt-60, 134Cs, europium-154 (154Eu), and 155Eu 

were determined to be less than 5% of the total gamma activity and therefore not reportable. 

There were no concerns regarding the adequacy of the radiometric and spectrometric data that 

INL-CCP used to support the development of radionuclide scaling factors for the containers in 

Waste Stream ID-MFC-SOLID-RH. 
12 

Figure 1. Radiological Characterization Flow Diagram for Waste Stream ID-MFCSOLID-RH (Lot 5A)

Model 1m dose rate using 

MicroShield® as a 

function of waste density 

to develop a 137Cs DTC 

correlation based on a 1-

Ci source of 137Cs

Measure 1-m dose rate at 0 ̊, 

90 ̊, 180 ̊ and 270 ̊ from each 

drum in the waste stream 

Determine 137Cs activity 

content in each drum

Sample waste using sampling 

plan 

Develop sampling plan to 

ensure adequate representation 

of wastes radionuclide 

contents

Samples are analyzed by the 

INL Analytical laboratory to 

determine radionuclide 

composition 

Review AK records to identify 

possible waste types that 

require unique scaling factors 

Review sampling results 

to determine if drums 

will require unique SFs 

Develop SFs unique to 

each grouping 

Apply relevant SFs to 

each drum to determine 

radionuclide content

Determine gamma 

emitters that contribute 

to 95% or greater of the 

dose rate

Determine uncertainties 

in the calculated 

activities 
13 

(3) EPA evaluated the scaling factor calculations found them to be adequate. 

Scaling factor generation is documented in INL-RH-148 and the calculations are demonstrated in 

the Microsoft Excel file “Lot 5A Sample Data”. Supplemental information is contained in the 

Post-Sampling Memo dated July 16, 2013. INL-CCP determined that 137Cs contributed at least 

95% of the 1-meter (m) dose rate.2

 Originally, INL-CCP intended to analyze all 12 samples and 

average them to develop a single set of scaling factors for the waste stream. However, INL-CCP 

determined that the mean and maximum to minimum ratios were unacceptable and they elected 

to combine the three results from each drum to develop drum-specific scaling factors, to 

minimize the uncertainty. EPA reviewed the documentation supporting the scaling factor 

calculations of and found it to be technically adequate and appropriately documented. There 

were no concerns regarding the technical development and documentation of scaling factors for 

this waste stream. 

(4) EPA evaluated the MicroShield® modeling and dose-to-curie execution and found them 

to be adequate. 

INL-CCP documented the radiological modeling that supported the DTC correlation in INL-RH150 and these calculations are demonstrated in the Microsoft Excel file “Lot 5A DTC 

Correlation”. INL-CCP modeled a 1-curie (Ci) source of 137Cs located in the very bottom of a 

30-gallon drum. INL-CCP also evaluated the “maximum” case in order to determine the upper 

bounds of the MicroShield® modeling uncertainty. EPA reviewed the assumptions used to model 

the waste configuration and found them to reasonably reflect the actual configuration in the 

drums. The MicroShield® modeling reflects the assumptions stated in the documentation. There 

were no concerns regarding the technical adequacy and documentation of the DTC modeling for 

the four containers in Waste Stream ID-MFC-SOLID-RH. 

INL-CCP executed DTC in accordance with CCP-TP-504, Revision 13, as documented in BDR 

No. INLRHDTC13005, which EPA evaluated. The BDR contained all appropriate elements, 

including the use of correct scaling factors for all four containers, and successful achievement of 

all measurement acceptance criteria. The BDR data validation was performed under CCP-TP504, Revision 14. There were no concerns regarding the execution of DTC for Waste Stream IDMFC-SOLID-RH. 

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

INL-CCP documented the RH determinations for Waste Stream ID-MFC-SOLID-RH drums on 

Radiological Survey Reports collected in October 2013. EPA reviewed the RH determinations 

for all four 55-gallon drums. All four drums had contact dose rates of greater than 200 millirem 

per hour (mrem/hr). Consistently, INL-CCP measured the highest dose rates at the bottom of the 

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

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

while technically incorrect, is commonly used. Additionally, gamma measurements which technically represent 

exposure in Roentgens (R) or milliRoentgens are commonly misstated in rem. In this report, the terms dose and dose 

rate are used in place of the technically correct term dose equivalent or dose equivalent rate, and the terms R and 

rem are used interchangably. The actual differences among these values for the purpose of this report are negligible. 
14 

container, which is to be expected given the configuration of the solidified liquids and debris. 

Three of the four drums had one-meter external dose rates in excess of 200 mrem/hr. The 

remaining container (DD-51A-1) had an average one-meter dose rate of 11.5 mrem/hr, which, 

while lower than the others, still qualified as RH waste. There are no concerns regarding Waste 

Stream ID-MFC-SOLID-RH meeting the criteria for RH TRU waste. 

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

DTC BDR No. INLRHDTC13005 lists all four drums from Waste Stream ID-MFC-SOLID-RH. 

INL-CCP found each container to have a TRU concentration greater than 100 nanocuries per 

gram. There are no concerns regarding Waste Stream ID-MFC-SOLID-RH drums meeting the 

criteria for TRU waste. 

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

and found them to be adequate. 

The development of total measurement uncertainty (TMU) for Waste Stream ID-MFC-SOLIDRH is based on the propagation of the contributions from various aspects of the radiological 

characterization process. These aspects are assumed to be independent; this independence allows 

them to be added in quadrature.3

 The TMU determination included uncertainty contributions of 

the following: 

 DTC correlation – waste density, MicroShield® code, and modeling uncertainties. 

 137Cs activity measurement – instrument and distance measurement uncertainties, and 

uncertainty in the dose contribution of other gamma-emitting radionuclides. 

 Scaling factor determination.

A general treatment of TMU for Waste Stream ID-MFC-SOLID-RH is presented in CCP-RCINL-541, Revision 1, section 7, and the detailed treatment of TMU is provided in Calculation 

Package INL-RH-151. The overall uncertainties are consistent with what EPA has observed for 

RH determinations at other RH TRU generator sites. Table 7-3 of CCP-RC-INL-541, Revision 1, 

provides examples of the TMU values for all reported radionuclides. There are no concerns 

regarding the technical adequacy and documentation of TMU for Waste Stream ID-MFCSOLID-RH. 

Summary of Radiological Characterization Findings and Concerns

EPA did not identify any radiological characterization-related findings or concerns relative to the 

addition of Waste Stream ID-MFC-SOLID-RH during this T1 change evaluation. 

 3

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

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

were simply added. For example, the TMU for 239Pu is derived by taking the square root of (0.7%)2

 plus (25.0%)2

plus (10.0%)2

 plus (5.6%)2, which equals 27.5% when added in quadrature, which is less than the value obtained by 

simply summing the individual uncertainty values (i.e., 41.3%, as shown in INL-RH-151 for Drum No. FF-32A). 
15 

Radiological Characterization Approval

Based on the results of this evaluation, EPA approves the addition of Waste Stream ID-MFCSOLID-RH. Based on this evaluation, there are no changes to the radiological characterization 

T1 or T2 designations. Characterization of any new waste stream not approved under the 

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

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

changes that were initiated during the baseline approval remain in effect. 

7.0 FINDINGS AND CONCERNS 

Summary of Findings and Concerns

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

Waste Stream ID-MFC-SOLID-RH during this T1 change evaluation. 

8.0 CONCLUSIONS 

Changes to Tiering 

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

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

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

Table 2 of the final report for EPA’s 2014 continued compliance inspection of INL-CCP (see 

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

in sections 6.1 and 6.2. 

Approval 

EPA concluded that the AK waste characterization process and radiological characterization 

approach used to characterize RH TRU Waste Stream ID-MFC-SOLID-RH are adequate, as 

evidenced by the records evaluated. There are no open issues relative to this T1 evaluation. 

Based on the results of this evaluation, EPA approves this T1 change to add Waste Stream IDMFC-SOLID-RH, consistent with the limitations specified in this report. INL-CCP may continue 

to characterize previously approved RH TRU waste consistent with the restrictions specified 

with the approvals listed in Appendix A to this report. 
A-1 

ATTACHMENT A 

APPROVAL SUMMARY FOR INL-CCP REMOTE-HANDLED WASTE 

CHARACTERIZATION PROGRAM 

Approved Activity EPA Inspection Number, 

Approval Dates EPA Docket Number 

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

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

T1 Change – Approval of WIPP Waste Information 

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

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

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

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

T1 Change – Approval of High-Range Gamma Probe 

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

T1 Change – Approval of Visual Examination 

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

T1 Change – Addition of Twelve Containers to Waste 

Stream ID-ANLE-S5000 and Addition of Waste 

Stream ID-HFEF-S5400-RH 

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Addition of Lot 1B to Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

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

T1 Change – Addition of Lot 4A to Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Addition of Lot 2 to Waste Stream 

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

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

T1 Change – Approval of Waste Stream ID-EBRS5000 April 16, 2014 A-98-49; II-A4-183 

T1 Change – Addition of Lot 5C to Waste Stream 

ID-HFEF-S5400-RH July 15, 2014 A-98-49; II-A4-185 

2014 Continued Compliance Inspection July 15, 2014 A-98-49; II-A4-190 
B-1 

ATTACHMENT B 

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION 

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

Objectives, Scott Smith, August 31, 2005 

C092, Argonne National Laboratory Intra-Laboratory Memo to M.E. Vaughn, re: TRU Sample 

Waste, W.R. Sovereign, June 30, 1987 

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

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

Analytical Laboratory Operations and Waste Management Information, Scott Smith and Carrie 

Johnson, April 15, 2008 

C4109, Argonne National Laboratory Intra-Laboratory Memo to R. Pohto, re: Disposal of Jr. 

Cave Waste Using the Pneumatic Transfer Cask, AL-7 at EBR-II RSWF, W.R. Sovereign, 

October 28, 1976 

C4112, Waste Material Parameter Memo, ID-MFC-SOLID-RH, Scott Smith, Revision 0, August 

13, 2010, and Revision 1, January 14, 2013 

C465, Evaluation and Summary of the Process Work Sheets (PWS), Carrie Johnson, Revision 1, 

May 27, 2009 

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

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

C758, Lot 5A Drums, Gregory Smith, December 6, 2012 

Cask Sealed Container Assessments, Westinghouse, U279-CCP-AK-INL-590, no date 

CCP-AK-INL-540, Central Characterization Program Remote-Handled Transuranic Radiological 

Characterization Technical Report for Remote-Handled Transuranic Debris Waste from the 

Materials and Fuels Complex at the Idaho National Laboratory, Waste Streams: ID-MFC-S5400-

RH and ID-MFC-SOLID-RH, Revision 3, February 7, 2013, and Revision 4, May 5, 2014 

CCP-AK-INL-545D, Central Characterization Program Sampling and Analysis Plan for the 

Materials and Fuels Complex (MFC) Analytical Laboratory Sampling of Remote-Handled 

Solidified Waste at the Idaho National Laboratory (INL), Waste Stream ID-MFC-SOLID-RH, 

Revision 1, February 15, 2013 

CCP-RC-INL-541, Central Characterization Program Remote-Handled Transuranic Radiological 

Characterization Technical Report for Remote-Handled Transuranic Debris Waste from the 

Materials and Fuels Complex at the Idaho National Laboratory, Waste Stream ID-MFC-SOLIDRH, Revision 0, October 24, 2013, and Revision 1, September 2, 2014 
B-2 

CCP-RC-INL-542, Central Characterization Program RH TRU Certification Plan f0r 40 CFR 

Part 194 Compliance and Confirmation Test Plan for INL Waste Stream: ID-MFC-S5400-RH 

and ID-MFC-SOLID-RH, Revision 1, March 23, 2011 

CCP-TP-005, Revision 26, CCP Acceptable Knowledge Documentation, Attachment 6 – Waste 

Form, Waste Material Parameters, Prohibited Items, and Packaging – Example Form, Waste 

Stream ID-MFC-SOLID-RH, October 28, 2013, and attached memoranda, August 13, 2010, and 

January 14, 2013 

CCP-TP-504, Central Characterization Program DTC Survey Procedure for Remote Handled 

Transuranic Waste, Revision 13, September 17, 2012, and Revision 14, July 9, 2013 

Configuration of Repackaged Bettis (Lot 3) Remote-Handled Transuranic Waste Cans, Idaho 

Cleanup Project, EDF-10441, January 28, 2013 

DR011, Acceptable Knowledge Source Document Discrepancy Resolution, Waste Stream IDMFC-SOLID-RH, Revision of Summary Category Group and Waste Matrix Code, S. Smith, 

DR011, January 21, 2013 

Dose-To-Curie BDR No. INLRHDTC13005 

INL-RH-148, Scaling Factor Development for Lot 5A Drums, Revision 0 and associated 

spreadsheet, July 19, 2013 

INL-RH-149, Determination of Lot 5A Reportable Radionuclides, Revision 0 and associated 

spreadsheet, July 20, 2013 

INL-RH-150, INL Lot 5A Cs-137 DTC Correlation, Revision 0 and associated spreadsheet, July 

20, 2013 

INL-RH-151, INL Lot 5A Uncertainty Analysis, Revision 0 and associated spreadsheet, July 22, 

2013 

INL-RH-152, DTC Spreadsheet Lot 5A Analytical Laboratory Waste, Revision 0 and associated 

spreadsheet, October 22, 2013 

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

West, H.F. McFarlane, ANL-NT-192, November 2001 

P042, Analytical Laboratory Safety Analysis Report Idaho National Laboratory, W0660-0055-

KH, Revision 4, April 6, 2006 

P055, Argonne-West Criticality Hazards Control Statement, W.P. Keeney, ID-CHCS-A11, 

Revision 7, May 7, 1984 

P060, ANL-West Remote-Handled Transuranic Waste Certification Plan Argonne National 

Laboratory – West, W0001-0898-ES-00, July 5,1988 
B-3 

P071, Plant Description, Administration and General Policy, GET/PD, August 1985 

P075, Waste Preparation Procedure for Analytical Laboratory Waste Disposal, William R. 

Sovereign, AW-AL-WM-002, June 1988 

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

Hampson, K.R. Ferguson, E. Hylsky, ANL-7959, LMFBR Fuel Handling (UC-79g), February 

1975 

P4071, ALP-7 Data Package for ANL-W On-Site Transfers, E.M. Franklin, W0085-0005-ES-00, 

Revision 0, April 2, 1999 

Post-Sampling Memorandum, Analysis of Sample Data for INL Lot 5A, Jene Vance to Irene 

Quintana, July 16, 2013 

Radiochemistry BDR No. ALD13003A, July 9, 2013 

Radiochemistry BDR No. ALD13003B, July 9, 2013 

Radiochemistry BDR No. ALD13003G, July 9, 2013 

Radiochemistry BDR No. ALD13003I, July 9, 2013 

Radiochemistry BDR No. ALD13003L, July 9, 2013 

Radiological Survey Report, Drum Nos. QQ-36A-1, OO-25A-1, FF-32A-1 and DD-51A-1, 

October 31, 2013 

RTR BDR No. INLRHRTR13005, April 1, 2013, revised June 5, 2013 

U140, X421 Radiochemistry, January 12, 1988 

U218, Analytical Research and Development Program Paper, Re: Determination of Burnup on 

Nuclear Fuels, R.P. Larsen, ANL-6900, no date 

U223, The Radiochemical Determination of Americium, ANL-CEN, Am-LaF3-α, July 24, 1959 

U224, The Spectrophotometric Determination of Cerium in Ammonium Tartrate, ANL-CEN, 

January 13, 1961 

U225, Radiochemical Determination of Cerium by Liquid-Liquid Extraction, ANL-CEN, Ce-FP, 

July 1960 

U226, Volumetric Determination of Cerium with EDTA, ANL-CEN, Ce-Vol, July 2, 1959 

U227, Volumetric Determination of Lanthanum with EDTA, February 26, 1959 

U228, Separation of Neptunium from Fission Products, ANL-CEN, NP-γ, February 26, 1963 
B-4 

U229, Fission Product Cesium, Cs, January 1959 

U230, Determination of Plutonium by Hexone Extraction and Alpha Counting, February 25, 

1963 

U231, Separation of Plutonium by Ferric Hydroxide – Lanthanum Fluoride Precipitation, PuFe(OH)3-LaF3-α, January 1958 

U232, Plutonium by Lanthanum Fluoride, Pu-A, no date 

U233, Procedure Manual: A Summary of Uranium Analyses, ANL-CEN, U-Sum, February 1959 

U234, Water Soluble Uranium Determination, W.S.U, July 16, 1956 

U235, Spectrophotometric Determination of Thorium, ANL-CEN, Th-C, October 1959 

U236, Colorimetric Determination of Zirconium with Alizarin-Red-S, ANL-CEN, Zr-C, 

Revision 0, October 1958 and Revision 1, July 6, 1960 

U237, Volumetric Determination of Thorium with EDTA, ANL-CEN, Th-V, July 1960 

U238, Volumetric Determination of Zirconium with EDTA, ANL-CEN, Zr-Vol, May 20, 1959 

U239, Fission Product Zirconium, ANL-CEN, Zr-F.P, February 23, 1959 

U240, Fission Product Strontium (and Barium), Sr-Ba-FP, January 1959 

U288, RH TRU Drum Repackaging Datasheets for Waste Stream ID-MFC-SOLID-RH, Various 

dates 

U4059, RH TRU RTR Prescreen for Repackaging/AK Worksheets, C.G. Davis, November 26, 

2012 

U483, HFEF Transuranic Waste Can Log Cards, no date 

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

Related Documents, no date 

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

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

includes HFEF PWS Log, Subassemblies, PWS Nos., and PCN Nos., Various authors, document 

Nos. and dates 

U552, Compilation of MFC Liner Documents, Various authors, document Nos. and dates 

U998, Lot 5A Fast Scan Videos, November 26, 2012