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

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT

EPA TIER 1 EVALUATION OF THE CENTRAL CHARA CTERIZATION PROGRAM REMOTE-HANDLED TRANSURANIC WA STE CHARACTERIZATION PROGRAM FOR THE IDAHO NATI ONAL 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 2014i TABLE OF CONTENTS Section Page Abbreviations and Acronyms .................................................................................................... ..... ii 1.0 Introduction .................................................................................................................. ........4 2.0 Purpose of Tier 1 Evaluations ..............................................................................................5 3.0 Purpose of This Report ........................................................................................................ 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 Str eam ID-MFC-SOLID-RH (Lot 5A) ...................................................................................................................... .................. 12

ATTACHMENTS Attachment A: Approval Summary for IN L-CCP RH Waste Char acterization Program Attachment B: List of Documents Reviewed by EPA during T1 Evaluationii 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 Scra p and Waste Facility RTR real-time radiography SAP sampling and analysis plan SCG summary category group SF scaling factor SNF spent nuclear fueliii T1 Tier 1 T2 Tier 2 TMU total measurement uncertainty TRU transuranic U uranium WIPP Waste Isolation Pilot Plant WMP waste material parameter Zr zirconium4 1.0 INTRODUCTION This report supports the U.S. E nvironmental 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 characte rization program at the U.S. Department of Energy’s (DOE’s) Idaho National Laboratory (IN L). In January 2007, EPA approved the Central Characterization Program (CCP) 1 to characterize RH TRU wa ste at INL. Using the EPAapproved waste characterization processes discusse d 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 inspectio ns of INL-CCP in May 2013 and May 2014, concluding in both instances that INL-CCP con tinues to adequately implement the RH TRU waste characterization processes, procedures an d 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 (CBF O) 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 ch aracterization 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 ev aluation. However, EPA raised several issues with documenta tion requiring INL-CCP to revise several reports and various calculation packages duri ng the evaluation. EPA re viewed the revised documents and concluded that the revisions address EPA’s issues. Attach ment B is a list of all documentation reviewed, including batch data reports (B DRs) 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 base line approval and modified subsequently as needed as a result of EPA’s approval of prev ious INL-CCP RH T1 change requests and EPA’s annual continued compliance inspections. The tier ing designations presented in Table 2 of the final report for EPA’s 2014 continued co mpliance inspection of INL-CCP (see EPA Docket No. A-98-49; II-A4-190; July 15, 2014) remain in effect and are listed as app licable in sections 6.1 and 6.2 of this report. Based on the information provided, EPA conclude d that the INL-CCP’s plan to use the EPAapproved system of controls to characterize th e four containers of Waste Stream ID-MFCSOLID-RH was acceptable and appropriate. These f our containers of TRU waste in Lot 5A are the subject of this T1 report, but EPA’s appr oval also includes any a dditional drums that are added to Waste Stream ID-MFC-SOLID-RH in the future, provided they are characterized using the processes used for characterizi ng the four containers in Lot 5A as discussed in this report.

1 The Central Characterization Program was formerly known as the Central Char acterization 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 act ivities from the date of the site’s baseline inspection must be reported to and, if a pplicable, approved by EPA according to the tiering requirements set forth in 40 CFR 194.8 regulatio ns 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 perf orm a single baseline inspection of a TRU waste generator site’s waste characteri zation program. The purpose of EPA’s baseline inspection is to approve the site’s waste char acterization program, based on the demonstration that the program’s components, with applicable conditions and limitations, can adequately characterize TRU wastes and comply with the re gulatory requirements imposed on TRU wastes destined for disposal at the WIPP. Following EPA’s baseline approval, EPA is author ized to evaluate and approve changes, if necessary, to the site’s approved waste char acterization program by conducting additional inspections under the authorit y 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 in spection reports and subsequent T1 evaluation reports. When evaluating proposed T1 changes fo r 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 evalua tion of a T1 change to add Waste Stream IDMFC-SOLID-RH to the EPA-approved waste charac terization program. This report presents the technical basis for and results of EPA’s appr oval decision. EPA’s approv al 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 pro cess 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 asse ssed during this evaluation.6 5.0 EVALUATION PERSONNEL

The EPA evaluation team member s 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 informati on 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 solu tions generated by radiochemical analysis of irradiated fuel and test materi als that were created during sepa ration, purification and preparation of sample solutions for mass spectroscopic anal ysis 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 compos ed 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 th e 30-gallon drum, metal sling and hook, and drum lifting bag from repack aging operations. The waste contains fissile materials and mixed fission products from fuel asse mblies 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 St ream 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 solu tions) 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-CC P personnel emptied each of the bottles from the various liners onto sampling trays, sampled the wa ste, 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 Evaluato r – 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 Charact erization, SC&A7 gallon drums. INL-CCP did not comingle the co ntents of each liner and placed the sampling debris, including the metal sampling tra y, in the corresponding 30-gallon drum. Radiography verified that the 30 -gallon drum contents do not in clude bracing and that INL-CCP placed the waste in the drum without special pa ckaging 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-IN L-540, Revisions 3 and 4; CCP-RC-INL-541, Revisions 0 and 1; CCP-AK-IN L-542, Revision 1; and CCP-AK -INL-545D, Revision 1, to EPA for review. EPA’s review identif ied several technical issues th at necessitated the revision of several reports and documents. INL-CCP provi ded revised documentation during the T1 evaluation.

The DOE documents that EPA reviewed for th is evaluation, including BDRs and calculation packages, are cited in different sections througho ut the report and are lis ted 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 techni cal 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 wast e generation and radiological and physical characteristics.

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

 Verification that the subject wa ste 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, Revisi on 3), certification plan (CCP-AK-INL-542, Revision 1) , and associated source documents. EPA identified several areas of the AKSR that required clarificati on or correction. INL-CCP revised the AKSR to include the correct waste stream definiti on 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 St ream 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. Referen ce C4112, Revision 0, with attached August 13, 2010, memorandum provides original pre-repa ckaging waste material parameter (WMP) estimates for the waste in the 16-inch liners, an d concludes that approxim ately 55% of the waste was composed of inorganic solidi fied material (by weight). Ho wever, INL-CCP later modified the waste stream’s SCG after re packaging the lin ers into drums. Reference DR011 states that “the waste stream was assumed to be Su mmary Category Group S3000...Repackaging of the RSWF liners was necessary to characterize and certify the waste for WIPP. However, following repackaging (Reference U288) a nd real-time radiography (RTR) fa st scan (References U998 and U4059), and with the addition of secondary wast e expected from sampling operations (see CCPAK-INL-545D), the waste stream will be pre dominantly (more than 50 percent by volume) Summary Category Group S5000, Debris.” Re ferences DR011 and C4112, Revision 1 with modified memorandum dated January 2013, provide recalculated WMPs a nd 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 ve rify 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 t ube, wire, knives, glass bottles, rubber stoppers, scrap plastic, plastic bottles and absorbent. (2) EPA examined the waste stream determin ation 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 radiologi cal properties. As described in the overview portion of section 6.0, above, INL generated th e waste in Waste Str eam 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 (R eferences C758, DR011, U998 and U4059). The radiological composition of the waste is well docu mented in AK records, and INL-CCP obtained drum-specific information during its radiochemist ry sampling program as documented in section9 6.2, below. The commonality of waste generati on 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 thr ough radiological sampling and analysis, dose-to-curie (DTC), and radiogra phy, 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 wast e stream and found it to be adequate. The WIPP Land Withdrawal Act prohibits the di sposal 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 Labo ratory hot cell operations , and may contain test residues, test materials, and the resultant test fragments from fuel pin test specimens, including irradiated pin fragments. Analy tical Laboratory operations consiste d of destructiv e analysis and examination of irradiated fuel and sample ma terials that did not i nvolve 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 in tact SNF or HLW. (5) EPA examined the information supporting that th e waste stream is defense in origin and found it to be adequate. AK indicates that while MFC personnel manage d non-defense material in the Analytical Laboratory, TRU wastes generate d by MFC operations are contam inated 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 primar ily 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 defe nse origin of the wa ste is adequately demonstrated based on waste comingling. Summary of Acceptable Knowledge Findings and Concerns The EPA evaluation team did not identify any AK-re lated findings or concerns relative to the addition of Waste Stream ID-MFC-SOLID-R H during this T1 ch ange 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 requ irements have been met. There are no changes to the AK T1 or T2 designations. Characterizati on of any new waste stream not approved under the baseline or subsequent T1 evaluations or a ddition of containers to an appr oved waste stream that requires10 changing the established radionucli de 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 characteriza tion of INL-CCP RH Waste Stream ID-MFCSOLID-RH in terms of its te chnical adequacy, as supported by the program’s documents, procedures and controls, and th e knowledge and understanding of the personnel involved in the RH waste characterization progr am. During this RH evaluation, the EPA team evaluated the following elements of the INL-CCP ra diological characterization program:

 Overall radiological characterization.

 Collection and analysis of swipe samples.

 Evaluation of measurement data to suppor t the scaling factor development.

 Development of DTC correlation and determin ation 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 evalua tion team evaluated the following aspects: (1) EPA evaluated the overall radiological char acterization process a nd 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 ( 137 Cs)-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 137 Cs. 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 concer ns regarding the tec hnical adequacy and documentation of the radiological characteriza tion process for Waste Stream ID-MFC-SOLIDRH.11 Consistent with the T1 and T2 designations that were establis hed during the baseline approval, any new RH waste stream not approv ed to date or the addition of containers to Waste Stream IDMFC-SOLID-RH that requires a ra diological characterization pro cess different from what is documented in CCP-RC-INL-541, Revision 1, remain s 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 re presented a variety of fuel types. A set of three composite swab samples was collec ted 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 su rface of each of the drum’s bottles and one from the liner contents after they were emptied on to a sample tray. For drums QQ-36A, FF-32A and OO-25A, each of the three composite swab sample s was obtained from the combination of four swab samples: one from the exposed interior su rface 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 sa mpling BDRs to document the sampling activity and EPA evaluated these. EPA found that th e sampling met the SAP’s overall objective of obtaining representative samples. There were no concerns regardi ng the representativeness of the sampling of containers in Waste Stream ID-MFC-SOLID-RH. EPA f ound that the analytical data to support the development of scaling factor s were adequate for their intended use.

The SAP for Waste Stream ID-MFC-SOLID-R H 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 spectrome try, gamma spectrometry, gas-flow proportional counting and liquid scintillation counting; spectrometric analys is (inductively-coupled plasma mass spectrometry) was also performed. INL-CCP ge nerated analytical BDRs for each analytical technique and EPA reviewed them.

INL-CCP examined the activities of the radi onuclides measured and removed some from consideration. Specifically, INL-CCP determined that curium-242 ( 242 Cm), 244 Cm, and 245 Cm were not reportable and the contributions of cobalt-60, 134 Cs, europium-154 ( 154 Eu), and 155 Eu were determined to be less than 5% of the to tal gamma activity and th erefore not reportable. There were no concerns regarding the adequacy of the radiometric and spectrometric data that INL-CCP used to support the development of radi onuclide scaling factors for the containers in Waste Stream ID-MFC-SOLID-RH.12 Figure 1. Radiological Characterization Fl ow Diagram for Waste Stream ID-MFCSOLID-RH ( Lot 5A ) Model 1m dose rate using MicroShield ® as a function of waste density to develop a 137 Cs DTC correlation based on a 1- Ci source of 137 Cs Measure 1-m dose rate at 0  ̊ , 90  ̊ , 180  ̊ and 270  ̊ from each drum in the waste stream

Determine 137 Cs 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 activities13 (3) EPA evaluated the scaling factor calc ulations 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 137 Cs 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 mini mum 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 ap propriately documented. There were no concerns regarding the technical development and documen tation of scaling factors for this waste stream. (4) EPA evaluated the MicroShield ® modeling and dose-to-curi e execution and found them to be adequate. INL-CCP documented the radiological modeling th at 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 137 Cs located in the very bottom of a 30-gallon drum. INL-CCP also evaluated the “m aximum” 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 th e actual configuration in the drums. The MicroShield ® modeling reflects the assumptions stated in the documentation. There were no concerns regarding the technical ade quacy and documentation of the DTC modeling for the four containers in Wast e 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 ev aluated. The BDR contained all appropriate elements, including the use of correct scaling factors for al l four containers, and su ccessful achievement of all measurement acceptance criteria. The BDR data validation was performed under CCP-TP504, Revision 14. There were no concerns regardi ng 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 Oct ober 2013. EPA reviewed the RH determinations for all four 55-gallon drums. All four drums ha d contact dose rates of greater than 200 millirem per hour (mrem/hr). Consistently, INL-CCP measur ed 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 expresse d 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 exp ected given the configuration of the solidified liquids and debris. Three of the four drums had one-meter extern al dose rates in excess of 200 mrem/hr. The remaining container (DD-51A-1) had an averag e one-meter dose rate of 11.5 mrem/hr, which, while lower than the others, still qualified as RH waste. There are no c oncerns regarding Waste Stream ID-MFC-SOLID-RH meeting the criteria for RH TRU waste. (6) EPA evaluated the transuranic determinat ions 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 c oncentration greater than 100 nanocuries per gram. There are no concerns regarding Waste Stream ID-MFC-SOLID-R H drums meeting the criteria for TRU waste. (7) EPA evaluated the technical basis and docum entation of total measurement uncertainty and found them to be adequate. The development of total measurement uncerta inty (TMU) for Waste Stream ID-MFC-SOLIDRH is based on the propagation of the contributio ns from various aspects of the radiological characterization process. These aspects are assume d 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.

 137 Cs activity measurement – in strument 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 StreamID-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 ar e consistent with what EPA has observed for RH determinations at other RH TRU generato r 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 docum entation of TMU for Waste Stream ID-MFCSOLID-RH. Summary of Radiological Characterization Findings and Concerns EPA did not identify any radiologi cal characterization-related findings or concerns relative to the addition of Waste Stream ID-MFC-SOLID-R H during this T1 ch ange evaluation.

3 Adding in quadrature is a standard statistical techniqu e 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 239 Pu 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 radiol ogical characterization T1 or T2 designations. Charact erization 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 sca ling factors remains a T1 change. T1 and T2 changes that were initia ted during the baseline a pproval remain in effect.

7.0 FINDINGS AND CONCERNS Summary of Findings and Concerns The EPA inspection team did not identify any findi ngs or concerns relati ve to the addition of Waste Stream ID-MFC-SOLID-RH duri ng this T1 change evaluation.

8.0 CONCLUSIONS Changes to Tiering As a result of this evaluation, EPA did not ma ke any changes to the INL-CCP RH T1 and T2 designations that were establis hed during the baseline approval a nd modified during subsequent T1 evaluations and continued compliance inspect ions. The tiering designations presented in Table 2 of the final report for EPA’s 2014 con tinued compliance inspection of INL-CCP (see EPA Docket No. A-98-49; II-A4-190; July 15, 2014) rema in in effect and are listed as applicable in sections 6.1 and 6.2. Approval

EPA concluded that the AK wast e characterization process and radiological characterization approach used to characterize RH TRU Wast e Stream ID-MFC-SOLID-RH are adequate, as evidenced by the records evalua ted. There are no open issues re lative to this T1 evaluation. Based on the results of this evaluation, EPA appr oves this T1 change to add Waste Stream IDMFC-SOLID-RH, consistent with the limitations sp ecified in this report. INL-CCP may continue to characterize previously appr oved RH TRU waste consistent w ith 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-A4-175T1 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-A4-190B-1 ATTACHMENT B

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION C002, Interview of Pam Crane, Analytical Labor atory, re: Analytical La boratory Mission and Objectives, Scott Smith, August 31, 2005 C092, Argonne National Laboratory Intra-Laborat ory 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 Ma nagement 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 Ca sk, 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 In tra-Laboratory Memo to Distri bution, 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, We stinghouse, U279-CCP-AK-INL-590, no date CCP-AK-INL-540, Central Characterization Program Remote-Handled Transuranic Radiological Characterization Technical Report for Remote-H andled Transuranic Debris Waste from the Materials and Fuels Complex at the Idaho Na tional Laboratory, Waste Streams: ID-MFC-S5400- RH and ID-MFC-SOLID-RH, Revision 3, Fe bruary 7, 2013, and Revision 4, May 5, 2014 CCP-AK-INL-545D, Central Characterization Progr am Sampling and Analysis Plan for the Materials and Fuels Complex (MFC) Analytic al Laboratory Sampling of Remote-Handled Solidified Waste at the Idaho National Laborat ory (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-H andled Transuranic Debris Waste from the Materials and Fuels Complex at the Idaho Na tional Laboratory, Waste Stream ID-MFC-SOLIDRH, Revision 0, October 24, 2013, a nd Revision 1, September 2, 2014B-2 CCP-RC-INL-542, Central Characterization Progra m RH TRU Certification Plan f0r 40 CFR Part 194 Compliance and Confirmation Test Pl an 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 Knowle dge 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, Septem ber 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 Categor y Group and Waste Matrix Code, S. Smith, DR011, January 21, 2013

Dose-To-Curie BDR No. INLRHDTC13005 INL-RH-148, Scaling Factor Development for Lo t 5A Drums, Revision 0 and associated spreadsheet, July 19, 2013 INL-RH-149, Determination of Lot 5A Reportabl e Radionuclides, Revision 0 and associated spreadsheet, July 20, 2013 INL-RH-150, INL Lot 5A Cs-137 DTC Correlation, Re vision 0 and associated spreadsheet, July 20, 2013 INL-RH-151, INL Lot 5A Uncertainty Analysis, Re vision 0 and associated spreadsheet, July 22, 2013 INL-RH-152, DTC Spreadsheet Lot 5A Analytical Laboratory Wast e, Revision 0 and associated spreadsheet, October 22, 2013 P001, The Defense Programs Origin of Transura nic 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 5,1988B-3 P071, Plant Description, Ad ministration and General Policy, GET/PD, August 1985 P075, Waste Preparation Procedure for Analyt ical Laboratory Waste Disposal, William R. Sovereign, AW-AL-WM-002, June 1988 P144, Hot Fuel Examination Facility/North, Fa cility 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. Fra nklin, 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, Apr il 1, 2013, revised June 5, 2013 U140, X421 Radiochemistry, January 12, 1988 U218, Analytical Research and Development Pr ogram 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 La nthanum with EDTA, February 26, 1959 U228, Separation of Neptunium from Fission Products, ANL-CEN, NP- γ , February 26, 1963B-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 Hydrox ide – Lanthanum Fluor ide Precipitation, PuFe(OH)3-LaF3- α , January 1958 U232, Plutonium by Lanthanum Fluoride, Pu-A, no date U233, Procedure Manual: A Summary of Uraniu m 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 Zirconi um with Alizarin-Red-S, ANL-CEN, Zr-C, Revision 0, October 1958 and Revision 1, July 6, 1960 U237, Volumetric Determination of Thoriu m with EDTA, ANL-CE N, Th-V, July 1960 U238, Volumetric Determination of Zirconi um with EDTA, ANL-C EN, 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 fo r Waste Stream ID-MFC-SOLID-RH, Various dates U4059, RH TRU RTR Prescreen fo r Repackaging/AK Worksheets, C.G. Davis, November 26, 2012 U483, HFEF Transuranic Waste Can Log Cards, no date U484, Radioactive Scrap & Waste Storage/Disp osal Request and Aut horization 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 Sh eets 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, Va rious authors, document Nos. and dates U998, Lot 5A Fast Scan Videos, November 26, 2012