DOCKET NO: A-98-49, II-A4-72

WASTE CHARACTERIZATION INSPECTION REPORT

EPA BASELINE INSPECTION NO. EPA-INL-CCP-RH-6.06-8

OF THE CENTRAL CHARA CTERIZATION PROJECT

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION

PROGRAM AT THE IDAHO NATIONAL LABORATORY June 12–16, and August 9 and 29, 2006

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air Center of Federal Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

January 2007i TABLE OF CONTENTS

Section Page

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

2.0 Purpose of Inspections ..................................................................................................... ... 5

3.0 Purpose of This Report ..................................................................................................... .. 6

4.0 Scope of Inspection........................................................................................................ ..... 7

5.0 Inspection-Related Definitions ........................................................................................... 8

6.0 Personnel.................................................................................................................. ........... 8
6.1 EPA Inspection Team ............................................................................................. 8

6.2 Personnel Contacted................................................................................................ 9

7.0 Performance of the Inspection ............................................................................................ 9

8.0 Technical Waste Characterization Areas.......................................................................... 11

8.1 Acceptable Knowledge ......................................................................................... 11

8.2 Radiological Characterization............................................................................... 36

8.3 Visual Examination............................................................................................... 64

8.4 Real Time Radiography ........................................................................................ 69

8.5 WIPP Waste Information System ......................................................................... 69

9.0 Response to Comments..................................................................................................... 69

10.0 Summary of Results........................................................................................................ .. 70
10.1 EPA Findings and Concerns ................................................................................. 70

10.2 Conclusions........................................................................................................... 70

11.0 References................................................................................................................ ......... 73ii ATTACHMENTS

Attachment A.1 Acceptable Knowledge (AK) Checklist Attachment A.2 Dose To Curie (DTC) Checklist Attachment A.3 Visual Examination (VE) Checklist

Attachment B.1 EPA Inspection Issue Tracking Form, EPA Issue No.

INL-CCP-RH-VE-06-001F/INL-CCP -RH-VE-06-001CR, Revision 1 Attachment B.2 EPA Inspection Issue Tracking Form, EPA Issue No.

INL-CCP-RH-VE-06-002CR Attachment B.3 EPA Inspection Issue Tracking Form

, EPA Issue No.

INL-CCP-RH-VE-06-003CR/ INL-CCP-RH-VE-06-003F Attachment B.4 EPA Inspection Issue Tracking Form

, EPA Issue No. INL-CCP-RH-AK-06-005CR, Revision 1 Attachment B.5 EPA Inspection Issue Tracking Form, EPA Issue No. INL-CCP-RH-AK-06-006CR, Revision 1 Attachment B.6 EPA Inspection Issue Tracking Form, EPA Issue No. INL-CCP-RH-AK-06-007CR, Revision 1 Attachment B.7 EPA Inspection Issue Tracking Form, EPA Issue No. INL-CCP-RH-AK-06-008CR, Revision 1 Attachment B.8 EPA Inspection Issue Tracking Form, EPA Issue No.

INL-CCP-RH-RH-VE-06-009C

Attachment C Public Comments and EPA’s Responses1 1.0 EXECUTIVE SUMMARY

In accordance with 40 CFR 194.8(b), the U.S. Envi ronmental Protection Agency (EPA or the Agency) conducted Baseline Inspection N o. EPA-INL-CCP-RH-6.06-8 of the Central Characterization Project’s (CCP) waste characterization (WC) program for remote-handled (RH) transuranic (TRU) waste at the U.S. Departme nt of Energy’s (DOE) Idaho National Laboratory (INL) located outside of Idaho Fa lls, Idaho. EPA conducted a base line inspection of the site’s program to characterize RH TRU wa stes proposed for disposal in the Waste Isolation Pilot Plant (WIPP). This inspection occurred in three segments:

• On-site inspection at INL on June 12–16, 2006

• Follow-up inspection on August 9, 2006, at DOE’s Carlsbad Area Fiel d Office (CBFO), for the purpose of assessing mass spectrometr y data used to support one element of the INL RH WC program

• Follow-up inspection at CBFO on August 29, 2006, for the purpose of resolving open issues from the previous two inspections

Additionally, there were ongoing technical discussions during July and August 2006 between members of the EPA inspection team and CBFO technical contractors related to technical aspects of the INL-CCP RH WC program.

On November 2006, EPA issued a Federal Regi ster (FR) notice (71 FR 65488, November 8, 2006) announcing the proposed approval of the RH waste characterization (WC) program implemented at INL by CCP. The FR notice ope ned a 45-day comment period to solicit public comment on the proposed approval of INL-CCP ’s RH WC program and the INL Baseline Inspection Report (EPA Air Docket A98- 49, II-A4-69). The comment period ended December 26, 2006. EPA received one set of public comments. (See EPA Docket ID No. EPA-HQ-OAR-2006-0881). EPA evaluated and responded to the public comments (see Attachment C of this report), and made ch anges to the proposed approval decision, where appropriate. This report discusses EPA’s appr oval of the RH waste characterization (WC) program implemented at INL by CCP.

EPA must verify compliance with 40 CFR 194.24 be fore waste may be disposed of at the WIPP, as specified in Condition 3 of the Agency’s cert ification of the WIPP’s compliance with disposal regulations for TRU radioactive waste (63 Federal Register (FR) 27354 and 27405, May 18, 1998). This was the first inspection of RH WC ac tivities conducted by EPA at INL-CCP. EPA Baseline Inspection No. EPA-INL-CCP-RH-6.06 -8 was performed in accordance with the provisions of 40 CFR 194.8(b), as issued in a July 16, 2004, FR notice (Vol. 69, No. 136, pp. 42571–42583). The purpose of the INL-CCP RH WC inspection was to evaluate the adequacy of the site’s WC programs for one (1) RH debris waste stream to be disposed of at the WIPP. The activities examined during the insp ection and approved for implementation included the following:2 • Acceptable knowledge (AK) fo r RH retrievably-stored TRU debris waste (S5000).

• Radiological characterization as described in this report fo r RH retrievably-stored TRU debris waste (S5000).

• Visual examination (VE) of audio/video me dia for RH retrievably-stored TRU debris waste (S5000) containers.

EPA’s inspection team determined that INL-CCP’s RH WC program activities were technically adequate. EPA is approving the INL-CCP RH WC program in the configuration observed during the baseline and follow-up inspections, desc ribed in this report, and documented in detail

in the checklists in Attachment A. The approval includes the following:

(1) The AK process for RH retrievably-stored TRU debris in one wa ste stream, designated by INL as INL Waste Stream No. ID-ANLE- S5000, Lots 1 through 20, which are defined by INL-CCP as a debris waste st ream in CCP-AK-INL-500, Revision 3

(2) The radiological characterization pro cess using dose-to-curie (DTC) and modelingderived scaling factors for assigning radionuc lide values to one RH waste stream for which the scaling factors are applicable, as described in CCP-AK-INL-501, Revision 1

(3) The VE of audio/video media proce ss used for a total of nineteen (19) retrievably-stored

RH debris waste drums included in three batch data reports (BDRs) – BDR Nos. RHINLVE60001, RHINLVE60002, and RHINLVE 60003. (See Section 8.3 for further explanation.)

During the comment period for the proposed appr oval, INL-CCP provided EPA with additional information related to an improved VE technique as well as an additional VE BDR. (See EPA’s response to Comments Nos. 8 and 12 in Attachme nt C of this report.) EPA has begun this

evaluation and the results of the Tier 1 (T1) evaluation wi ll be provided upon completion separately. If appropriate, EPA could expand its approval to the VE process evaluated as a T1 change.

EPA is not approving the WIPP Waste Information System (WWIS) for entry and tracking of the

waste contents of RH debris wastes at this time. Although the WWIS is currently approved by EPA for tracking contact-handled (CH) waste, INL-CCP had not demonstrated its adequacy to

enter and track RH waste conten ts during this baseline inspec tion. During the comment period for the proposed approval CBFO notified EPA th at the WWIS was operational for RH wastes and was ready for EPA evaluation as a T1 change . EPA has begun this evaluation and the results

of EPA’s T1 evaluation will be provided upon completion separately.

EPA is also not approving real-t ime radiography (RTR) at this time. INL-CCP did not have an operational RTR unit in place at the time of th e inspection. This final baseline inspection requires the use of RTR as a T1 change. Theref ore, INL-CCP cannot ship RH waste to the WIPP using RTR as a WC technique until it is appr oved by EPA. EPA received a request for an evaluation and approval of a RTR pr ocess. Once the evaluation is complete, the results of the T1 evaluation will be provided separately.3 Any changes to the WC activities from the date of the baseline inspection must be reported to and, if applicable, approved by EPA, according to Table 1. Please note that each T1 and Tier 2 (T2) change listed in Table 1 is followed by a re ference to the report section where the technical basis for the T1 or T2 designation is presented.

In October 2006, EPA concurred with CBFO’s request for allowing INL-CCP to submit T2 changes implemented at the EPA-approved TRU sites four times a year at the end of each fiscal quarter. (See EPA letter to CBFO dated October 26, 2006; EPA Air Docket No. A-98-49, II-A4-76). INL-CCP may submit all T2 changes discussed in this report on the same schedule.4Table 1. Tiering of RH TRU WCProcesses Implemented by INL-CCP(Based on June 12–16 Baseline and August 9 & 29, 2006, Follow-Up Inspections)RH WC Process ElementsINL-CCP RH WC Process - T1 ChangesINL-CCP RH WC Process - T2 Changes*Acceptable Knowledge (AK)Modification of the approved waste stream ID-ANLE-S5000 toinclude additional containers, i.e., K Cell or other debris wastes;AK (1) and AK (5)Any new waste streams not approved under this baseline; AK (1) andAK (7)Substantive modification(s)*** that have the potential to affect thecharacterization process: CCP-AK-INL-500, CCP-AK-INL-501, orCCP-AK-INL-502; AK (6) and AK (7)Load management for any RH waste stream; AK (16)Notification to EPA when updates to CCP-INL-AK-500,CCP-INL-AK-501, and CCP-INL-AK-502 are approvedby CBFO; AK (4)Notification to EPA when changes to AK documentationas a result of WCPIP revisions** have been made (e.g.,CRR); AK (7) and AK (9)Notification to EPA when aCorrelation or SurrogateSummary Form is completed for each of the RHcontainers in this waste stream identified as CH basedupon measured dose rates that present NDA results forassayed containers; AK (10), AK (14) and RC (8.2.2)Notification to EPA once waste stream data package fordebris waste stream, and any modifications to the WSPFincluding the CRR and AK Summary are completed;AK (14)Notification to EPA that the final DTC determination iscomplete for RH containers numbers 728 through 737, asidentified in AK ReferenceP030; all other AK accuracyreports prepared annually at a minimum; AK (15)Radiological Characterization, includingDose-to-Curie (DTC)Application of new scaling factors for isotopic determination otherthan those documented in CCP-AK-INL-501; RC (8.2.2 and 8.2.3)Use of any alternate radiological characterization procedure other thanDTC with established scaling factors as documented in CCP-TP-504or substantive modification of the DTC procedure***; RC (8.2.2 and8.2.3)Any new waste stream not approved under this baseline or addition ofcontainers to Waste Stream ID-ANLE-S5000 that requires changingthe established radionuclide scaling factors; RC (8.2.3)Revisions of CCP-AK-INL-501or CCP-TP-504 thatrequire CBFO approval; RC (8.2.2 and 8.2.3)Visual Examination of audio/video media(VE)Implementation of VE following this baseline approval; if INL-CCPdecides to use VE in the future, EPA approval is necessaryNoneReal-Time Radiography (RTR) Any use of RTR requires EPA approvalNoneWIPP Waste Information System (WWIS) Any use of WWIS requires EPA approval prior to RH waste disposal None* Upon receiving EPA approval, INL-CCP will report all T2 changes to EPA every three months.** Excluding changes that are editorial in nature or are required to address administrative concerns.***Substantive modificationrefers to a change with the potential to affect INL-CCP’s RH WC process, e.g., the use of an inherently different type of measurement instrumentor the use of the high-range probe as described in CCP-TP-504.5 EPA will notify the public of the re sults of its evaluations of T1 and T2 changes established as part of today’s approval through the EPA Web site and by sending e-mails to the WIPPNEWS list (see Section 2.0, below, for a brief discussion of tiering). All T1 changes must be submitted for approval before their implementation and wi ll be evaluated by EPA. Upon approval, EPA will post the results of the evaluations through the EPA Web site and the WIPPNEWS list, as

described above.

2.0 PURPOSE OF INSPECTIONS

On May 18, 1998, EPA certified that the WIPP will co mply with the radioactive waste disposal regulations in 40 CFR Part 191. In this cer tification, EPA also included Condition 3, which states that “the Secretary shall not allow shipme nt of any waste from...any waste generator site other than LANL [Los Alamos National Laboratory] for disposal at the WIPP until the Agency has approved the processes for characterizing thos e waste streams for shipment using the process set forth in §194.8.” The approval proce ss described at 40 CFR 194.8 requires DOE to (1) provide EPA with information on AK 1 for waste streams proposed for disposal at the WIPP, and (2) implement a system of controls used to confirm that the total amount of each waste component that will be emplaced in the WIPP will not exceed limits identified in the WIPP Compliance Certification Application (CCA).

Under the changes to 40 CFR 194.8 promulgate d in the July 16, 2004, FR notice, EPA must perform a baseline inspection of a TRU waste gene rator site’s WC program . The purpose of the baseline inspection is to approve the site’s WC program based on the demonstration that the program’s components, with applicable conditions and limitations, can ad equately characterize TRU wastes and comply with the regulatory re quirements imposed on TRU wastes destined for disposal at the WIPP. An EPA inspection team conducts an on-sit e inspection to verify that the site’s system of controls is technically adeq uate and properly implemen ted. Specifically, EPA’s inspection team verifies compliance with 40 CFR 194.24(c)(4), which states the following:

Any compliance application shall: . . . Pr ovide information which demonstrates that a system of controls has been and will continue to be implemented to confirm that the total amount of each waste component that will be emplaced in the disposal system will not exceed the upper limiting value or fall below the lower limiting value described in the introductory text of paragraph of this section. 2

The system of controls sha ll include, but shall not be limited to: measurement; sampling; chain of custody records; record keeping systems; waste loading
schemes used; and other documentation.

1 As of the FR notice of July 16 , 2004, EPA has replaced the term process knowledge with acceptable knowledge . Acceptable knowledge refers to any information ab out the process used to generate waste, material inputs to the process, and the time period during which the wastes were generated, as well as data resulting from the analysis of waste conducted prior to or separate from the waste cer tification process authorized by an EPA certification decision to show compliance with Condition 3 of the certification decision.

2 The introductory text of 40 CFR 194.24(c) states, “For each waste component identified and assessed pursuant to [40 CFR 194.24(b)], the Department shall specify the limiting value (expressed as an upper or lower limit of mass, volume, curies, concentration, et c.), and the associated uncertainty (i .e., margin of error) for each limiting value, of the total inventory of such waste proposed for disposal in the disposal system.”6 In other words, the purpose of the baseline in spection is to implement the requirements of 40 CFR 194 by assessing whether DOE sites that char acterize TRU waste prio r to disposal at the WIPP are capable of characterizing and tracking the waste. EPA may also conduct follow-up inspections to address issues remaining from the baseline inspection or to seek further clarification/discussion related to WC proce sses evaluated during a ba seline inspection. By approving the WC systems and processes at INL-CCP applied to retrievably-stored RH debris waste, EPA confirms that the Agency has eval uated the capabilities of systems and processes implemented by a site to accomplish two tasks: (1) the identification and measurement of waste components (such as plutonium (Pu)) that must be tracked for compliance, 3 and (2) the confirmation that the waste in any given contai ner has been properly id entified as belonging to the group of approved waste streams.

Based on the adequacies of th e WC processes demonstrated during the baseline inspection, including all conditions and limitations, EPA speci fies which subsequent WC program changes or modifications must undergo further EPA insp ection or approval under 40 CFR 194.24. This is accomplished by assigning a tier level to each aspect of the characterization program, i.e., T1 and

T2 activities. T1 activities ha ve more stringent re porting and EPA notification requirements and require EPA approval prior to implementation. T2 activities are reported to EPA based on the frequency established in the insp ection report. DOE may choose to characterize and dispose of

the waste from T2 activities at risk while EP A considers the T2 changes. If INL-CCP contemplates a change that is not identified in this report, EP A recommends that the site, in consultation with CBFO, discuss the nature of th e change with EPA. This would minimize the possibility of EPA not approving the site-assigned tiers. The rule applying to this baseline inspection can be found in the FR (Vol. 69, No. 136, pp. 42571–42583, July 16, 2004).

Following EPA’s approval of WC processes ev aluated during the baseline inspection, EPA can conduct additional inspections to evaluate and approve, if necessary, changes to the site’s approved WC program under the authority of 40 CFR 194.24(h). Under 40 CFR 194.24, EPA also has the authority to conduc t continued compliance inspections to verify that the site continues to use only the approved WC processe s to characterize the waste and remains in compliance with all the regulatory requirements.

3.0 PURPOSE OF THIS REPORT

This report documents the basis for EPA’s approval decision and explains the results of Baseline Inspection No. EPA-INL-CCP-RH-6.06-8 in terms of findings or concerns. Specifically, this report does the following:

3 The potential contents of a single waste stream or group of waste streams determine which processes can adequately characterize the waste. For ex ample, if AK suggests that the waste form is heterogeneous, the site should select the matrix-appropriate radiologi cal characterization technique to obtain adequate radionuclide measurements. VE serves to confirm and quantify waste components, such as cellulosics, rubbers, plastics, and metals. Once the nature of the waste has been confirmed, characterization techniques quantify selected radionuclides in the waste. In some cases, a TRU waste generator site may be able to ch aracterize a range of heterogeneous waste streams or only a few. A site’s stated limits on the applicability of pr oposed WC processes govern the scope of EPA’s inspection.7 • Describes the characterization systems proposed for approval

• Provides objective evidence of the a pproval basis for all WC systems

• Identifies all relevant limitations and or conditions for each WC system

• Provides objective evidence of outstanding fi ndings or concerns in the form of documentation, as applicable

• Describes any tests or demonstrations comple ted during the course of the inspection and

their relevance to EP A’s approval decision

The completed checklists attached to this report in conjunction with the li stings in each section reference the documents that the EPA inspectio n team members reviewed in support of the

technical determination. To see or obtain co pies of any items identified in the attached checklists, write to the following address:

Quality Assurance Manager

USDOE/Carlsbad Field Office

P.O. Box 3090 Carlsbad, NM 88221

EPA’s final approval decision regarding the INL-CCP WC program is conveyed to DOE separately by letter. This information is also available on EPA’s Web site at http://www.epa.gov/radiation/WIPP, in accordance with 40 CFR 194.8(b)(3).

4.0 SCOPE OF INSPECTION

The scope of Baseline Inspection No. EPA -INL-CCP-RH-6.06-8 included the technical adequacy of the WC systems in use at INL-CCP to characterize RH TRU wastes. These systems were evaluated with respect to thei r ability to perform the following:

• Identify and quantify the activities of the 10 WIPP-tracked radionuclides ( 241 Am, 137 Cs,

238 Pu, 239 Pu, 240 Pu, 242 Pu, 90 Sr, 233 U, 234 U, and 238 U) using a combination of AK and radiological characterization, including DTC and radionuclide scaling factors derived from modeling

• Assign waste material parameters (WMPs) corr ectly using VE for RH retrievably-stored

debris waste

Specifically, these systems consisted of the following components:

• The AK process that supports retrievably-st ored S5000 debris wastes from one (1) RH debris waste stream (INL Waste Stream No. ID-ANLE-S5000, Lots 1 through 20)

• The system of radiological characterizati on including DTC and the application of radionuclide scaling factors derived by modelin g for one RH debris waste stream (INL Waste Stream No. ID-ANLE-S5000)

• VE for retrievably-stored S5000 RH debris wastes8 During an inspection, EPA does not approve charact erization data; that function is the sole responsibility of the site bei ng evaluated during the inspection, in this case INL-CCP. EPA evaluated the WC processes implem ented by the site to characterize RH retrievably-stored debris

waste. The evaluation consists of interviewing personnel, obse rving equipment operations that are controlled through site procedures, and in specting records related to each of the WC processes within the inspection’s scope. An impo rtant aspect of this ev aluation is the objective

evidence that documents the effectiveness of the WC processes. Objective evidence typically

takes the form of BDRs for ra diological characterization and VE, AK accuracy reports, and VE tapes. During an inspection, EPA typically select s samples of each of these items, based on the number and variety of items that were complete d and available for each WC process, consistent with standard auditing techniques. Because the RH TRU characterization program is new, there was initially only one completed BDR for VE and radiological characteriza tion available for the EPA inspection team’s evaluation. By the end of the inspection process, INL-CCP had produced

two more VE BDRs for a total of three. The EP A inspection team evaluated all of the drums in the three VE packages and the one radiologi cal characterization package. Based on the evaluation of the WC processes in conjunction with the objective evidence, EPA determined the technical adequacy of the WC processes within the inspection’s scope.

5.0 INSPECTION-RELATED DEFINITIONS

During the course of an inspection, EPA inspectors may encounter items or activities that require further inquiry for their potential to adversely affect WC and/or isolation within the repository. The two main categories relevant to WC inspections are identified below:

Finding : A determination that a specific item or activity does not conform to 40 CFR 194.24(c)(4). A finding requ ires a response from CBFO.

Concern : A judgment that a specific item or activity may or may not have a negative effect on compliance and, depending on the magnitude of the issue, may or may not require a response. (Concerns not requiring a respons e do not have to be addressed prior to program approval.)

6.0 PERSONNEL

6.1 EPA Inspection Team

The members of the EPA WC inspection team are identified in Table 2.

Table 2. EPA Inspection Team Members

Inspection Team Member Position Affiliation

Ms. Rajani Joglekar Inspection Team Leader U.S. EPA ORIA

Mr. Ed Feltcorn Inspector U.S. EPA ORIA

Ms. Connie Walker Inspector S. Cohen & Associates, Inc.

Ms. Dorothy Gill Inspector S. Cohen & Associates, Inc.

Mr. Patrick Kelly Inspector S. Cohen & Associates, Inc.9 6.2 Personnel Contacted

EPA and its support personnel c onducted interviews with INL-CCP personnel in several disciplines. The personnel cont acted represented a sample of the CH TRU WC staff, and they are listed in Table 3, along with their affiliation and technical area.

Table 3. Personnel Contacted During Inspection

Personnel Affiliation Area of Expertise

Eric D’Amico CCP AK, DTC, SPM Jene Vance CCP AK/DTC; Scaling Factors-MS Data Lisa Price CCP AK, AKE Larry Porter CCP AK, SPM; Scaling Factors-MS Data Steve Schafer CCP AK, AKE Kevin Peters CCP AK, AKE Lee Smith CCP RTR, SME & Operator Ed Gulbransen CCP DTC, SME Mark Doherty CCP/WTS DTC & Scaling Factors-MS Data Joe Harvill CCP/WTS DTC & Scaling Factors Keith B. Farmer CWI DTC, Nuclear Facility Manager Ken Pierce CWI DTC, Shift Manager Chris Davis CWI DTC, Dose-Rate Operator Suay Andrews CWI DTC, Dose-Rate Operator Mark Hawker CWI DTC, Rad Con Technician Swami Raman CCP VE, Operator/ITR Tommy Mojica CCP Operator/ITR, SME/OJT, VEE Patrick Boyd CCP Operator/ITR John Hegsted CCP Operator/ITR Irene Quintana WTS SPM

During the baseline inspection, INL-CCP provide d a list of RH TRU WC personnel from which

EPA selected the individuals to be interviewed. The EPA inspectors review ed the qualifications and training records of these indi viduals relative to th eir WC responsibilities. Based on this evaluation, EPA determined that INL-CCP WC personnel responsible fo r characterizing RH TRU waste and certifying it as TRU waste were qua lified and had received adequate training to perform their assigned functi on. If key WC personnel changes occur, EPA may request qualification and training records of the new i ndividuals identified as key WC personnel. EPA will review these records and may interview the personnel to determine their abilities to produce quality data. This personnel qualification evaluati on and review of training records would be the equivalent of the evaluation done by the EPA in spection team on site during this inspection.

7.0 PERFORMANCE OF THE INSPECTION

Site Background and History

INL is located in southeastern Idaho, about 60 miles outside of Idaho Falls, Idaho. The site encompasses approximately 890 square miles. The U.S. government established INL in 1949 as the National Reactor Testing Station, and its original mission was the design, construction, and10 testing of prototype nuclear reactors. Over the years, site activities ha ve shifted from reactor development to multi-program research, hazardous and radioactive waste management and cleanup, and the development of environmental te chnologies. In January 1997, the site, then known as the Idaho National Engineering Laborato ry (INEL), changed its name to the Idaho National Engineering and Environm ental Laboratory (INEEL) to hi ghlight its role in developing waste cleanup and other environmental technologie s. In February 2005, the site’s name was changed to the Idaho National Laboratory (INL) 4 to better reflect its ro le in the development of nuclear-related technologies.

The 2004 Compliance Recertif ication Application 5 states that there ar e eight individual RH waste streams currently in storage at INL. Th ese wastes originated from a variety of DOE generators, including Argonne National Labor atory-East (ANL-E) and Argonne National Laboratory-West (ANL-W), Battelle Columbus Laboratories, and INL 6 . The wastes are expected to consist primarily of debris, incl uding metal waste, labor atory wastes, Pu-neutron source metallic wastes and heterogeneous debris; one RH sludge waste stream is identified. INL has approximately 202 cubic meters (m 3 ) of RH TRU waste in storage, and it is projected that no additional RH waste streams will be generated. It is worth noting that the number of actual waste streams may change as a function of the requirements of the WC Program Implementation Plan (WCPIP).

Inspection Process Overview

EPA Inspection No. EPA-INL-CCP-RH-6.06-8 occurred in three segments:

• On-site inspection at INL on June 12–16, 2006

• Follow-up inspection on August 9, 2006, at DOE’s CBFO for the purpose of assessing mass spectrometry data used to support one element of the INL-CCP RH WC program

• Follow-up inspection at DOE’s CBFO on Augus t 29, 2006, for the purpose of resolving open issues from the above-listed inspections

The inspection had the scope described in Sect ion 4.0, above, for the purpose of determining the site’s compliance with 40 CFR 194.24. The in spection was conducted in the following steps:

(1) Obtaining and reviewing site procedures, re ports, and other technical information related

to RH WC activities at INL-CCP in advance of the inspection

(2) Preparing draft checklists and technical que stions specific to WC areas prior to the inspection, as appropriate

4 Documentation cited in this report may bear an identification number from INL, INEEL, or INEL, depending on the document’s time of generation. These distinctions are not significant.

5 Appendix data, Attachment F, Annex J

6 As a result of the incorporation of the facility former ly known as ANL-W into INL, the facility in Argonne, Illinois, that was formerly known as ANL-E is now ca lled ANL. The ANL-W facility is now called the Materials and Fuel Complex. The terms ANL-E and ANL-W may be used in this report to maintain consistency with specific

references.11 (3) Evaluating INL-CCP’s implementation of WC processes for adequacy and demonstrating compliance with 40 CFR 194.24 requirements

(4) Participating in several conference calls w ith CBFO technical support contractors to brief the EPA inspection team members regarding te chnical details related to the INL-CCP RH WC program

(5) Interacting with CBFO and INL-CCP pe rsonnel to arrange inspection logistics

(6) Conducting initial baseline insp ection visit at INL-CCP to ve rify the technical adequacy or qualifications of RH WC personnel, proc edures, processes, and equipment by means of interviews, observation, and demons trations, and recording the results

(7) Making one follow-up visit to CBFO headquarters in Carlsb ad, New Mexico, to perform an independent technical evalua tion of analytical data used to support the development of radionuclide scaling factors

(8) Making one follow-up visit to CBFO headquart ers in Carlsbad, New Mexico, to complete the evaluation of specific RH WC technical aspects

(9) Holding ongoing technical discussions between members of the EPA inspection team and INL-CCP technical support contractors for the purpose of clarifying technical aspects of the RH WC program

(10) Recording all concerns on EPA issue- tracking forms, which were completed and provided to CBFO and site personnel as th ey were generated (see Attachment B)

(11) Communicating all pertinent information with CBFO and INL-CCP personnel on site and in other meetings, as appropriate

(12) Pursuing resolution of all id entified issues prior to completion of the inspection and after the inspection by discussions w ith CBFO and INL-CCP personnel

(13) Conducting entrance, exit, and daily br iefings for CBFO and INL-CCP management personnel at INL and CBFO, as appropriate

(14) Preparing the dr aft inspection report

8.0 TECHNICAL WASTE CHARACTERIZATION AREAS

8.1 Acceptable Knowledge

EPA examined the AK process and associated in formation to determine whether the INL-CCPRH program demonstrated compliance with 40 CFR 194.8 requirements for RH retrievablystored debris waste.

Waste Characterization Element Description

As part of the inspection, EPA reviewed the following with resp ect to the use of AK for WC:

• Waste stream definition and identifica tion, including radiological content

• Identification of high-level waste, TR U versus non-TRU, spent nuclear fuel12 • Role of AK in the characterization methodol ogy (including alternative characterization methods related to AK)

• Compilation of AK documentation and a ssembly of required information

• Adequacy of WCPIP AK process imp lementation and AK Summary Report

• AK data traceability

• AK source document sufficiency

• WCPIP interpretation with respect to AK qualification

• Confirmatory Test Plan prepar ation and plan adequacy

• Characterization Reconci liation Report preparatio n and report adequacy

• Correlation and Surrogate Summary Form and contact-handled (CH)-RH correlation

• Personnel training

• Traceability of mass spectrometry data used to support radionuclide scaling factors

• Nonconformance reports (NCRs) a nd AK discrepancy resolution

• AK accuracy

• Implementation of load management

• Identification of the method for determini ng data quality objectives (DQOs) including those to be attained by AK qualification

• Attainment of DQOs

The checklist included as Attachment A.1 identifie s the objective evidence reviewed by the EPA inspector. AK is used to provide informati on regarding several aspects of TRU wastes at INL-CCP, including the following:

• Defense waste status

• Material parameters

• Waste stream

• Radionuclide composition

• Waste matrix codes (WMCs)

Documents, Waste Containers, and Batch Data Reports Reviewed

• DOE/WIPP-02-3214, Remote Handled TRU Waste Characterization Program Implementation Plan, Re vision 0D, October 30, 2003

• DOE/WIPP-02-3122, Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plan, Revision 5, effective date TBD

• CCP-PO-002, CCP Transuranic Waste Certif ication Plan, Revision 16, approved May 8,

2006

• CCP-QP-002, CCP Training and Qualification Pl an, Revision 20, effective date May 3, 2006

• CCP-AK-INL-500, Central Characterization Project Acceptable Knowledge Summary Report for Remote-Handled Transuranic Debr is Waste from Argonne National LaboratoryEast Stored at the Idaho National Laborat ory, Waste Stream ID-ANLE-S5000, Revision 2, June 1, 2006 and Revision 3, July 7, 200613 • CCP-AK-INL-501, Central Characterization Project Remote-Handled Transuranic Radiological Characterization Technical Report for Remote-Handled Transuranic Debris

Waste from Idaho National Labor atory, Revision 1, June 6, 2006

• CCP-AK-INL-502, Central Characterization Proj ect Confirmatory Test Plan for Waste

Stream: ID-ANLE-S500 0, Revision 0, May 5, 2006

• CCP-AK-INL-502, Central Characterization Proj ect Confirmatory Test Plan for Waste

Stream ID-ANLE-S500 0, Revision 1, May 31, 2006

• CCP-TP-506, CCP Preparation of the Remote -Handled Transuranic Waste Acceptable Knowledge Characterization R econciliation Report, Revision 1, effective date May 5, 2006

• Interoffice correspondence (for audit demonstrati on purposes only), to I. Quintana from A.J. Fisher, Acceptable Knowledge Accuracy Repor t: Idaho National Laboratory Waste Stream Number ID-ANLE-S5000 Lot 1, June 8, 2006

• EDF-6946, Engineering Design File Project N o. 23048, Identification of Additional Fuel Elements/Materials Examined in the Alpha Gamma Hot Cell Facility for ANL-E TRU Waste, Revision ID:0, effective date May 19, 2006

• FUEL PIN data source documents (CD), provided June 2006

• P593, Engineering Design File, Quantifying Sp ecial Actinides in RH-TRU Waste from

Irradiated Fuel Examined at ANL-E , EDF-2555, Revision 0, December 16, 2002

• P592, Evaluation of Radionuclide contents in RH-TRU Waste Drums 728 through 737 Based on Reported Irradiated Fuel Examination INEEL/EXT-02-00168, Revision 0, September

2003

• Fuel Element Examination Sheets (Fuel Element Examined at Argonne National Laboratory), AG Nos. 421A, 429A

• Drum number list, Waste Stream INL-ANL-E-S5000, provided June 2006

• EDF-6685, Engineering Design File, Project No. 23048, Information on Fuel Elements

Examined at the AGHCF 7 at ANL from November 1971 to August 7, 1995, Based on Waste Consolidation Records, Revision ID:0, effective date May 19, 2006

• Characterization Reconciliati on Report (CRR), draft, for Waste Stream CRR-INL-AGHCFS5000-001 and for Waste Stream ID-ANLE-S5000, June 9, 2006

• AK Qualification Card, Kevin Peters, August 6, 2003

• NCR-RHINL-0004-06, Revision 0 (note reas on for NCR not provided on sheets)

• Waste Can Inventory Sheets, Can Nos. 105, 107, and 108, March 31, 1993

• Waste Package Data Sheet, Drum Nos. 00739 (top can 107, bottom can 105), April 22, 1993

• Waste Can Inventory Sheets, Can Nos. 118 and 119, March 26, 1993

• Waste Package Data Sheet, Drum Nos. 00743 (top can 118, bottom can 119), April 30, 1993

7 AGHCF is the Alpha-Gamma Hot Cell Facility at ANL-E.14 • Waste Package Data Sheet, Drum Nos. 00742 (top can 117, bottom can 115), April 30, 1993

• Waste Can Inventory Sheets, Can Nos. 117 and 115, April 30, 1993

• Waste Package Data Sheet, Drum Nos. 00741 (top can 110, bottom can 112), April 23, 1993

• Waste Can Inventory Sheets, Can Nos. 110 and 112, April 2, 1993

• Waste Package Data Sheet, Drum Nos. 00740 (top can 109, bottom can 108), April 23, 1993

• Waste Can Inventory Sheet, Can No. 109, April 2, 1993

• Waste Package Data Sheet, Drum No. 00738 (top can 102, bottom can 104), April 17, 1993

• Waste Can Inventory Sheets, Can Nos.102 and 104, April 1, 1993 (camera was off for No.104)

• DR11, Waste Requisition and Vide o Discrepancies, June 13, 2006

• DR10, Discrepancy Resolution Regarding the Vo lume of 7-Gallon Waste Cans, K. Peters, June 6, 2006

• Source Documents Reference List (CCP-TP- 005, Revision 17, Attach ment 4), June 13, 2006

• Sample/Fuel Element and Other AK Data for Index 293 (see EDF-6685, Revision 11, page 23)

• Data for AG No. 421A, UBA-15, en d installation da te April 19, 1990

• ICP/EXT-05-0886, Project 23048, ILTSG Drum Re trieval Completion Report, Revision 0,

October 2005

• ID-ANLE-S5000, Draft Waste Stream Profile Fo rm for Audit Purposes Only, June 2006

• DTC BDR and related attachments: (1 ) CCP-TP-504, Revision 2, Attachment 8, SPM

Checklist for BDR INL RH DTC 06 001; (2) CCP-QP-005, CCP NCR Report RHINL-0500-06, for containers 00745 and 00746 (with container rejected because dose rate less than 10 times background), Revision 10; (3) CCP-TP-504, Revisi on 2, Attachment 4, BDR Cover Sheet INL RH DTC 06001; Attachme nt 5, BDR Table of C ontents; Attachment 6, BDR Narrative Summary; Attachment 7, ITR Review Checklist; Attachment 1, Measurement Control Reports (various dates) ; Attachment 2, Individual Container Data Sheets for Containers 771, 70, 73, 739, 743, 738, 742, 744, 747, 740, 741, 745, and 746;

Waste Container Dose-to-Curie Conversi on Record (same container numbers); (4) NCR-RHINL-0004-06, measured container dose rate not at least 10 times greater than background for Container 00763

• RH TRU Waste Correlation and Surrogate Summary Form for ID-ANLE-S5000, undated and unsigned

• Solid Radioactive Waste Disposal Requisition Date Sheets, various containers, provided

June 2006

• C003, Intralaboratory Memorandum to H. Wels h Re: Dimensions of Intermediate TRU Waste Containers, prepared by D. Donahue, September 14, 198915 • P002, Central Characterization Project Accep table Knowledge Report for Argonne National Laboratory-East Contact Ha ndled TRU Waste Facility Maintenance and Laboratory Operations; CCP-AK-ANLE-001, Revision 11, December 31, 2003

• C024, Intralaboratory Memorandum to W.C. Kettm an from L.A. Neimark IPR, Clarification of 00 No. 29 with Regard to Inventory of 8 Inch Storage Holes, December 7, 1993

• C058, Intralaboratory Memorandum to R. Boule from R. Ditch, Re : Needs Prior to Shipment

of Neimark’s TRU-RH Drums to Idaho, March 1, 1990

• C060, Intralaboratory Memorandum to R. Boule from A.C. Smith, Re: Status: Resumption of Shipments of TRU Waste to INEL, March 30, 1990

• C066, Record of Communication between B. Kettman and D. Donahue, Re: AGHCF Operations and Waste Packaging, recorded by J. Whitworth and M. Wyco, August 7, 2001

• C067, Record of Communication with F. Paus che and T. Bray, by J. Whitworth and M. Wyco, Re: Calculation of U/Pu Ra tios in Waste Containers, August 8, 2001

• C084, Intralaboratory Memorandum to Buildi ng 212 Personnel, Re: Disposal of Solid Radioactive Waste, F.P. Ma rchetti, February 4, 1986

• C108, Correspondence to J.T. Case, USDOE Idaho Field Office from T.L. Clements, TLC224, 92, Re: Strategy Plan for Long-Term Management and Storage of Remote-Handled (RH) Transuranic (TRU) Waste, November 30, 1992

• C121, Record of Communication with L. Ne imark, A. Cohen, and F. Pausche by J. Whitworth and J. Biedscheld, and P. Kuan, R. Bhatt, and S. Kheriche, Re: ACHCF Radiological Characterization of RH-TRU Waste Shipped to INEEL, December 19, 2001

• C330, Memorandum to I. Triay, CBFO from F. Marcinowski, Determination and Findings, Defense Origin of Nuclear Wast e, Kerr-McGee Waste, April 15, 2005

• C331, Memorandum to CCP Central Records from K. Peters, Re: Evaluation of Kerr-McGee Production and FFTF History, June 26, 2004

• C332, Memorandum to CCP Central Records from D.B. Becker, Re: Assessment of Waste

Material Parameters for Waste St ream ID-ANLE-S5000, January 3, 2006

• C333, Memorandum to CCP Central Records from D.B. Becker, Re: Assessment of Waste

Material Parameters for Wast e Stream AERHDM, January 2006

• C350, Memo to CCP File, DRAFT — Evaluation for Radiological Waste Stream Delineation for Waste Stream ID-ANLE-S5000 (AK Refere nce C350), K. Peters, September 1, 2006

• C348, Evaluation of Generator Reported Radionuclides for Waste Stream ID

- ANLE-S5000,

Steve Schafer, INL-CCP, June 30, 2006

• P001, ACHCF Operations Manual, Argonne Na tional Laboratory, IPS-2-00-00, Revision 2, September 10, 1990

• P006, Safety Analysis for Twenty Year Retrievable Storage of Intermediate Gamma Level Transuranic Waste, W.D. Jackson Alpha-G amma Hot Cell Facility, Argonne National Laboratory, June 1, 197616 • P009, TRU-RH Waste Certificati on Plan for Waste Management Operations, R.W. Ditch and G. Griggin, J0306-0033-SA, Revisions 2 a nd 4, November 10, 1986, and April 16, 1991

• P023, Argonne National Laboratory-East Re mote Handled Waste, W.M. Hellaeson, EDF-RWMC-759, August 29, 1994

• P030, Radiological Acceptable Knowledge Re port for Drums 728 through 737, J. Whitworth, Shaw Environmental Team Lead, INEEL/EXT-02-00527, July 31, 2002

• P032, Procedure for Sorting Remote-Handled TRU Waste (30-Gallon Intermediate-Level Waste), Alpha-Gamma-Hot Cell Facility Irra diation Performance Section Materials and Components Technology Division, January 7, 1987

• P055, [ANL-E] Waste Handling Procedures, C. L. Cheever, Manager, Waste Management Operations, September 18, 1986

• P587, Program Scoping Plan for the Fast Fl ux Test Facility, A Nuclear Science and

Irradiation Services User Facil ity, PNNL-12245, Revision 1, August 1999

• P590, Methodology to Determine Radioisotope Contents in RH TRU Waste Drums from Irradiated Fuel Examination at ANL-E, INEEL/EXT-02-001 69, Revision 0, September 2003

• P591, Engineering Design File, Estimation of Inventory of Significant Isotopes in RH-TRU Waste Drums 728 through 737, EDF-1979, Revision 1, March 19, 2003

• P592, Evaluation of Radionuclide Contents in RH TRU Waste Drums 728 through 737 Based on Reported Irradiated Fuel Ex amination, INEL/EXT-02-00168, Revision 0, September 2003

• P593, Engineering Design File, Quantifying Sp ecial Actinides in RH-TRU Waste from

Irradiated Fuel Examined at ANL-E ; EDF-255, Revision 0, December 16, 2002

• P595, Engineering Design File, Verification a nd Validation of a Portion of ORIGEN2 Code Used for RH-TRU Radiological Character ization, EDF-1980, Revision 0, March 2002

• P596, Peer Review of Proposed Radiological Characterization Methodology for RemoteHandled Transuranic Waste Stored at the Id aho National Engineering and Environmental Laboratory, INEEL/EXT-03-01182, September 2003

• P599, The Defense Programs Origin of Transu ranic Waste at Argonne National LaboratoryWest, H.F. McFarlane, ANLE-NT-192, November 2001

• U001, AGHFC Position Statement Regarding De fense Versus Non Defense TRU Waste, no author cited, April 7, 2000

• U013, Waste Stream Fissile C ontent [AGHCF], March 23, 1990

• U015, RH-TRU 1995, Book 5 Drums 798 to 809, no author cited, January 1, 1995

• U022, TH-TRU 1985-1987, Book 3 Drums 617 to 686, no author cited, undated

• U040, Spreadsheet Correlating Number Quota wi th Quota Title and Number Project, no author cited, July 31, 200217 • U041, Videotape Log Data [Cans 100, 102–187, 217–231, and 234–246], C.L. Schulz, September 15, 2001

• U042, RH-TRU 1976 to 1982, Book 1 [AGH CF], no author cited, undated

• U072, Material Safety Data Sheets, vari ous components, no author cited, undated

Waste Container and Batch Data Reports Reviewed

The BDRs for RH waste containers that were examined are provided in Table 4, below.

Table 4. BDRs Reviewed

Drum Number VE BDR No. DTC BDR No. Waste Lot

Number

00738 RH INL VE 06001 INL RH DTC C06001 17

00739 RH INL VE 06001 INL RH DTC C06001 17

00740 RH INL VE 06001 INL RH DTC C06001 17

00742 RH INL VE 06001 INL RH DTC C06001 17

00743 RH INL VE 06001 INL RH DTC C06001 17

Waste Stream ID-ANLE-S5000 has been characteriz ed by AK with respect to almost all of the DQOs, and “confirmatory testing” was performe d to confirm AK information. Unlike CH TRU waste, RH containers will not be tested for AK confirmation usi ng a nondestructive assay (NDA). Instead, the confirmation of AK-reported ra diological contents of the RH debris waste containers, TRU waste designa tion, and activity-related DQOs is performed through the application of the DTC technique in conjunction with AK-based scal ing factors that were derived through ORIGEN2.2 modeling. Input parameters to this modeling were not individual drum AK data, but rather fuel pins that contributed to radionuclides in va rious waste drum lots. The data for individual fuel pins were us ed as input to the ORIGEN2.2 c ode. The evaluation presented in this section assesses the AK process and related activities necessary to the determination of physical and radiological waste composition. The development of modeling parameters and the determination of scaling factor s is addressed in Section 8.2.

Technical Evaluation

(1) Waste Stream ID-ANLE-S5000 was examined with respect to whether the stream is adequately defined.

The WCPIP defines waste stream as “waste materi al generated from a single process or activity, or as waste with similar physical, chemical, a nd radiological properties. ” The waste stream examined, ID-ANLE-S5000, is a debris waste st ream generated in the ANL-E hot cell and K cell. The physical and radiological composition of the waste with respect to waste stream

definition is evaluated below. At the time of EPA’s inspection, EPA found that the definition of waste stream was not fully supported in CCP -AK-INL-500. This was discussed with AK personnel and EPA included this on an EPA Inspec tion Issue Tracking Form (See Attachment B. of this report for this form). It is di scussed below, as well, under item (4).18 EPA Concern No. INL-CCP-RH-AK-06-005CR, Revision 1: EPA’s concern addressed the lack of clear support for the waste stream’s defin ition. Specifically, the document needs to make a better argument that the wastes generated in the cells were never segr egated by fuel pin or generator, so there is no way a specific fuel pin or radionuclide conten t can be assigned to individual waste containers. Therefore, the radiol ogical characteristics of the fuel pins must be assigned as a whole to the entire population. Th is assumption must be s upported and justified in the AK Summary.

Resolution: In response to EPA’s concern, INL-CCP revised CCP-AK-INL-500 to state:

Waste stream ID-ANLE-S5000 meets the WCPIP waste stream definition...[because] all of the containers in the stream were gene rated by AGHCF processes that remained relatively unchanged containing the same type of materials in approximately the same relative percentages. As described in Sec tion 5.3, period campaigns were conducted in the ABHCF to prepare shipments of containers to be sent to INL. Waste were generally

collected at individual work st ations then moved to the wa ste packaging area in WS5 to be stockpiled until the next packaging campai gn. Technicians in WS5 visually examined,
sorted, and loaded the waste. Due to these waste management practices, in conjunction with the destructive nature of the exami nations performed in the AGHC, further delineation of this waste stream based on radiol ogical contamination is not possible. In
addition, the waste stream c ontains waste materials ge nerated during maintenance and waste management activities th at could contain any radiological materials contaminating the cell surfaces and equipment (Ref erences C332, C333, C347, P006, P009, P023, U042)

.

EPA examined INL-CCP’s response and each of the cited references. References C332, C333, and C347 address the physical characteristics of the waste, while P006, P009, and U042 address waste packaging and records related to radiol ogical characterization of the waste. P023 addresses chemical components (lead) in the waste.

INL-CCP assessed the characteristics of the wast e stream to determine whether the composition of the waste stream generated from 1990–1995 is phys ically similar (C332, C333). This analysis showed that for the wastes examined, on average the containers consiste d of approximately 79% inorganic waste (non combustible) and 21% organic waste (combustib le) (noting that individual containers may be highly variab le). Reference C347 is dated 1976 and states that wastes were segregated into combustible and non combustible material at that time, due to radiolysis concerns, so there is evidence to suggest that pr ocedures required waste separation very early in the program. While no other written references were prepared by INL-CCP that summarize their assessment of pre-1990 waste, INL-CCP presented its analysis in inte rviews with the EPA inspection team member(s). IN L-CCP representatives indicated that prior to 1984, waste form was identified only as “combustible” or “non-combus tible”, with no other a dditional descriptors. INL-CCP representatives also indicated that between 1984 and 1990, more detailed descriptions could be found, but upon examination, each data sheet showed that the site identified nearly the

same waste contents for each container. Theref ore, INL-CCP representa tives felt that only post1990 data were of sufficient detail to support the detailed analysis that was presented in C332 and C333. EPA examined the references provi ded (e.g., U022) and agrees that available19 information is not amenable to detailed physical drum content assignment for drums generated prior to 1990. INL-CCP indica ted, during interviews, that it had compared the number of containers identified prior to 1984 as being combus tible or noncombustible and compared that to the detailed analysis. Pre-1990 containers were approximately 75% noncombustible and 25% combustible, which agreed with INL-CCP’s detailed analysis of the post-1990 waste 29% combustible, 71% noncombustible). The WCPIP a llows the assumption to be made that all

debris waste containers are filled with plastic, so detailed id entification of RH WMPs for the purposes of WWIS input is not required. Howe ver, according to EPA regulations, assessment and documentation of physical and chemical WMPs are necessary to ensure that the waste stream is appropriately assigned.

Radiological data pertaining to content of waste drums is addressed in several documents, including those referenced by INL-CCP in the response to EPA’s comments on the AK procedure as well as EDF-6946 and EDF- 6685. EDF-6685, Appendix A, presents the radiological composition (Pu and 235 U) for each fuel pin identified by INL-CCP. In general,

EPA’s examination of EDF-6685 showed that 72% of the identified pins contain both Pu and U, with 28 percent containing only 235 U. EPA also examined available data (EDF-6685 and EDF6946) for each waste lot to ensure that each lot and therefore each drum contained TRU material as identified through AK. EPA’s evaluation showed that for Lots 0–20 8 , at least one fuel pin containing both Pu and U is associated with each lot, verifying that some level of Pu could be expected in each drum based upon available AK. These documents did not fully address EPA’s concerns regarding radiologica l contents of waste drums reported in AK documents. EPA, therefore, conducted additional interviews with INL-CCP AK personnel to understand and assess how data are used to develop the gross radiologi cal characteristics of th e waste and radiological components within the waste and assign the waste stream designation with respect to radiological constituents. These interactions assi sted EPA in determining that the waste stream was appropriately assigned and its radiological contents were reported.

To further evaluate whether the waste stream was appropriately assigned from a radiological perspective, EPA examined the AK-id entified radionuclide (i.e., Pu and 235 U) ratios found in the

AK records with EDF-6685 to assess common elemen ts between waste streams. This evaluation

showed that the Pu/U ratio for Lots 1–20 varied by two orders of magnitude, i.e., 0.06 to 1.38 9

. INL-CCP identified additional data in EDF-6946 that were not included in the fuel pin and lot assignments presented in EDF-6685. Inclusion of the values from EDF-6946 tightened the

Pu/ 235 U distribution such that 21 of the 25 lots and sub-lots examined in EDF-6946 had Pu/ 235 U ratios between 0.4 and 0.85, with three values ab ove 1 (Lots 2, 10, and 16) and one value below 0.1 (Lot 11). The purpose of this analysis was to assess the comm on elements of the radionuclide content among specific wastes based on available data, and it was not intended as a measure of expected waste content. This ex amination showed that when additional INL-CCP data are taken into account, the waste stream exhibits a similar radiological content.

8 In some cases Lots 0-20 were subdivided into Sub-lots, resulting in a total of 25 groupings.

9 This estimate is based solely on AK Lot Records, not on individual fuel pin data. However, individual fuel pin ratios presented in EDF-6685 show a similar Pu/ 235 U distribution for pins containing both 235 U and Pu, i.e.,

0.007 to 0.49.20 INL-CCP personnel were interviewed to understa nd their perspective on AK determination of radiological constituents in each drum as assi gned through AK. Additional references (C348 and C350) were provided during the interview to cl arify INL-CCP’s positi on. INL-CCP personnel indicated that drum-specific radiological data are available for each cont ainer (C348), these data

confirm EPA’s assessments that AK indicates eac h drum would contain TRU material, and the Pu/U ratios are equivalent to the ranges identif ied by EPA. However, INL-CCP also pointed out that the type of radiological da ta available for each drum is highly variable and that many identify only the 235 U and Pu (presumably 239 Pu) content. INL-CCP identified several additional fuel pins and other information that may conflic t with this AK information on a drum-by-drum basis. EPA agrees that there are uncertainties associated with the historic drum-specific assignments made by ANL-E, but th e overall data show that the wast e consists of materials that are similar with respect to radiol ogical content. EPA concludes th at the available data indicate that the waste stream is appropr iately assigned from a radiological perspective. This approval applies only to the waste stream examined during th is inspection. Specifically, it applies only to the waste stream as specified in AK documenta tion for Lots 1–20 that the EPA inspection team reviewed, and does not apply to wastes that orig inated outside of the AGHCF, e.g., K Cell. Any new waste stream(s) or additi ons or modifications to INL Waste Stream No. ID-ANLE-S5000 Lots 1 through 20 is a T1 change. (See Table 1, where this is included as a T1 change.)

Status of Concern: Based on the information examined, the EPA inspection team determined that the waste stream has been appropriately defi ned with respect to physical characteristics. This concern is also addressed under (4), below. Based on the discussi ons presented above, EPA

considers this concern closed.

(2) The identification of high-level waste (HLW), TRU versus low-level waste (LLW), and spent nuclear fuel (SNF) was examined.

CCP-AK-INL-500 indicates that SNF is separated from the RH debr is waste that was generated through testing of this fuel and is therefore not included in this wa ste stream. INL-CCP representatives interviewed indicated that HLW, by definition, is not included in this waste stream. See item (16)

, below, for a discussion of load management.

(3) The detailed AK-based drum analysis pr ocess introduced in CCP-AK-INL-500 for drums

728–737 was examined.

The WCPIP requires that as much container-spe cific information as possible be assembled (Attachment A, Section 5.2). While a large quantity of detailed information for wastes has been assembled (much of which is drum or lot speci fic), INL-CCP did not perform detailed analyses of each item to develop AK-based drum radiol ogical values. INL-CCP, however, did examine and present an analysis performed on a subset of these containers.

The examined references, P030, P590, P591, P592, P593, P594, P595, and P596, document a detailed data assembly and analysis activity designed to assess and assign drum-specific radiological values based on AK a nd related calculations/modeling. The process also underwent peer review. The analysis was performe d in 2002–2003 for a 10-drum population (Drums 728–21 737) from Lot 16 10 , generated from 1990 to 1991. The appr oach focused first on determination of isotopic values for each drum based solely on the AK record, with modeling and other data manipulation or calculations performed to acquire the additional radiological data required in the

WCPIP. Examination of records for these 10 drums was performed to determine actual waste contents provided pre- and post-irradiation fuel element compositions. Ultimately, these efforts

resulted in the identification of fuel element compositions (pre- and post- irradiation values) and

identification of 234 U, 235 U, 236 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 241 Pu, 242 Pu, 241 Am, and 237 Np. Postirradiation compositions were sometimes evalua ted via computer code (BURNOUT, ORIGEN). The effort resulted in assignment of radionuclide compositions to the 10 examined containers, and several supporting references further document the approach used to generate “actual” radionuclide values based on AK (P590, P591, P592, P593, P594, P595, and P596).

These documents show that detailed analyses of AK data assembled for each drum can be performed to determine, in some detail, th e estimated radiological content of each lot, recognizing that the process to develop an accurate and complete picture requires analysis well beyond that performed by the generator site, ANL -E (see item (1), above , and reference C350). This activity is also an altern ative approach to characterizing waste based on the AK record that does not use DTC in the manner currently proposed by INL-CCP, but instead uses various calculations and modeling efforts to determine valu es for the individual waste drums. INL-CCP has indicated, and EPA agrees, that this approach is time consuming (e.g., two years for 10 drums alone), and various assumptions and questions may still remain that could bring considerable uncertainty to this approach (see reference C350). This al ternative approach has not been used at INL–CCP; therefore, EPA did not evaluate it in depth.

(4) Sufficiency of the AK summary was evaluate d, as well as implementa tion of AK as required

in Attachment A of the WCPIP.

Attachment A of the WCPIP specifies that the following be incl uded in AK summaries:

• Executive summary

• Waste stream identification summary

• AK data and information description

• Program information

• Waste stream information

• Qualification of AK information

• Container-specific information

Attachment A presents a process to collect and an alyze data similar but not identical to what is

used for CH waste that should be followe d. Both the content of the AK summary and sufficiency of AK implementation were assessed. Note that based on the EPA requirements, the DQOs will require revision to include identifi cation and quantification of the 10 EPA WIPPtracked radionuclides in CCP-INL-CCP-AK- 500. The AK summary was found to not adequately address several issues , including the data assembly process, and these were combined

10 The intent is to reference a discreet number of c ontainers (Drums 728-737) that the EPA inspection team thought were designated as Lot 16; however, these contai ners may in fact have a different lot designation.22 and recorded on one EPA Inspection Issue Tracki ng Form. (See Attachment B.4 of this report for this form.) This concern is also discussed under item (1), above, and is presented below in four parts:

EPA Inspection Concern No. INL-CCP-RH-AK-06-005CR, Part 1, DQO and AK Qualification 11 : Attachment A of the WCPIP requires that for each DQO related to AK, AK personnel must identify the DQO and s upporting AK information, justify the assignments/conclusions, reference the AK sour ce documents and applicable pages supporting the assessment, and identify th e qualification method in 40 CFR 194.22(b) that will be used to qualify the AK.

Resolution: INL-CCP responded to EPA’s concern by revising Chapter 6 of CCP-AK-INL-500, Revision 3, to state that a "combination of methods" will be used to qualify AK information. Table 6 was added which presents the AK qualif ication method for each DQO. Table 6 shows that there is no qualification me thod for AK-derived defense determinations, consistent with the

WCPIP and the fact that defense determina tion is based entirely upon AK and may not be qualified by measurement.

Status of Concern: Upon reviewing INL-CCP’s response, EPA closed this part of the concern.

EPA Inspection Concern No. INL-CCP-RH-AK -06-005CR, Part 2, Identification of

Inundated Drums: EPA’s concern was that the AK summary implies that some containers in this population may have been submerged in a fe w of the vaults. The AK summary states that none of the approximately 70 containers whose videotapes were revi ewed during VE were inundated, while others may have been. The discussion does not clea rly indicate the total number of drums in the stream, the number of drums suspected of having been inundated, and how the inundated drums will be handled or otherwise managed.

Resolution: INL-CCP responded to EPA’s concern by indi cating that several drums were either submerged in vaults or showed evidence of havi ng been submerged, thus indicating that there could be water present in these containers. IN L-CCP revised the AK summary to state that of the 549 drums in the waste stream, 34 were either retrieved from water in the vault, retrieved from a vault that once contained water, or exhi bited evidence that the drums were exposed to water. These 34 will undergo radiography to ensure that the drums have not been inundated with water. EPA expects that INL-CCP will tag and se gregate drums in these categories for additional analysis. EPA also expects that radiography will be used to ensure that containers do not include any prohibited items, including liquids.

Status of Concern: EPA will evaluate INL-CCP’s confirmati on of the absence of water in these 34 drums and other “suspect” drums when EPA inspects the use of radiography for INL-CCP’s RH WC program. EPA considers this part of the concern to be closed.

EPA Inspection Concern No. INL-CCP-RH- AK-06-005CR, Part 3, Documentation of

Defense Determination and Was te Stream Justification: Documentation for the waste’s

11 AK Qualification is the term used in the WCPIP, Revision 0D . Using DTC, INL-CCP is confirming AK and not qualifying AK in lieu of NDA, a meas urement technique used for CH TRU waste.23 defense determination was not included in the records the EPA inspection team evaluated, and these records did not provide information that clearly supported the waste stream definition. Specifically, they did not fully document the ba sis for INL-CCP’s conten tion that the wastes generated in the cells were neve r segregated by fuel pin or gene rator, thus precluding INL-CCP from assigning a fuel pin or radionuclide specific content to individual wast e containers. This is of key importance since it supports INL-CCP ’s approach to assigning the radiological characteristics of the fuel pi ns to the entire population.

Resolution: In response to EPA’s concern, INL-CCP revised the AK summary to include Table 6 listing AK source documents that INL-CCP uses to support the defense determination. As written, CCP-AK-INL-500, Revision 3, implie s that many nondefense activities were performed at ANL-E and these activities generate d wastes. INL-CCP stated that since some

defense activities occurred at ANL-E and the wast es from these activities are commingled with the nondefense waste, all commingled waste is defense related. While CCP-AK-INL-500 does not clearly show that defens e-related activities occurred ear ly in the process, INL-CCP representatives pointed out that the defense-related activities were performed in the AGHCF throughout the time that waste wa s generated in the hot cell.

Status of Concern: Based on the information INL-CCP provided and the subsequent discussion, EPA determined that this part of the concern is closed.

EPA Inspection Concern No. INL-CCP-RH-AK- 06-005CR, Part 4, Inclusion of Additional Radiological Data: The radiological data presented in the AK summary do not present a good understanding of the overall is otopic distributions that are applied to Waste Stream No.

ID-ANLE-S5000 based on AK. While CCP-AK-INL-501 presents how each container is assessed, the AK summary in CCP-AK-INL 500 should still include a general discussion of the overall anticipated distribution on a waste stream basis, particular ly since AK is used to address all DQOs. Page 40 presents information for drums from 1990–1995, but more information

should be included for the entire waste stream.

Resolution: INL-CCP responded to EPA’s c oncern by modifying CCP-AK-INL-500, Revision 3, Section 5.4.2.1, to includ e text and Table 5 that summari zes the reported radiological content of waste drums as reported by ANL-E. Th e text of the AK summar y was also revised to state that “...the radionuclides reported by ANL-E varied significantly over the time period of waste shipment to INL, which is reflected in Table 5.”

Status of Concern: Based on the information INL- CCP provided and the subsequent discussion, EPA determined that this concern is closed. EPA requires that INL-CCP notify EPA through a T2 change notice that CCP-AK-INL-500 has been revised or updated to include radiological and other information obtained th rough verification. Consistent with EPA’s authority under 194.24(h), EPA may re quest this information if EPA deems it necessary to ensure continued compliance with EPA regulations. (See Table 1 where this is included as a T2 change.)24 (5) Data traceability was examined.

Traceability of data was assessed on various levels. Data traceab ility from the AK record to

waste drum or waste lot content was assessed and is addresse d herein. Note that there are 617 drums of waste, 549 of which or iginated in the AGHCF. INL-CCP did not examine the other 68 drums of waste, so they are not included in th is waste stream nor are the post-1995 drums, which number 50–100 according to INL-CCP. When INL- CCP adds any of the 68 drums from the pre1995 time period or those generated since 1995, EPA will review this new information added to the AK for debris waste evaluated during this in spection as a T1 change , as discussed above. (See Table 1, where this is included as a T1 change.)

Because the fuel pins contribute directly to the radionuclide c ontent in waste generated through analysis of these pins, fuel pin data traceabilit y was performed to understand the types of data available for each fuel pin. Data for Index Nos. 297 (AG 421E), 293 (AG 421A Fuel Element UBA-15) and 311 (AG 429A) were chosen for exam ination of data and traceability, and this

information is also included in EDF 6685. Availa ble data for each fuel pin includes: the Fuel Element Summary Sheet for ANL fuel pins pr epared by INL-CCP; weight, radiological, and other data from the origination site; safeguards an d materials management report data; individual pin burnup calculations; and fuel composition by AG or fuel pin number. Data for each fuel pin/index number may not be the same, but INL-CCP has attempted to collect all available data regarding each fuel element and su mmarized the available information.

AK data traceability for Waste Can Inventory Sheets and Waste Package Data Sheets provided for Drum Nos. 00739, 00740, 00741, 00742, and 00743 was also examined. These sheets present general waste content information and measurement data, but do not provide isotopic information. Radionuclide information is conveyed upon Loss or Gain of Materials forms (SPM-23) and Fuel Element Listi ngs that provide the fuel elements/waste lots and ultimately

estimate the Pu and 235 U quantities per drum in grams. No te that the AK summary states that once the Pu value per drum was obtained, “...the isotopes 239 Pu, 240 Pu, and 241 Pu were calculated by multiplying the total value by a percentage to obt ain the grams of each.” INL-CCP states that the values from 1990–1995 showed a relatively cons istent distribution, and provided reference C348 that summarizes assembled radiological data for each. Several references (e.g., EDF-6685) include drum or lot-specific data. Based on this analysis, the traceability of available information for both fuel pins and drum/waste lot contents was demonstrated.

(6) Sufficiency of AK support documents a nd related document tr acking was evaluated.

An AK Source Document Reference List was prepar ed using unique identifi ers for the different document types following the format used by IN L-CCP for CH wastes. The listing provided is based on CCP-TP-005 Revision 17, Attachment 4, and is dated June 13, 2006. The listing appears complete, and is easy to understand becau se it follows the same format that INL-CCP uses for CH waste streams. Several AK support documents were referen ced in the text; those

references examined to date address the elemen t or issue that is referenced with the AK summary, although applicability does vary. It sh ould be noted that EPA only examines support documentation specific to the technical element be ing referenced in the AK summary that caused that support reference to be se lected for examination. If any information is added to either25 CCP-AK-INL-500 or CCP-AK-INL-501 that modifies the characteri zation approach or changes the understanding of radiological or physical content of wastes in the stream as currently defined, this would be considered a T1 change. (See Tabl e 1, where this is included as a T1 change.)

(7) Interpretation of WCPIP, with respect to co ntents of the Certificati on Plan and Confirmatory Test Plan (CTP) was evaluated.

EPA’s RH WCPIP Framework approva l letter indicated that sites must generate a Certification Plan that explains how RH waste characterization will take place at each site, as well as a CTP, when required. EPA’s intent was that the sites present how charac terization is to take place on a waste stream basis, followed by a detailed pl an explaining implementation of confirmatory testing when this is to take place. INL-CCP personnel interviewed had different interpretations of some aspects of the WCPIP, and hence differe nt opinions as to what the Certification Plan

should contain versus the CTP. EPA understands how this has occurred, as the WCPIP lends itself to different interpretations . EPA learned during the inspecti on that INL-CCP intends to use AK qualification for every DQO possibl e, and that they intend to prepare a CTP for each waste stream that describes, in detail, how that waste stream will be characterized including qualification methods (e.g., Peer Review) other than confirmation. EPA noted that “where” the detailed waste stream characterization process is presented should be clarified, and recorded these issues on EPA Inspection Issue Tracking Fo rms, as discussed below (see Attachments B.5 and B.6, respectively, for these forms). IN L-CCP-RH-AK-06-006CR is also discussed under item (15), below.

EPA Concern Nos. INL-CCP-RH-AK- 06-006CR and INL-CCP-RH-AK-06-007CR: Specifically, EPA’s concern in INL-CCP-RH-AK -06-006CR was that INL-CCP representatives stated that AK qualification will always be the ap proach used to meet DQOs. As such, INL-CCP will always prepare an AK CTP fo r each waste stream that presen ts a description of each DQO.

The CTP must be revised to indicate that AK qualification is the selected DQO determination methodology for each DQO and to specify the qua lification pathway se lected, including a detailed discussion of confirmatory methods used. Based on EPA requirements, the DQOs will require revision to include identification and quantification of the 10 WIPP-tracked

radionuclides.

EPA Concern No. INL-CCP-RH-AK-06-007CR was based on the fact that INL-CCP representatives indicated that AK qualificati on will be the method by which DQOs will always be addressed. Based on this, EPA expects INL-CCP to examine site documents that discuss the characterization methodologies to ensure that each reflects the requirements presented in the WCPIP when AK qualification is used. For exampl e, the WCPIP requires that [the] certification plan include how the DQOs will be addressed, and EPA indicated that this should include waste stream information. INL-CCP representatives i ndicated that a CTP will be prepared for each

stream and will include this information. Theref ore, EPA expects INL-CCP to ensure that this commitment is clearly cited in related documents such that the CTP always fulfills this requirement. Note that based on EPA requireme nts, the DQOs will require revision to include identification and quantification of the 10 WIPP-tracked radionuclides.26 Resolution: INL-CCP responded to EPA’s concerns by recognizing the conflicting requirement of providing detailed information in the Certific ation Plan (per EPA’s letter) versus their intent of including this information in a CTP. INL- CCP combined the CTP and Certification Plan (CCP-AL-INL-502, Revision 2), and included in this plan their intent to qualify almost each DQO using AK qualification. Chapter 1 of CCP-AK-INL-502, Revision 2, states that “Acceptable Knowledge will be used to documen t that each RH TRU waste Data Quality Objective (DQO), with the exception of the payload container ba sed parameters, have been met.” Chapter 4 addresses the methodologies for the de termination of DQOs. EPA acknowledges that each of the DQOs will be verified through the applica tion of radiological characterization and VE/RTR. Payload container-based parameters such as the Land Withdrawal Act (LWA) limit of 23 curies per liter will also be determined via radi ological characterization.

INL-CCP created Revision 17 of CCP-PO-002 to a ddress this modification. These modifications have adequately addressed the requirement to cl arify that AK data is the source of all but one DQO, and there are various methods to verify the AK. Note that the document makes a single mention of the QA equivalency determination us ed to verify ORIGEN2.2 using the LANL mass spectrometry data. The technical aspect of this element was determined to be adequate by EPA (see Section 8.2). CCP-AK-INL-502 has been modified to state that the 10 WIPP-tracked radionuclides are to be identified and reported, but does not specifically state that they will be quantified. The approach discussed in CCP-PO- 002 adequately addresses EPA’s concern. As

INL-CCP adds new waste stream to AK or if the current plan is revised, EPA expects that INLCCP will prepare or revise the Certification/C onfirmation Plan to address each waste stream. Changing the current plan for the approved waste st ream is a T1 change. (See Table 1, where this is included as a T1 change.)

Note that the revised Certific ation Plan, provided in response to EPA’s concern, has numerous changes that appear unre lated to this concern; EPA has not reviewed these changes for adequacy

at this time. EPA notes that revisions to th e WCPIP have been proposed. EPA requires that INL-CCP notify EPA through a T2 change notice if implementation of this revised WCPIP results in changes to the INL-CCP documents. Consistent with EPA’s authority under 194.24(h), EPA may request these revisions if EPA deem s they are necessary to ensure continued compliance with EPA regulations. (See Table 1 where this is included as a T2 change.)

Status of Concern: Based on the above discussions, EPA cons iders these concerns to be closed.

(8) Content and technical adequacy of th e Confirmatory Test Plan was evaluated.

The WCPIP requires the following to be included in the Conf irmatory Test Plan (CTP):

• A description of the waste stream or waste stream lots to which the plan applies

• A description of the confirmatory testing proposed, including the percentage of waste containers that will be subj ect to confirmatory testing

• An explicit description of the waste ch aracterization DQOs and QAOs that will be satisfied with the data being qualified27 • A description of the DQOs and QAOs that wi ll not be confirmed with the data being qualified and an explanation of how compliance with those DQOs and QAOs will be

demonstrated

• A description of how the tested subpopulation will be represen tative of the waste stream

or waste stream lot

INL-CCP revised the CTP in response to EPA comments (see item 7, above). The revisions presented the proposed characterization plan for individual waste streams, and now is a

combined CTP and Certification Plan. The revi sed CTP includes the required technical elements presented in the above listing. The requirement identifying the percentage of containers that undergo confirmatory testing is confusing becau se none of the actual containers at INL will undergo confirmatory testing. Instead, CCP sought to demonstrate that drums containing fuel pins that were assayed by mass spectrometry (MS) at LANL are comparable to the wastes at INL. The MS data would be qualified by the de termination of an equivalent QA program, and the 400 pins that were assayed by MS would be considered to have undergone confirmatory testing. Physical form and residual liquid conf irmation is achieved th rough 100 percent VE or, at a later date through radiography. This desc ription is accepted as meeting the requirement presented in bullets 1 and 5, and the technical ad equacy of the information and conclusions is

addressed in Section 8.2.4.

The revised CTP also addresses DQOs, and has a new section that deals with AK QAOs and application of AK accuracy. See item 15 for techni cal evaluation of this information, noting that inclusion of AK accuracy determinations unde r the DQO for Defense Determinations is inappropriate and the information should be include d elsewhere or in a st and-alone section. The adequacy of DTC with respect to addressing related DQOs is addresse d in Section 8.2.2.

(9) Content and technical adequacy of the Char acterization Reconciliati on Report was evaluated.

EPA evaluated CCP-TP-506, Revision 1, CCP Preparation of the Remote-Handled Transuranic Waste Acceptable Knowledge Charac terization Reconciliation Report, to determine whether this document reflected the assembly of informati on required in the WCPI P. Additionally, EPA

evaluated the Characterization R econciliation Report (CRR) to see whether this report reflected requirements of CCP-TP-506, to ensure that the CRR addressed requirement elements as specified in the WCPIP, including:

• Specification of applicable site and waste stream

• A listing of each DQO

• Data from the AK record that addresses each DQO

• AK source document references th at support/provide the data

• A listing of AK record discrepancy resolutions , if any, that are relevant to each DQO

• Documentation, including specific references , of how the AK data for each DQO were qualified, such as batch data reports, corrobor ative data, proceedings of a peer review,

etc.28 • Radiography and/or visual examination summar y to document that liquids greater than 1 percent are absent from the waste and to confirm AK concerning the physical properties

of the waste

• A summary presentation of radiological measur ement data used to meet the DQOs and to

confirm AK

• A complete AK summary

• A complete listing of all container identific ation numbers used to generate the WSPF,

cross-referenced to ea ch batch data report

• A listing of AK discrepancies generated by an AK qualification process and the corresponding resolutions

• Signature of the SPM

The example the EPA inspection team examined included all of the above requirements when taken as a whole. The CRR DQO worksheet (Att achment 3 of CCP-TP-506) lacks a listing of the 10 WIPP-tracked radionuclides as part of the DQO assessment process, and these radionuclides need to be specified, quantified, and assessed as part of the CRR. Site representatives declined to spec ifically address these because the WCPIP does not specifically require this inclusion, but EPA’s rule specifi es de facto limits fo r the ten WIPP-tracked radionuclides based on modeled quant ities. Therefore, EPA expect s that INL-CCP include these radionuclides in the DQO analysis. EPA requi res that INL-CCP notify EPA through a T2 change notice upon completion of the CRR with re lated changes and the revised Waste Stream Profile Forms (see item (14), below). Consiste nt with EPA’s authority under 194.24(h), EPA may request this information when EPA deems it necessary to ensure continued compliance with EPA regulations. (See Table 1 where this is included as a T2 change.)

(10) Use of a Correlation and Surrogate Summary Form was evaluated.

Completion of a Correlation and Surrogate Summary (CSS) Form is required when AK information from a related CH waste stream is used in the RH waste characterization process. INL-CCP representative indi cated that CH data was not used in this manner

. However, a CSS was completed to support the use of LANL mass spectrometry data to verify ORIGEN2.2 model that is used to generate INL data. The use of a CSS for this purpose is satisfactory, but does not discuss why the form is required, e.g., in this case to allow use of destructive assay data performed on LANL fuel pins as representative or correlated to similar fuel pins at INL. If containers from this waste stream are ultimately determined to be CH waste and are segregated, NDA will be performed on these wastes. Data from the CH wastes would be available for comparison with the isotopic ra tios applied to the waste stre am under the RH radiological characterization protocol. A ccording to INL-CCP’s approach observed during this baseline inspection, when this occurs the information will be documented on a CSS Form. In the proposed decision EPA required th at INL-CCP provide this info rmation under T2 change notice process. EPA received a comment objecting to obta ining this information as a T2 change. (See Attachment C, Comment No.10). Upon review of the comment EPA concurs with the reasoning provided by the Commenter and EPA agrees with the Commenter. (See Attachment C for the EPA response to Comment No. 10). EPA is re quiring that INL-CCP notify EPA through a T229 change notice regarding the inclusion of isot opic ratios obtained from NDA of a CH waste stream that was previously considered to be RH as a T2 change. Consistent with EPA’s authority under 194.24(h), EPA may request this information if EPA deems it necessary to ensure continued compliance with EPA regulations. (See Table 1 where this is included as a T2 change.)

(11) Personnel training was evaluated.

Training records for Kevin Peters (AKE), Steve Sc hafer (AKE), Lisa Price (AKE), Larry Porter (SPM), Michael Walantine (SPQAO), and Jene Vance (SME) were evaluated with respect to: training to the RH TRU WCPIP; non conformance and corrective action processes; the AK procedure presented in Attachment A of the WCPIP; site-specific training relative to the contents of the subject waste stream(s); and determination of radiological contents of individual drums. Each person demonstrated training in the first f our areas. With respect to determination of radiological contents of each drum, only Jene Vance’s expertise was examined since he

assembled and assessed AK data that were used to derive the scaling factors. Although Mr. Vance did not show direct training with respect to this area, his resume showed considerable expertise suitable to de monstrating proficiency.

(12) AK traceability of LANL mass spectrome try information and information/data relationships were examined.

INL-CCP has proposed the use of mass spectrometr y data obtained from LANL to verify the output of the ORIGEN2.2 for INL data. INL-CCP contends that the LANL and INL (ANL-E) pins have similar origins, overlapping experimenter s, similar if not the same reactor irradiation or sources, and therefore have sufficiently similar radionuclide cont ent, so the use of LANL data for this purpose is appropriate. Of the 506 fuel pins identified, approximately 62% are associated with EBR-II, and the rest are from va rious reactors, i.e., Unirad and Shippingport. Most fuel pins are from the Fast Breeder Fuel program, although some were also from light water and other reactor types. Specifically, INL- CCP states that: “Mass spectrometry results for a total of 400 fuel pins were located and retrie ved. The mass spectrometry measurements were conducted under a QA program which has been evaluated to be equi valent ...to NQA-1 and, therefore, these data are acceptable as AK inform ation.” INL-CCP also states that “...On the

basis of the similarities between the two fuel pin examination programs, the fuel types, the sources of the pre-irradiation fuel composition and burnup information, and the identical reactors for a majority of the fuel pins, the LANL conf irmatory sampling is sufficient to satisfy the qualification required for the INL AK informati on.” EPA found that the above statement required additional references to support the assertions and issued an EPA Inspection Issue Tracking Form (see Attachment B.7 for this fo rm). This concern is discussed below.

EPA Concern No. INL-CCP-RH-AK-06-008CR: EPA’s concern was that CCP-AK-INL-501 includes several statements, assumptions, and argument s that lacked references to calculations or other information to support th e arguments. In particular, several other documents (CCP-AKINL-500, CCP-AK-INL-502, etc.) stat e that CCP-AK-INL-501 shows that LANL and INL fuel pins had many common elements. The brief discu ssion on page 33 states th at: “On the basis of the similarities between the two fuel pin examinati on programs, the fuel type s, the sources of the30 pre-irradiation fuel compositions and burnup information, and the identical reactors for a majority of the fuel pins, the LANL confirmatory sampling is sufficient to satisfy the qualification required for the INL AK informati on.” However, the document does not cite

references or other detailed information to s upport this assertion. The document provides charts and other comparisons between pins and INL fuel pins, but the specific INL fuel pin numbers

and related data and calculations are not referenced. Table 5-1 presents a summary of sponsors associated with ANL-E and LANL pins, but of the top three sponsors for LANL and ANL-E, only one was common to both. Additional inform ation that better supports the commonalities

between the two sites in the text of CCP- AK-INL-501 is necessary, e.g., the 33 calculation packages that support the development and application of ORIGEN2.2. The documentation lacked a strong link between th e INL and LANL fuel pins. Accordingly, EPA was unable to confirm the findings and results.

Resolution: INL-CCP responded by adding references to the calculation packages, as well as by adding text and a table to Section 5.0 in CCP-AK-INL-501. This information presented experimenters common to LANL and INL, and locatio ns of fuel pins to sh ow that seven of the experiments involved in the fast breeder program were conduct ed at both ANL-E and LANL. INL-CCP’s description, however, doe s not clarify whether these fuel pins also had MS data

associated with them.

Status of Concern: The relationship established by INL-CCP for the LANL and INL pins is

sufficient. EPA considers th is concern to be closed.

INL-CCP found seven different expe rimenters who shipped fuel pins to both LANL and INL for examination. Two of the seven experimenters sent more than one PIN/AG to each, so a total of nine fuel pins were common to LANL and INL. The fuel pins identified were examined during creation of waste Lots 2, 3, 7A, 7C, and 8B; all but one of the fuel pins were irradiated at EBR-II. Upon interview, it was determined that the above analysis is the most significant traceability identified by INL-CCP between the INL (ANL-E) and LANL fuel pins. While the

data do show that there are at least seven individual experiment ers common to both sites, it does

not show that the LANL MS data were common to pins at both LANL and INL. It is understood that a majority of fuel pins associated with both sites were irradiated at EBR-II, and would therefore have a common isotopic signature. INL- CCP has not directly esta blished that the fuel pins with MS data are equivalent to or repr esentative of LANL fuel pins or a significant population thereof, and that these fuel pins are “e quivalent” to or representative of the INL fuel pins (in whole or in part). It should be noted that the MS results are used to verify the ORIGEN2.2 output and are not used as direct input to any of the adjustments or scaling factors for INL RH waste. Therefore, establishment of this relationship in the manner presented by INL-CCP is sufficient, since the MS data are not directly used in the INL calculations other than to verify the model. Note that this analysis does not address the gra phic presentation of data representativeness shown in Chapter 5 of AK-INL- CCP-501; evaluation of these presentations is presented in Section 8.3 of this report.

It must also be pointed out that INL-CCP makes the basic assumption that material from all fuel pins may be present in every waste container. INL-CCP base s the analysis presented in AK-INL-CCP-501 upon this assumption, and builds th e remainder of the analysis on fuel pin31 commonalities. EPA’s examination showed that each lot contained material from pins that were irradiated by EBR-II and, assuming that EBR-II imparted a common radiologi cal signature, each

waste lot has this common thr ead, thus supporting INL-CCP’s contentions regarding common radiological constituents. Howe ver, INL-CCP proposes a “waste stream” rather than a “waste container” approach that is applicab le only for this RH waste stream.

(13) Non Conformance Reports (NCRs) and Discrepancy Resolution (DR) Forms were

examined.

NCR-RHINL-0004-06 is among those provided to EPA to assess documentation of NCRs. Unfortunately, this NCR did not include enough information to determine the reason for the NCR. Discrepancy Resolutions (DR) DR11 and DR10 were also provided for examination. DR11 addresses waste requisition and video discrepancies, while DR10 concerns a discrepancy regarding the volume of a 7-gallon waste can. This information suggests that INL-CCP can adequately prepare NCRs and DRs to document nonconforming items or containers, as well as the types of discrepancies presen ted for review. EPA was not provi ded a specific example of an AK-AK discrepancy resolution i nvolving radiological compositi on of waste, although INL-CCP representatives indicated that drum/lot AK da ta had been assessed and was not called upon to provide an absolute or qualitative comparison on a drum or lot basis. EPA expects that INLCCP will include AK-AK discrepancies in the AK record as they are identified.

(14) A waste stream profile form was examined.

An example Waste Stream Profile Form was examined for Waste Stream Number ID-ANLE-S5000. The form included required line items as presented in the WCPIP, Attachment 4; the CRR and RH AK summary are al so required for submission to CBFO to allow

assessment of the WSPF. EPA understands that th is form is abbreviated because it was provided for audit purposes only, and expects that the completed form will include more AK data, checklists, etc., to better present the required information. See comments above pertaining to CRR and AK Summary for additional information. In the proposed approval, EPA required that INL-CCP submit this information to EPA through a T2 change notice. Instead, EPA is requiring that INL-CCP notify EPA regarding the availabi lity of the completed, final WSPF with all related documentation, including any subsequent re visions to this approved WSPF, through a T2 change notice. Consistent with EPA’s au thority under 194.24(h), EP A may request this information when EPA deems it necessary to ensure continued compliance with EPA regulations. (See Table 1 where this is included as a T2 change.)

(15) AK accuracy was assessed.

AK accuracy was assessed with respect to the requi red contents as presented in the WCPIP. The WCPIP requires AK accuracy to be assessed in three areas: r eassignment of the waste to a different Summary Category Group; reassignment of the waste to a different waste stream; and, stream-specific assessment of radiological pa rameter accuracy. AK accuracy of the first two parameters was adequately documented for the c ontainers in the lot that were examined. INL-CCP stated that only one radiological DQO, co mparison of survey results with AK data that classify the waste as RH, shall be a measure of AK radiological accuracy. However, if INL-CCP32 uses confirmatory testing for any radiological parameter, EPA expects that the evaluation of AK accuracy for that parameter will be performed. EPA presented this on an EPA Inspection Issue Tracking Form (see Attachment B.5 for this form) and it is discussed in item (7), above, as well

as below.

EPA Concern No. INL-CCP-RH-AK-06-006CR: This concern stated that the CTP includes the proposed approach for assessing [radiologi cal] AK accuracy, which is only the verification that waste is RH as identified by AK. The CTP also assumes that the CCP-501 document has established “no significant di screpancies” between AK information and confirmation of modeling/sampling. However, this assumes that the LANL MS data are demonstrated to be applicable, and EPA has not fully assessed CCP -AK-INL-501, which presumably includes this information. Since AK qualification and confirma tory testing are used for all radiological parameters, it would appear that each radiological DQO should be evaluated with respect to how the confirmatory data collected will be assessed as part of AK accuracy (if this is not feasible, a detailed argument should be included). The accuracy report should be revised accordingly.

Resolution: INL-CCP responded by revising CCP-AK -INL-502 to produce Revision 2 that addresses the determination of AK accuracy for the AK-based radiological parameters that are

discussed below.

TRU Waste Determination : AK accuracy was determined in two parts. Part 1, isotopic abundance assessment, has already been comple ted, and CCP-AK-INL-501 st ates that there are no significant discrepancies between AK informa tion used in the modeling and the qualification of that AK (modeling and sampling). Part 2 of the AK accuracy determination will be accomplished through measurement comparison against AK documentation that shows the waste as being TRU waste. EPA’s analysis of this with regard to Part 1 was that fuel pin data and related burnup are used in modeling, and the result s of this modeling were verified by LANL MS

data. INL-CCP does not address how the c ontent of the drums with respect to TRU radionuclides as defined by AK will be compared to the ultimate radionuclide content assigned to that drum using the applicati on of DTC/scaling factors. INL- CCP representatives contend that

the AK-identified content is in sufficient (see item 1 above and reference C350), although detailed analysis has been performed on a sele ct waste drum population for which AK accuracy could be determined. In the proposed deci sion EPA identified a comparison of radionuclide

values based on AK with radionuclide values deri ved by the application of the application of DTC/scaling factors as a T2 ch ange. The Commenter objected to such a comparison. (See Attachment C, CBFO Comment No. 9). Upon revi ew, EPA concurs with the reasoning provided by the Commenter and EPA agrees with the Co mmenter. (See Attachment C for EPA response to Comment No. 9). Upon completion of the final DTC determination for each of the RH containers numbers 728 through 737, as identifie d in AK Reference P030, INL-CCP must notify EPA that these determinations are complete thro ugh a T2 change notice. EPA may then request

these results or other related data from INL-CCP in order to compar e how the data sets compare. Consistent with EPA’s authority under 194.24(h) EPA may request new or additional information when it is necessary to ensure continued compliance with EPA regulations. Providing notification of the completion of th e final DTC determination for each of these containers is a T2 change. (See Table 1, where this is included as a T2 change).33 RH Waste Determination : INL-CCP stated that AK accuracy will be determined by comparing the actual survey results with AK information id entifying the waste as RH wastes. EPA agrees

that containers where the external dose rate is less than RH levels because of radioactive decay of the container’s contents since collecting AK data should not be considered an actual AK discrepancy, and the AK-classified RH containers that are not currently RH whose status change cannot be attributed to decay al one on the basis of calculations would be considered against AK

accuracy.

Activity Determination : As with TRU waste determinati on, the Part 1 response deals with modeling input vs. MS data, not a comparison of the radionuclide co ntent/quantities per drum as identified by AK compared to that assigned by DTC/scaling. AK confirmation and AK record comparison for activity determination will be ac complished in two parts. Part 1, isotopic abundance assessment, has been completed and IN L-CCP states that there are no significant discrepancies between AK information used in the modeling and the qualification of that AK (modeling and sampling); this includes the “ident ification and reporting” of the 10 WIPP-tracked radionuclides. Part 2 is a comparison of the meas urement results (curies per liter) with the LWA limit of 23 curies per liter. Containers with greater than 23 curies/liter based on DTC will be counted against AK accuracy. In the same manne r as for TRU waste identification discussed above, EPA’s position is that IN L-CCP’s Part 1 response deals with modeling input from the inventory (i.e., PIN data), compared to MS re sults after both have been input to ORIGEN2.2. The response does not address comparison of ra dionuclide content of the waste drums as identified through AK, recognizing that drums contai n several different fuel pins that can have different U and Pu contents. The application of DTC/scaling essentially superimposes an overall isotopic distribution on the waste stream, re gardless of whether AK has shown individual containers or groups of containers to be dissimilar. INL-CCP repr esentatives have indicated that AK assembled by ANL-E has a number of assumptions associated with it, and is not an accurate representation of lot or drum contents, so an AK-DTC comparison would not be meaningful (reference C350). However, a detailed analysis has been performed on a select waste drum population and that information is useful for comp arison purposes to veri fy the scaling factor approach used by INL-CCP. When RH containe rs numbers 728 through 737, as identified in AK Reference P030 (Lot 16) is characterized, EP A expects INL-CCP to notify EPA through a T2 change notice. Consistent with EPA’s au thority under 194.24(h) EP A may request this information if EPA deems it necessary to ensu re continued compliance with EPA regulations. (See Table 1, where this is included as a T2 change).

Status of Concern: Based on the discussions described a bove, EPA considers this concern

closed.

An example AK memo was presented, and the me mo stated that the comparison between the modeling results using fuel pins and the ORIGEN2.2 and MS data show good agreement. Also please see the commentary above concerning the AK accuracy calculations. To date, only six containers have undergone complete characterizati on so meaningful accuracy calculations cannot be made. If future reports show accuracies less than 100%, EPA expects the report to address any accuracy issues that arise and how the cont ainers in question have been managed. EPA requires that INL-CCP notify EPA when AK accuracy reports are completed and available for EPA evaluation through a T2 change notice. EP A expects that INL-CCP will complete these34 reports on a yearly basis, at a minimum. Cons istent with EPA’s authority under 194.24(h) EPA may request these reports if EPA deems them ne cessary to ensure continued compliance with EPA regulations. (See Table 1, where th is is included as a T2 change).

(16) Load management was assessed.

The possibility that containers may exhibit less than 100 nCi/g TRU wa s evaluated. AK data presented in EDF-6685 were evaluated to determ ine the average Pu drum value, understanding that this value is a gross estimate because ad ditional data presented in EDF 6946 could impact the gram values. As such, the data were asse ssed only to evaluate the possibility that some containers may ultimately be determined to contain less than 100 nCi/g Pu (e.g., drums in Lot 11). Data suggested that INL-CCP may en counter containers that measure less than 100 nCi/g, requiring the implementation of load management. However, INL-CCP representatives also indicated th at a container would have to measure less than 10 mR/hr at 1

meter to result in a TRU content less than 100 nCi/g using the scaling factors from CCP-INL-AK-501. At that point, INL-CCP pers onnel stated that the container would be considered CH and would be segreg ated for shipment in a different waste stream. Note that the CTP states, “In the rare event th at a waste container might be 200 mrem/hr at its surface (and as such, RH waste), but less than 200 mrem/hr at th e surface when three such containers are loaded into an RH-72B canister, the canister will still be considered RH waste as defined in the LWA.” EPA expects that every container em placed in the canister will exhibit ≥ 200 mrem/hr prior to loading. If a container has a contact reading of less than 200 mrem/hr, the waste will be

considered CH waste and will be removed from the waste stream. When such segregation is not

considered and INL-CCP determines that a RH c ontainer is to be handled as CH waste, EPA requires notification of the decision to take these actions and the supporting rationale concurrently when the issue is first presented to CBFO. This is a T1 change. (See Table 1, where this is included as a T1 change).

(17) Verification methods fo r each DQO were assessed.

INL-CCP representatives indicate d that all DQOs except for RH wa ste determination will be met through verification of AK, see item (7), above. INL-CCP indicates that confirmatory testing will be used for each DQO, but also implies that establishment of an equivalent QA program may be used when using the mass spectrometry data to verify the OR IGEN2.2 output. Revision of various INL-CCP documents to clarify that AK qualification will be performed for almost all DQOs is addressed in other parts of this section.

(18) Attainment of DQOs was evaluated.

As a result of the analysis presented in items (1)–(17), above, EPA was able to assess how each DQO will be addressed. The following DQOs must be addressed as per the WCPIP:

- Defense determination

- TRU waste determination

- RH waste determination35 - Activity determination (TRU Alpha activity per canister, includi ng quantification and

identification of 10 WIPP-t racked radionuclides)

- Residual liquids

- Physical form, including metals and CPR

All of these DQOs, except for RH waste and de fense determination, are based on AK that is confirmed through various WCPIP-allowed technique s or variants thereof. RH status is determined through direct dose rate measurement. Defense determination is based on AK alone and cannot be confirmed. As indicated above, EPA required clarificati on regarding how DQOs would be met and, if done by AK, the specific c onfirmation pathway. As a result of information provided and EPA’s analysis of these data, EPA concludes that INL-CCP has adequately presented how DQOs will be obtained.

Summary of AK Findings and Concerns

The EPA inspection team identified the concerns rela ted to AK that are discussed above. Copies of the EPA Inspection Issue Tr acking Forms are provided in A ttachments B.4 through B.7. EPA considers all findings and concer ns to have been adequately addressed and there are no open finding or concerns related to AK resulting from this inspection.

AK Baseline Approval

EPA is approving the AK process evaluated duri ng this baseline inspection. Specifically, the approval is limited to Waste Stream ID-ANLE-S5000 RH retrievably- stored debris waste, Lots 1 through 20, consistent with the limitati ons described in CCP-AK-INL-500, Revision 3.

AK Tiers

Based on the inspection and the results discu ssed above, EPA assigns the following tiers:

T1 AK changes that will require EPA review and approva l prior to implementation and apply to any new waste category not evaluated during th e baseline inspection include the following:

• Any new waste streams not approved unde r this baseline (e.g., solids)

• Modification of the approved waste str eam ID-ANLE-S5000 to include additional containers, i.e. K Cell or other debris wastes.

• Load management for any RH waste stream.

• Substantive modifications that have the potential to affect the characterization process: CCP-AK-INL-500, Revision 2; CCP-AN-IN L-501, Revision 1; or CCP-AK-INL-502,

Revision 0

T1 changes will be reported and documentation will be submitted when INL-CCP is ready for EPA review. Upon initial review, EPA will inform INL-CCP and CBFO whether a site inspection is necessary. EPA may request add itional information, choose to conduct a desktop36 review, and/or confer with INL-CCP AK personnel. Upon AK evaluation with or without site inspection, EPA will issue a decision. Only upon receiving EPA written approval may INL-CCP implement T1 changes.

T2 AK changes that do not require EPA approval prior to implementa tion but require reporting and a brief description of the changes to the documents, include the following:

• Notification to EPA when updates to CCP-INL-AK-500, CCP-INL-AK-501, and CCPINL-AK-502 are approved by CBFO;

• Notification to EPA when changes to AK docum entation as a result of WCPIP revisions have been made (e.g., CRR);

• Notification to EPA when a Correlation or Surrogate Summary Form is completed for

each of the RH containers in this waste stream identified as CH based upon measured dose rates that present NDA resu lts for assayed containers

• Notification to EPA once waste stream data package for debris waste stream, and any modifications to the WSPF including the CRR and AK Summary are completed;

• Notification to EPA that the final DTC dete rmination is complete for RH containers numbers 728 through 737, as identified in AK Reference P030; all other AK accuracy reports prepared annually at a minimum;

Following EPA approval, INL-CCP will provide EP A with information concerning T2 changes on a quarterly basis. EPA will evaluate these changes and communicate with INL-CCP as to whether the changes raise any concerns and requi re an INL-CCP response, or whether INL-CCP can continue to implement the changes. Cons istent with EPA’s authority under 194.24(h) EPA may request information relative to these changes if EPA deems the information is necessary to ensure continued compliance with EPA regulations.

8.2 Radiological Characterization

EPA inspected the method by which the required radiological constituents for each waste

container were determined. The nature of RH TR U wastes presents considerable difficulty with respect to obtaining meaningful measurement data. Apart from the obvious workers’ exposure

considerations associated with external radiation fields in ex cess of 200 mrem/hr, RH TRU waste containers typically contain concentrations of 137 Cs that prevent a meaningful isotopic

determination in the same manner as is done for CH TRU wastes. At this time, INL-CCP has not proposed to assay RH containers fo r radiological contents. An alte rnative approach is the use of a scaling factor, which allows the correlation of an easily measurable gamma emitter such as

137 Cs with difficult-to-measure actinides and transuranic radionuclides. This is the essence of INL-CCP’s approach to radiologi cal characterization. This met hod is a complex process and the inspection focused primarily on the following two aspects:37 • The application of the Dose-to-Curie (DTC) t echnique to determine a container’s external

gamma exposure rate 12 (dose rate) by correlating the meas ured dose rate to an activity

concentration for 137 Cs

• Using scaling factors to convert the derived 137 Cs activity to activity values for the other

9 of the 10 WIPP-tracked radionuclides , including the uncertainty for each

This section provides an overview of the INL RH radiological charac terization process and discusses EPA’s evaluation of the adequacy of INL-CCP’s radiolog ical characterization program. The checklist in Attachment A.2 identifies the objective evidence that was examined and used to complete the technical assessment for the DTC aspect. Evaluation of the scaling factors was not amenable to a checklist, and th is aspect is discussed in the text directly.

8.2.1 Overview of INL Radiological Characterization Program

The radiological characterization aspect of the INL RH WC program that EPA evaluated focused on techniques to characterize containers from a single RH TRU waste stream, ID-ANLE-S5000.

This stream consists of debris wastes that were transferred to INL between 1976 and 1995 and were generated at ANL-E in the Alpha Ga mma Hot Cell facility (AGHFC) during the

examination of irradiated and un-irradiated fuel pins from various reactor programs at ANL-W

and other DOE and commercial reactors. Based on the nature of the waste materials and the types and quantities of information available, INL-CCP chose the approach of developing a waste characterization protocol that, in their opinion, was best suited for characterizing the population of all RH TRU waste containers within INL Waste Stream ID-ANLE-S5000. Specifically, a single scaling factor was assigned to fuel pin-related wastes generated from a variety of fuel types, an approach which begs the question whether a si ngle waste stream can contain materials that are so dissimilar with resp ect to radiological compos ition. This aspect was discussed in detail during all phases of this insp ection and these discussions are reflected in the

text that follows.

The actual measurement aspect, formalized in IN L-CCP procedures, consists of four simple external gamma readings of each waste container (the average value is used), all of which are attributed to a single photon-emitting radionuclide, 137 Cs. From a radiometric perspective, this is a simple task. The complexity of radiological characterization is contained in the development of the DTC approach that transforms each container’s measured dose rate into a 137 Cs activity value which, in turn, is used in conjunction with scaling factors to produce concentrations for the remaining 9 of the 10 WIPP-tracked radionuclide s and their correspondi ng uncertainties.

12 The external exposure rate is a numerical value expressed in units of rem per unit time (typically mrem/hr) that includes the contributions of all radiations, i.e., neutro n, gamma, beta, and alpha. The formal determination of a container’s RH status is documented in mrem/hr, but for the DTC procedure only a photon (gamma) determination is performed and this is referred to informally as a dose rate . For consistency, term dose rate is used throughout this

report.38 INL-CCP generated the scaling factors us ing the MCNP5, ORIGEN2.2, and MicroShield computer codes and compared them to mass spect rometry (MS) data that were generated at LANL. Beginning in the 1970s, dest ructive analyses were performed on 400 fuel pins at LANL

to determine the relative abundances of Pu and uranium (U) isotopics, along with isotopes of neodymium ( 148 Nd). Neodymium-148 is a fission product th at is used to cal culate burn-up in fuel and is analogous to the fission product 137 Cs. INL-CCP refers to this use of the MS data as qualifying the ORIGEN2.2 results with the LANL MS data, and the scaling factors were adjusted as a result of the comparison. In general, MS is an excellent analytical technique and use of the MS data to adjust the isotopic sc aling factors provided the opportunity to verify the results of the application of the codes mentione d previously. A technical assessm ent of the LANL MS data is

addressed in Section 8.2.4.

Figure 1 presents a flow chart of the INL-CCP radiological characterization process given in CCP-TP-501, Revision 1. Document ation of the conceptual basi s for the DTC approach and development of the scaling factors is documente d in 35 calculation packages that are listed in Section 8.2.5, as well as other technical documents, all of which were reviewed as part of this inspection.

8.2.2 Radiological Characterization Element: Dose-to-Curie Procedure

DTC Overview

INL-CCP’s approach was based on translating th e measurable external gamma radiation from

137 Cs into an activity value usi ng the Monte Carlo Neut ron-Photon (MCNP) code, as documented in INL-RH-03. All of the measured gamma radiation was attributed to 137 Cs, as discussed in LANL-RH-10, INL-RH-09, and INL-RH- 08, including contributions from 60 Co and other gamma emitting members of the 232 U decay series, e.g., 228 Ac and 208 Tl. Once the container’s

measured gamma dose rate was converted into a 137 Cs activity, the other nine WIPP-tracked

radionuclides were scaled to the 137 Cs activity using a single set of scaling factors that were applied to all waste containers within th e Waste Stream ID-ANLE-S5000. An example calculation using the observed dose rate in the DTC procedur e is presented in Section 8.2.3, along with a discussion of the developm ent of radionuclide scaling factors.

INL-CCP formalized the 137 Cs measurement in the Dose-to-Curie (DTC) procedure, CCP-TP-504, Dose-to-Curie Survey Procedure for Remote Handled Transuranic Waste,

Revision 2 . This procedure was evaluated prior to and during the inspection. The DTC process was evaluated relative to the following:

• Capability of the DTC hardware to adequate ly determine a container’s external gamma exposure (dose) rate

• Technical adequacy of the radiological characterization program’s documents, procedures, and controls

• Knowledge and understanding of the pe rsonnel involved in the radiological characterization program39Figure 1. Flow Chart of RH TRU Radiological Characterization ProcessDevelop Uncertainties inQuantitiesPin Characteristics fromFuel Suppliers andReactor OperatorsU-235 EnrichmentPu-240 EnrichmentU/Pu RatioBurnupLocate and RetrieveRelevant LANLRecordsCalculate FuelComposition for603PinsMake ORIGEN2.2 Runsfor603PinsOutputMass SpectrometryResults for 400LANLPinsU and Pu RelativeAbundancesCompare Mass SpecResults to ORIGEN22Output for400PinsDetermine AverageAdjustment Factors to Applyto ORIGEN ResultsPost-IrradiationForms for 400 LANLPinsU-235 EnrichmentPu-240 EnrichmentU/Pu RatioBurnupCalculate Fuel Compositionfor400Fuel PinsMake ORIGEN22Runs for400PinsOutputApply Average AdjustmentFactors to ORIGEN Resultsfor Fast Reactor Pins andAdjust RERTR OutputsCalculate Isotope/Cs-137Scaling Factors from isotopetotals for 506 PinsDevelop Cs-137 Dose-to-CurieRelationships for 30-GallonDrums as a Function of WasteDensity Using MCNP5Determine the Quantitiesin Mass and Curies inDrums for AllReportable NuclidesCalculate Cs-137 Contentin Each Waste CanDetermine AverageDose Rate for 30-gallon DrumsLocate and RetrieveRelevant INL Records40 The external dose rate determination was done em pirically using measurements that took place

on-site at INL within the Idaho Chemical Processing Plant, Idaho Nuclear Technology Engineering Center (INTEC), Building No. CCP-659, Rooms 302 and 306, for instruments and operators, respectively

. This approach is explained in CCP-AK-INL-501, Revision 1, and is formalized in procedure form in CCP-TP-504, Revi sion 2, both of which were reviewed for this inspection. The requirements of these two documen ts were used to formulate a basis by which the EPA inspection team evaluated the DTC proce ss. Additionally, several of the calculation packages listed in Section 8.2.5 s upported technical aspects of the DTC approach, and these were reviewed and discussed at length at INL in June and during s ubsequent telephone conversations between Patrick Kelly and Jene Vance, Jim Holderness, and Mark Doherty that took place throughout the month of July 2006. The purpose of these conversations was to obtain answers to specific technical questions that were not addressed during the INL site visit.

DTC Technical Evaluation

The EPA inspection team evaluated the following aspects:

(1) Instrumentation for making dose rate measurements

The EPA inspection team verified the following:

• There are three ion chamber probes available for use with the RO-7 Ion Chamber: RO7LD with a full-scale range of 1,999 mR/hr a nd a resolution of 1 mR/hr (Low Range); RO-7BM, with a full-scale range of 199,900 mR/hr and a resolution of 100 mR/hr (Medium Range); and, RO-7BH with a full-scale range of 199,900,000 mR/hr and a resolution of 10,000 mR/hr (High Range). The ca librations are essentially probe-specific, allowing the probes to be intercha nged between ion chamber bodies.

• The Low Range Probe No. 802038 and the Medium Range Probe No. 801254 had been

calibrated and were in calibration at the ti me of the inspection. The High Range probe was not observed in use, INL- CCP personnel stated that it ha d been neither calibrated nor source checked. INL-CCP personnel stated that there was no intention of using this probe in the foreseeable future.

• The ion chamber used to measure the dose or exposure rate of containers for the DTC method had been calibrated, as evidenced by the calibration due dates on the ion chamber itself and the probes, see previous bullet.

• Instrument calibration was performed by th e Battelle Energy Alliance (BEA) Health Physics Instrument Laboratory (HPIL) located at INL, and this facility is on the WTS Qualified Suppliers List. Calibration was pe rformed in accordance with HPIL Procedure CW1-240, Revision 2, which was reviewed dur ing the inspection. INL-CCP personnel had a spare RO-7 Ion Chamber that had been calibrated but was not observed in use.

• It was verified that the scale used to weigh the containers has been calibrated and that the scale has been checked daily.

• The battery and performance checks for the instrument used to measure the dose or exposure rate of containers for the DTC me thod had been performed and documented at least once per day prior to the first measurement of the shift.41 • The background rate was measured and record ed. Measurement personnel stated that they would take actions to reduce the bac kground if the measured background radiation levels are greater than one-tenth of the e xpected container dose or exposure rate, as required by the WCPIP and CCP-TP-504, Revision 1.

(2) Execution of the dose rate measurements

The EPA inspection team verified the following:

• For the waste containers observed (Drum N o. 00761), the dose rate was measured four times, each at a distance of 1 meter and the container was rotated on the turntable 90°

between each measurement.

• The INL-CCP personnel were working to the approved document, CCP-TP-504, Revision 1, and all measurements were taken at the center line of the drum’s height and were lined up to the center height of the active volume of the ion chamber probe.

• The appropriate range probe for the ion chamber was used (Low Dose Probe No. 802038).

• The container, waste stream, and measurement data were entered into the “Waste Container Dose-to-Curie Conversion Record” sp readsheet. Information entered included:

o Date of the gamma measurements with the RO-7 Ion Chamber and Probe SNs

o Waste stream designation

o Container number

o Container gross weight

o Estimated can size for Cans #1, #2, #3, as appropriate

o Estimated fill percentage for Cans #1, #2, #3, as appropriate

o Four quadrant dose rate measurements

o Waste material type (e.g., steel, cement, organic)

(3) DTC BDR

The EPA inspection team verified that the one DTC BDR included the following:

• BDR Cover Sheet, Attachment 4

• BDR Table of Contents, Attachment 5

• BDR Narrative Summary, Attachment 6

• ITR Review Checklist, Attachment 7

• Measurement Control Report, Attachment 1

• Container Data Sheet(s), Attachment 2

• Waste Container DTC Conversi on Record(s), Attachment 3

• Copies of NCR Nos. RHINL-0505-0 6, RHINL-0004-06, a nd RHINL-0501-06

• Evidence of signatures by the ITR and a SPM

• Type of waste in each contai ner (steel, concrete, organics)

• Fill height of the container: < 25% full; 25% - 66% full; 66% - 90% full; > 90% full42 (4) Meeting quality assurance objectives (QAOs)

The EPA inspection team verified that:

• Precision had been established and maintained within the manufact urer’s specifications for the RO-7 Ion Chamber by successful sour ce checks made prior to obtaining dose rate

measurements on actual waste containers.

• Accuracy had been establishe d and maintained by operating the instrument within the

manufacturer’s recommendations.

• Representativeness had been maintained by applying the dose rate measurement to the

entire waste container.

• Completeness had been achieved by measuring the dose rate for every container in the BDR, i.e., 100% assay.

• Comparability had been achieved by using st andardized instructions to design and implement the DTC protocol, including the dose rate measurements.

(5) RH TRU determination

It was not entirely clear at what point the formal determinatio n regarding a waste container’s

status would be made relative to the criteria for RH TRU. The EPA inspection team evaluated the two following aspects:

• RH TRU containers must have a contact exte rnal dose equivalent rate in excess of

200 mrem/hr:

The DCT measurements that were observed a nd are discussed in th is section represent only the photon (gamma) contribution to a contai ner’s external radiat ion field. There was a neutron-sensitive instrument (Rem Ball) in the same area as the RO-7 that could be used to provide the necessary information to support a complete determination regarding

a waste container’s status relative to th e 200 mrem/hr criterion. INL-CCP personnel

stated that the Rem Ball was used to measur e each waste container, but the results were used primarily for health physics/ALARA purpos es. However, the RH determination is typically made on the basis of the transporta tion package and is ther efore not within the purview of this inspection.

• RH TRU containers must have a concentr ation of TRU radionuclides greater than 100 nCi/g:

CCP-TP-504 requires the container’s dose rate to be at least a factor of ten greater than background and the lowest readi ng possible on the RO-7 is 1 mR /hr. This means that the

minimum measured dose rate at 1 meter th at is required for the proper execution of

CCP-TP-504 at the 200 mR/hr criterion is 10 mR/hr, based on a factor of 20 difference

between the measured dose rate at 1 meter fr om the container relative to the reading on contact with the container. The EPA inspec tion team was concerned that it may not be possible to ensure that a container with a 1-meter dose rate of 20 mR/hr did in fact contain greater than 100 nCi/g of TRU radionuc lides. As a check, the spreadsheet shown in Figure 3 was used with input values for th e 1-meter dose rate of less than 10 mR/hr.43 For this hypothetical case, th e spreadsheet yields a valu e in excess of 3,000 nCi/g for TRU Alpha Activity, based on the application of the scaling factors encoded in the Excel spreadsheet. This indicates that a containe r may not qualify as RH based relative to the 200 mR/hr criterion, but it would still qualify as TRU relative to the 100 nCi/g criterion. Of course, it was not clear at this time how c ontainers that showed a contact dose rate of less than 200 mR/hr would be dispositioned, i.e., as CH or RH. If any containers that are currently considered RH from this waste stre am are eventually dispositioned as CH TRU, it would be valuable to compare the NDA results for the containers with those generated using the application of DTC and scaling factors that are discussed in this report.

EPA received a comment objecting to obtaining this information as a T2 change. (See Attachment C, CBFO Comment No.10). Upon review of the comment EPA concurs with the reasoning provided by the Commenter a nd EPA agrees with the Commenter. (See Attachment C for EPA response to Comment No. 10). EPA now requires that INL-CCP notify EPA through the T2 change notice pro cess that updates to the above documents have been made, and that they have been approved by CBFO and are available for EPA evaluation. EPA may then request these upda tes under the authorit y of 40 CFR 198.24(h) for the purpose of determining continued compliance with EPA regulations. Providing

notification to EPA that this ha s occurred would be a T2 change. (See Table 1, where this is included as a T2 change). Consistent with EPA’s authority under 194.24(h), EPA may request new or additional information when it is necessary to ensure continued compliance with EPA regulations. EPA unders tands that the comparison of radionuclide concentrations derived from the applicati on of DTC and scaling factors and NDA may

exhibit considerable va riation and does not necessarily consider that such variations would be problematic. See Section 8.1 (10) for a more detailed discussion of this issue.

The EPA inspection team did not have any technical concerns or issues with the execution of the DTC methodology observed at INL- CCP during this inspection, or with the method’s technical basis and documentation based on the objective ev idence that was reviewed. The use of an

alternate characterization techni que other than DTC observed duri ng this baseline inspection as

documented in CCP-TP-504 or substantive modificat ion of the DTC procedure is a T1 change. (See Table 1, where this is included as a T1 change)

8.2.3 Radiological Characterization Elem ent: Scaling Factor Development

Scaling Factor Overview

As shown in the 33 calculation packages listed in Section 8.2.5, this was a complex task that incorporated information from ANL-E, ANL -W, INL, and LANL, including the following:

• Fuel pin type and characteristics from fuel suppliers and reactor operators

• 235 U enrichment

• 240 Pu enrichment (for mixe d oxide fuels) and burnup

• U/Pu ratios (for mixed oxide fuels)

• Examination of 603 fuel pins examined at ANL-E

• Mass spectrometry results for de structive assay (DA) of 400 fu el pins (See Section 8.2.5)

• Other records related to AGHCF activiti es, names of experimenters, etc.44 The scaling factors were incorporated in a drum characterization spreadsheet that required the following input:

• Drum gross weight in kilograms (kg)

• Identification of the can sizes (5-, 7- or 10-gallon) and number of cans in the drum

• Estimates of the can fill heights in percent

• Dose rate measurements at f our quadrant points in mR/hr

The drum’s gross weight is calculated as:

Gross drum weight – (d rum weight + packaging materials + can weights) (1)

The weight values used for the variou s drum items are listed in Table 5.

Table 5. Weights of It ems Used to Calculate Waste Weight and Density

Items Weight, kg

30-gallon drum 16.36 Polyethylene liner 3.61 Plastic pouch 1.73

Cardboard sleeve 1.41

Plastic lid 0.39

Total minus cans 23.5 7-gallon drum 2.84 5-gallon drum 2.26 10-gallon drum 3.42

The container’s apparent weight density in g/ cm 3 is calculated as:

Net Waste Weight / (can #1 %H fill + can #2 %H fill + can #3 %H fill ) (2)

Where the net waste weight is in units of grams and can fill volume is given by:

C size * %H fill * 3785 cm 3 /gal (3)

Where:

C size = can size in gallons

%H fill = estimated fill height of each can in percent, expressed as a decimal

The input of the spreadsheet is shown in Fi gure 2 with hypothetical dose rates values that average 450 mR/hr, an assumed drum configura tion of two 7-gallon cans each 100% full, an assumed net weight of 46.5 kg, and an a pparent weight dens ity. The drum’s 137 Cs content is

derived as follows:

137 Cs Activity in Ci = dose rate / (11.91 * X 2 - 82.126 * X + 194.64) (4)45 Where: X = apparent waste density, g/cm 3

A B C D E F G H Operating procedure CCP-TP-504 Rev. 2 8 Date of survey 6/1/2006 9 Waste stream designation ID-ANLE-S5000 10 Container number 11 Container gross weight 70 Kg 12 Waste cans Can #1 Can #2 Can #3 13 Can sizes 7 7 0 gallons 14 Estimate fill percentages 100 100 78.5 % 15 Container net weight 46.5 Kg 16 Measured container dose rate 17 Quadrant #1 300 mR/hr 18 Quadrant #2 500 mR/hr 19 Quadrant #3 600 mR/hr 20 Quadrant #4 400 mR/hr 21 Calculated average dose rate 450 mR/hr 22 Waste material type (organic, steel, cement)

Figure 2. EXCELTM (Version 2002, Release 10) Spreadsheet “DTC Spreadsheet.xls”

Equation (4) is taken from INL-RH-03, pages 6 –7, and is based on a total of eight MCNP cases that were run with the waste material density varying from 0.0 g/cm 3 to 1.4 g/cm 3 in intervals of 0.2 g/cm 3 , a range that spans the expected range of wa ste densities in INL drums. The results of the eight runs are presented in Table 6, below, and were used to generate a second-order polynomial curve to fit the data, shown in Figure 3.

Table 6. Waste Density Versus Observed Dose Rate

Waste Density Dose Rate mR/hr

0.0 193.993

0.2 179.322

0.4 164.203

0.6 149.743

0.8 136.207

1.0 124.006

1.2 112.991

1.4 103.4546 Figure 3. MCNP Input – Observed Dose Rate As a Function of Waste Density

Calculation of the 137 Cs activity for a container allows th e further calculation of the following quantities for each RH container measured:

• Activity in curies (Ci) and mass in gr ams (g) for each of the 10 WIPP-tracked radionuclides, i.e., 137 Cs, 241 Am, 238 Pu, 239 Pu, 240 Pu, 242 Pu, 90 Sr, 233 U, 234 U, and 238 U

• Associated uncertainty for all va lues listed in previous bullet

• Fissile gram equivalent (FGE)

• Pu equivalent curies (PE Ci)

• Decay heat in watts

The constants and other values required for thes e calculations were taken from the appropriate sources (CH WAC and TRAMPAC) and were spot -checked for accuracy. These were found to be accurate and they are summarized in Table 7. The results of these calculations are shown in Table 8 using the hypothetical dose rate input from Figure 2. The values listed in the Activity

and Mass columns are the actual data that would be reported on the container’s assay sheet to be included in the radiological charac terization BDR. Note that the scaling factors are the same for all containers; the sample-specific variables are the container’s measured dose rate and density, as shown in Equation 5, taken from IN L-RH-05, page 5, and duplicated below:

137 Cs Activity in Ci = dose rate / (11.91 * X 2 - 82.126 * X + 194.64) (5)

At a hypothetical value of zero de nsity (X = 0), this equation b ecomes essentially a bare-source calculation; at higher densities , the effects of the waste’s self-shielding are evident.47 Table 7. Constants Used in Scaling Factor Development

Radionuclide Specific Activity (Ci/g) FGE/g PE-Ci/Ci Watts/g

U-233 9.76E-03 9.00E-01 3.90 2.84E-04

U-234 6.32E-03 0.00E+00 0.00 1.82E-04

U-235 2.19E-06 6.43E-01 0.00 6.04E-08

U-238 3.40E-07 0.00E+00 0.00 8.62E-09

Pu-238 1.73E+01 1.13E-01 1.10 5.73E-01

Pu-239 6.29E-02 1.00E+00 1.00 1.95E-03

Pu-240 2.30E-01 2.25E-02 1.00 7.16E-03

Pu-241 1.04E+02 2.25E+00 51.00 3.31E-03

Pu-242 3.97E-03 7.50E-03 1.10 1.17E-04

Am-241 3.47E+00 1.87E-02 1.00 1.16E-01

Cs-137 8.80E+01 0.00E+00 0.00 9.74E-02

Ba-137m 5.38E+08 0.00E+00 0.00 2.12E+06

Sr-90 1.38E+02 0.00E+00 0.00 1.60E-01

Y-90 5.44E+05 0.00E+00 0.00 3.01E+03

Table 8. Summary of Reportable Values Using Hypothetical Input

Radionuclide Curie Scaling

Factors Activity (Ci) Mass

Grams FGE PE-Ci Watts

U-233 1.65E-04 5.35E-04 5.48E-02 4.94E-02 1.37E-04 1.56E-05

U-234 2.98E-04 9.68E-04 1.53E-01 0.00E+00 0.00E+00 2.79E-05

U-235 1.05E-05 3.43E-05 1.56E+01 1.01E+01 0.00E+00 9.45E-07

U-238 1.77E-06 5.74E-06 1.69E+01 0.00E+00 0.00E+00 1.46E-07

Pu-238 2.54E-02 8.24E-02 4.76E-03 5.38E-04 7.49E-02 2.73E-03

Pu-239 9.19E-02 2.99E-01 4.75E+00 4.75E+00 2.99E-01 9.26E-03

Pu-240 4.84E-02 1.57E-01 6.83E-01 1.54E-02 1.57E-01 4.89E-03

Pu-241 7.26E-01 2.36E+00 2.27E-02 5.11E-02 4.63E-02 7.51E-05

Pu-242 1.52E-05 4.96E-05 1.25E-02 9.36E-05 4.51E-05 1.46E-06

Am-241 4.46E-02 1.45E-01 4.18E-02 7.81E-04 1.45E-01 4.85E-03

Cs-137 1.00E+00 3.25E+00 3.69E-02 0.00E+00 0.00E+00 3.60E-03

Ba-137m 9.46E-01 3.07E+00 5.72E-09 0.00E+00 0.00E+00 1.21E-02

Sr-90 7.41E-01 2.41E+00 1.74E-02 0.00E+00 0.00E+00 2.79E-03

Y-90 7.41E-01 2.41E+00 4.42E-06 0.00E+00 0.00E+00 1.33E-02

Totals 1.42E+01 3.83E+01 1.49E+01 7.22E-01 5.37E-02

Scaling Factor Technical Evaluation

The technical basis and degree to which the scal ing factors are representative of the RH TRU wastes for which INL-CCP requested approval we re evaluated during this inspection. The following elements were evaluated and verified:48 (1) Waste stream definition

This inspection focused on a group of wastes that INL-CCP stated were contained in a single waste stream, which included fuel pins that were dissimilar with respect to their radionuclide content. Specifically, they c onsisted of three fuel types:

• U, low enriched U (LEU), and highly enriched U (HEU)

• U and Pu

• Thorium

The following definition is taken from page 12 of the WCPIP:

A waste stream is defined as waste mate rial generated from a single process or from an activity, which is similar in ma terial, physical form and radiological constituents. Only those containers that can be related to a particular waste

stream will be contained in that waste stream.

In light of the apparent differences among the th ree fuel types listed above, the consolidation of these drums in a single waste stream bears inve stigation. The radionuclide profiles of the three fuel types are clearly different; however, follo wing irradiation these fu el types have a common, salient characteristic, i.e., the presence of fission and activation products. Of these, 137 Cs is the main interest due to its physical half-life (~30.2 years) and high transition probability photon

emission at 662 keV. There are ot her fission and activation products but these are not an issue to this approach because they have short physical ha lf-lives and have decayed or, more importantly, their contribution is insignificant relative to 137 Cs. In a sense, one could consider that these materials have been treated by their exposure to the intense neutr on field produced during irradiation (fission). The materials’ characteri stics that have bearing on DTC have been reduced to a common element, i.e., the predominance of 137 Cs, after irradiation, and the differences of the fuel’s pre-irradiation composition do not affect the radiological characterization process. The EPA inspection team concluded that the assignmen t of all containers to a single waste stream was technically justified a nd technically supportable.

(2) Technical aspects and de rivation of scaling factors

The EPA inspection team evaluated the following aspects:

• Activity values that are used are derived from modeling and statistical metrics that support their use, and the statistical metrics include mean and standa rd deviation values

for each measured radionuclide.

• Isotopic activity values are normalized to th e major radionuclide(s) responsible for the external container dose rate, i.e., 137 Cs.

• The calculated results used to develop the f actors and convert the measured dose rate to radionuclide activity levels.

• The expected dose rates at a distance of 1 meter from the outer surface of the waste container, at the mid-height of the container, have been calculated as a function of the waste’s activity, and the calcu lation accounts appropriately fo r container properties i.e.,49 fill height or (apparent) density, waste type, sh ielding effects of the container and/or liner

wall.

• Calculations supporting the scaling factors are performed using appropriate shielding analysis techniques, i.e. , MCNP5 and Microshield 7.00.

• Computer programs (ORIGEN2.2) used for cal culations of the activities of the WIPPtracked radionuclides account for the following:

o The beginning conditions of the fuel used to produce the TRU isotopes

o Exposure of fuel to neutron fields in a nuclear reactor (fission)

o Change in radionuclide s following irradiation

o Reactor neutron energy spectrum is known or calculated in order to determine the

effective cross-sections of radionuclides leading to the creat ion of WIPP-tracked

radionuclides

o Appropriate cross-sections are used or generated for each reactor condition

o Fuel exposure history is used to calc ulate isotope genera tion and depletion

(3) Documentation of technical aspects

Development of the scaling factors is documented in 33 calculation packages that were prepared by Jene Vance and Jim Holderness (see Section 8.2.5). These packages address a variety of aspects, including:

• Verification of MCNP5, Mi croshield 7.00 and ORIGEN2.2

• Evaluation of all potential contributors to a container’s dose rate, specifically 60 Co and other gamma emitting members of the 232 U decay series, e.g., 228 Ac and 208 Tl

• U and Pu relationship in the fuel pins from which the wastes originated

• The nature and history of the fuel pins, r eactor cross-sections, a nd operating histories

• Potential sources of uncer tainty, discussed below

The EPA inspection team members reviewed a subset of these packages in detail and discussed

them with the documents’ authors and Mark Dohe rty. During these discussions, several aspects were probed in detail and several modifications to the calculation packages were made in response to the EPA inspection team’s concerns. All potential concerns were resolved and, apart from minor discrepancies with respect to specific documentation details, the calculation packages were found to be technically adequate.

(4) Evaluation of Total Measurement Uncertainty (TMU)

The development of TMU for ID-ANLE-S5000 is based on the propagation of uncertainties present in all aspects of the de termination of the radiological c onstituents of RH TRU waste.

The TMU determination incl uded the contributions of:

• Drum weight measurement

• Measurement uncertainty of 137 Cs

• MCNP5 issues50 • MicroShield issues

• Other gamma emitters

• Individual pins to the total

• Specific pins in a single drum

• Burnup history

• Reported burnup

• Internal code issues

• Contributions from unirradiated pins

• Modeling

There was a technical concern regarding TMU w ith respect to the appropriateness of the statistical model, i.e., that all components of the uncertainty were sta tistically independent and could therefore be added in quadrature. Sin ce the radionuclide values are derived from the 137 Cs dose rate that is measured, this aspect cannot be considered independe nt and its contribution must be treated differently, i.e., it cannot be a dded using the square ro ot of the sum of the squares. The TMU is expected to increase when the correct approach is taken and, in fact, the

corrected calculation in INL-RH -06, Revision 1, shows a TMU that is approximately 1.5 times greater than the original, inco rrect TMU value. The CTAC Technical Specialist identified the issue as well and INL-CCP acknowledged that the TMU equation required modification. As a result, INL-CCP issued Non Conformance Re port (NCR) No. RH-INL-0501-06. This also resulted in the reissuing of BDR No. INLRHDTC-06001 and the calculation package INLRHDTC-06001 that provides th e technical support for the cal culation of TMU. The EPA inspection team reviewed the reissued BDR and the calculation package and determined that both had been appropriately corrected. The EPA inspection team reviewed the applicability of the reissued procedure to the INL RH waste stream and determined that it was technically appropriate. The EPA inspection team did not have any open technical issues or concerns relative to the development and application of radionuclide sca ling factors based on the objective evidence reviewed during this in spection. The application of ne w scaling factors for isotopic

determination other than those documented in CCP-AK-INL-501 and observed during this baseline inspection is a T1 change. (See Tabl e 1 where this is listed as a T1 change.)

8.2.4 Radiological Characterization Element: Evaluation of Mass Spectrometry Data to Support ORIGEN2.2

The purpose of the ORIGEN2.2 modeling was to de velop technically base d scaling factors to

allow a waste container’s measured dose rate to be transformed into activity values for each of the 10 WIPP-tracked radionuclides, including uncer tainty. While this exercise was based essentially on modeling, there was a verificatio n/validation of the ORIGEN2.2 output performed using data from 400 fuel pins that were samp led and assayed using mass spectrometry. The use of mass spectrometry (MS) data in support of ORIGEN2.2 derive d scaling factors had been assessed on August 9, 2006, in Carlsbad, New Mexico. The INL-CCP and CBFO/CTAC representatives in attendance are listed in Table 3. The MS data and information EPA assessed had been located, identified, and compiled by INL- CCP’s AK personnel and ranged in date from 1970 through 1984. As expected, the information ga thered did not constitute a complete and continuous record. However, EPA determined th at there was sufficient information and data available to make a determination with regard to the technical adequacy of the MS data for the stated purpose.51 Analytical Methods

The ultimate purpose of the procedures and analy tical data reviewed was to establish the burnup rate for the fuel pins. Two processes were used to generate the data required to make this calculation. A spiked and a separa te unspiked aliquot of the disso lved fuel pin were analyzed; the spiked results provided the at om percent fission in the U and Pu fuel and the unspiked results determined the isotopic compositions of U and Pu in the fuel. These two results were used to calculate the burnup rate. Although ORIGEN input consisted of the isotopic data only, the entire process used for burnup determinations was includ ed in the review becau se generation of the spiked and unspiked data was part of the same process. Figure 4 is an example of a typical LASL burnup result sheet titled “B urnup Results for Irradiated Fuel.”

Sample Number WARD W8-37 WARD 8-57 WARD W31-20

LASD Job Number 1226-L 1227-L 1228-H

Total U Atoms* 8.171E16 1.222E17 1.952E17

Total Pu Atoms* 2.447E16 3.770E16 4.864E16

Nd-148 Atoms* 2.025E14 3.142E14 1.996E14 Isotopic Distributions
U, Atom % 233 - - -

234 .673 .664 .868

235 61.12 61.01 77.81

236 2.04 2.03 1.25

238 36.17 36.29 20.08
Pu, Atom % 238 .139 .215 .052

239 88.62 88.57 90.06

240 10.50 10.48 9.24

241 .672 .670 .592

242 .068 .068 .058 Burnup, Atom % Fission 10.24 10.52 4.67

** * All three elements determined on the same sample aliquot. ** Calculated using Nd-148 fission yield data reported in ENDF VB. Fission yield value used = 0.0167 2 , 0.0167 0

Remarks: _________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

Analyst: HJK, CB, PGA, MEO, JA, RMA Date: 3/17/82 Group Leader: ____________

Figure 4. Los Alamos Scientific Laboratory Group CMB-1 Burnup Results For Irradiated Fuel, Reproduced From Original Data Sheet Provided by Jene Vance, Original Was Initialed By RMA and Disp layed the Initials of the Group Leader52 By reviewing quarterly reports, analytical result sheet s, and logbooks, it was determined that the following procedures were used to control the preparation and anal ysis of fuel pin samples for the purpose of establishing the isotopic ratios of U and Pu:

• ANC-DE-1-HC-3 “The Dissolution of Irradiated Materials”: This was used to prepare the fuel pins for analysis. Revi sion 2, Section 3.1 of this procedure, dated August 22, 1973, required that SRM 13 U-500 (U) be used to prepare calibration standards for the mass spectrometer. Section 3.2 requi red at least one sample of SRM 946 (Pu) be processed by this procedure every five days. The procedure required control charts to be

maintained of the 239/240 atom ratio data. Control charts were not located by INL-CCP and this was the only revisi on of this procedure found.

• ANC-DE-1-MS-2 “Determination of Atom Percent Fission in Uranium and

Plutonium Fuel”: This used the triple spike techni que. Two revisions of this procedure were located, Revision 2 dated August 22, 1973, and Revision 3 dated March 24, 1976. The procedure required the use of SRM U-500 (U), SRM 960 (Pu) and SRM 950 (Pu) and referenced procedure ANC-DE-1-HC-3 for sample preparation. SRMs were required to be analyzed every 5 days and for control charts of the 239/240 atom ratio data to be

maintained. Control charts were not availa ble for review. Five or more mass spectra were recorded for each sample (Section 4.5.3) in Revision 2 of the procedure but this requirement was reduced to three or more sp ectra in Revision 3. Acceptance criteria for quality control (QC) samples were provided in Section 3.1, as well as corrective action to be implemented if the SRM failed to meet acceptance criteria. Section 4.5.5 provides the

calculations used to determine th e burnup and the atom percent fission.

• ANC-DE-1-MS-3 “Determination of the Iso topic Compositions of Uranium and

Plutonium”: This was used to analyze unspiked a liquots of the fuel pin solutions by mass spectrometry to determine the isotopic compositions of U and Pu. Revision 3 of this procedure dated August 22, 1973, a nd Revision 4 dated April 13, 1981, were available for review. SRMs U-500 (U) and 946 (P u) were required to be analyzed every five days and control charts maintained. Acceptance limits were specified, as were

corrective actions to be taken if the standard results were outside of those limits. The procedure listed the reagents used and the storage conditions required for those reagents. Instructions for introducing th e samples into the MS system were provided and Section 4.5.4 required at least five mass spectra to be recorded for each sample. Review of the

available raw data demonstrated that the minimum number of spectra requirement was met. Although Section 4.5.5 states that at om percent abundances of the U and Pu isotopes are calculated, the procedure doe s not provide the calculation used.

• Quarterly Reports: Many reports were recovered by INL- CCP for the period of interest (1972–1984) and some of them contain useful but limited information for this assessment. The following information was used to help EPA make a determination with regard to the acceptability of the mass spectrometry data used for ORIGEN input:

- Progress Report, LA-5067-PR, April 1 to June 30, 1972, page 9: “The quality assurance procedures written... include: Dissolution of Irradiated Material and

Determination of Atom Percent Fission in Uranium and Plutonium Fuel.” It is

13 SRM is Standard Reference Material.53 assumed that these two procedures we re ANC-DE-1-MS-2 and ANC-DE-1-HC-3, although the report did not specifical ly identify the methods as such.

- Progress Report, LA-5390-PR, April 1 through June 30, 1973, page 1:

“Characterization of unirradiated and irradi ated fuels by analytical chemistry will

continue and additional methods will be modified and mechanized for hot cell application. ...”

- Page 39: Development of Burnup Method Using Conventional Low-Cost Apparatus. “Mass spectrometry is the most reliable technique for determining nuclear fuel burnup using the triple spike technique.” The triple spike technique was used to generate the “spiked” data used in the burnup calculation.

- Progress Report, LA-9372-PR, January 1 – March 31, 1982, page 3: “Chemical separation of uranium, plutonium, and neodymium.... followed by mass spectrometric.... measurement currently is used to determine burnup”.

- Progress Report, LA-9959-PR, July 1 – October 31, 1983, page 2, III Analytical Chemistry: Reports that 15 fuel sample s were dissolved for burnup analysis by mass

spectrometry.

The above information demonstrates that analytical procedures that were developed early in the project continued to be used throughout the peri od of interest (see Sec tion 1-3 in Analytical Methods).

Accuracy

Records of replicate analyses of isotopic SRMs were available from March 26, 1979. SRMs U-005 (U) and 947 (Pu) were analyzed five times, one set of samples was subjected to chemical separation and one set of samples was not. The average and standard deviation (SD) of the results were calculated and the results are pr ovided below in Tables 9a and 9b for the unseparated and separated aliquots for DRM U-005, respectively, and 10a and 10b for unseparated and separated aliquots for SRM Pu 947, respectively. These results demonstrate acceptable precision (PRD # 3.3%) and accuracy (Recovery # 103.4%) of the analytical method ANC-DE-1-MS-3 for U and Pu isotopes.

Table 9a. SRM U-005 Analytical Re sults, Unseparated Aliquots

Analysis Date Certified 234 U

0.00218 Certified 235 U

0.4895 Certified 236 U

0.00466 Certified 238 U

99.503

3/15/79 0.0024 0.4923 0.0050 99.5002

3/16/79 0.0024 0.4922 0.0051 99.5004

3/16/79 0.0022 0.4913 0.0050 99.5016

3/16/79 0.0022 0.4907 0.0050 99.5020

3/16/79 0.0022 0.4912 0.0049 99.5018

SD 0.00011 0.00069 0.00007 0.00084

Average 0.00228 0.49154 0.0050 99.50120

% Recovery 104.6 100.4 107.3 99.998

RPD 4.5 0.41 7.04 <0.0154 Table 9b. SRM U-005 Analytical Results, Separated Aliquots

Analysis Date Certified 234 U

0.00218 Certified 234 U

0.00218 Certified 236 U

0.00466 Certified 238 U

99.503

3/19/79 0.0024 0.4924 0.0052 99.4999

3/19/79 0.0024 0.4928 0.0051 99.4997

3/19/79 0.0022 0.4911 0.0050 99.5016

3/19/79 0.0024 0.4932 0.0050 99.4993

3/19/79 0.0025 0.4918 0.0054 99.5003

SD 0.00011 0.00083 0.00017 0.00088

Average 0.00238 0.49226 0.00514 99.50016

% Recovery 109.2 100.6 110.3 99.997

RPD 8.8 0.56 <0.1 <0.1

Table 10a. SRM Pu 947 Analytical Results, Unseparated Aliquots

Analysis Date Certified 238/239 Pu

0.003688 Certified 240/239 Pu

0.241461 Certified 242/239 Pu

0.015594

3/14/79 0.003735 0.241545 0.015577

3/14/79 0.003726 0.241487 0.015611

3/14/79 0.003723 0.241474 0.015589

3/15/79 0.003743 0.241521 0.015586

3/15/79 0.003723 0.241497 0.015581

SD 0.000009 0.000028 0.000013

Average 0.003730 0.241505 0.015589

% Recovery 101.1 100.0 99.97

RPD 1.1 <0.1 <0.1

Table 10b. SRM Pu 947Analytical Results, Separated Aliquots

Analysis Date Certified 238/239 Pu

0.003688 Certified 240/239 Pu

0.241461 Certified 242/239 Pu

0.015594

Date Pu 238/239 Pu 240/239 Pu 242/239

3/16/79 0.003760 0.24124 0.015546

3/16/79 0.003812 0.241310 0.015611

3/16/79 0.003949 0.241444 0.015614

3/16/79 0.003780 0.241492 0.015587

3/16/79 0.003772 241296 0.015589

SD 0.000078 0.000107 0.000027

Average 0.003815 0.241356 0.015589

% Recovery 103.4 100.0 100.0

RPD 3.3 <0.1 <0.1

RPD = (C 1 -C 2 ) / (C 1 +C 2 /2) x 10055 Precision

Only two samples with duplicate analyses that were analyzed on March 20, 1980, were located, fuel pins WARD-W33-27 and WA RD-W32-20. The results for U and Pu radionuclides are provided in Tables 11a and 11b below:

Table 11a. Analytical Result s, Replicate Analysis

Radioisotope WARD-W33-27

Atom % WARD-W33-27, Atom %, RPD

U-233 <0.001 <0.001 0.00

U-234 0.868 0.871 0.35

U-235 77.59 77.52 0.10

U-236 1.34 1.34 0.00

U-238 20.20 20.27 0.35

Pu -238 0.037 0.036 2.74

Pu-239 89.92 89.90 <0.1

Pu-240 9.30 9.33 0.16

Pu-241 0.670 0.670 0.00

Pu-242 0.070 0.070 0.00

Table 11b. Analytical Re sults, Replicate Analysis

Radioisotope SRM WARD-W32-20

Atom % SRM WARD-W32-20

Atom % RPD

U-233 <0.001 <0.001 0.00

U-234 0.851 0.864 1.52

U-235 78.37 78.36 <0.01

U-236 0.891 0.904 1.45

U-238 19.89 19.87 0.20

Pu -238 0.037 0.031 17.64*

Pu-239 90.40 90.37 <0.01

Pu-240 8.86 8.90 0.45

Pu-241 0.641 0.633 1.26

Pu-242 0.062 0.060 3.28

RPD = (C 1 -C 2 ) / (C 1 +C 2 /2) x 100

* This value was excluded from considera tion because it appears to be an outlier.

The acceptability of the precision of the above m easurements is adequately demonstrated by the calculated RPD values that range from 0.00 to 3.28%. Replicates for SRMs U-005 and Pu 947 were analyzed and demonstrated acceptable precis ion for the analytical me thod used. The results of these replicate measurements are pres ented in Tables 9a, 9b, 10a, and 10b above.56 Bias

Bias in analytical methods is typically assessed from blank results, but the results of analytical standards may also be used. Based on reviewin g the available logbooks and analytical methods, EPA Inspectors realized that bla nks were not analyzed for this project, which complicates the evaluation of bias. However, the lack of bias in the analytical method is also demonstrated by the percent recoveries obtained for SRMs U-005 and Pu 947, as shown in Tables 9a and 9b and 10a and 10b, above.

Blind Sample Analysis (Performance Evaluation)

SRM standards were analyzed on a routine basi s for this program, as well as performance evaluation samples that were made by ANL and s upplied to LANL as QC samples. Analytical data, original data, and original calculations were available for fi ve samples of this type, BU-1- 77, BU-1-78, BU-1-79, BU-3-112 and BU-3-113 th at were analyzed on May 1, 1979, and are shown in Table 12, below. Alt hough the result data sheet does not unambiguously identify these as performance evaluation samples, the resu lt sheet for BU-1-80 and BU-2-95, analyzed on February 28, 1979 and July 16,1979, respectively, was titled “Analysis of ANL Synthetic Burnup Standard.” It is reasonabl e to infer that these other “BU-1- xx” samples were part of this QC program. The expected burnup value for th ese QC samples was provided in the records reviewed. Using the original data shown in Ta ble 13, J. Vance made an independent calculation of the burnup values. As the data used for ORIG EN input is part of th e burnup calculation, it is

reasonable to assume that the RPD for the is otopic abundances did not exceed the burnup RPD provided in Table 12. These results demonstrat e that LANL analyzed the QC samples with acceptable accuracy (recovery # 107%) and precision (RPD # 6.76%).

Table 12. Available LASL Quality Control Samples

QC Sam p le LANL Observed ANL Known % Recovery RPD

BU-1-77 2.13 2.0 106.5 4.90

BU-1-78 2.19 2.0 109.5 6.67

BU-1-79 2.13 2.0 106.5 4.90

BU-1-112 4.25 4.0 106.3 6.06

BU-1-113 4.28 4.0 107.0 6.76
RPD = (C 1 -C 2 ) / (C 1 +C 2 /2) x 100

Standards

The Certificates of Analysis for some of th e standards used in method ANC-DE-1-MS-3 were available for review. Only two of the SRMs liste d below were identified as having been assayed,

U-005 and Pu 947 as discussed above and shown in Tables 9a and 9b, and 10a and 10b, above. The other SRMs for which we examined objective evidence of the SRM’s certified values are

listed below:

U SRMs: U-500, U-0002, U-005, U-010U-015, U- 020, U-030, U-050, U-100, U-150, U-200, U-350, U-500, U-750, U-800, U-850, and U-900

Pu SRMs: 946, 947, and 94857 Table 13. Mass Spectrometry Calculations for Fuel Pin WARD-W8-37, LANL-1226-L

The data in light green are provided in the wo rksheets attached to the burnup results sheet. The numbers in yellow are the calculated num bers that can be checked against the corresponding values on the worksheets.

Nd-148 Yield 0.01672

Grams Spike 1.03809 These data are from attached data sheets for fuel pin 1226-L for WARD-W8-37

Atoms of U233/g 3.9989E+16
Atoms of Pu242/g 1.2440E+16
Atoms of Nd150 9.5302E+13

Uranium Data Unspiked Spiked

1 U-233 0 33.688

U-234 0.673 0.446 These data are from attached data

U-235 61.116 40.528 sheets for fuel pin1226-L for

U-236 2.04 1.352 WARD-W8-37

U-238 36.172 23.986

2 U-233 Spiked Sample Corrected for U-233 from Sample

U-233csx 33.688

3 Uranium Sensitivity Factor

SF(u) 1.2323E+15

4 Total Atoms of Uranium in Sample

U 8.17132E+16 OK

5 Uranium Percent of Sample Computed fr om Spiked Sample Data Correction

(F)u 1.508022681

Spike Corrected

U-233 0 OK

U-234 0.673 OK

U-235 61.117 OK

U-236 2.039 OK

U-238 36.171 OK

Pu Data Unspiked Spiked

1 Pu-238 0.139 0.091

Pu-239 88.624 58.013 These data are from attached data sheets for fuel pin 1226-L for WARD-W8-37

Pu-240 10.497 6.87258 Table 13. Mass Spectrometry Calculations for Fuel Pin WARD-W8-37, LANL-1226-L

Pu-241 0.672 0.44

Pu-242 0.068 34.585

2 Pu-242 of Spiked Sample Corrected for Pu-242 from Sample

Pu-242

csx 34.54048741

3 Pu Sensitivity Factor

(SF)pu 3.7388E+14

4 Total Atoms of Pu in Sample

(Pu) 2.44737E+16 OK

5 Pu Atom Percent of Sample Computed from Spiked Sample Data Corrected for Spike

(F)pu 1.527661848

Spike Corrected

Pu-238 0.139 OK

Pu-239 88.624 OK

Pu-240 10.498 OK

Pu-241 0.672 OK

Pu-242 0.068 OK

Neodymium Data Unspiked Spiked

1 Nd-142 0 0.978

Nd-143 1 1

Nd-144 1 1 These data are from attached data sheets for fuel pin 1226-L for WARD-W8-37

Nd-145 1 1

Nd-146 1 1

Nd-148 1 49.927

Nd-150 0.484 48.329

2 Nd-150 of Spiked Sample Corrected for Nd-150 from Sample

(Nd-150)s 24.28067528

3 Apparent Natural Nd Contamination Based on Mass 142

(142)c 0.708484504

3a 0.708484504

4 Correction of Unspiked

Data59 Table 13. Mass Spectrometry Calculations for Fuel Pin WARD-W8-37, LANL-1226-L

Unspiked

Nd-142 0

Nd-143 1

Nd-144 1

Nd-145 1

Nd-146 1

Nd-148 1

Nd-150 0.484

5 Correction of Spiked Data

(142)c 0.708484504

Nd-142 0.269515496

Nd-143 0.681961306

Nd-144 0.376746182

Nd-145 0.783062045

Nd-146 0.549970643

Nd-148 49.77722638

Nd-150 48.18213116

4 Nd-150 of Spiked Sample Corrected for Nd-150 from Sample and Corrected

for

Natural Nd Contamination

(Nd150)cs 24.20593877

5 Neodymium Sensitivity

Factor

(SF)nd 4.0871E+12

6 Atoms of Nd Isotopes in Sample

Nd-142 Nd-143 Not calculated for burnup determination

Nd-144

Nd-145

Nd-146

Nd-148 2.02465E+14 OK

Nd-150

7 Burnup Using Nd-148

F 1.21092E+16 OK Burnup 10.236% OK60 Conclusion

EPA has determined that there is sufficient inform ation and data available to demonstrate that the isotopic data used to verify the ORIGEN2.2 output were technically sound. Based on the objective evidence evaluated during the inspection, the data were generated by an analytical system with acceptable accuracy, precision, a nd bias to support its use in supporting the radionuclide scaling factors derived usi ng ORIGEN2.2 for INL-CCP RH TRU wastes.

8.2.5 Documents, Waste Containers, and Batch Data Reports Reviewed

The list of documents provided below includes all documents related to the INL-CCP RH radiological characterization pr ogram that were evaluated to support this inspection:

• CPP-PO-002, CCP Transuranic Wast e Certification Plan, Revision 16

• CCP-AK-INL-500, Central Characterization Project Acceptable Knowledge Summary Report for Remote-Handled Transuranic Debr is Waste from Argonne National LaboratoryEast Stored at the Idaho National Laboratory, Revision 2 and Revision 3

• CCP-AK-INL-501, Central Characterization Project Remote-Handled Transuranic Radiological Characterization Technical Report for Remote Handled Transuranic Debris

Waste from Idaho Nationa l Laboratory, Revision 0

• CCP-AK-INL-501, Central Characterization Project Remote-Handled Transuranic Radiological Characterization Technical Report for Remote Handled Transuranic Debris

Waste from Idaho National Labor atory, Revision 1, June 6, 2006

• CP-AK-INL-502, Central Characterization Project Confirmatory Test Plan for Waste Stream: ID-ANLE-S5000, Revision 0

• CCP-TP-504, Dose-to-Curie Survey Procedure for Remote-Handled Transuranic Waste,

Revision 2

• CCP-TP-506, CCP Preparation of the Remote –Handled Transuranic Waste Acceptable Knowledge Characterization Rec onciliation Report, Revision 1

• Information on Fuel Elements Examined at the AGHCF at ANL from November 1971 to August 7, 1995, Based on Waste Consolidatio n Records; Project No. 23048, EDF-6695, Revision 0, Effective Date May 19, 2006

• Identification of Additional Fuel Elements/M aterials Examined in the Alpha-Gamma Hot Cell Facility for ANL-E TR U Waste; Project No. 23048, ED F-6946, Revision 0, Effective Date May 19, 2006

• Neutron and Gamma-Ray Dose Conversion Fact ors from 1 Meter to Contact for Argonne National Laboratory-East Remote Handled Transuranic Waste; Project No.32-48, EDF-7069, Revision 0, Effective Date June 08, 2006

• INL Batch Data Report No. INL-RH -DTC 06001: Twenty nine drums

• Calculation Package Supporting Scaling Factor Derivation: INL-RH -01, Fuel Composition

Calculations61 • Calculation Package Supporting Scaling Factor Derivation: INL-RH -02, Scaling Factor Development

• Calculation Package Supporting Scaling Fact or Derivation: L ANL-RH-03, U and Pu Isotopic Relationships in Fuel

• Calculation Package Supporting Scaling Factor Derivation: INL- RH-03, Dose-to-Curie

Derivations for Cs-137 in 30-Gallon Drums

• Calculation Package Supporting Scaling Factor Derivation: INL-RH-04, MCNP5 Sensitivity

Studies

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-05, Mass Spectrometry Results Input Check Calculation

• Calculation Package Supporting Scaling Factor Derivation: INL- RH-05, Cs-137 Dose-toCurie Uncertainty

• Calculation Package Supporting Scaling Fa ctor Derivation: INL-RH-06, Drum Characterization, DTC and Related Calc ulations for Drum Characterization

• Calculation Package Supporting Scaling Fa ctor Derivation: INL-RH-06, Drum Characterization, DTC and Rela ted Calculations for Drum Characterization, Revision 1

• Calculation Package Supporting Scaling Fact or Derivation: IN L-RH-07, Uncertainty Analysis for Drums

• Calculation Package Supporting Scaling Factor Derivation: INL- RH-08, Evaluation of Isotope Contribution to the Total Radiological Hazard

• Calculation Package Supporting Scaling Fa ctor Derivation: LANL-RH-09, ORIGEN2.2

Verification Check

• Calculation Package Supporting S caling Factor Deriva tion: INL-RH-09, Dose-to-Curie for Cs-137 and Co-60, Shielded and Unshielded

• Calculation Package Supporting Scaling Factor Derivation: LANL -RH-08, Microshield 7.00

Verification

• Calculation Package Supporting Scaling Fact or Derivation: L ANL-RH-18, MCNP5 Code

Verification Check

• Calculation Package Supporting Scaling Fa ctor Derivation: LANL-RH-09, ORIGEN2.2

Verification

• Calculation Package Supporting Scaling Fact or Derivation: LANL -RH-15, ORIGEN2.2 Data

Extraction

• Calculation Package Supporting Scaling Fa ctor Derivation: LANL-RH-14, ORIGEN2.2 Input Generation

• Calculation Package Supporting Scaling Fact or Derivation: L ANL-RH-10, Fission Product

Contribution to Total Dose Rate

• Calculation Package Supporting Scaling Fa ctor Derivation: INL-RH-11, RERTR Adjustment Factor Development62 • Calculation Package Supporting Scaling Factor Derivation: LANL -RH-12, Evaluation of PotentialCs-137 Migration

• Calculation Package Supporting Scaling Factor Derivation: INL-RH -12, Disposition of

Identified Radioactive Materials from AGHCF

• Calculation Package Supporting Scaling Factor Derivation: INL-RH -13, Modification of ORIGEN2.2 Input Files fo r Specific Fuel Pins

• Calculation Package Supporting Scaling Factor Derivation: LANL -RH-13, Evaluation of One-Step Irradiation Input to ORIGEN2.2

• Calculation Package Supporting S caling Factor Deriva tion: INL-RH-14, Co-60 Dose Rate

Contribution

• Calculation Package Supporting Scaling Fa ctor Derivation: LANL-RH-14, ORIGEN2.2 Input Generation

• Calculation Package Supporting Scaling Factor Derivation: INL-RH -15, Burnup Estimates

for Thorium Pins

• Calculation Package Supporting Scaling Fa ctor Derivation: LANL-RH-15, ORIGEN2.2 Output Data Extraction

• Calculation Package Supporting Scaling Factor Derivation: INL-RH -16, Scaling Factor Sensitivity Study

• Calculation Package Supporting Scaling Factor Derivation: LANL-RH-16, Mass Spectrometry Comparison to ORIGEN2.2 Results

• Calculation Package Supporting Scaling Fa ctor Derivation: LANL-RH-18, MCNP5

Verification Check

• Calculation Package Supporting Scaling Factor Derivation: LANL-R H-29, Sensitivity of

ORIGEN2.2 to Other Fast Reactor Cross Sections

• Calculation Package Supporting Scaling Factor Derivation: LANL -RH-30, Evaluation of Reactor Operating History

• MS Exhibit 1: Typica l MS result sheet

• MS Exhibit 2: Manual calculation of burn-up ra te from data generated for fuel pin WARDW8-37, LASL Job Number 1226-L (Courtesy of Jene Vance)

• ANC-DE-1-HC-3 “The Dissolution of Irradiated Materials,” Revision 2, Sections 3.1, 3.2, August 22, 1973

• ANC-DE-1-MS-2 “Determination of Atom Percen t Fission in Uranium and Plutonium Fuel,” Revision 2, August 22, 1973 and Revision 3, March 24, 1976 (Section 4.5.3; 4.5.5)

• ANC-DE-1-MS-3 “Determination of the Isotopi c Compositions of Uranium and Plutonium,” Revision 3, August 22, 1973, and Revision 4, April 13, 1981 (Sections 4.5.4, 4.5.5)

• Quarterly Reports:

o Progress Report, LA-5067-PR, April 1 to June 30, 1972

o Progress Report, LA-5390-PR, April 1 through June 30, 197363 o Page 39: Development of Burnup Method Using Conventional Low-Cost Apparatus.

o Progress Report, LA-9372-PR, January 1 – March 31, 1982

o Progress Report, LA-9959-PR, July 1 – October 31, 1983, page 2, III Analytical Chemistry

Summary of Radiological Characterization Findings and Concerns - DTC and Scaling Factor Development

The EPA inspection team did not identify any c oncerns or findings relative to DTC or the development of radionuclide scaling factors as part of the radiol ogical characterization technique evaluated during this inspec tion. There are no open issu es related to radiological

characterization resultin g from this inspection.

Radiological Characterization Baseline Approval

EPA approves the INL_CCP radiolog ical characterization program that the EPA inspection team evaluated during this baseline in spection and consists of the following two techniques used jointly for containers of RH TRU in one waste stream, ID-ANLE-S5000:

• The determination of the 10 WIPP-tracked radionuclides based on the DTC procedure presented in CCP-TP-504

• The application of radionuclide scali ng factors derived as documented in CCP-AK-INL-501 and supported by the 33 calc ulation packages referenced in

Section 8.2.5

Radiological Characterization Tiers

Based on the inspection and the results discu ssed above, EPA assigns the following tiers:

T1 Radiological Characterization changes that require EPA review and approval prior to implementation are the following:

• Application of new scaling factors for isotopic determ ination other than those

documented in CCP-AK-INL-501

• The use of an alternate charac terization technique other than DTC and the application of

established radionuclide scal ing factors as documented in CCP-TP-504 or substantive modification of the DTC procedure 14

• Addition of a new waste stream not approved un der this baseline or a ddition of containers to Waste Stream ID-ANLE-S5000 that requir es changing the esta blished radionuclide scaling factors

14 Substantive modification refers to the use of an inherently different type of measurement instrument or the use of the high range probe described for INL-CCP-504, si nce both of these would constitute a WC component not previously evaluated by EPA.64 T1 changes will be reported and documentation will be submitted when INL-CCP is ready for EPA review. In case of T1 NDA changes, EPA will inform INL-CCP and CBFO whether a site inspection is necessary. EPA may request add itional information, choose to conduct a desktop review, and/or confer with INL-CCP personne l. Upon evaluation (w ith or without site inspection), EPA will issue an approval lette r and only upon receiving the EPA approval can INL-CCP continue to use the equi pment affected by the change.

T2 Radiological Characterization changes that do not require EPA approval prior to implementation but require reporting and a brief description of the changes to the documents, include the following:

• Changes made to CCP-INL-AK-501, Revision 2, or CCP-TP-504, Revision 2 that require CBFO approval

Following EPA approval, INL-CCP will provide EP A with information concerning T2 changes on a quarterly basis. EPA will evaluate these changes and communicate with INL-CCP as to whether the changes raise any concerns and requi re an INL-CCP response, or whether INL-CCP can continue to implement the changes. Cons istent with EPA’s authority under 194.24(h) EPA may request information relative to these changes if EPA deems the information is necessary to ensure continued compliance with EPA regulations.

8.3 Visual Examination

Waste Characterization Element Description

The VE process for RH waste consists of review ing existing audio/visual recordings that were made at the time of packaging for the purpos e of generating VE data. Using CCP-TP-500, Revision 2, Remote-Handled Waste Visual Examination , two VE operators identified and

documented the waste contents of the containers examined by this process. VE determines the following aspects of RH TR U Waste Characterization:

• Confirmation that the waste matches the waste stream description given in AK

• Description of the container contents in cluding waste material parameters (WMP)

• Confirmation of the presence or absence of residual liquid that exceeds one percent of the

volume of the waste container

Documents Reviewed

The following documents, procedures and other pi eces of objective evidence were reviewed to assess whether VE operations follow the appr opriate approved procedures and meet VE requirements:

• CCP-TP-500, Revision 1, Remote-Handled Waste Visual Examination , April 27, 2006

• CCP-TP-500, Revision 2, Remote-Handled Waste Visual Examination , June 19, 200665 • CCP-QP-002, Revision 20, Training and Qualification Plan , May 3, 2006

• Remote-Handled TRU Waste Characterization Program Implementation Plan, Revision 0D, October 30, 2003

• VE Batch Data Report (BDR) RHINLVE60001, cons isting of 19 containers, 5 of which were subject to a CCP Non Conformance Report (NCR)

• VE BDR RHINLVE60002, consisting of 19 contai ners, 17 of which were subject to a CCP

NCR

• VE BDR RHINLVE60003, consisting of 20 containe rs, 17 of which were subjected to a CCP

NCR

• Audio/visual recording for BDRs RH INLVE60001, RHINLVE60002, and RHINLVE60003 The following records were reviewed:

• Visual Examination Op erator/ITR/TS/FQAO

• Qualification Card for one VEE

• List of qualified VE personnel

• List of currently qualified VE personnel

• Qualification cards for three Visual Examination Operators

• Comprehensive examination for VE Operators

• AK Summary training material

• Daily Production Report, dated June 13, 2006

• List of exempted software

• Review of CY 2000 Retrieved RH -TRU Drums for Water (report)

Technical Evaluation

During the inspection, the technical elements of the VE process were evaluated using the

checklist contained in Attachment A.2. These ar eas are summarized below. Please note that during the on-site inspecti on, EPA Issue No. INL-CCP-RH-VE-06-001F was originally designated as a finding and EPA Issue No. INL-CCP-RH-VE-06-003CR was designated as a concern requiring a response. Following discussions after the c onclusion of the inspection, EPA changed the status of each concern, whic h produced the concern INL-CCP-RH-VE-06-001CR (formerly INL-CCP-RH-VE-06-001F) and the finding INL-CCP-RH-VE-06-003F (formerly INL-CCP-RH-VE-06-003CR). This is di scussed in the s ections below.

(1) Overall procedural technical adequacy and implementation

The visual examination procedure is documen ted in CCP-TP-500 and was written to provide instructions to VE personnel wh en they perform actual VE. EP A identified a concern with this process that was recorded on EPA Issue Inspecti on Issue Tracking Form (see Attachment B.2 for this form). The concern is discussed below.66 EPA Concern No. INL-CCP-RH-VE-06-002CR: For the RH waste containers processed to generate BDR RHINLVE60001 at the time of the inspection, VE consisted of reviewing existing VE audio/visual recordings. During this process VE operators had to “interpret” the instructions in the VE pro cedure to adjust them to wh at they were actually doing.

Resolution: In response to EPA’s concern, INL- CCP revised the procedure to include instructions for performing VE by reviewing th e audio/visual record ings, and INL-CCP VE personnel generated BDRs RHINLVE60002 and RH INLVE60003 using the revised procedure, both of which were available during the follow-up inspection.

Status of Concern: EPA considers this concern to be closed.

(2) Characterization of WMPs and prohibited items were evaluated

EPA did not observe the RH VE process during the initial on-site inspection. The data sheets

contained in BDR RHINLVE60001 were reviewed in conjunc tion with the audio/visual recordings to ensure consistency between the vi sual and written records. Upon inspection of these records, EPA generated an EPA Issue Insp ection Issue Tracking Form (see Attachment B.3 for this form) to address the issue discussed below, as well as in item (3):

EPA Finding No. INL-CCP-RH-VE-06-003F: EPA’s review determined that all waste items in the containers were not recorded on the data sheets, resulting in incomplete inventories for the

RH containers.

Resolution: In response to EPA’s concern, INL-CCP provided additional training to the VE operators and VEE during the initial on-site inspection.

Status of Concern: EPA considered this finding to be closed.

The presence or absence of prohibited items a nd confirmation that the waste matched the waste stream description given in the AK were dete rmined and documented as required. During the follow-up inspection, EPA reviewed the audio/visu al recordings and data sheets for selected

containers in BDR RHINLVE6000 3. During this review, a VE operator explained the process and how decisions were made with regard to id entification of WMPs. EPA identified a concern that was captured on an EPA Inspection Issue Tr acking Form (see Attachment B.8 for this form)

that is discussed below.

EPA Concern No. INL-CCP-RH-VE-009C: EPA determined that although INL-CCP had provided additional training to VE operators, the original inventories recorded for containers in BDR RHINLVE60003 were still incomp lete. INL-CCP had identified this issue prior to EPA’s follow-up inspection and had revised the containe r inventories as needed. Additionally, when the ITR reviewed and approved this data package, he did not identify that the QAO for representativeness for all three of the containers that were not subject to an INL-CCP NCR was not met. This concern also impacted the docum entation of VE activities and is also discussed under item (3), below.

Resolution: INL-CCP was not required to provide a formal response to EPA’s concern, but INL-CCP provided additional trai ning to the VE personnel.67 Status of Concern: EPA considers this concern closed.

(3) Documentation of VE activities was examined

During the initial on-site inspec tion, EPA reviewed data packag e RHINLVE60001 to verify that the VE data were documented correctly and co mpletely. EPA generated an EPA Inspection Issue Tracking Form (see Attachment B.8 for this form) to capture the issue discussed below.

EPA Finding No. INL-CCP-RH- VE-06-003F, Revision 2: EPA determined that the VE data was incomplete. Operators were not recording all waste items identified in containers, and hence the waste can inventories were incomplete. This concern also impacted the characterization of WMPs and prohibited items and is also discussed in item (2), above.

Resolution: INL-CCP prepared a briefing addressing this issue and presented it to VE operators during the initial on-site inspection. At the follow-up inspection, EPA reviewed an additional two BDRs, RHINLVE60002 and RHINLVE60003.

Status of Concern: EPA considered this concern to be closed.

EPA Concern No. INL-CCP-RH-VE-06-009C: Although RHINLVE60003 was generated after the additional training the original data shee ts did not contain a comp lete inventory of waste items. INL-CCP had identified this issue prio r to EPA’s follow-up inspection and had revised the container inventories. EPA generated an EPA Issue Inspection Issue Tracking Form to capture this issue (see Attachment B.8 for a copy of this form). Completed data generation and project-level review checklists we re included in the data packag e that was reviewed. The VEE who performed the ITR review on BDR RHINLVE60003 failed to re cognize that all data were not being recorded, which was included in Concern No. INL-CCP-RH-VE-06-009C.

Resolution: Concern No. INL-CCP-RH-VE-06-009C did not require a formal response from

INL-CCP.

Status of Concern: EPA considers this concern closed.

(4) Training for VE personnel was examined

The site maintains a list of qualified individuals, which is used to ensure that all training is current. During the inspection, th e qualification packages for th e three RH VE operators were reviewed and found to document adequate training for VE personnel. Upon examination of the qualification packages, EPA generated an EPA In spection Issue Tracking Form (see Attachment B.1 for a copy of this form) to cap ture the issue discussed below.

EPA Concern No. INL-CCP-RH-VE-06-001CR: In accordance with the requirements of the WCPIP and CCP-TP-500, VE operato rs are only considered to be qualified when they have completed the required on-the-job training (OJT) and passed a writ ten examination with a grade

of 80% or better. At the time the BDR RHIN LVE60001 was generated, the operators had not taken the comprehensive examination and were not therefore qualified to perform the VE event according to the WCPIP and CCP-TP-500.68 Resolution: In response to EPA’s issue, INL-CCP’s RH VE expert reviewed the data in RHINLVE60001 and determined that data quality was not affected. VE operators took and passed the required examination prior to generation of BDRs RHINLVE60002 and RHINLVE60003, both of which were reviewed during the follow-up segment of this inspection.

Status of Concern: EPA considers this concern closed.

Summary of VE Findings and Concerns

The EPA inspection team identified the findings a nd concerns related to VE that are discussed above. Copies of the EPA Inspection Issue Tr acking Forms are provided in Attachments B.1 through B.3, and B.8. EPA considers all findings and concerns to have been adequately addressed, and there are no open findings or concerns related to VE resulting from this inspection

.

VE Baseline Approval

EPA approves the VE of audio/vi deo media process for RH waste that the EPA inspection team evaluated during this base line inspection and which consisted of the following:

• Trained personnel: VE operators, VEE

• Approved and controlled operating proce dures CCP-TP-500, Re vision 2; CCP-QP-002,

Revision 20

• VE records and supporting data: Visual Ex amination Data Forms, CCP-TP-500 review checklists, and three VE BDRs (VE BDR Nos. RHINLVE60001, RHINLVE60002 and RHINLVE60003)

• INL RH S5000 Debris Waste Stream ID- ANLE-S5000, 19 drums total from the three BDRs listed in the previous bullet

Based on the results of this inspection, EPA propos ed this process of VE by review of existing audio/visual recordings for approval for S5000 wast e. The VE process EPA evaluated as part of this inspection is based on the three VE BDRs (listed above) th at INL-CCP generated during the inspection. Based on this review, EPA propos ed a limited approval by identifying eight (8) drums that can be disposed of at WIPP. EPA received comments questioning the proposed limited approval (See Comment Nos. 8 and 12 in the EPA Docket ID No. EPA-HQ-OAR-2006- 0881). Also, during the comment period for th e proposed approval, INL-CCP provided EPA with additional information related to an improve d VE technique as well as an additional VE BDR (No. RHINLVE60004). Upon ex amination of this additional information, EPA determined the proposed baseline approval in correctly limited the approval to eight (8) drums. The final baseline approval is corrected to state that ninete en (19) drums of retrie vably-stored RH debris waste from the 3 BDRs reviewed by EPA are appr oved for disposal. EPA also determined that the improved VE process that was identified by DOE during the comment period is subject to a T1 evaluation (See Attachment C, EPA’s res ponse to Comment Nos. 8 and 12). EPA has begun

this evaluation and the results of the T1 evalua tion will be provided upon completion separately.69 VE Tiers

EPA assigns a T1 change designation for the VE process based on the unde rstanding that (a) the VE process used to examine 58 RH debris waste containers discussed in three BDRs listed above

was not to be used for VE of the INL RH waste c ontainers in the future; and, (b) these containers were to be reexamined using a real-time-radi ography process. In th e event that INL-CCP decides to use the VE process observed during th is baseline inspection as described in this

section to examine RH waste containers in th e future, EPA review and approval are necessary prior to implementation as a Tier 1 change

8.4 Real Time Radiography

The technical area of RTR was not evaluated duri ng this inspection. If INL-CCP wishes to use

RTR to characterize RH TRU wast es, EPA approval (separate from what is contained in this report) is required.

EPA is not approving RTR at this time. INL-CC P did not have an operational RTR unit in place at the time of the inspection. This final base line inspection requires the use of RTR as a T1 change. Therefore, INL-CCP cannot ship RH wa ste to the WIPP using RTR as a WC technique until it is approved by EPA. EP A received a request for an evaluation and approval of a RTR process. Once the evaluation is complete, the results of the T1 evaluation will be provided separately.

8.5 WIPP Waste Information System

The technical area of WWIS was not evaluated du ring this inspection. Pr ior to INL-CCP using the WWIS to characterize RH TRU wastes, EPA appr oval separate from what is contained in this report is required.

EPA is not approving the WWIS fo r entry and tracking of the wa ste contents of RH debris wastes at this time. Although the WWIS is cu rrently approved by EPA for tracking CH waste, INL-CCP had not demonstrated its adequacy to enter and track RH waste contents during this baseline inspection. During the comment period for the proposed approval CBFO notified EPA that the WWIS was operational for RH wastes and was ready for EPA evaluation as a T1 change. EPA has begun this evaluation and the results of EPA’s T1 evaluation will be provided upon completion separately.

9.0 RESPONSE TO COMMENTS

By the end of the comment period (December 26, 2006), EPA received one set of public comments. (Comments are available from EP A Docket ID No. EPA- HQ-OAR-2006-0881.)

EPA evaluated those comments a nd revised the report accordingl y. Attachment C provides the public comments and EPA’s response.70 10.0 SUMMARY OF RESULTS

10.1 EPA Findings and Concerns

The findings and concerns issues identified during the inspection, as well as INL-CCP’s responses, are discussed in the pr eceding sections of this report. Copies of the EPA Inspection Issue Tracking Forms that capture these issues are included in Attachment B. INL-CCP responded to all EPA findings and concerns that required a response prior to the inspection closeout on site, as well as subsequent to th e inspection. The EPA inspection team members evaluated all responses for completeness and ad equacy, and concluded that each EPA issue requiring a response had been resolved satisfactoril y. No EPA issues remain open at this time.

10.2 Conclusions

EPA’s inspection team determined that INL-CCP’s RH WC program activities were technically adequate. EPA is approving the INL-CCP-RH WC program in the configuration observed during this inspection, described in this report, and documented in detail in the checklists in Attachment A. The approval includes the following:

• The AK process for RH retrievably-stored TRU debris in one waste stream, Waste Stream No. ID-ANLE-S5000, Lots 1 th rough 20, as defined in CCP-AK-INL-500,

Revision 3

• The radiological characterization proce ss using DTC and modeling-derived scaling factors for assigning radionuclide values to one RH waste stream for which the scaling factors are applicable, as desc ribed in CCP-AK-INL-501, Revision 1

• The VE of audio/video media process used for a total of nineteen (19) retrievably-stored

RH debris waste drums included in th ree batch data reports (BDR Nos. RHINLVE60001, RHINLVE60002, and RHINLVE60003

As stated in Attachment C (see response to Comment Nos. 8 and 12), EPA is reviewing additional information submitted during the comment period for the proposed approval regarding an improved VE procedure. Upon examination, EP A determined that this VE information is subject to a T1 evaluation. EPA has begun the evaluation of this new VE information and the results of the T1 evaluation will be provided upon completion.

EPA is not approving the WWIS for tr acking the waste contents of RH debris wastes at this time. Although the WWIS is currently approved by EP A for tracking CH waste, INL-CCP had not demonstrated its adequacy to track RH waste c ontents during this baseline inspection. During the comment period for the proposed approva l CBFO notified EPA that the WWIS was operational for RH wastes and was ready for EPA evaluation as a T1 change. EPA is in the process of reviewing the WWIS database that ha s been populated with actual RH waste content

data. The results of the T1 evaluation will be provided upon completion. No RH waste can be shipped to WIPP for disposal until EPA approves the WWIS as a T1 change.

EPA is not approving RTR. INL-CCP did not have an operational RTR unit in place at the time of the inspection. EPA requires that INL-CCP pr ovide notification when RTR is ready for EPA71 inspection as a T1 change. INL-CCP cannot ship RH waste to WIPP using RTR as a WC technique until it is inspected and approved by EPA.

Any changes to the WC activities from the date of the baseline inspection must be reported to and, if applicable, approved by EPA, according to Table 14.72Table 14. Tiering of RH TRU WCProcesses Implemented by INL-CCP(Based on June 12–16 Baseline and August 9 & 29, 2006, Follow-Up Inspections)RH WC Process ElementsINL-CCP RH WC Process - T1 ChangesINL-CCP RH WC Process - T2 Changes*Acceptable Knowledge (AK)Modification of the approved waste stream ID-ANLE-S5000 toinclude additional containers, i.e., K Cell or other debris wastes;AK (1) and AK (5)Any new waste streams not approved under this baseline; AK (1) andAK (7)Substantive modification(s)*** that have the potential to affect thecharacterization process: CCP-AK-INL-500, CCP-AK-INL-501, orCCP-AK-INL-502; AK (6) and AK (7)Load management for any RH waste stream; AK (16)Notification to EPA when updates to CCP-INL-AK-500,CCP-INL-AK-501, and CCP-INL-AK-502 are approvedby CBFO; AK (4)Notification to EPA when changes to AK documentationas a result of WCPIP revisions** have been made (e.g.,CRR); AK (7) and AK (9)Notification to EPA when aCorrelation or SurrogateSummary Form is completed for each of the RHcontainers in this waste stream identified as CH basedupon measured dose rates that present NDA results forassayed containers; AK (10), AK (14) and RC (8.2.2)Notification to EPA once waste stream data package fordebris waste stream, and any modifications to the WSPFincluding the CRR and AK Summary are completed; AK(14)Notification to EPA that the final DTC determination iscomplete for RH containers numbers 728 through 737, asidentified in AK ReferenceP030; all other AK accuracyreports prepared annually at a minimum; AK (15)Radiological Characterization, includingDose-to-Curie (DTC)Application of new scaling factors for isotopic determination otherthan those documented in CCP-AK-INL-501; RC (8.2.2 and 8.2.3)Use of any alternate radiological characterization procedure other thanDTC with established scaling factors as documented in CCP-TP-504or substantive modification of the DTC procedure***; RC (8.2.2 and8.2.3)Any new waste stream not approved under this baseline or addition ofcontainers to Waste Stream ID-ANLE-S5000 that requires changingthe established radionuclide scaling factors; RC (8.2.3)Revisions of CCP-AK-INL-501or CCP-TP-504 thatrequire CBFO approval; RC (8.2.2 and 8.2.3)Visual Examination of audio/video media(VE)Implementation of VE following this baseline approval; if INL-CCPdecides to use VE in the future, EPA approval is necessaryNoneReal-Time Radiography (RTR) Any use of RTR requires EPA approvalNoneWIPP Waste Information System (WWIS) Any use of WWIS requires EPA approval prior to RH waste disposal None* Upon receiving EPA approval, INL-CCP will report all T2 changes to EPA every three months.** Excluding changes that are editorial in nature or are required to address administrative concerns.***Substantive modificationrefers to a change with the potential to affect INL-CCP’s RH WC process, e.g., the use of an inherently different type of measurement instrumentor the use of the high-range probe as described in CCP-TP-504.73 11.0 REFERENCES

U.S. Department of Energy, Carlsbad Area Fiel d Office, “Contact-Handled Transuranic Waste Acceptance Criteria for the Waste Isolation P ilot Plant (CH-WAC),” Revision 3, DOE/WIPP-02- 3122, Carlsbad, New Mexico, April 25, 2005.

New Mexico Environment Department, Waste Is olation Pilot Plant Hazardous Waste Facility Permit, NM48901 139088-TSDF, Santa Fe, New Mexico, 1989.

U.S. Environmental Protection Agency, “Criteria for the Certification and Recertification of the Waste Isolation Pilot Plant’s Compliance with the Disposal Regulations: Certification Decision; Final Rule,” Federal Register , Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405.

U.S. Code of Federal Regulations, Title 40

, Protection of Environment , Part 191, “Environmental Radiation Protection Standards for Management a nd Disposal of Spent Nuclear Fuel, High-Level

and Transuranic Radioactive Wastes.”

U.S. Code of Federal Regulations, Title 40

, Protection of Environment , Part 194, “Criteria for the

Certification and Re-Certification of the Wast e Isolation Pilot Plant’s Compliance with the 40 CFR Part 191 Disposal Regulations.”

U.S. Department of Energy, Carlsbad Area Field Office, “Remot e Handled TRU Waste Characterization Program Implementation Pl an”, DOE/WIPP-02-3214, Revision 0D, Carlsbad, New Mexico, October 30, 2003.

U.S. Department of Energy, Title 40 CFR Part 191, Compliance Certificati on Application for the Waste Isolation Pilot Plant, DOE/C AO 1996-2184, Carlsbad, New Mexico, 1996.

U.S. Department of Energy, Title 40 CF R Part 191, SUBPART D AND C, Compliance Recertification Applica tion 2004, DOE/WIPP/2004-3231.

U.S. Department of Energy, Carlsbad Area Field Office, “Quality Assurance Program Description (QAPD)”, DOE/ CBFO-94-1012, Revision 7, Carlsb ad, New Mexico, July 2005.

U.S. Nuclear Regulatory Comm ission, “Contact-Handled Transuranic Waste Authorized Methods for Payload C ontrol (CH-TRAMPAC).”Attachments A.1 through A.3AK-1ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/AdequacyImplementation of Characterization Methods to Satisfy DQOs (WCPIP Section 4.2)How are the following DQOs being addressed—any ofthese that AK is used to determine must bequalified/verified as per section 4.3, except for the firstbullet (defense):•Defense determination•TRU waste determination•RH waste determination•Activity determination (total and activity percanister)•Residual liquids•Physical form•Metals•Cellulosics, plastics, rubberWCPIP Revision 0D, Section 4.2;CCP-P0-002, Rev. 17.Interview of AKEsincluding Steve Schafer,Kevin Peters, Lisa Price;Mark Doherty;Examination of objectiveevidence.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-500 Rev. 1-3; CCP-AKINL-501 Rev. 1, CCP-AK-INL-502 Rev. 0,CCP-TP-506 Rev. 2, CRR for waste streamID-ANLE-S5000, AK Accuracy Report,WSPF, CRR.Addition of a DQO requiringidentification/quantification of the EPA10 radionuclides is required to comportwith EPA regulations. Furthermore, theCTP, Certification Plan, and otherdocuments did not clearly indicate theprocess by which DQOs would be achievedas determined during interviews:verification (qualification) of AK in allinstances. Note that EPA expects revisionsto any and all of the above listeddocuments in response to changes to theWCPIP. EPA expects these documents tobe provided to EPA if WCPIP-relatedrevisions occur.Qualification/Verification of AK Data (WCPIP Section 4.3)Is AK Qualification/verification required becausecharacterization information exists that was generatedprior to an established QA Program?WCPIP Revision 0D, Section 4.3,CCP-P0-002, Rev. 17.Interview of AKEsincluding Steve Schafer,Kevin Peters, Lisa Price,Mark Doherty;examination of objectiveevidence.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-502 Rev. 0; CCP-AK-INL500 Revisions 1-3All wastes are retrievably stored and weregenerated prior to an established EPAapproved QA program.a. If yes, what Qualification approach is used and forwhich characterization data (e.g. Peer Review,WCPIP Rev. D, Section 4.3, CCPP0-002, Rev. 17.Interview of AKEsincluding Steve Schafer,Kevin Peters Lisa Price;Examples of objective evidence obtainedinclude but are not limited to:AK-2ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/AdequacyConfirmatory Testing, Equivalent QA)Kevin Peters, Lisa Price;examination of objectiveevidence.CCP-AK-INL-502 Rev.0; CCP-AK-INL500b. If Peer Review performed, does it follow requirementspresented in Section 4.3.1 of the PIP?WCPIP Rev. D, Section 4.3, CCPP0-002, Rev. 17.Interview of AKEsincluding Steve Schafer,Kevin Peters, Lisa Price.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-502 Rev.0; CCP-AK-INL500 Revs. 1-3, P596Peer Review performed but was notsubmitted as qualification/verificationmethod; Peer Review included in AKrecord.c. If Confirmatory Testing is performed, does it followrequirements presented in Section 4.3.3 of the PIP andwhich methods are used?•100 percent VE at time of packaging•10-10-all•Representative sample collection to confirmisotopic distribution•100% NDA•DA•DTC•Other as described in a Confirmatory Testing Plan:- VE by review of a percentage ofaudio/videotapes- Analysis of representative samples forradiological data- VE/radiography of a subpopulation of waste- Qualification of existing radiological samplingand analytical info via modeling (e.g.ORIGEN)WCPIP Rev. D, Section 4.3, CCPP0-002, Rev. 17.Interview of AKEsincluding Steve Schafer,Kevin Peters, Lisa Price.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-502; CCP-AK-INL-500; AKTracking Spreadsheet, CCP-AK-501, DTCconversion Records, CRR-, BDRs for00738, 00739, 00740, 00742, 00743CCP is to perform DTC and examination ofall VE tapes/records for each container.CTP described process including requiredcontents of PIP including DQO and QAOidentification (see checklist discussionbelow).AK-3ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacy•Did the generator submit a Confirmatory Test Planas described in Section 4.3.3 of the PIP? If so, hasCBFO audited and approved the process? Did itcontain the following and was it adequate:- Description of the waste stream or wastestream lots to which the plan applies- Explicit description of DQOs and QAOs thatwill be satisfied with the data being qualified- Description of DQOs and QAOs that willNOT be confirmed with the data beingqualified and an explanation of howcompliance with those DQOs and QAOs willbe demonstrated- Description of the confirmatory testingproposed, including the percentage of wastecontainers subject to confirmatory testing- Description of how the tested subpopulationswill be representative of the waste stream orwaste stream lot- Quantitative acceptance criteria fordetermining that the AK information inquestion can be qualified as characterizationdata.General Checklist QuestionsIs the scope of the waste for which approval is soughtdefined? What is it?WCPIP Rev. 0D, CCP-P0-002,Rev. 17.Interview of AKEsincluding Steve Schafer,Kevin Peters, Lisa Price.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-500; CCP-AK-INL-502.Approval sought for single waste streamID-ANLE-S5000. It does not include otherwastes (e.g., K cell) discussed in the AKSummary but currently not included in theidentified waste stream. Changes to thestream to include these new wastes wouldrequire EPA notification, as would additionAK-4ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacyof any new waste streams. Furthermore,changes to AK documents CCP-AK-INL500 and 501 that affect the characterizationprocess require EPA notification andapproval.Is the waste TRU by definition as presented in the LWA?(P.L.102-579)WCPIP Rev. 0D, CCP-P0-002,Rev. 17.Interview of AKEsincluding Steve Schafer,Kevin Peters, Lisa Price;review of objectiveevidence.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-500, CCP-AK-INL-501,TRU WAC, P002, U015, U022, U040,U072, U041, U042.INL-CCP does not intend to load managethis stream, but if this is performed EPAnotification is required. This includes theinclusion of CH containers in the streamthat were originally identified as RH, butdetermined to be CH based onmeasurements.Are any wastes considered (or previously considered)HLW? HLW are prohibited.(P.L.102-579)Are any wastes considered (or previously considered)Spent Nuclear Fuel?(P.L.102-579)WCPIP Rev. D, CCP-P0-002, Rev.17.Interview of AKEsincluding Steve Schafer,Kevin Peters, Lisa Price;review of objectiveevidence.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-500, CCP-AK-INL-501;P593, P592, C121,C332, P001, P002,P023, P032, P055, U013Personnel and TrainingWho are the AK Personnel?Upon interview, do theyperform the duties presented inAttachment A, Section 3?Who is the Site Project Manager (SPM)? Uponinterview, do they perform the duties presented inAttachment A, Section 3?Who is the Site ProjectQuality Assurance Officer(SPQAO)? Upon interview, do theyperform the dutiesWCPIP Rev. D Attachment A; CCPP0-002, Rev. 17; CCP-QP-001,Rev. 20Interview of AKEsincluding Steve Schafer,Kevin Peters, Lisa Price,Larry Porter, A.J. Fisher;Jene Vance (SME); reviewof objective evidence.Examples of objective evidence obtainedinclude but are not limited to:Qualification cards and training records forKevin Peters, Steve Schafer, and JeneVance. During interview, ascertained thatpersonnel were knowledgeable in areasrequired by the WCPIP.AK-5ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacypresented in Attachment A, Section 3?Are the above trained in the following:•The RH TRU WCPIP•Non conformance and corrective actionprocesses•The AK Procedure presented in Attachment A ofthe PIP•Site-specific training relative to the contents ofthe site’s waste streams•Determining radiological contents of individualcontainersCompiling AK Documentation andDefining the Waste Stream(s)AK documentation must be compiled. What documentshave been compiled? Are they among the following:•Published documents/controlled databases•Unpublished data•Internal procedures and notes (log books,correspondence, etc.)•Engineering documents•Mission statements•OtherDocumentation is among the data used to define the wastestream. Has the waste stream been adequately defined asper the definition of waste stream as presented in theWCPIP: Waste stream is a waste material generated froma single process or from an activity which is similar inmaterial, physical form, and radiological constituents.WCPIP Rev. D Attachment A Interview of AKEsincluding Steve Schafer,Kevin Peters, Lisa Price,Review of AK Summaryand AK Source DocumentReference List;examination of selectedobjective evidence.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-500, CCP-AK-INL-501,Source Documents Reference List forAERHDM. Dozens of examples ofCorrespondence (C), Published (P), andUnpublished (U) documents were providedby INL-CCP that included variousdatabases, internal procedures/notes,engineering documents, missionstatements, Safety Analysis Reports, etc.The waste stream, as defined in CCK-AKINL-500 was not adequately defined,although Rev. 3 provided post inspectionwas revised to better define the wastestream. EPA’s examination of data,independent from INL-CCP, showed thatthe waste stream was adequately defined aspresented in the AK Summary.AK-6ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/AdequacyDoes additional documentation used to characterize wasteand delineate the waste stream include the following:•Previous NDA, radiochemistry, dosimetry, andnon destructive examination data•Waste generating procedures•Physical, chemical, and radionuclide inputs tothe process•Time period that the process took place•Facilities involved•Types of waste generated (waste materialparameters)•Process descriptions and flow diagrams•Packaging logs and videotapes•MSDS•Procurement records•Administrative/Process controls used as the basisfor the absence of residual liquids•Container-specific information (AK data, i.e.waste container input forms, etc.).Were correlations made between CH and RH TRU Wasteoperations at a site including related CH wastecharacterization data? If so,are correlations documentedon a Correlation and Surrogate Summary Form and is thisform adequate and included in the AK Summary?WCPIP Rev. D Attachment A Interview of AKEsincluding Steve Schafer,Kevin Peters, Lisa Price,Jene Vance (SME, MarkDoherty; review of AKSummary and AK SourceDocument Reference List;examination of selectedobjective evidenceExamples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-500, CCP-AK-INL-501,Source Documents Reference List; P593,P592, EDF6685, EDF6946, BDRs 00738,739, 740, 742, 743, C121, C350, C348,P030, P032, P590,U015, U022, U040,U072, U041, U042; Correlation SurrogateSummary Form.Note that the CRR did not correlate CHRH wastes.Were correlations and similarities with the RH TRUwaste operations at other generator/storage sites made,including characterization information for that RH TRUwaste stream? If so, are the correlations documented onthe Correlation and Surrogate Summary Form and is thisform adequate and included in the AK Summary?WCPIP Rev. D Attachment AInterview of AKEsincluding Steve Schafer,Kevin Peters, Lisa Price;review of AK Summaryand AK Source DocumentReference List;Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-500, CCP-AK-INL-501,CCP-AK-INL-500, CCP-AK-INL-501,Correlation/Surrogate Summary Form,P593 P592 P030 P590-595 (generalAK-7ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacyexamination of selectedobjective evidenceP593, P592, P030, P590-595 (generalinformation on stream)If containers from this stream are found tobe CH rather than RH, then NDA of thedrums would occur and the isotopic datawould be presented on a Correlation andSurrogate Summary Form that must beprovided to EPA.Has an AK Source Document Reference list beenassembled for each AK Summary/waste stream, and havereferences been assigned unique identifier (Attachment 2of the Attachment A of the PIP)?WCPIP Rev. D Attachment A Interview of AKEs/SPMincluding Steve Schafer,Kevin Peters, Lisa Price;review of AK Summaryand AK Source DocumentReference ListExamples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-500, Source DocumentReference List.Reference list is complete and easy tofollow.Have Source Document Summaries been developed perAttachment 5 and are these adequate? Do they identifydata limitations?WCPIP Rev. 0D Attachment A Review of SourceDocument SummariesExamples of objective evidence obtainedinclude but are not limited to:See all Source Documents (C), (P), and (U)provided (C121, P593, U015, etc). Eachsource document has a source documentsummary attached to the front of thereference that summarizes documentcontents and provides a location fordocumenting data limitations.AK-AK Discrepancy ResolutionHow are AK-AK discrepancy resolutions documentedand does the documentation:•Identify the affected waste stream(s)•Identify all relevant AK source documents•State the nature of the discrepancyHas there been an instance where an AK-AK discrepancycannot be resolved or if the resolution results in a failureof a DQO? If so, the waste cannot be shipped to WIPPwithout further evaluation.WCPIP Rev. 0D Attachment A Interview of AKEs/SPMincluding Steve Schafer,Kevin Peters, Lisa Price,Larry Porter, MarkDoherty; review of AKSummary and AK SourceDocument Reference List;examination of selectedobjective evidenceExamples of objective evidence obtainedinclude but are not limited to:No AK-AK radiological DRs provided;EPA expects these to be included in the AKrecord as they are identified. DR010, andDR011 show ability of INL-CCP todocument and resolve discrepancyresolutions. No examples of major issuesidentified thus far.AK-8ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/AdequacyCharacterization of the Waste – DQO Assessment Preparation of the AK Summary ReportWhat DQOs are assigned by AK? How is each to bequalified/verified (peer review, confirmation, equivalentQA program)?•Defense determination•TRU waste determination•RH waste determination•Activity determination (total and activity percanister)•Residual liquids•Physical form•Metals•Cellulosics, plastics, rubberFor each DQO related to AK, AK personnel must identifythe DQO, supporting AK information, justify theassignments/conclusions, reference the AK SourceDocuments and applicable pages supporting theassessment, method of 40 CFR 194.22(b) will be qualifiedWCPIP Rev. 0D Section 4 Interview of AKEs/SPMincluding Steve Schafer,Kevin Peters, Lisa Price,Larry Porter, MarkDoherty; review of AKSummary and AK SourceDocument Reference List;examination of selectedobjective evidenceExamples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-500; CCP-AK-INL-502.AK Summary did not adequately addressDQOs; Rev. 2 was changed to include thisinformation. Furthermore, the CTP(discussed below) did not clearly state theprocess by which DQOs would be attained,including the relationship ofqualification/verification to AK. Revisionsto the CTP (CCP-AK-INL-502) wereoffered to address the issues.Have applicable DQOs been addressed as follows:•Has adequate review of AK information beenperformed to determine whether the waste wasgenerated by defense activities or is commingledwith RH TRU waste generated by defenseactivities? This determination will beestablished by the AK data compiled.•Review the AK information to determine thenuclear properties of the waste stream. Thenuclear properties relevant to RH TRU wasteinclude: TRU activity of the waste streamgreater than 100 nCi/g of waste. Is this TRUwaste? Will load management takeplace?WCPIP Rev. 0D Section 4 Interview of AKEs/SPMincluding Steve Schafer,Kevin Peters, Lisa Price,Mark Doherty, LarryPorter; review of AKSummary and AK SourceDocument Reference List;examination of selectedobjective evidenceExamples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-500, CCP-AK-INL-502,CCP-AK-INL-501 Rev. 0, CCP-AK-INL502 Rev. 0, CCP-TP-506 Rev. 2, CRR forID-ANLE-S5000, U001, P599, C331,C330, U015, EDF6685, EDF6946, C350,C348, P030, P032, P002, U015, U022,U040, U072, U041, U042, P593, P592,C121, P001, P002, P023, P032, P055,U013. P030, P590-595.AK record includes defense determinationsupportingdocuments. AK record includesAK-9ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacywaste? Will load management take place?•What information is included in the AK Recordand AK Summary to demonstrate that the wasteis RH waste? Dose equivalent rate equal to orgreater than 200 mrem/hr and less than 1,000rem/hr at the surface of the payload container.•Does the AK Record adequately present, supportand report activity of the 10 requiredradionuclides (TRU isotopes238Pu,239Pu,240Pu,242Pu, and241Am; and non-TRU isotopes137Cs,90Sr,233U,234U, and238U)? Furthermore, DoesAK provide information to determine the totalactivity in each canister.Must be less than 23curies per liter.•Are AK records used to calculate, compute, orotherwise derive the total activity and/or TRUactivity of the waste and the records? If so, werethey qualified by peer review, confirmation, orequivalent QA (see relevant checklists/analysesfor these elements, if performed)? Were datacollected under an EPA-approved program? Ifso, the records alone may be used to satisfyDQOs; otherwise, the above characterizationobjectives must be met by collecting additionaldata during packaging, etc. Was data collected,that would be considered AK collected under anEPA qualified program, assembled and used? Ifso, what was it and how was it used? (e.g.,identification of SCG for use in DTC)•Has AK been used to compile informationregarding the waste stream waste materialparameters to provide a detailed description ofthe waste stream in accordance with the formatof the AK Summary Report?•Has AK information been used to to determinethe absence of residual liquids? This reviewdata that support TRU and RH designationof waste noting that the RH determinationwill be made through measurement ratherthan the AK record. Data pertaining to theEPA 10 radionuclides is present in the AKrecord, and INL did a separate radiologicalanalysis based solely on AK for a selectcontainer group (apparently Lot 16).Because DTC was not performed for thesecontainers, a comparison of the AK for Lot16 vs. the DTC could not be performed.Note that confirmation is used for allverification except for the defensedetermination. WMPs identified via wastedisposal records and can be used to assesswaste stream assignments; examination ofVE tapes/records is performed separatefrom the AK effort.EPA expects the AK record to includeinformation pertaining to waste storage thatwould identify whether any residual liquidsdue to post container inundation ormanagement might have occurred. TheAK Summary was revised to include thisinformation for this INL RH waste stream.Also, load management is not planned, butwould require direct notification of EPA ifit were done. Also, EPA expects an AKAccuracy Report will be prepared specificto Lot 16 comparing DTC and AK data forthis lot (see AK Accuracy discussion,below).AK-10ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacymay include waste packaging procedures andother documented administrative controls, suchas training records that identify control ofresidual liquids. It may also include previouswaste characterization data or information fromwaste-container-specific packaging logs. Thecriterion in the DQO is that residual liquids mustbe less than 1 percent by volume of the wastecontainer.AK Summary Report PreparationHas an AK Summary been prepared and does it followthe format specified in Attachment 1? The report shallinclude the following:•Program and waste stream narrative•Sections as defined in the WCPIP.•Detailed description of the waste streamincluding information on, for example, specificwaste matrix materials and fill volumes.•The report shall address all of the DQOs as notedin previous steps with appropriate justificationsand references in the text.WCPIP Rev. 0D Attachment AInterview of AKEsincluding Steve Schafer,Kevin Peters, Lisa Price;review of AK Summaryand AK Source DocumentReference List;examination of selectedobjective evidenceExamples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-500, CCP-AK-INL-501.The AK Summary Report CCP-AK-INL500 includes required sections. However,the report initially did not include adequateradiological information, noting that INLCCP revised the report and included thisinformation in Rev. 3. Also, theradiological report CCP-AK-INL-501 didnot include sufficient references forstatements made therein, and did notadequately address or link the LANL Massspec data with the INLuse/reliance on saiddata. INL-CCP submitted a revision toCCP-AK-INL-501 (Rev.1). To addressthese issues. CCL-AK-INL 500 and 501are important to the characterizationprocess, so EPA must be notified ofchanges to the documents that mightimpact the characterization process.Changes to both 500 and 501 could impactthis process.AK-11ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/AdequacyHave the following documents been completed inaddition to the AK Summary; are they available for EPAreview and are they technically adequate?•AK Waste Summary Report,•AK Source Document Reference List,•Correlation and Surrogate Summary Form,•AK discrepancy resolution documentation andthe•AK source document summariesWCPIP Rev. 0D Attachment A Interview of AKEsincluding Steve Schafer,Kevin Peters, Lisa Price;review of AK Summaryand AK Source DocumentReference List;examination of selectedobjective evidenceExamples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-500; AK Source DocumentReference List, Correlation and SurrogateSummary Form, DR010, DR011. SourceDocument Summaries are placed on eachcorrespondence (C), published (P), andunpublished (U) document.Have all of these been provided to the SPM for review asrequired in Section 6.7 of the WCPIP Attachment A? Didthe AK personnel recommend how the SPM should assessand qualify the information? (6.8)WCPIP Rev. 0D Attachment A Interview of AKEsincluding Steve Schafer,Kevin Peters, Lisa Price,Review of AK Summaryand AK Source DocumentReference List;examination of selectedObjective Evidence.Examples of objective evidence obtainedinclude but are not limited to:Characterization Reconciliation Report andWaste Stream Profile form, CCP-AK-INL500 and 501, Correlation and SurrogateSummary Form, DRs as cited above.Interview with SPM indicated he had allinformation cited in Section 6.7 availablefor review. It was not determined that AKpersonnel recommend how the SPMassesses data, as the SPM did soindependently.Reconciling Compiled AK InformationHas the SPM Reviewed the AK Summary Report, AKSource Document Reference List, Correlation andSurrogate Summary Forms, the referenced sourcedocument summaries, if applicable, batch data reportsfrom any confirmatory activities such as VE or NDA and,if applicable, supplementaldata collected duringrepackaging using an approved technique, to determine ifthe AK record is reconciled and is adequate tocharacterize the waste stream or waste stream lot andsatisfy the relevant DQOs?WCPIP Rev. 0D Attachment AInterview of Larry Porter;review of the AKSummary Report,Correlation and SurrogateSummary forms, BDRsand other supportingverification activities.Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-500; CCP-AK-INL-502, AKSource Document Reference List,Correlation and Surrogate SummaryForms; source document summaries (asincluded for each source documentprovided), BDRs for drums 00738, 739,740, 742, 743.AK-12ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/AdequacyDiscrepancies between the AK record and confirmatorytest results identified during this reconciliation processmust be resolved and documented. What is the AKmeasurement discrepancy resolution process employedand is it satisfactory? Does it involve reevaluation of theAK record, reassignment of waste stream parameters, anda revision to the AK Summary Report?WCPIP Rev. 0D Attachment A Interview of AKEs/SPMincluding Steve Schafer,Kevin Peters, Lisa Price,Mark Doherty, and LarryPorter; review of AKSummary and AK SourceDocument Reference List;examination of selectedobjective evidence.Examples of objective evidence obtainedinclude but are not limited to WSPFs andCRRs. No discrepancies between the AKRecord and the confirmatory test resultswere found. However, ANL-E performed adetailed analysis of the stream based onAK using a similar process as that used byCCP at INL. Comparison of results willbolster use of the waste stream-scalingfactor assuming that the results arecomparable. Provision of an AK Accuracyreport comparing radiological and physicalAK for these drums (presumably Lot 16)and DTC/VE results is required.AK AccuracyHas the SQAO, consistent with the requirements ofSection 4.1.1.2 of the WCPIP, reviewed the AK SummaryReport, confirmatory test data and identified AKdiscrepancies, and prepared an AK Accuracy Report. Thisreport will identify the percentage of containers that havebeen assigned to another SCG as well as radiologicalissue.WCPIP Rev. 0D Attachment A Interview of A.J. Fisher;examination of AKAccuracy report.Examples of objective evidence obtainedinclude but are not limited to:AK Accuracy Report for initial containers,waste stream ID-ANLE-S5000. Provisionof an AK Accuracyreport comparingradiological and physical AK for thesedrums (presumably Lot 16) and DTC/VEresults is required. Provision of all otherAK Accuracy reports prepared in the futureis also required.How did the SQAO determine what is to be considered a“significant” radiological discrepancy and is thisdetermination technically sufficient and adequate?WCPIP Rev. 0D Attachment A Interview of A.J. Fisher;examination of AKAccuracy report.Examples of objective evidence obtainedinclude but are not limited to:AK Accuracy Report; CCP-AK-INL-502.INL-CCP committed to freeze file changesto CCP-AK-INL-502and CCP-AK-INL500 that both address why comparison ofAK and DTC data, with respect toaccuracy, is not appropriate. CCP-AKINL-502 was also revised to clarify howthe mass spectrometry data are used in thecomparison process.AK-13ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/AdequacyHas the AK Accuracy report been updated annually?Even if the report is only updated annually, will theycontinually assess AK Accuracy?WCPIP Rev. 0D Attachment A Interview of A.J. Fisher;examination of AKAccuracy report.Examples of objective evidence obtainedinclude but are not limited to:AK Accuracy Report. INL-CCP, in thepast, has performed AK Accuracy on a lotbasis. Provision of AK Accuracy reports toEPA as prepared, is required.Has the AK Accuracy fallen below 90%? If so, the siteshall document this as a significant condition adverse toquality as defined by the CBFO QAPD. The site shallnotify the CBFO of this condition and implementappropriate corrective actionsbefore proceeding withfurther characterization activities on the affected wastestream(s).WCPIP Rev. 0D Attachment A Interview of A.J. Fisher;examination of AKAccuracy Report.Examples of objective evidence obtainedinclude but are not limited to:Accuracy reports, as revised to addressWCPIP and EPA concerns is required, butit is anticipated that these revisions will notshow that the accuracy has fallen below90%.Preparation of the CRRHas the SPM reviewed the qualified AK characterizationinformation and the corresponding required DQOs anddocumented this review in an RH TRU waste AKCharacterization Reconciliation Report (CRR)? At aminimum the CRR shall include:•Specification of applicable site and wastestream.•A listing of each DQO•Data from the AK record that addresses eachDQO•AK source document references thatsupport/provide the data•A listing of AK record discrepancy resolutions,if any, that are relevant to each DQO•Documentation, including specific references, ofhow the AK data for each DQO were qualified,such as batch data reports, corroborative data,proceedings of a peer review, etc.WCPIP Rev. 0D Attachment A; CPTP-506 Rev. 2Review of the CRR forselect ANLE RH wastestream; Interview of LarryPorter, SPM.Examples of objective evidence obtainedinclude but are not limited to:WSPF and CRR; BDRs for containers00738, 739, 740, 742, 743. CRR shall berevised to include WCPIP revisions thatrecognize identification of EPA 10 nuclidesas a DQO.The CRR included information required bythe WCPIP Attachment A.AK-14ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacy•Radiography and/or visual examinationsummary to document thatliquids greater than 1percent are absent from the waste and to confirmAK concerning the physical properties of thewaste•A summary presentation of radiologicalmeasurement data used to meet the DQOs and toconfirm AK•A complete AK summary•A complete listing of all container identificationnumbers used to generate the WSPF, crossreferenced to each batch data report.•A listing of AK discrepancies generated by anAK qualification process and the correspondingresolutions•Signature of the SPMHas the SPM verified that the applicable QAOs(accuracy, completeness,representativeness, andcomparability) associated with the AK process have beenmet?WCPIP Rev. 0D Attachment A;CCP-TP-506 Rev. 2Review of the CRR forselect ANLE RH wastestream; interview of LarryPorter, SPM.Examples of objective evidence obtainedinclude but are not limited to:WSPF, CRR. Applicable QAOs have beenincluded on the CRR.Preparation of the Waste Stream Profile FormHas the SPM completed the Waste Stream Profile Form(WSPF) (Attachment 4) based on AK characterizationand confirmation results and other relevantcharacterization data? Is the form complete andadequate/accurate?WCPIP Rev. 0D Attachment A Review of the WSPF andrelated attachments;interview of Larry Porter,SPM.Examples of objective evidence obtainedinclude but are not limited to:Draft WSPF and related attachments (AKSummary and CRR).See comments pertaining to the AKSummary and CRR. Note that the WSPFwas a draft versionprepared for auditpurposes only; EPA must be provided thefinal version of the WSPF once it iscompleted and approved, including allrelated attachments.AK-15ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/AdequacyHave the WSPF, the RH AKSummary Report, and theCharacterization Reconciliation Report, resulting fromwaste characterization activities, been transmitted to theDepartment of Energy Carlsbad Field Office(DOE/CBFO)? Only RH TRU waste that is characterizedin accordance with the EPA requirements and WCPIPwill be accepted for disposal at the WIPP.WCPIP Rev. 0D Attachment A Review of the WSPF andrelated attachments;interview of Larry Porter,SPM.Examples of objective evidence obtainedinclude but are not limited to:Draft WSPF, CRR, AK Summary for CCPAK-INL-500. Only draft versions wereavailable at the inspection; EPA must beprovided the final version of the WSPF andrelated attachments once completed andapproved.RecordsHave the following records been generated and what isthe disposition of these records?•AK Summary Report (Attachment 1)•AK Source Document Reference List(Attachment 2)•Correlation and Surrogate Summary Form(Attachment 3)•Waste Stream Profile Form (Attachment 4)•AK Source Document Summary (Attachment 5)•Characterization Reconciliation Report•AK Source Documents•AK Training Records•AK Discrepancy Resolution Documentation•AK Accuracy ReportWCPIP Rev. 0D Attachment A Interview of AKEs KevinPeters, Steve Schafer, LisaPrice, Sheila Pearcy;examination of requiredreferences as listed(objective evidence).Examples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-500, CCP-AK-INL-501, AKSource Document Reference List,Correlation and Surrogate Summary Form,draft WSPF including the CRR, requestedC, U, and P source documents, trainingrecords for K Peters and S. Schafer,DR010, DR011, AK Accuracy Report(current containerswaste stream).Ms. Pearcy verified that all documents areincluded at the INL-CCP Files in Carlsbad,New Mexico.Confirmatory Test PlanWCPIP Rev. 0D Attachment AInterview of AKEs KevinPeters, Steve Schafer, andMark Doherty, andexamination of objectiveidExamples of objective evidence obtainedinclude but are not limited to:CCP-AK-INL-502. The CTP examinedduringthe inspection was not clearAK-16ATTACHMENT A.1: ACCEPTABLE KNOWLEDGE (AK) RH CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsProcedure Location/AdequacyVerification of ActivityObjective Evidence/Adequacyevidence.regarding the specific characterizationapproach to be used with respect to the useof AK, and it was not clear that theapproach used by INL-CCP (CTPcontaining the EPA required explanation ofcharacterization approach) adequatelyreflected EPA’s requirement that theCertification Plan document thisinformation. INL-CCP revised the CTP tomore clearly state the approach, and retitledthe document to be both a CTP and CertPlan. EPA expects INL-CCP to submit adocument that clearly, completely, andprecisely presents the proposedcharacterization process for each RH wastestream, regardless of the document selectedto present this information.Revision No.: 3RC-DTC-1Date of Revision: 05/25/06ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIEEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceTechnical Documents/ProceduresIdentify all INL-CCP documents that providetechnical information relative to performingand documenting the implementation of theDTC method, including operationalprocedures, and indicate the current revisionof each.Y DOE/WIPP-02-3124,Rev. 0DAll INL-CCP documents were reviewedbefore, during, or directly following thisinspection. The correct revisions foreach are noted in Objective Evidence inthe cell to the left in this row.Y Documents include: CCP-TP504, Rev. 3; CCP-AK-INL-500,Rev. 2; CCP-AK-INL-501, Rev.0; and 36 Calculation packagesprepared by J. Vance & J.Holderness cited in Section 8.3.Dose-To-Curie InstrumentsVerify the following:•Specifications for the instrumentsused for dose rate measurements ofRH TRU waste containers areprovided in INL-CCP documents•Performance and measurementcontrol criteria for dose rateinstruments have been specified andintegrated in INL-CCP operatingprocedure(s)•The instruments used to make doserate measurements of RH containersare identified•The instruments identified inprevious bullet have beenappropriately calibrated•The scale used to weigh thecontainers has been calibrated andthat the scale has been checked eachoperational dayY CCP-TP-504, Rev. 3,Section 4.1These technical aspects were verified byexamination during the inspectionY CCP-TP-504, Rev. 3; CCP-AKINL-501, Rev. 0; INL-CCP DTCBatch Data Report No. INL-RHDTC 06001 (29 drums total) thatcontains copies of Attachment 1,Measurement Control Report,Attachment 2,Container DataSheet,from CCP-TP-504 andAttachment 3,Waste ContainerDose-to-Curie ConversionRecord, from CCP-TP-504, Rev.3, for each container in the BDRthat was assayedVerify that the instruments used for dose ratemeasurements of RH TRU containers areproperlycalibrated toprovide data that areY CCP-TP-504, Rev. 3,Section 4.1Calibration sheets for the ion chambersused were examined.Y INL-CCP DTC Batch DataReport No. INL-RH-DTC 06001(29 drums total)Revision No.: 3RC-DTC-2Date of Revision: 05/25/06ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIEEPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidenceconsistent with those used in the calculationof the radionuclide-specific activity.(29 drums total)Verify that the position of the detectorrelative to the waste container and anyintervening shielding is consistent with thatused in the calculation of the expectedradiation dose.Y CCP-TP-504, Rev. 3,Section 4.1Detector position relative to the wastecontainer and shielding is addressedappropriately.Y INL-CCP DTC Batch DataReport No. INL-RH-DTC 06001(29 drums)Revision No.: 3RC-DTC-3Date of Revision: 05/25/06ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIE (DTC)EPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceGeneral Technical RequirementsDTC must provide information to support thereporting of quantitative values anduncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr and137Cs.Y DOE/WIPP-02-3124, Rev.0D, Attachment C, Section8.0Quantitative values and uncertainties for238Pu,239Pu,240Pu,242Pu,241Am,233U,234U,238U,90Sr, and137Cs are reported.Y INL-CCP DTC Batch DataReport No. INL-RH-DTC 06001(29 drums total)Verify that a waste container is classified asRH TRU only if the dose equivalent rate atthe exterior of the surface of the container isbetween 200 mrem/hr and 1000 rem/hr andthe concentration of alpha-emitting TRUradionuclides is greater than 100 nCi/g waste.Y DOE/WIPP-02-3124, Rev.0D, Attachment C, Section12.0All containers in RH TRU waste streamID ANLES5000 meetthe criteria forTRU (concentration of alpha emittingTRU radionuclides greater than 100nCi/g waste) and RH (dose equivalentrate at the exterior of the surface of thecontainer between 200 and 1000 rem/hr)Y INL-CCP DTC Batch DataReport No. INL-RH-DTC 06001Assess the technical adequacy of thecalculations involving the application ofscaling factors and/or correlation techniques.Y DOE/WIPP-02-3214, Rev.0D, Attachment C, Section7.0The technical adequacy of thecalculations involving the application ofscaling factors and/or correlationtechniques is addressed in Section 8.3.Y See Section 8.3 of this report,also INL-RH-02; INL-RH-03;INL-RH-05; INL-RH-06; INLRH-07Measurements: Dose Rate and BackgroundVerify the following:•Dose rates are measured four (4)times at a detector-to-containerdistance of 1 meter, with thecontainer rotated 90° between eachof the four measurements•The appropriate ion chamber andprobe are used•The radiation field is measured atleast two locations about thecontainer at the mid-height of theY DOE/WIPP-02-3214, Rev.0D, Attachment C, Section7.0INL-CCP DTC Batch Data Report No.INL-RH-DTC 06001 examined for thisinspection documented technicallyappropriate collection of containerspecific dose rate data.Y INL-CCP DTC Batch DataReport No. INL-RH-DTC 06001,copies of Attachment 1,Measurement Control ReportandAttachment 3,Waste ContainerDose-to-Curie ConversionRecord, from CCP-TP-504,Rev. 3Revision No.: 3RC-DTC-4Date of Revision: 05/25/06ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIE (DTC)EPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidencecontainer and a distance of onemeter from the surface of thecontainer.Verify that the background rate is measuredand recorded and that actions are taken toreduce the background if the measuredbackground radiation levels are greater thanone-tenth of the expected container rate.Y CCP-TP-504, Rev. 3,Section 4.1INL-CCP DTC Batch Data Report No.INL-RH-DTC 06001 examined for thisinspection documented technicallyappropriate background measurementdata.Y INL-CCP DTC Batch DataReport No. INL-RH-DTC 06001,copies of Attachment 2,Container Data Sheet,fromCCP-TP-504, Rev. 3Measurement DocumentationVerify that containernumber, waste streamidentifier, and all pertinent container-specificmeasurement data are entered into the“Waste Container Dose-to-Curie ConversionRecord” spreadsheet, including:•Date of the gamma measurements•Waste stream designation•Container number•Container gross weight•Estimated can size for Cans #1, #2, #3•Estimated fill percentage for cans #1,#2, #3•Four (4) quadrant dose rates•Average of four (4) dosemeasurements•Expected container dose rate•Waste material type (matrix)Y DOE/WIPP-02-3124, Rev.0D; CCP-TP-504, Section4.2INL-CCP DTC Batch Data Report No.INL-RH-DTC 06001 examined for thisinspection contained all requireddocumentation.Y INL-CCP DTC Batch DataReport No. INL-RH-DTC 06001,copies of Attachment 2,Container Data SheetandAttachment 3,Waste ContainerDose-to-Curie ConversionRecord, from CCP-TP-504,Rev. 3Revision No.: 3RC-DTC-5Date of Revision: 05/25/06ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIE (DTC)EPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceVerify that DTC BDR INL-RH-DTC 06001contains the following items:•Batch Data Report Cover Sheet,Attachment 4•Batch Data Report Table ofContents, Attachment 5•Batch Data Report NarrativeSummary, Attachment 6•ITR Review Checklist,Attachment 7•Measurement Control Report,Attachment 1•Container Data Sheet(s),Attachment 2•Waste Container Dose-to-CurieConversion Record(s), Attachment 3•Copy of NCRs, if applicable•Evidence of a review by an ITR andSPM, as appropriate.Y CCP-TP-504, Rev. 3,Section 4.3INL-CCP DTC Batch Data Report No.INL-RH-DTC 06001 contained allrequired elements.Y INL-CCP DTC Batch DataReport No. INL-RH-DTC 06001(29 drums)Verify that records generated in support ofDTC are available for inspection. Recordsinclude the following, at a minimum:•Site-specific procedures developedto implement the DTC method•Technical basis for thedetermination of the waste stream’s“Standard Mix”, shieldingY DOE/WIPP-02-3214, Rev.0D, Attachment C, Section15.0All records related to DTC wereavailable for this inspection on-site atINL and in CBFO Headquarters inCarlsbad, New Mexico.Y INL-CCP DTC Batch DataReport No. INL-RH-DTC 06001(29 drums)Revision No.: 3RC-DTC-6Date of Revision: 05/25/06ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIE (DTC)EPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidencecalculations for waste containers•Technical basis for determination ofradionuclide scaling factors•TMU technical support documentsRevision No.: 3RC-DTC-7Date of Revision: 05/25/06ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIE (DTC)EPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceTechnical BasisVerify the following:•Results of sampling and calculationform the basis for the developmentof radionuclide scaling factors usedto convert measured dose rates toradionuclide-specific activities•Dose rates are measured at adistance of one meter from the outersurface of the waste container at themid-height of the container•Calculations appropriately presentthe relationship between acontainer’s measured dose rate andthe waste’s activity•Calculations account for all relevantcontainer properties, specifically fillheight (apparent density), wastetype (matrix), and attenuation(shielding) of the container and/orliner wall•Calculations are performed usingtechnically appropriate shieldinganalysis techniquesY DOE/WIPP-02-3214, Rev.0D, Attachment C, Section7.0; CCP-AK-INL-501,Rev. 0; CCP-TP-504, Rev.3, Section 4.3These technical aspects were examinedbefore, during, and following thisinspection in consultation with CTACtechnical personnel.Y CCP-AK-INL-501, Rev. 0; INLRH-02; INL-RH-03; INL-RH-05;INL-RH-06; INL-RH-07; INLRH-09; INL-RH-10; INL-RH-12Verify that waste containers contain onlymatrices for which the DTC methodology hasbeen established.Y DOE/WIPP-02-3214,Rev. 0D, Attachment C,Section 5.0RH waste cans contain metals (steel),concrete, or organics with a minimumof mixing of dissimilar types ofmaterials. Fill heights are specified forall containers, i.e., less than 25% full,Y INL-CCP DTC BDR No.INL-RH-DTC 06001 (29 drums);DTC Spreadsheets contained inBDRRevision No.: 3RC-DTC-8Date of Revision: 05/25/06ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIE (DTC)EPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective EvidenceVerify that the type of waste (waste matrix)in each container is recorded along with theheight of the waste in the container.25% to 66% full, 66% to 90% full, morethan 90% full).Verify that all DTC-related calculations havebeen subjected to a technical review and thatall technical review comments and theirresolutions are documented.Y DOE/WIPP-02-3214, Rev.0D, Attachment C, Section14.0With minor exceptions, all calculationpackages contain evidence of atechnical review.Y Examination of the 36 calculationpackages that supported thedevelopment of radionuclidescaling factors prepared by J.Vance & J. Holderness, seeSection 8.3Verify that the ratio of actual measured doserate to the calculated dose rate is used tocalculate a scaling factor that is applied to the“Standard Mix” or subset thereof, that wasused to estimate individual radionuclideactivities.Y DOE/WIPP-02-3214, Rev.0D, Attachment C, Section11.0; CCP-TP-504, Rev. 3,Section 4.2The “Standard Mix” was not used togenerate scaling factors for this wastestream. The technical documentation ofthe scaling factor development supportsthe use of dose rate measurements.Y CCP-AK-INL-501, Rev. 0; INLRH-02; INL-RH-03; INL-RH-05;INL-RH-06; INL-RH-07Total Measurement Uncertainty (TMU)Verify that a method for estimating totalmeasurement uncertainty (TMU) has beendeveloped and documented for RH TRUwaste stream ID ANLES5000.Y DOE/WIPP-02-3214, Rev.0D, Attachment C, Section13.0This checklist addresses the aspects ofTMU attributable to DTC. The aspectsof TMU related to the development andapplication of radionuclide scalingfactors are addressed in Section 8.3.Y CCP-AK-INL-501, Rev. 0; INLRH-02; INL-RH-03; INL-RH-05;INL-RH-06; INL-RH-07TMU is based upon the propagation ofuncertainties present in all aspects ofradiological characterization, including DTC.Y DOE/WIPP-02-3214, Rev.0D, Attachment C, Section13.0TMU includes the contributions of allapplicable aspects of the DTC process.Y CCP-AK-INL-501, Rev. 0; INLRH-02; INL-RH-05; INL-RH-06Verify that the approach for TMUdetermination incorporates the contributionsof all applicable components of DTC,including:•Measured sample isotopic activities•Relative uncertainties associatedY DOE/WIPP-02-3214, Rev.0D, Attachment C, Section13.0TMU includes the contributions of allapplicable aspects of the DTC process.Y CCP-AK-INL-501, Rev. 0; INLRH-02; INL-RH-03; INL-RH-05;INL-RH-06; INL-RH-07Revision No.: 3RC-DTC-9Date of Revision: 05/25/06ATTACHMENT A.2: RH RADIOLOGICAL CHARACTERIZATION CHECKLIST: DOSE-TO-CURIE (DTC)EPA Inspection No.: EPA-INL-CCP-RH-6.06-8Inspection Date: June 12–16 and August 29, 2006Required Technical ElementsY/NLocationVerification of ActivityY/NObjective Evidencewith each measured radionuclide•Measurement of the container’sdose rate•Determination of waste mass•Modeling errors or biases.Verify that the TMU approach has beenformally submitted to CBFO for review andapproval.Y DOE/WIPP-02-3214, Rev.0D, Attachment C, Section13.0The TMU approach was evaluated bythe CTAC Technical Specialist(D. Stuenkel) during this inspection.Y INL-RH-02; INL-RH-03; INLRH-05; INL-RH-06; INL-RH-07VE-1ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-06.06-8Inspection Date: June 12–16 and August 29, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentRHVE-1Site procedures identify requiredtraining and qualifications forRHVE personnel.WCPIP,Rev. 0D,Section.4.1.2.2CCP-QP002,Rev. 20•OJT training for operators, including:identification of summary categorygroups, WMPs, packagingconfigurations, and residual liquids•Formal training elements include: projectrequirements, container identification andlabeling, applicable state and federalregulations•Site-specific instructions wastegenerating practices and expectedpackaging configurationsY INL-CCP uses Qualification Cards to document training ofpersonnel. The training procedure included all requirementsof the WCPIP for training of RH VE operators.INL-CCP provided documented evidence that operators hadbeen trained on the AK summary for the waste stream beingprocessed. On some of the reviewed training certificates theincorrect waste stream number was documented. INL-CCPcorrected this error during the inspection.Objective evidence:1. Qualification cards for VE operators.RHVE-2Operator qualification and requalificationrequirements aredescribedWCPIP,Rev. 0D,Section.4.1.2.2CCP-QP002, Rev.20, Section.4.2.5•To become qualified, the RHVE operatormust pass a comprehensive written testbased on training objectives with aminimum score of 80%•Demonstrate capability in the presence ofthe site VEE during OJT•RHVE operators re-qualified every 2years based on continued satisfactoryperformance•Unsatisfactory performance – failed toidentify prohibited item during OJT ofscore of less than 80% on examN INL-CCP had only generated one (1) Batch Data Report(BDR) that had been through project level review. At the timethat the BDR was generated, the operators had not taken therequired written examination. EPA generated the findingbelow to address this issue:INL-CCP-RH-VE-06-001F, Rev 1:The three VE operators(Swami Raman, William Boyd, and John Hegsted) completedtheir OJT training requirements on February 22, 2006, but didnot take the required written test until April 10, 2006. Theseoperators were not qualifiedto perform VE between thesetwo dates, but they performed VE on containers in BDRRHINLVE060001 during this time period. INL-CCPinitiated CAR-RHINL-0001-06 in response to thisoccurrence. However, the corrective action implemented didnot include review of the subject VE data to ensure that dataquality had not been negatively affected. BDRRHINLVE060001 is the only completed BDR that INL-CCPcan use to demonstrate the RH VE process.Objective evidence:1. BDR # RHINLVE60001VE-2ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-06.06-8Inspection Date: June 12–16 and August 29, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentRHVE-3Each site has a designated VEexpert (VEE)WCPIP,Rev. 0D,Section.4.1.2.2CCP-PO001, Rev.12•VEE designation is documented•VEE has knowledge of the RH TRUwaste being characterized•Responsible for overall direction andimplementation of VE at the facility•Certification Planspecifies theselection, qualification, and trainingrequirements of VEEY VEE training and designation were reviewed during the onsite inspection.Objective evidence:1. Qualification Card for VEERHVE-4CCP-TP509, Rev. 0,Section. 4.4•Operators review AK TrackingSpreadsheet to verify that correctcontainers examined•Rejected containers are placed in ashielded container with an INL-CCPHold Tag attached•Provide container processing informationto SPM/VPMYINL-CCP intends to use two (2) operators to generate VEdata for RH containers. The operators will review existingaudio/videotapes and complete the required data sheets fromtheir observation of the recorded VE event. Operators haveaccess to the AK for the waste stream on the INL-CCP ftpsite.INL-CCP had only generated one (1) Batch Data Report(BDR) that had been reviewed at project level.EPA did not observe the VE process during the inspection.Objective evidence:1. BDR # RHINLVE60001RHVE-5Procedures and technicalguidance documents providecomplete instructions forperforming RHVE.WCPIP,Rev. 0D,Sections.4.1.2,4.1.2.1,4.3.3CCP-TP500, Rev. 1,Section. 4.0,Attachment1Procedures are sufficiently detailed to enablethe operator to determine if a waste containermeets the criteria of 194.24 with regard toidentifyingapplicable parameters with wastelimits•All existing VE tapes will be reviewedand the VE data will be documented•Existing waste container packagingrecords will be qualified by VE or RTRNCCP-TP-500 was written based on the assumption that INLCCP would be performing actual VE. INL-CCP decided notto write a procedure for watching videotapes. EPA generatedconcern INL-CCP-RH-VE-06-002CR to address this issue.Weight for 30-gallon containers is contained in an operatoraid. Weight of cans given to 2 decimal places and thereforeWMP weights also in 2 decimal places.INL-CCP uses a spreadsheet “RH VE Analysis”, softwareversion 0.xls, to ensure that the WMP weights total the netweight of the container. This software is not controlledVE-3ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-06.06-8Inspection Date: June 12–16 and August 29, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Comment1•100% of containers will be subject to VEat the time of packaging•Waste stream description and WMCverified•Presence/absence of prohibited itemsbecause the data will not beused for certification.EPA reviewed the video recordings and associated datasheets for containers in BDR # RHINLVE60001. Thepresence/absence of prohibited items was determined and theWMC was confirmed. However, operators did not makecomplete inventories of the waste as required. EPAgenerated the concern INL-CCP-RH-VE-06-003CR, Rev. 1to address this issue.INL-CCP provided EPA with the following informationabout the waste stream being examined:•There are 549 drums in waste stream, 70 of which havevideotapes recording the original VE event.•15 of the drums were located in a flooded vault and willbe examined by RTR.•36 drums had been looked at prior to the inspection.INL-CCP does have some original paperwork for thecontainers, but the PIP does not allow the use of this.•None of the 70 drums that will be examined by VE werein flooded vaults.•Started video taping the VE in 1990.•INL-CCP is buying a new RTR unit (anticipated to beavailable in July 2006) to examine the remaining drumsin the waste stream.ANL-E waste: 48 drums ± 50 drum content volume still inhot cells and needs to be packaged.Use spreadsheet to total weights: RH VE analysis, softwareversion 0.xls. Software not controlled but exempted becausedata will not be used for certification.INL-CCP-RH-VE-06-003CR, Rev. 1:There does not appearto be a consistent protocol for entering items on the VE dataVE-4ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-06.06-8Inspection Date: June 12–16 and August 29, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentforms, Attachment 1 of CCP-TP-500. For example, wastecan 161 in container No. 00761 contained both Kleenex andcardboard that were not entered in the item descriptionsection of Attachment 1. For waste can # 149 in containerNo. 00748, cardboard and Kleenex were clearly called outover 5 times each but were not entered in the item descriptionof Attachment 1. However, for this same waste can a singlepiece of wood was called out and entered into Attachment 1as was a single marking pen. The operators interviewed wereunable to provide the rationale for the discussions regardingwhat items were/were not recorded on the VE data form. Thereported inventory for waste cans is therefore incomplete.Resolution: A briefing was prepared and given to VEoperators addressing this issue during the on-site inspection.INL-CCP-RH-VE-06-002CR: Procedure CCP-TP-500,Remote-Handled Waste Visual Examination, Rev. 1, containsinstructions for performing and documenting a visualexamination (VE) event. However, the VE performed insupport of the RH program does not involve actual VE, butconsists of operators viewing previously generated VEaudio/visual recordings. The operators complete a data formdocumenting the items and WMPs seen in the audio/visualrecording. INL-CCP has not generated a standard operatingprocedure for this process.Objective evidence:BDR # RHINLVE60001RHVE-6CCP-TP500,Section.2.4.2•Corrective actions are taken whennecessary•When are NCRs necessary?Y Glass bottles form part of the inorganic portion of the wastesstream contents. Some bottles are capped, brown bottles andcontents cannot be seen. These drums were NCR’d asrequired.NCRs are listed on the BDR Table of Contents and arereviewed to ensure that they are complete.VE-5ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-06.06-8Inspection Date: June 12–16 and August 29, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/CommentObjective evidence:1. BDR # RHINLVE60001RHVE-7Site procedure(s) require datageneration and project levelreviews of Batch Data Reports(BDRs).WCPIPSection.4.1.2.1CCP-TP500, Rev. 1,ITR:Section.4.3.5-4.3.8,Attachment2SPM:Section. 4.4,Attachment3•ITR review Attachment 2•SPM review Attachment 3Y The generation level and project level review checklists werereviewed in the one (1) BDR available.Objective evidence:1. BDR # RHINLVE60001RHVE- 8CCP-TP500, Rev. 1,Section. 5.0•Lifetime/QA records – Attachments 1-5,Copy of NCRs•QA/nonpermanent records – VHS tape orDVD (primary and backup)Y When INL-CCP reviews an original tape, personnelresponsible for records make 2 copies from the original VHS.Objective evidence:1. BDR # RHINLVE60001RHVE-9Quality Assurance Objectives aredefined and met.WCPIP,Rev. 0D,Section.4.1.2.3QOAs are defined for:Precision – maintained by reconciling anydiscrepancies between 2 operators (oroperator and ITR) with regard to physicalform of waste, absence of residual liquidAccuracy – maintainedby requiring operatorsto pass a comprehensive test with a score of80% and demonstrated satisfactoryN At the time of the inspection INL-CCP could not demonstratethat the QAOs for accuracy, representativeness, andcomparability had been met (see inspection issues INL-CCPRH-VE-06-003CR, Rev.. 1 and INL-CCP-RH-VE-06-001F,Rev. 1).Objective evidence:1. Qualification cards for VE operatorsVE-6ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-06.06-8Inspection Date: June 12–16 and August 29, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentperformance for initial qualification and requalificationRepresentativeness – Contents placed incontainer will be described on the data formsCompleteness – Relevant waste informationmust be collected and documented on avideotape and/or data form or otherunalterable mediaComparability – ensured by site meetingtraining requirements and complying with theminimum standards used to implement VE2. BDR # RHINLVE60001RHVE-10VE as a method to qualify AKdataWCPIP,Rev. 0D,Section. 4.3,4.3.3If VE is used as a qualification method forAK, all of the requirements in Sections 4.3and 4.3.3 are met:•Quality and reliability of themeasurement control program underwhich the data were generated (QCsamples included in the VE process)•Extent to which the data demonstrate theproperties of interest (VE processgenerates data for allitems in containers)•Qualification of personnel generatingdata (training records for personnel ontapes performing the original VE event)•Technical adequacy of the proceduresused to generate the original data (copiesof original procedures)N•INL-CCP uses 2 operators to generate VE data.•The VE events (original video recording and data sheets)reviewed during the inspection did not record all of theitems identified in the containers (INL-CCP-RH-VE-06-003CR, Rev. 1)•The two operators that generated the completed BDR #RHINLVE60001 were not qualified when they generatedthe VE data (INL-CCP-RH-VE-06-001F).•The procedure CCP-TP-500 did not contain instructionsfor performing VE by review of original videotapes(INL-CCP-RH-VE-06-002CR)RHVE-11Confirmatory testing plan for useof VE data to qualify AKWCPIP,Rev. 0D,Section.4331. Description of waste stream or wastestream lots to which the plan applies2.Explicit description of the wasteNASee AK checklist.VE-7ATTACHMENT A.3: VISUAL EXAMINATION (VE) CHECKLISTEPA Inspection No.: EPA-INL-CCP-RH-06.06-8Inspection Date: June 12–16 and August 29, 2006Establishment of RequiredTechnical Elements inProceduresY/NLocationExecution of ProceduresY/NObjective Evidence/Commentof VE data to qualify AK4.3.3CCP-AKINL-502,Rev. 0characterization DQOsand QAOs thatwill be satisfied with the data beingqualified3. Description of the confirmatory testingproposed and the percentage of wastecontainers that will be tested4. Description of how the testedsubpopulation will be representative ofthe waste stream or waste stream lot5. Quantitative acceptance criteria fordetermining that the AK information inquestion can be qualified ascharacterization informationInformation Included in INL-CCP RH VE BDRRequired Testing Batch ContentPresentY or NRequired Testing Batch ContentPresentY or NRequired Testing Batch ContentPresentY or NTable of Contents Y Date of measurement Y Testing batch number YTest facility name Y SGC Y Batch report date YContainer or sample numbers in batch Y Prohibited items Y QC documentation NAProcedure used Y Testing reportsheet for each container Y Copies or reference to NCRs YOperator signature and date Y Data review checklists Y ITR signature and date YSignature release by SPM or designeeAttachments B.1 through B.8Page 1 of 1


### ***DRAFT*** Upon further analysis, the EPA issue presented here may be included in the EPA Inspection Report as an EPA Finding or
Concern and can be the basi s for EPA approval/disapproval

B-1 Inspection No. EPA-INL-CCP-RH 06.06-8 Issue Number: INL-CCP-RH-VE-06-001CR, Rev. 2

Date: 6-13-06
Inspector: Dorothy E. Gill

Attachments? YES NO Sample Size: AK NDA Memos

Population size (if known): Three (3) A. Description of Issue: The three VE operators (Swami Raman, William Boyd, and John Hegsted) completed their OJT training requirements on February 22, 2006 but did not take the required written test until April 10, 2006. These operators were not qualified to perform VE between these two dates, but they performed VE on containers in BDR RHINLVE060001 dur ing this time period. INL-CCP initiated CARRHINL-0001-06 in response to this occurrence. However, the corr ective action implemented did not include review of the subject VE data to ensure that data quality had not been negatively affected. BDR RHINLVE060001 is the only completed BDR that INL-CCP can use to demonstrate the RH VE process.

B. Regulatory Reference: 40 CFR 194.24 (c),

C. Site requirement(s): CCP-QP-002, Revision 20

D. Discussed with:

Site Personnel: Larry Porter, Rebecca Walker, Cindi Becker DOE/CTAC Personnel: Wayne Ledford, Porf Martinez

Other Personnel: NA

E. Additional Comments: Before implementing this procedure at other CCP sites, the impact of this concern should be evaluated for inadequacies.

F. Site Response Information:

Site Response Required? YES NO Site Response Due Date: July 5, 2006Page 1 of 1


### ***DRAFT*** Upon further analysis, the EPA issue presented here may be included in the EPA Inspection Report as an EPA Finding or
Concern and can be the basi s for EPA approval/disapproval

B-2 Inspection No. EPA-INL-CCP-RH 06.06-8 Issue Number: INL-CCP-RH-VE-06-002CR

Date: 06-13-06
Inspector: Dorothy E. Gill

Attachments? YES NO Sample Size: 1 procedure

Population size (if known): 1 procedure A. Description of Issue: Procedure CCP-TP-500, Remote-Ha ndled Waste Visual Examination,

Revision 1 contains instructions for performing and documenting a visual examination (VE) event. However, the VE performed in support of the RH pr ogram does not involve actual VE, but consists of operators viewing previously generate d VE audio/visual recordings. Th e operators complete a data form documenting the items and WMPs seen in the audio/ visual recording. INL-CCP has not generated a standard operating procedure for this process.

B. Regulatory Reference: 40 CFR 194.24 (c)

C. Site requirement(s): CCP-TP-500, Revision 1

D. Discussed with:

Site Personnel: Larry Porter, Tommy Mojica DOE/CTAC Personnel: Wayne Ledford, Porf Martinez

Other Personnel: NA

E. Additional Comments: Before implementing this procedure at other CCP sites, the impact of this concern should be evaluated for inadequacies.

F. Site Response Information:

Site Response Required? YES NO

Site Response Due Date: July 5, 2006Page 1 of 1


### ***DRAFT*** Upon further analysis, the EPA issue presented here may be included in the EPA Inspection Report as an EPA Finding or
Concern and can be the basi s for EPA approval/disapproval

B-3 Inspection No. EPA-INL-CCP-RH 06.06-8 Issue Number: INL-CCP-RH-VE-06-003F, Rev. 2

Date: 6-13-06
Inspector: Dorothy E. Gill

Attachments? YES NO Sample Size: 4

Population size (if known): <70 A. Description of Issue: There does not appear to be a consis tent protocol for entering items on the VE data forms, Attachment 1 of CCP-TP-500. For exam ple, waste can #161 in container No. 00761 contained

both Kleenex and cardboard that were not entered in the item description secti on of Attachment 1. For waste can # 149 in container No. 00748, cardboard and Kleenex were clearly ca lled out over 5 times each but were not entered in the item description of Attach ment 1. However, for this same waste can, a single piece of wood was called out and entered into Attachme nt 1, as was a single marking pen. The operators interviewed were unable to provide the rationale for the discussions re garding what items were/were not recorded on the VE data form. The reported i nventory for waste cans is therefore incomplete.
B. Regulatory Reference: 40 CFR 194.24 (c)

C. Site requirement(s): CCP-TP-500, Revision 1

D. Discussed with:

Site Personnel: Larry Porter, Tommy Mojica DOE/CTAC Personnel: Wayne Ledford, Porf Martinez

Other Personnel: NA

E. Additional Comments: Before implementing this procedure at other CCP sites, the impact should be evaluated for inadequacies.

F. Site Response Information:

Site Response Required? YES NO Site Response Due Date: July 5, 2006Page 1 of 1


### ***DRAFT*** Upon further analysis, the EPA issue presented here may be included in the EPA Inspection Report as an EPA Finding or
Concern and can be the basi s for EPA approval/disapproval

B-4 Inspection No. EPA-INL-CCP-RH 06.06-8 Issue Number: INL-CCP-RH-VE-06-003F, Rev. 2

Date: 6-13-06
Inspection No. EPA-INL-CCP-RH-06.06-8 Issue Number: INL-CCP-RH-AK-06-005CR, Rev. 1

Date: 06-15-06
Inspector: Connie Walker

Attachments? YES NO Sample Size: Waste Stream ID-ANLE-S5000 and all

other INL RH streams Population size (if known): Above waste streams

Description of Issue: INL-CCP has indicated that AK will be used to dete rmine all DQOs that must be assessed as specified in the WCPIP (e.g., Sections 2.2 and 4.2). The WCPIP, Attachment A, requires that for each DQO related to AK, AK personnel must identify the DQO and supporting AK information, justify the assignments/conclusions, reference the AK Source Documents and applicable pages supporting the assessment, and identify the qu alification method in 40 CFR 194.22(b) that will be used to qualify the AK. This requirement is not adequately reflected in CCP-INL-AK-500. Revise the AK Summary CCP-INL-AK-500 to address the above requirement, including revision of Chapter 6, entitled “Qualificatio n of AK Information.” Note that based on the EPA requirements, the DQOs will re quire revision to include identification and quantification of the 10 EPA WIPPtracked radionuclides in CCP-INL-CCP-AK-500. This AK Summary must be revised to address the following:

• The AK Summary implies that some of the containers in the population may have been submerged in a few of the vaults. The

AK Summary states that none of the population of approximately 70 containers that have videotapes being reviewed as a VE exercise were inundated, while others may ha ve been. The discussion should be modi fied to clearly indicate the total number of drums in the stream, number of drums suspected of having been inundated, and how the inundated drums will be handled or otherwise managed.

• Documentation for the waste’s defense determination should be included.

• The definition of waste stream should be cl early supported. Specifically , the document needs to make a better argument that

the wastes generated in the cells were never segregated by pi n or generator, so there is no way a specific pin/radionuclide content can be assigned to waste containers. Therefore, the radiological characteristics of the pins must be assigned as a whole to the entire population. This assu mption must be supported and justified.

• The radiological data presented in the AK Summary does not provide a good understanding of the overall isotopic

distributions being applied to the waste stream based on AK. While CCP-AK-INL-501 presents how each container is assessed, the AK Summary CCP-AK -INL-500 should still include a general discussi on of the overall anticipated distribution on a waste stream basis, particularly since AK is being used to address all DQOs. Page 40 presents information for drums from 1990–1995, but more information should be included for the entire waste stream. B. Regulatory Reference: WCPIP, Attachment A; 40 CFR 194.24(c)(3), 40 CFR 194.22

C. Site requirement(s): WCPIP, Attachment A (no site-specific AK procedure prepared).

D. Discussed with: Site Personnel: Steve Schafer, Kevin Pete rs, Mark Doherty, Eric D’Amico, Lisa Price

DOE/CTAC Personnel: Dick Blauvelt

Other Personnel:

E. Additional Comments:

F. Site Response Information:

Site Response Required? YES NO

Site Response Due Date: Prior to the next CCP RH inspectionPage 1 of 1


### ***DRAFT*** Upon further analysis, the EPA issue presented here may be included in the EPA Inspection Report as an EPA Finding or
Concern and can be the basi s for EPA approval/disapproval

B-5 Inspection No. EPA-INL-CCP-RH-06.06-8 Issue Number: INL-CCP-RH-AK-06-006CR, Rev. 1

Date: 06-15-06
Inspector: Connie Walker

Attachments? YES NO Sample Size: Waste Stream ID-ANLE-S5000 and all

other INL RH streams Population size (if known): See above waste streams A. Description of Issue: INL-CCP representatives stated that AK Qualif ication will always be the approach used to meet DQOs. As such, INL-CCP will always prepare an AK Confir matory Test Plan (C TP) for each waste stream that presents a description of the proposed characterization plan for the wa ste stream and which will include how characterization will be accomplished for each DQO. The CT P CCP-AK-INL-502 must be revised to indicat e, for each DQO, that AK qualification is the selected DQO determination methodology, and to specify th e qualification pathway selected included detailed discussion of confirmatory methods used. Also, note that based on EPA requirements, the DQOs will re quire revision to in clude identification and quantification of the EPA 10 radionuclides. Also, the CTP includes the proposed approach for assessing AK Accuracy, which is only the verification that waste is RH as identif ied by AK. The CTP also assumes that CCP-AK-INL-501 has established “no significant discrepancies” between AK information and confirmation of modeling/sampling. However, this assumes that the LANL Mass spec data are demonstrated ap plicable, and EPA has not fully assessed CCP-AK-INL-501, which presumably includes this information. Furthermore, since AK Qu alification and confirmatory tes ting is used for all radiologica l parameters, it would appear that each radiol ogical DQO should be evaluated with respect to how the confirmatory data collected will be assessed as part of AK Accuracy (if this is not possible for some reas on, a detailed argument should be included). The AK Accuracy report should be revised accordingly. B. Regulatory Reference: 40 CFR 194.24(c)(3), 40 CFR 194.22, WCPIP

C. Site requirement(s): CCP-TP-002, Rev. 16

D. Discussed with: Site Personnel: Steve Schafer, Kevin Pete rs, Lisa Price, Mark Doherty, Eric d’Amico

DOE/CTAC Personnel: Dick Blauvelt

Other Personnel:

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES NO Site Response Due Date: Prior to the next CCP RH inspectionPage 1 of 1


### ***DRAFT*** Upon further analysis, the EPA issue presented here may be included in the EPA Inspection Report as an EPA Finding or
Concern and can be the basi s for EPA approval/disapproval

B-6 Inspection No. EPA-INL-CCP-RH-06.06-8 Issue Number: INL-CCP-RH-AK-06-007CR, Rev. 1

Date: 06-15-06
Inspector: Connie Walker

Attachments? YES NO Sample Size: Waste Stream ID-ANLE-S5000 and all

other INL RH streams Population size (if known): See above waste streams A. Description of Issue: INL-CCP representatives have indica ted that AK Qualification will be the method by which DQOs will always be addressed. Base d on this, INL-CCP must examine site documents that discuss the characterization methodologies to ensure that each reflect the requirements presented in the WCPIP when AK Qualification is use d. For example, the WCPIP requires that Certification Plan include how the DQOs will be addressed, and EPA indicated that this should include stream information. INL-CCP representatives have indicated that the Confirmatory Te st Plan (CTP) will be prepared for each stream and

will include this information. Ther efore, INL-CCP should revisit documentation to ensure that this commitment is clearly cited in related documents to en sure that the CTP always fulfills this requirement. Note that based on EPA requirements, the DQOs w ill require revision to in clude identification and quantification of the EP A 10 radionuclides. B. Regulatory Reference: 40 CFR 194.24(c)(3), 40 CFR 194.22, WCPIP

C. Site requirement(s): CCP-TP-002, Rev. 16; CCP-AK-INL- 500; CCP-AK-INL-502; & CCP-TP-506

D. Discussed with:

Site Personnel: Steve Schafer, Kevin Pete rs, Lisa Price, Mark Doherty, Eric d’Amico

DOE/CTAC Personnel: Dick Blauvelt

Other Personnel:

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES NO Site Response Due Date: Prior to the next CCP RH inspectionPage 1 of 1


### ***DRAFT*** Upon further analysis, the EPA issue presented here may be included in the EPA Inspection Report as an EPA Finding or
Concern and can be the basi s for EPA approval/disapproval

B-7 Inspection No. EPA-INL-CCP-RH-06.06-8 Issue Number: INL-CCP-RH-AK-06-008CR, Rev. 1

Date: 06-15-06
Inspector: Connie Walker

Attachments? YES NO Sample Size: Waste Stream ID-ANLE-S5000 and all

other INL RH streams Population size (if known): See above waste streams A. Description of Issue: CCP-AK-INL-501 includes several stat ements, assumptions, and arguments

without references to calculations or other information to su pport the argument s. Without references, it is not possible to verify conclusionary statements in the document. In particular, several other documents (CCP-AK-INL-500, CCP-AK-INL-502, etc. ) state that CCP-AK-INL-501 show s that LANL and INL fuel pins had many common elements. The brief discussi on on page 33 states that : “On the basis of the similarities between the two fuel pin examination programs, the fuel types, the sources of the pre-irradiation fuel composition and burnup information, and the identical reactors for a majority of the fuel pins, the LANL confirmatory sampling is sufficient to sa tisfy the qualification required for the INL AK information.” However, the document does not cite refe rences or other detailed information to support this assertion. The document provides charts and other comp arisons between pins and INL pins, but the specific INL pin numbers and related data a nd calculations are not referenced. Table 5-1 presents a summary of sponsors associated with ANL-E and LANL pins, but of the top three sponsors for LANL and ANL-E, only

one was common to both. Additional information that better supports the comm onalities between the two

sites in the text of CCP-AK-INL- 501 is necessary. The 28 calculati on packages that support ORIGEN2.2

should be included and/or referenced. The link betw een the INL and LANL fuel pins should be better documented and/or supported. Note that EPA has not concluded their review of input parameters to the ORIGEN2.2 code, so no issues associat ed with input data are provided. B. Regulatory Reference: 40 CFR 194.24(c)(3), 40 CFR 194.22, WCPIP

C. Site requirement(s): WCPIP

D. Discussed with:

Site Personnel: Steve Schafer, Kevin Pete rs, Lisa Price, Mark Doherty, Eric d’Amico

DOE/CTAC Personnel: Dick Blauvelt
Other Personnel:

E. Additional Comments: None

F. Site Response Information:

Site Response Required? YES NO Site Response Due Date: Prior to the next CCP RH inspectionPage 1 of 1


### ***DRAFT*** Upon further analysis, the EPA issue presented here may be included in the EPA Inspection Report as an EPA Finding or
Concern and can be the basi s for EPA approval/disapproval

B-8 Inspection No. EPA-INL-CCP-RH-06.06-8 Issue Number: EPA-INL-CCP-RH-06-009C

Date: 8/29/06
Inspector: Dorothy E. Gill

Attachments? YES NO Sample Size: 1 BDR

Population size (if known): Three (3) Description of Issue: INL-CCP responded to EPA’s Concer n Number INL-CCP-RH-VE-06-003CR, Revision 1 by providing additiona l training for VE operators a nd VEE/SME on June 15, 2006, Visual Examination Briefing to Clarify the Recording of Desc ription of Container Contents on VE Data Forms. During this inspection, EPA evaluated the implementation of this response. Upon review, EPA verified that INL-CCP had provided additional training regarding how to inventory drum contents such that the DQOs for completeness and representativeness are met. Since generating the or iginal data package (RHINLVE060001), INL-CCP has: tested and qualifie d VE operators and completed two more data packages (RHINLVE060002 and RHINLVE060003). However, EPA review of data package

RHINLVE060003 indicates that furthe r improvements are necessary. Based on the INL-CCP SPM’s (Larry Porter) review of this BDR, he determined that ope rators were not generating container inventories as required by training provided on June 15, 2006. When th e ITR reviewed and approved this BDR to verify that all QAOs had been met, the ITR did not identify that the QAO for repr esentativeness for all three of the

containers in the BDR was not met. B. Regulatory Reference: 40 CFR, Part 194.22, b, (3)

C. Site requirement(s): WCPIP, Revision 1, Section 4.2.3

D. Discussed with: Larry Porter, Irene Quintana

E. Does this concern adversely affect the isolation of TRU waste? YES NO

Does this concern affect TRU waste that the site is approved to characterize? YES NO

F. Additional Comments: EPA may examine additional VE BDRs at a later date.

G. Site Response Required? YES NO Site Response Due Date: NAAttachment C

EPA’s Response to Public CommentsC-1 EPA’s Response to Public Comments

EPA received one set of public comments from DOE ’s Carlsbad Area Field Office (CBFO) in response to the November 8, 2006, Federal Register notice that proposed EPA’s decision to approve various components of the RH TRU waste characterization program implemented by CCP at ANL and INL (71 FR 65488, November 8, 2006).

All comments are reproduced here along with EPA’s response to each comment. Both ANL and INL Baseline Inspection Reports have been revised to reflect EPA’s response , where appropriate.

Comment No. 1: On page 65490 of the Federal Register (FR) Notice in the 3 rd column it references “EPA INL CCP RH Inspection Report A-98-42, II-A4-69” and the correct reference is A-98-49. In addition, on page 65492 of the same notice in the 1 st column the reference should be to A-98-49, as well, instead of A-98-42.

Response: The comment applies to the FR notic e. We concur with the comment, however, the error does not affect the sufficie ncy of the public’s notice of the proposed approval nor does it affect th e final approval itself.

Comment No. 2: EPA is using the Tier I and Tier II ch ange notice process to collect additional information regarding a site’s waste characteri zation program. See Comments 9 and 10 below. The Tier change process is designed to notify the EPA of changes or e xpansions to programs subsequent to a Baseline Comp liance Decision, not to generate additional information. The authority provided to the Agency under 40 CFR Pa rt 194.8(b)(4) is for th e expressed purpose of reporting changes to the Agency. For request s for additional information, the Agency is encouraged to implement the provisions of 40 CFR 194.4(b)(2).

Response: By requiring INL-CCP and ANL-CCP to notify EPA of the availability of new or additional information generated follo wing the EPA’s baseline inspection and the approval decision as part of the Tier 2( T2) change notice process, EPA will remain informed of improvements in the approved waste charac terization processes (e.g., AK and DTC) in a timely manner. Through this process, EPA will verify that CCP has updated/substantiated inform ation that was EPA evaluat ed during the baseline and follow-up inspections.

EPA’s baseline inspection approvals are not contingent on review of any additional information. EPA agrees that T2 reports are intended to report changes to approved waste characterization programs. Also, T2 change reports are not the appropriate mechanism to generate new information t hat would assist in evaluating continuing compliance. As described in EPA’s final modification to 194. 8(b) (69 FR 42571, July16, 2004), EPA uses its authority under §194.24(h), wh en it is necessary, to generate new or additional information to ensure continue d compliance with EPA regulations. When reporting T2 changes reflecting updates or additi on of new information to the material inspected during the baseline inspections, EPA expects the RH site to provide a brief description of additions/updat es to various AK and DTC documents. EPA can then decide whether review of th is additional information unde r the authority of §194.24(h) isC-2 warrented for evaluating adequacy and con tinued compliance with regulatory requirements. EPA then will request such information. EPA have made appropriate modifications to the INL and ANL final baselin e inspection reports to clarify our intent.

Comment No. 3: DOE is unclear as to the reasoning that the addition of a new piece of RTR equipment is considered a Tier I change by EP A for RTR of RH. Howe ver, as evidenced, for example, by the EPA approval of the INL-CCP CH Baseline, the addition of new RTR equipment would be a Tier II change. DOE requests that EPA explain this inconsistency.

Response: EPA identified the use of new RTR equipment for RH waste as a Tier I change because we did not evaluate any RTR equipment during th e baseline inspection of June 2006 at INL. Since EPA has no informat ion of how RTR would be applied to RH waste to characterize physical waste contents and the absence of pr ohibited items in the retrievably-stored RH containers, EPA id entified RTR equipment and its use for RH waste as a T1 change. Under the CH program, EPA identified a new RTR process at an approved site as a T2 change because we had evaluated the CH RTR process during baseline inspections at all CH sites.

Comment No. 4: There are a number of inaccuracies in the Inspection Re port A-98-49, II-A4- 69 for EPA Baseline Inspection No. EPA-INL- CCP-RH-6.06-8. Some examples follow:

a. Page 63, Section 8.3 in fifth bullet under Documents Reviewed identifies 19 containers in VE Batch Data Report (BDR) RHINLVE60001, 17 of which were subject to a CCP Non Conformance Report (NCR). Actually, at the time of the inspection, 5 of the 19 containers were rejected by an NCR.

b. Page 8, Section 6.2, Table 3 identifies pers onnel that were not at the inspection. For example, James Mobley (as a VEE), Buddy Fussell (as VE/VET) and Marcus Steade (as VE/VET) did not participate in the inspection.

Response: EPA concurs with the comment. We ha ve revised report text accordingly. The revision described in (a), above increase s the number of acceptable RH containers to 19 and not the number of containers stated in the proposed for approval in November 2006. (For additional discussion, see EPA’s response to Comment Nos. 8 and 12, below.)

Comment No. 5: On page 2 of the EPA-INL-CCP-RH- 6.06-8 Inspection Report, the EPA limits their approval of processes (AK, DTC, and VE) based upon waste streams reviewed during the inspection. The CBFO agrees that the EPA has the authority to lim it their approvals to specific waste streams at a particular site; however, it is important to note that these characterization processes do not change between waste streams.

As written, it is confusing as to which characterization processes are approved. The CBFO recommends that the EPA remove any waste st ream specific approvals from process approvals and add an item 4 specifically detailing wh ich waste streams are approved, as follows:C-3 (4) Waste Stream No. ID-ANLLE-S5000 is appro ved for shipment. Any waste stream not approved under this approval must undergo a T1.

The removal of waste stream approvals from process approvals should be done throughout the text, including Table 1 and Table 14 of Baseline Inspection Report No.

EPA-INL-CCP-RH-6.06-8.

Response: Waste characterization processes may change depending on the complexity of different waste streams. Therefore, un til the RH sites generate and apply detailed procedures for the derivation/ge neration of scaling factors and other critical radiological characterization inputs from the analytical data and AK records, EPA must restrict its approval to waste streams that have demonstrated compliance during the baseline inspection and cannot approve entire waste ca tegories as is typically done under the CH program. EPA expects scaling factors will vary by waste stream and the RH sites need a consistent way to generate them. Theref ore, we believe it is premature for EPA to approve the DTC process until the RH sites deve lop procedure(s) for calculating scaling factors.

EPA did not approve CH TRU Summary Waste Ca tegories at the beginning of the CH program. When approving the site-specific CH TRU waste characterization programs initially, EPA approval was also limited to specific waste streams. The reason for a limited approval was that both characterizati on activities at the waste generator sites and EPA’s inspection process were in their infan cy. As knowledge was gained and the sites’ CH waste characterization program matured, EPA was able to approve summary waste categories. EPA expects that as RH waste characterization programs mature and gains confidence in the sites’ abili ty to implement the RH WCPI P and comply with regulatory requirements as additional waste streams ar e characterized, we may be able to approve RH waste by Summary Waste Categories. The experience gained would then justify such an approval and could support moving from more restrictive tiering of waste streams to broader approvals of RH summary waste categories.

INL-CCP and ANL-CCP provided EPA several AK documents (CCP-AK-INL-500, CCPAK-INL-501 and CCP-AK-INL-502) that described the results of analyses or activities performed at both sites to generate sca ling factors, which are critical to the characterization of radiological components in the RH waste streams. These documents

were reports , not controlled procedures , with the exception that a portion of the AK process dealing with data assembly/assimilatio n is included in the RH WCPIP. These reports present the results of AK-related characterization activities and do not provide the detailed procedures used to obtain the re sults. The reports contain the results of a process used to develop radionuclide concen trations retrospectively. They did not provide instructions whereby RH site’s WC staff could perform th e task in the same manner prospectively. The technical calcul ations and data handling th at were performed to assess AK in support of the generation of radionuclide scaling factors were complex and were appropriately presented to EPA during in spection interviews and in the form of approximately 36 calculation packages. The calculation packages contained considerable detail and repr esent the primary documenta tion of the results of theC-4 activities and processes used to derive the scaling factors. During the inspection and follow-up interviews, EPA did not obtain objective evidence docu menting a set of instructions governing this waste steam-sp ecific concentration development activity ensuring that the processes we observed at INL and ANL would be the same. Therefore, approving the DTC process beyond the wa ste streams evaluated during the EPA inspection, in the absence of a formal, controlled procedure for developing scaling factors would be premature. For this re ason, EPA is approving the DTC process for only specific waste streams. If an RH site choos es to develop procedure(s) to control the generation of scaling factors for additi onal waste streams and upon EPA review of the procedure(s), EPA may, if appropriate, be abl e to give a broader approval of a DTC process that can be applied to a waste category.

With respect to AK, EPA does not distinguish between parts of the AK process because INL-CCP and ANL-CCP use AK for a continuum of characterization activities, from data collection through modeling and scaling factor development. The only measurement part of the characterization process, i.e., DT C, occurs well after the fundamental AK data assessment has been performed. Because the en tire AK process is not formalized in a procedure or procedures for a summary wast e category, and is instead applied to wastestream specific activ ities, AK is approved for the wa ste stream evaluated during the baseline inspection and discussed in Sec tions 8.1 and 8.2 of the final INL and ANL baseline inspection reports. Both EPA and CC P’s experience to date is limited for RH, i.e., essentially one waste stream at two s ites, INL and ANL. As additional waste streams are brought forward, the need for Tier 1 change designation can be reevaluated and a tier adjustment could be made through the process identified in 40 CFR 194.8.

Comment No. 6: Section III.A.(1) of the Federal Register Notice references the June 1, 2006 version (Revision 2) of CCP- AK-INL-500. Though this revision of the report was reviewed during the June inspection, Revisi on 3 of this report (dated July 7, 2006) addressing comments made during this inspection was presented and reviewed during the follow-up inspections in August as documented in Inspection Report A-98-49, II-A4-69.

Response: In Section 8.1 of this final basel ine inspection report EPA has made appropriate changes to reflect Revision 3 that addresses EPA comments on the initial AK report made during the baseline inspection.

Comment No. 7: Section III.A.(1) of the Federal Register Notice, and the associated Inspection Report A-98-49, II-A4-69 identifies “... Waste Stream No. ID-ANLE-S5000, Lots 1 through 20, as defined in CCP-AK-INL-500, Revision 2, June 1, 2006. ” CCP-AK-INL-500 does not define

these lots. The Central Char acterization Project (CCP) accepta ble knowledge (AK) process was applied to a population of 549 thir ty-gallon RH debris drums, which is described in CCP-AKINL-500. Of these drums, approximately 70 had been subjected to visual examination (VE), which was recorded on audio/video media during p ackaging. There is no further distinction made in this waste stream inventory. The designation of “lots” has no relevance in the

characterization and certification process and should be deleted. As described in CCP reference C350 prepared for EPA during th e inspections, CCP determined, and EPA agreed, that further segregation of the waste stream into lots based on the radiological char acterization performed by ANLE was not appropriate. References to “lot s” occur in numerous places in docket EPA-HQ-C-5 OAR-2006-0881 and the associated Inspection Report A-98-49, II-A4-69; these references

should be deleted.

Response: EPA recognizes that historic AK data is presented in “lots” by INL (and therefore EPA examined this historic data by the groupings provid ed by CCP), but EPA does not expect CCP to characterize this waste stream by these or any other predetermined lots.

INL-CCP AK supporting references identify INL’s Lot assignment of “lots” and several AK documents that are important to th e characterization process (e.g., EDF-6946 and EDF-6685) discuss the waste stre am by INL “lots”. Therefore, portions of the EPA’s

reports use the same terminology and refer to “lots” because the references examined present the information in this fashion. Appropriate changes to the text have been made when referring to the term “lots” in the context of historic AK data.

Comment No. 8: Section III.A.(3) of the Fede ral Register Notice states: “ The VE process used for a total of 8 retrievably-stor ed RH debris waste drums included in three batch data reportsBDR No.’s RHINLVE 6001-3. CCP has terminated the use of VE process for this waste until further notice. If CCP decides to use VE in the future, EPA inspection and approval is

necessary .” This citation is incorrect. CCP used the VE process to characterize a total of 70 drums of retrievably-stored RH debris waste where the waste contents were recorded on audio/video media during waste pa ckaging operations. The approva l should apply to the process of conducting VE using audio/video media, not to a particular population of drums characterized using that process.

As stated in Section 4.0 on pa ge 7 of both the INL EPA Insp ection Report A-98-49, II-A4-69 and the ANL EPA Inspection Report A-98-49, II-A4-70: “ During an inspection, EPA does not approve characterization data; that function is the sole responsibil ity of the site being evaluated during the inspection...EPA evaluated the WC processe s implemented by the s ite to characterize RH retrievably-stored debris waste. ” 40 CFR Part 194.8(b)(2) states, “ The Agency will verify the compliance of waste characteriza tion programs and processes. . . ” Nowhere does the Agency’s mandate require or allow for the approval by EPA, on a drum-by-drum basis, waste to be shipped

to WIPP. Their mandate is to ensure that the waste characterization programs and processes are compliant. By approving eight drums (and only ei ght drums) for shipment to WIPP, the Agency is usurping the authority of the Department of Energy (the Certifying Authority for Waste Characterization Activities) to approve drums for shipment to WIPP. The process of visual examination using audio/video media was extens ively demonstrated during the inspection. EPA has not indicated any noncompliance with the process but has arbitrarily restri cted its use to eight

drums.

The reference to the eight contai ners should be removed and it is recommended that the text read

as follows:

The VE process as defined in CCP-AK-INL- 502, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation TestPlan for INL RH Waste Stream ID-ANLE-S5000 and implemented by procedure CCPTP-500 CCP Remote-Handled Waste Visual Examination.C-6 This same comment applies to item 3 on page 2, a nd any related text, of the associated inspection report (A-98-49, II-A4-69) for EPA Baselin e Inspection No. EPA-INL-CCP-RH-6.06-8.

DOE CBFO agrees the language in the VE Tiering designation in Ta ble 2 of the Federal Register Notice correctly indi cates what was inspected and should be approved regarding the VE process. DOE CBFO requests that Table 1 in the FR and the corresponding sections of the two inspection reports be made consistent with this language.

Response: EPA’s proposed approval was based on an evaluation of the VE process (i.e., visual examination of waste container contents recorded on audio/visual media), interviews with VE personnel, and review of VE personnel training records. EPA identified one finding and one concern as a re sult of this review and concluded that the VE process implementation was not inadequate. CCP took steps to correct the EPAnoted inadequacies (e.g., additional training to VE staff and revisions to VE procedure(s) used by the VE personnel). EPA limited its proposed approval to only 9 drums because CCP had categorized the remaining 61 contai ners as not suitable for WIPP disposal using its own NCR (non compliance reporting) process. Following the inspection, CBFO informed EPA that (a) CCP does not plan to use this VE process beyond the 70 containers (included in 4BDRs that were part of the AK documentation), and (b) the 61 NCR drums would be reevaluated using real -time radiography (RTR), or another nondestructive examination pro cedure, in the future.

Since the baseline inspecti on, however, DOE informed EPA that all 70 RH waste containers from INL were subjected to anothe r VE review using a better monitor. Upon the review of the video records for these drums, CCP revised the associated BDRs and after using a modified VE process (with a better monitor) CCP concluded that 60 of the 70 containers are eligible for disposal at WI PP. DOE submitted this new information to

EPA

.

As stated in the Comment No. 4, Comm enter corrected EPA’s understanding of the number of containers suitable for the disposal at WIPP sa ying that 19 and not 9 RH waste containers were eligible for WIPP di sposal at the time of the proposal.

In the proposed approval EPA designated the reuse of the VE process (since then being retired) as a T1 change. EPA considers the use of a better monitor as a change in key VE equipment. Therefore, EPA must consider this new information as a T1 change. Since CCP used a modified VE process and the additional

, (new) data generated from this action was provided during the public comment period on EPA’s proposed approval, EPA must consider this as a T1 change and comp lete a review accordingly. Therefore, as part of the T1 change review and approval process an EPA inspector will complete a review of the modified VE process. CBFO will be notified of EPA’s decision, regarding the VE of additional drums in the waste stre am. EPA’s T1 decision will also be posted on the EPA website at www.epa.gov/radiation/wipp

.

Comment No. 9: Table 1 of the Federal Register Notic e, INL-CCP RH WC process-T2 changes and the associated Inspection Re port A-98-49, II-A4-69 identifies “ ...AK accuracy report for LotC-7 16 (or the appropriate Lot) wherein individual drum data assessed by INL (e.g., P030) will be compared against DTC-derived values... ” As described in Comment 7 above, INL-CCP determined that the “lot” approach was not appr opriate for the reasons described in reference C350 and addressed on page 20 in Inspection Report A-98-49, II-A4-69:

“ These documents show that detailed analyses of AK data assembled for each drum can be performed to determine, in some detail, th e estimated radiological content of each lot, recognizing that the process to develop an accurate and complete picture requires analysis well beyond that performed by th e generator site, ANL-E (see item (1) above, and reference C350). This ac tivity is also an alternati ve approach to characterizing

waste based on the AK record that does not use DTC in the manner currently proposed by INL-CCP but instead uses various calc ulations and modeling efforts to determine values for the individual waste drums. IN L-CCP has indicated, and EPA agrees, that this approach is time consuming (e.g., two years for 10 drums alone), and various assumptions and questions may still remain that could bring considerable uncertainty to this approach (see reference C350). This alte rnative approach has not been used at INLCCP; therefore, EPA did not evaluate it in depth. ”

In Inspection Report A-98-49, II-A4-69, EPA re quests that INL-CCP compare AK and DTC results for ten containers (lot 16) for the pur pose of determining AK accuracy as a T2 change; however, since INL-CCP has chosen to radiologically characterize the waste stream as a whole, the level of accuracy can not be determined by comparing the DTC results to those previously

calculated for a small subset of containers with in the stream. If any of the containers are determined to be non-transuranic (TRU) waste using the dose-to-curie (DTC) methodology, they will be reported as an AK inaccuracy. There is neither a plan nor a requirement currently in place to prepare a separate AK Accuracy Report fo r the ten drums cited. This requirement for a T2 change notification should be deleted from th e applicable tables and the text of Docket EPA-HQ-OAR-2006-0881 and Inspection Report A-98-49, II-A4-69.

Response: EPA’s intent behind the comparison re quirement was to better understand the relationship between the results of the proposed characterization approach and data for a small number of waste containers review ed during the baselin e inspection. The comment objects to the comparison of a small se t of AK data to results that were obtained through DTC because INL-CCP proposes to ch aracterize the stream “as a whole”, and the small subset may not match the stream as characterized to that point. EPA

understands this concern and also understands that there may be variability in the characterization data at any point in time. EPA has changed the T2 change to require the site to notify EPA when this data set is available. Under its authority of §194.24(h), EPA may request these data from INL-CCP in order to perform comparison as a verification of how the data sets compare. EPA believes that a comparison may provide additional insight regarding AK accuracy and he lp to better understand the variability of the characterization data, not to find a means to criticize INL-CCP’s characterization approach for this waste stream that this re port approves. EPA has made the appropriate clarifications to the INL and ANL final bas eline inspection reports to reflect this explanation.C-8 Note that the DTC process evaluated by EPA during the baseline inspection had been proposed for approval and is being approved now and the comparison discussed here does not affect this approval.

Comment No. 10: Table 1 of the Federal Register Notice, INL-CCP RH WC process-T2 changes and Table 1 on page 3 of the associat ed Inspection Report A-98-49, II-A4-69 identifies

“... Completed Correlation or Surrogate Summary Form of RH containers identi fied in this waste stream identified as CH based upon measured dos e rates that present NDA results for assayed containers, including isotopic ratios... ” As described in the AK procedure of the WCPIP, a Correlation and Surrogate Form is prepared to document when contact-handled (CH) data are used to meet a required DQO for an RH waste str eam. This form would not be completed unless the resulting CH assay data is specifically used to meet one of the RH DQOs. The comparison of isotopic ratios derived from modeling and mass spectrometry for the waste stream as a whole to any isotopic ratios measured via NDA for one or more individual containers is likely to be

inconclusive. This is because variations in the isotopic ratios between cont ainers is expected and may be difficult to quantify. Th is requirement for a T2 change notification should be deleted

from cited tables and the text of the Inspection Report A-98-49, II-A4-69.

Response: The Correlation or Summary (CSS) Form , if prepared, can easily address any discrepancies between an RH waste stream and its CH counterpart. The CSS could also add valuable information because it would provide actual assay measurement data. Accordingly, EPA requires that the site provid e notification, as a T2 change notice, when the CSS Form is available for a RH waste stream.

As stated in the previous responses to Comment Nos. 2 and 9 above, T1 and T2 reports are intended to report changes to approved waste characterization programs. As described in the final mo dification to 40 CFR 194.8(b) (69 FR 42581, July 14, 2004), EPA uses its authority under 194.24(h), when necessary, to evaluate new or additional information to ensure continued complian ce with regulatory requirements. Under §194.24(h) authority, EPA may ask for the CSS Fo rm for an RH waste stream in question and may also require a listing of all RH cont ainers that are ultimately identified as CH and the measurement (i.e., NDA) data for thos e containers not pres ented on a CSS. EPA has made the appropriate clarifications to the INL and ANL final baseline inspection reports in accordance with this response.

EPA understands that the comparison of isot opic ratios derived from modeling and mass spectrometry for the waste stream as a whol e to any isotopic ratios measured via NDA for one or more individual containers ma y be inconclusive. EPA also understands the potential for variations in the isotopic ratios between containers. We do not necessarily

consider that such variat ions would be problematic.

Comment No. 11: On page 16 of the inspection report, in the paragraph under Table 4, it states

that NDA will not be used “because of workers’ h ealth concerns.” This entire sentence should be deleted. The DTC technique is an approved tec hnique that is being implemented at this site and there is no reason for addressing why another technique is not being used.C-9 Response: We concur, the final repo rt the text has been revise d to remove reference to

the worker’s health concerns.

Comment No. 12: Clarify that implementation of VE fo llowing this baseline approval is a T1 change (Table 1 of the Federal Register Notice) . This should apply to VE, not to VE using

audio/video media:

a. Under VE T1 changes, the use of the VE process and data, in a manner consistent with that applied to the subject waste stream, s hould not require an EPA T1 approval as noted

above.

Response: When characterizing RH waste, INL CCP performed a visual examination of audio/video media depicting co ntents of RH waste containers. EPA has renamed the waste characterization process as “VE of audio/ video media” in the Tiering tables in the Executive Summary and Conclusion sections of the report.

Following the June 2006 baseline inspection, DOE provided additional information regarding drums that had been cited in INL- CCP non-conformance reports. Because this information identified a m odified procedure for VE of this waste stream, EPA is evaluating this additional VE information as a T1 change. (For additional discussion, see Response to Comment No. 8, above.) U pon completion of the T1 evaluation, EPA may issue an approval of the modified VE pr ocess and data applying to the waste stream

as a whole and not restricted to the 8 containers as proposed. As noted in the Response to Comment No. 4, above, the EPA proposed appr oval incorrectly st ates the number of containers as 9. The correct number of appr oved containers for the proposed approval should have been 19. EPA has been informed by CCP that it will no longer use the VE of audio/visual media process for characterizing RH contai ners at INL. If CCP again uses this process for visually examini ng audio/video media records for RH waste containers at INL, its implementation w ill be subject to theT1 change procedures requiring EPA notification and approval prior to implementation.

Comment No. 13: Table 2 of the Federal Register Notice, ANL-CCP RH WC process-T2 changes and Table 1 on page 3 of the associat ed Inspection Report A-98-49, II-A4-70 identifies

“... Comparison of AK versus DTC-derived radiologi cal data to support the use of waste streamspecific instead of drum-speci fic radiological data and the co mpleted DTC results for all

containers in this waste stream ...” As discussed on page 20 in Inspection Report A-98-49, IIA4-70, the following language was added to the AK Report:

The stated purpose of the method employed by Argonne to estimate the radiological composition in individual waste containers was to address site accountability requirements and to comply with the maximu m allowable fissile content of RH TRU drums. While the Argonne reported radiologi cal content of contai ners in this waste stream was used to support the CCP waste stream delineation, RH, and TRU determinations, the Argonne methodology did not produce results adequate for the purposes of WIPP certification. For this re ason, it is not appropria te to compare the Argonne estimates to the result s of the CCP radiological char acterization activities in AK accuracy evaluations.C-10 For this reason, the level of accuracy can not be determined by comparing the DTC results to those previously estimated by ANLE and this stipulation should be deleted from the cited Tables and the text of the Inspection Report A-98-49, II-A4-70.

Response: EPA concurs with the comment. The repor t including the Tables is modified accordingly.

Comment No. 14: Table 1 of the Federal Register No tice, INL-CCP RH WC process-T1 and Table 2 of the Federal Register Notice, ANL-CCP RH WC process-T1 changes are identified for

the addition of containers to th e existing waste streams. Additi on of containers to the existing waste streams should not be considered a change unless the addition of the containers changes the characteristics of the waste stream, which w ould require a change to the certification plan (CCP-AK-INL-502 for INL and CCP-AK-ANL-502 for ANL). As stated in Section 4.0 on page 7 of both the INL EPA Inspection Report A-98-49, II-A4-69 and the ANL EPA Inspection Report A-98-49, II-A4-70: “ During an inspection, EPA does not approve characterization data; that function is the sole responsibility of th e site being evaluated during the inspection...EPA evaluated the WC processes implemen ted by the site to characterize RH retrievably-stored debris

waste .” Therefore, EPA is only approving the wa ste characterization processes implemented, such as the process used to assign waste containers to a waste stream, and not the assignment of individual, specific containers to a waste stream. As defined in the inspection reports (page 2, 6 th
paragraph) “ Any changes to the WC activities from the date of the baseline inspection must be reported to and if applicable, approved by EPA. ” EPA tier changes therefore, should only address changes to WC and not routine modifi cations performed in accordance with the WC.

This same comment applies to th e corresponding tables, and any related text, in the associated inspection reports (A-98-49, II-A4-69 and A-98- 49, II-A4-70) for EPA Baseline Inspection No.’s

EPA-INL-CCP-RH-6.06-8 and EPA-ANL-CCP-RH-9.06-8.

Response: EPA inspected and approved the full AK process (including scaling factor development, etc.) through interviews and evaluations that were applicable to a small sample size. It is quite possi ble that “new” containers woul d require a different approach to scaling factor development following a process that EPA has not inspected or examined. Therefore, addition of cont ainers to the waste stream requires EPA notification to ensure that CCP has implemented a process that is well documented. If CCP seeks a broader approval in the future whereby containers could be added without review, CCP could present to EPA for appr oval a documented process for AK data analysis beyond that in the WCPIP. This will need to include all other AK data manipulation (e.g., scaling factor devel opment) up to application of the DTC
measurement. Until that time, EPA believes it is prudent to lim it the approval to the waste stream evaluated during the baseline insp ection, noting that our T1 review of waste stream expansion could be accomplished in a timely manner.

Comment No. 15: Under AK T2 changes, the term “w aste stream data package” does not appear in the Remote-Handled Transuranic Waste Characterization Program Implementation Plan (WCPIP). CBFO assumes that EPA is re ferring to the primary AK documents referenced including the waste stream pr ofile form (WSPF), the charac terization reconc iliation report (CRR), and the AK Summary Report.C-11 Response: EPA agrees that the term “waste stream data package” is broad, and CBFO’s assumption is correct. EPA is re ferring to the AK documents including the WSPF and CRR. If a Characterization Information Summary is prepared and includes information pertinent to EPA compliance, EPA mu st be notified of its availability using the T2 change notice process. EPA may reque st that this inform ation be provided, consistent with 194.24(h). EPA has made th e appropriate clarifications to the INL and ANL final baseline in spection reports.

Comment No. 16: Delete the wording: “or the use of the high range probe as described in CCP-TP-504”, from footnote *** to Table 1 and Table 2 of th e Federal Register and the corresponding tables in the inspect ion reports. Use of the high range probe is authorized in CCP-TP-504. Its operation is no different from the low- and mid-range probes that were demonstrated at the two inspections.

Response: EPA agrees that the use of all thr ee probes is authorized under CCP-TP-504, as discussed below. The operations observed at INL and ANL did not involve the use of the high range probe and EPA would be interest ed in such an application, not because of the probe itself, but because its use would require a signifi cantly different DTC operation from what was observed during the inspections.

As stated in the INL-CCP Report:

• There are three ion chamber probes availabl e for use with the RO-7 Ion Chamber: RO-7LD with a full-scale range of 1, 999 mR/hr and a resolution of 1 mR/hr (Low Range); RO-7BM, with a full-scale r ange of 199,900 mR/hr and a resolution of 100 mR/hr (Medium Range); and, RO-7BH with a full-scale range of 199,900,000 mR/hr and a resolution of 10,000 mR/hr (High Range). The calibrations are essentially probe-specific, allowing the probes to be interchanged between ion
chamber bodies.

• The Low Range Probe No. 802038 and the Medium Range Probe No. 801254 were in calibration at the time of th e inspection. The High Range probe was not observed in use, INL-CCP personnel stated that it had been neither ca librated nor source checked. INL-CCP personnel stated that there was no intention of using this probe in the foreseeable future.

CCP-TP-504 states that, prior to use, the high range probe requires a source check with a source of greater than or equal to 500,000 mR and less than or equal to 12,000,000 mR, i.e., a source with an external gamma exposure rate of between 500 and 12,000 R/hr (Roentgens per hour). The logistical aspect s of such an operation would be considerably different from the operation observed duri ng the inspections, and EPA wants to know about this in advance and have the opportunity to evaluate it prior to or during its application.