DOCKET NO: A - 98 - 49; II - A4 - 183

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT

EPA TIER 1 EVALUATION OF THE CENTRAL CHARACTERIZATION PROGRAM REMOTE - HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM

FOR THE IDAHO NATIONAL LABORATORY : ADDITION O F WASTE STREAM ID - EBR - S5000 ( L OT 5B )

U.S. Environmental Protection Agency Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460 March 2014i TABLE OF CONTENTS Section Page 1.0 Introduction ................................ ................................ ................................ .......................... 1 2.0 Purpose of Tier 1 Evaluation ................................ ................................ ............................... 2 3.0 Purpos e of This Report ................................ ................................ ................................ ........ 3 4.0 Scope of The Tier 1 Evaluation ................................ ................................ ........................... 3 5.0 Evaluation Personnel ................................ ................................ ................................ ........... 3 5.1 EPA Evaluation Personnel ................................ ................................ ...................... 3 5.2 DOE Evaluation Personnel ................................ ................................ ..................... 4 6.0 Technical Evaluation ................................ ................................ ................................ ........... 4 6.1 Acceptable Knowledge ................................ ................................ ........................... 5 6.2 Radiological Characterization ................................ ................................ ............... 11 6.3 Nondestructive E xamination ................................ ................................ ................. 17 7.0 Findings and Concerns ................................ ................................ ................................ ....... 19 8.0 Conclusions ................................ ................................ ................................ ........................ 19 TABLES Table 1. EPA Tier 1 Evaluation Team Members ................................ ................................ ............ 4 Table 2. DOE Tier 1 Evaluation Personnel ................................ ................................ .................... 4 Table 3 . Waste Packaging Configurations ................................ ................................ ...................... 5 FIGURES Figure 1. Radiological Characterization Flow Diagram for Waste Stream ID - EBR - S5000 ........ 12 ATT ACHMENTS Attachment A: Approval Summary for I NL RH Waste Characterization Program Attachment B: List of Documents Reviewed by EPA during T1 Evaluation Attachment C: List of DOE Personnel Present at Evaluationii ABBREVIATIONS AND ACRONYMS AK acceptable kn owledge AKSR acceptable knowledge summary report ANL Argonne National Laboratory ANL - W Argonne National Laboratory - West BDR batch data report CBFO Carlsbad Field Office CCP Central Characterization Pro gram CFR Code of Federal Regulations Ci curie cm 2 squar e centimeter Cs cesium DOE U.S. Department of Energy DQO data quality objective DTC dose - to - curie EBR - I Experimental Breeder Reactor - I EBR - II Experimental Breeder Reactor - II EPA U.S. Environmental Protection Agency EU enriched uranium g gram HLW high - level waste INL Idaho National Laboratory INTEC Idaho Nuclear Technology and Engineering Center kg kilogram LOQI List of Qualified Individuals LWA Land Withdrawal Act MFC Materials and Fuels Complex MWh megawatt - hours nCi/g nanocuries per gram NCR nonconformanc e report NDA nondestructive assay NDE nondestructive examinationiii

NU natural uranium NWP Nuclear Waste Partnership NWPA Nuclear Waste Policy Act ORIGEN Oak Ridge Isotope Generator ppm parts per million Pu plutonium RH remote - handled RSWF Radioactive Scrap a nd Waste Facility RTR real - time radiography s second SNF spent nuclear fuel SPM Site Project Manager Sr strontium T1 Tier 1 T2 Tier 2 TMU total measurement uncertainty TRU transuranic U uranium VE visual examination WCPIP Waste Characterization Program Imp lementation Plan WIPP Waste Isolation Pilot Plant1

1.0 INTRODUCTION This report supports the U.S. Environmental Protection Agency’s (EPA’s) approval of a Tier 1 (T1) change to add Waste Stream ID - EBR - S5000 ( Lot 5B ) to the approved characterization program at t he U.S. Department of Energy’s (DOE’s) Idaho National Laboratory (INL) . In January 2007, EPA approved the Central Characterization Pr ogram (CCP) 1 to characterize remote - handled ( RH ) waste at I NL. Using the EPA - approved waste characterization processes disc ussed in this report, INL - CCP can characterize Waste Stream ID - EBR - S5000 for disposal at the Waste Isolation Pilot Plant (WIPP). In accordance with Title 40 of the Code of Federal Regulations [ 40 CFR 194.8(b) ] , EPA conducted Baseline Inspection No. EPA - I N L - CCP - RH - 6 .06 - 8 of the CCP waste characterization program at I NL on June 12

– 1 6 and August 9 and 29 , 2006. The I NL - CCP b aseline f inal i nspection r eport (see EPA Docket No. A - 98 - 49; II - A4 - 7 2; January 12, 2007 ) documents EPA’s approval of the acceptable knowl edge (AK), radiological characterization using dose - to - curie (DTC) , visual examination (VE) and real - time radiography (RTR) processes specific to I NL CCP’s RH waste characterization program. EPA conducted a continued compliance inspection of INL - CCP in May 2013 , and concluded in July 2013 that INL - CCP continues to adequately implement the R H transuranic ( TRU ) waste characterization processes, procedures and equipment at INL that EPA approved in the January 2007 baseline approval and in subsequent tiering ch anges listed in Attachment A. On October 1 , 201 3 , the Carlsbad Field Office (CBFO) requested EPA approval of a T1 change to add Waste Stream ID - EBR - S5000 (Lot 5B) (hereafter referred to as “Waste Stream ID
- EBR S5000”) . Consistent with the streamlined appro ach to EPA’s evaluation and decision process described in section 2.0 of this report , EPA limited the scope of this T1 evaluation to the components of AK , radiological characterization and nondestructive examination (NDE) specific to the addition of Waste Stream ID - EBR - S5000. Because INL - CCP did not use new equipment or processes to characterize the subject waste , EPA conducted a desktop review of this change during a meeting with INL - CCP personnel in Denver , Colorado, on December 3

– 5 , 2013. Upon receipt o f revised information and specific clarifications, EPA conclud ed that the I NL - CCP plan to use the EPA - approved system of controls to characterize the 21 containers of Waste Stream ID - EBR - S5000 was acceptable. These 21 drums of TRU waste are the subject of this T1 report , but EPA’s approval also includes any additional drums that may be added to Waste Stream ID EBR - S5000 in the future , provided they are characterized using the processes discussed in this report . EPA did not identify any findings or concerns during this evaluation. INL - CCP revised several reports and various calculation packages during the evaluation and provided them to EPA. Attachment B is a list of all documentation reviewed, including batch data reports ( BDRs ) and calculation packages.

1 The Central Characterization Progra m was formerly known as the Central Characterization Project, and both names are used in the documentation reviewed for this evaluation.2

As a result of this evaluation, EPA did not make any changes to the INL - CCP RH T1 and T2 designations that were established during the baseline approval and modified during subsequent T1 evaluations and continued compliance inspections. The tiering designati ons presented in Table 1 of the final report for EPA’s 2013 continued compliance inspection of INL
- CCP (see EPA Docket No. A - 98 - 49; II - A4 - 1 7 5; July 16, 2013 ) remain in effect and are listed as applicable in sections 6.1

– 6. 3 . This report serves as EPA’s pub lic notification of the results of the proposed T1 change and its evaluation. This information will be provided through the EPA website and by emails to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3). 2.0 PURPOSE OF TIER 1 EV ALUATION Certain changes to the waste characterization activities from the date of the site’s baseline inspection must be reported to and, if applicable, approved by EPA according to the tiering requirements set forth in 40 CFR 194.8 regulations and incorporated into the I NL - CCP RH baseline final report (see EPA Docket No. A - 98 - 49; II - A4 - 7 2 ). Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, Federal Register notice (Vol. 69, No. 136, pages 42571

– 42583), EPA must perform a single baseline inspection of a TRU waste generator site’s waste characterization program. The purpose of EPA’s baseline inspection is to approve the site’s waste characterization program, based on the demonstration that the program’s components, with applicable conditions and limitations, can ad equately characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes destined for disposal at the WIPP. Following EPA’s baseline approval, EPA is authorized to evaluate and approve changes, if necessary, to the site’s approve d waste characterization program by conducting additional inspections under the authority of 40 CFR 194.24(h). Changes requiring EPA notification and approval prior to implementation (T1) and those requiring post - implementation notification (T2) are identi fied in the site - specific baseline inspection reports and subsequent T1 evaluation reports . When evaluating proposed T1 changes for approval, EPA may conduct a s ite inspection to observe implementation of the change or can opt to conduct a desktop review o f information provided specific to a change. DOE may choose to characterize and dispose of any previously approved TRU waste using processes, procedures or equipment implemented as T2 changes at risk of subsequent EPA disapproval. In November 2012, DOE, DO E contractor staff and EPA and EPA contractor staff discussed DOE’s TRU site cleanup goals through 2016 and ways to improve EPA’s evaluation and decision process to support DOE sites’ state
- mandated cleanup needs. As a result of this discussion, EPA finali zed a streamlined evaluation and decision process that includes an EPA annual continued compliance inspection at each active, EPA - approved TRU waste site. The annual inspections will cover the common elements of waste characterization processes that are no t expected to significantly vary on a waste stream or T1 basis. Examples of the common characterization elements are personnel training, procedures and equipment capabilities. EPA will evaluate these elements during T1 change evaluations or in conjunction with the quarterly3

T2 change reports as necessary to ensure that EPA’s waste characterization approvals reflect any significant changes made to DOE’s waste characterization program. This streamlined approach allows EPA to consider the results of continued compliance inspection s when setting the scope and evaluating site - specific T1 changes. EPA conducted a continued compliance inspection of INL - CCP in Ma y 2013, and concluded in July 2013 (see EPA Docket No. A - 98 - 49; II - A4 - 17 5 ) that INL - CCP continues to adeq uately implement the R H TRU waste characterization processes, procedures and equipment that EPA approved in the January 200 7 baseline approval and in subsequent tiering changes listed in Attachment A. 3.0 PURPOSE OF THIS REPO RT This report presents the resul ts of EPA’s evaluation of a T1 change to add Waste Stream ID EBR - S5000 to the EPA - approved waste characterization program , as described in CCP - AK INL - 600, Revision s 0 and 1 ; CCP - RC - INL - 601, Revision s 0 and 1 ; and CCP - AK - INL - 602, Revision s 1 and 2 . EPA’s ap proval decision regarding the addition of Waste Stream ID - EBR S5000 has been conveyed to DOE separately by letter. EPA will also announce the decision on its website at www.epa.gov/radiation/wipp , in accordan ce with 40 CFR 194.8(b)(3). The DOE documents that EPA reviewed for this evaluation are cited in different sections throughout the report and are listed in Attachment B , including those that were revised to incorporate EPA’s comments . Any of these documen ts can be requested from the following address: Manager, National TRU Program Carlsbad Field Office U.S. Department of Energy P O Box 3090 Carlsbad, NM 88221 - 3090 4.0 SCOPE OF THE TIER 1 EVALUATION The scope of EPA’s T1 evaluatio n consists of the AK and NDE pr ocesses and radiological characterization approach used to characterize Waste Stream ID - EBR - S5000. INL - CCP performed both VE and RTR to characterize Waste Stream ID - EBR - S5000; therefore, EPA assessed both during this T1 evaluation. Sections 6.1

– 6.3 o f this report detail the technical elements assessed during this evaluation. 5.0 EVALUATION PERSONNEL 5.1 EPA Evaluation Personnel The EPA evaluation team members consisted of the personnel listed in Table 1 with their affiliations and functions .4 Table 1 . EPA Tier 1 Evaluation Team Members Name Affiliation & Function Ed Feltcorn Lead Inspector, U.S. EPA Kira Darlow Technical Evaluator

– Acceptable Knowledge, SC&A , Inc. Connie Walker Technical Evaluator

– Acceptable Knowledge, SC&A , Inc. Rose Gogliotti Technical Evaluator

– Radiological Characterization, SC&A , Inc. Patrick Kelly Technical Evaluator

– Radiological Characterization, SC&A , Inc. Amir Mobasheran * Technical Evaluator

– Radiological Characterization, SC&A , Inc. Dorothy Gill* Technical Evaluator

– Nondestructive Examination, SC&A , Inc. *Participated remotely 5.2 DOE Evaluation Personnel EPA and its support personnel conducted interviews with INL - CCP waste characterization personnel in radiological characterization and AK . The IN L - CCP personnel contacted during the T1 evaluation in Denver , Colorado , are listed in Table 2 with their affiliations and areas of expertise or function. Following the Denver meeting, members of the EPA Evaluation Team had discussions with DOE personnel vi a email regarding document revisions and other technical details. All DOE personnel present at the evaluation are listed in Attachment C. Table 2 . DOE Tier 1 Evaluation Personnel

6.0 TECHNICAL EVALUATION Waste - Generating Activities and Waste Overview Waste Stream ID - EBR - S5000 consists of 21 containers of irradiated reactor components generated by the decommissioning of Experimenta l Breeder Reactor (EBR) - I . The materials were irradiated from reactor startup in December 1951 to permanent shutdown in December 1963. During this period, Argonne National Laboratory (ANL) 2 operated EBR - I with four distinct loadings: three were fueled with enriched uranium (EU) , i.e., uranium enriched in 235 ( 235 U) , and the final loading was fueled with plutonium (Pu). The U.S. Atomic Energy Commission (DOE’s predecessor) ret ired EBR - I in April 196 4 (References P777, P4078 and P4081) . Waste Stream ID - EBR - S5000 is a debris waste stream consisting of the components of the EBR - I outer blanket. The bricks, control rods an d base slab were natural uranium (NU) metal clad in stainless steel. From October 1965 to Octobe r 1966, ANL disassembled the outer blanket and transferred the components to five liners for storage at the Materials and Fuels Complex (MFC) Radioactive Scrap and Waste Facility (RSWF) (References C4124 and P4084 ). In March

2 The documentation for EBR - I indicates it was first operated in 1951 by Argonne National Laboratory or ANL. In approxi mately 1958 , the facility’s name was changed to Argonne National Laboratory
- West or ANL - W, which is now called the Materials and Fuel Complex or MFC. For the sake of convenience, this report does not make any distinction between ANL and ANL - W , and simply u ses ANL.

Name Affiliation & Function Scott Smith INL - CCP, A K Expert Derek Ott URS , Radiological Characterization Technical Expert Steve Schafer CCP, AK Expert5

2011, INL transferred the waste from RSWF to the Idaho Nuclear Technology and Engineering Center (INTEC) for repackaging from the RSWF liners into WIPP - eligible containers for characterization and ultimately emplacement in WIPP (Reference U293). The primary contaminants of the waste are NU , neutron activation products , and fission products . While t he two predominant radionuclides by mass are 238 U and 235 U , over 95 percent of the total acti vity in the waste stream is due to strontium - 90 ( 90 Sr ) , yttrium - 90 , cesium - 137 ( 137 Cs ) , barium - 137m , cobalt - 60 , iron - 55 , and 239 Pu (Reference CCP - RC - INL - 601 , Revisions 0 and 1 ) . Packaging Configuration The outer blanket includes 84 bricks, and each brick has an NU content of 38.73 kilograms (kg) for a total weight of 3,253.3 kg. There are 12 control rods , each having an NU content of 15.52 kg. The base slab includes the donut ring, the safety plug and the slab inserts with an NU content of 311.4 kg. The packaging configuration for these materials is a 30 - gallon drum inside a 55 - gallon drum, except for th e base slab materials , which are packaged directly in a 55 - gallon drum. The waste co mponents have been packaged in 21 55 - gallon drums as shown in Table 3 (Reference U293) . Table 3 . Waste Packaging Configurations

Documents Provided EPA evaluated the I NL - CCP documentation that supported the addition of Waste Stream ID EBR - S5000. I NL - CCP provided CCP - AK - INL - 600, Revision 0 ; CCP - RC - INL - 601, Revision 0 ; and CCP - AK - INL - 602, Revision 0 , to EPA for review. EPA’s review identified several technical issues that necessitated the revision of all three reports. INL - CCP provided the revised reports during the T1 evaluation. Attachment B is a list of all documentation reviewed, including BDRs and calculation packages. 6.1 Acceptable Knowledge EPA examined the programmatic requirements and AK process and associated information during the continued compliance inspection in May 2013 (see EPA Re port A98 - 4 9; II - A4 - 175 ) . Therefore, EPA limited the scope of this AK evaluation to those elements necessary to assess the

55 - Gallon Drum Nos. Number

of Drums Packaging Includes

30 - Gallon Drum? Contents FF - 43A

– FF - 43H 8 Yes 4 bricks in each FF - 45A

– FF - 45C 3 Yes 8 bricks in each DD - 45A

– DD - 45C 3 Yes 8 bricks in each FF - 45D and DD - 45D 2 Yes 2 bricks in each FF - 46A

– FF - 46B 2 Yes 4 control rods in each FF - 46C 1 Yes 1 control rod FF - 46D 1 Yes 3 control rods D - 48A 1 No Base slab materials6

technical adequacy of the information support ing the evaluation of 21 waste containers in Waste Stream ID - EBR - S5000. Waste Characteriz ation Element Description EPA limited this T1 evaluation to the technical elements listed below.  Identification of the Waste Characterization Program Implementation Plan ( WCPIP ) 3 waste characterization process.  Adequacy of the certification plan.  Adequa cy of AK procedure.  Waste stream definition, including radiological and physical characteristics.  Verification that the subject waste is of defense origin and is not high - level waste (HLW) or spent nuclear fuel (SNF).  Role of AK in the characterization met hodology, including radionuclide scaling factors.  Attainment of data quality objectives (DQOs). Technical Evaluation EPA evaluated the adequacy of AK information specific to Waste Stream ID - EBR - S5000 , as described in the AK Summary Report ( AKSR ) (CCP - AK - IN L - 600, Revision s 0 and 1 ) and Certification Plan ( CCP - AK - INL - 6 02, Revision s 1 and 2 ) . (1) EPA examined the waste stream determination for Waste Stream ID - EBR - S5000 and found it to be adequate. The WCPIP defines a waste stream as “ waste material that is (1) gen erated from a single process/activity and (2) similar in material, physical form, and radiological properties. ” The debris in Waste Stream ID - EBR - S5000 was generated during EBR - I decommissioning activities from October 1965 to October 1966. DOE stored the disassemb led outer blanket c omponents at the RSWF in designated storage liners until late 2010, when INL transferred the liners and their contents to INTEC for repackaging and characterization (References C4124, P881, P4072, P4084, U293, U552 and U4041). A ll 21 of the containers in Waste Stream ID - EBR - S5000 were generated by a single process. The EBR - I outer blanket components are the primary components of the wast e stream and we re constructed of NU clad in stainless steel. The waste containers may also con tain lesser amounts of cellulosic, plastic, rubber and ferrous metal debris generated during decommissioning of the EBR - I reactor or during repackaging of the RSWF liners at INTEC. This additional debris is expected to comprise less than 1% of the entire w aste population, and includes blotting paper;

3 All references to the WCPIP in this report refer to Revision 3, unless specified otherwise. U.S. Department of Energy, Carlsbad Field Office, “Remote Handled TRU Waste Characterization Program Implementation Plan,” Revision 3, Carlsbad, New Mexi co, September 19, 2012.7

cloth rags; plastic bags, sleeves, disks and woven drum lifting bags; rubber gaskets; and metal waste cans and dru ms (References P089, P115, P778, P838, P881, P4090 , U293 and U552). All 21 of the containers in Waste Stream ID - EBR - S5000 are similar in material and physical form. The outer blanket was designed to provide a material for capturing neutrons from the reactor core for the production of Pu. With the exception of a few of the 84 blanket bricks, t he blan ket components were unchanged throughout the reactor’s lifetime. Therefore, the radiological properties of all Waste Stream ID - EBR - S5000 containers are influenced by the same four reactor loadings: three were fueled with EU and the f inal loading was fueled with Pu . All of the outer blanket components are expected to contain the same mix of fission products and small amounts of inbred Pu (References P778, P838, P881, P954, P4078, P4082, P4084, P4090 and U552). A ll 21 of the containers in Waste Stream ID - EBR - S5000 have similar radiological properties. The 21 containers of debris waste in Waste Stream ID - EBR - S5000 were generated from a single activity, are similar in material and physical form, and have similar radiological properties. Therefore, Waste Stream I D - EBR - S5000 meets the WCPIP requirements for the definition of a waste stream and is eligible for characterization and emplacement at the WIPP facility. (2) EPA determined that INL - CCP identified t he waste characterization pathway and that documentation of the approach i s adequate. INL - CCP planned to use a variety of waste characterization methods to generate the required information for Waste Stream ID - EBR - S5000 and documented this approach in the certification plan (CCP - AK - INL - 602, Revision 1). INL - CCP adequa tely documented the plan to define the waste stream, verify that the waste is defense - related in origin, and confirm that the waste is neither SNF nor HLW using AK. EPA assessed the adequacy of implementation of this plan in Items (1), (4) and (3), respect ively. The AK used to define the waste stream and identify the defense pedigree and lack of SNF and HLW does not need to be qualified per one of the methods described in the WCPIP because it is not being used to directly quantify radiological or physical c omponents. INL - CCP us ed the ORIGEN2.2 computer code to quantify the radionuclides in the components of each drum based on the ir mass. INL - CCP gathered most of the ORIGE N2.2 input from AK records, and derived the re maining component using established neutro n flux data as a starting point , with minor adjustments. INL - CCP personnel compared the ORIGEN2.2 results to a n ANL study to confirm that the correct neutron flux had been identified ( Reference P4085) . EPA approved the AK qualification for the general clas s of ORIGIN2.2 input for fast breeder reactors during the INL - CCP RH baseline inspection (EPA Docket No. A - 98 - 49, II - A4 - 72). EBR - I was the original fast breeder reactor; therefore the AK used as input to ORIGEN2.2 does not need to be qualified at this time . INL - CCP used the textbook neutron flux data as a starting point to reconstruct the neutron flux values for this application and used the ANL study to check their work . Neither data source will be used to directly quantify the radionuclides in Waste Strea m ID EBR - S5000; therefore, neither data source needs to be qualified. The ORIGEN2.2 output is the radionuclide content of each drum on a per unit mass basis. INL CCP used mass data identified in the AK record to complete the radiological characterization f or each drum (Reference s P4084 and U4041 ). Per the WCPIP and 40 CFR Part §194.22(b) , any AK8

data used directly in radiological characterization must be qualified per one of four methods. After discussing this requirement with EPA, INL - CCP decided to perfor m confirmatory testing to verify the weights of the uranium components in each drum. INL - CCP revised the certification plan to document this confirmatory testing and clarify a few other details. The radiological characterization pathway is adequately defin ed and documented. The technical adequacy and implementation of th e radiological characterization pathway are discussed in section 6.2. INL - CCP plans to chara cterize the physical components of Waste Stream ID - EBR - S5000 using RTR or VE. This approach was a dequately documented. Selected technical components from INL - CCP’s implementation of RTR and VE for RH debris waste are discussed in section 6.3. (3) EPA examined t he waste stream information that indicates that the waste stream does not contain spent nuclear fuel or high - level waste and found it to be adequate . The L and Withdrawal Act (L WA ) prohibits WIPP disposal of SNF and HLW, as defined by the Nuclear Waste Policy Act (NWPA). Section 2(23) of the NWPA states that SNF is “fuel that has been withdrawn from a nuclear reactor following irradiation, the constituent elements of which have not been separated by reprocessing.” Section 2(12)(A

– B) of the NWPA defines HLW as “the highly radioactive material resulting from the reprocessing of spent nuclear fuel, includ ing liquid waste produced directly in reprocessing and any solid material derived from such liquid waste that contains fission products in sufficient concentrations; and...other highly radioactive material that the Commission, consistent with existing law, d etermines by rule requires permanent isolation.” Waste Stream ID - EBR - S5000 contains components of the EBR - I outer blanket. This includes uranium bricks, control rods and base slab, all clad with stainless steel. The waste stream also contains minor quanti ties of plastic and rags from the repackaging operations as mentioned in Item (1). Waste Stream ID - EBR - S5000 does not contain any fuel elements or SNF - reprocessing wastes (References P4084 , U293, U552 and U4041 ). Therefore, Waste Stream ID - EBR - S5000 does n ot contain SNF or HLW. (4) EPA examined t he waste stream information that indicates that the waste stream is defense in origin and found it to be adequate . RH TRU waste is eligible for disposal at the WIPP if it was generated in whole or in part by one of the atomic energy defense activities listed in Section 10101(3) of the NWPA. Waste Stream ID - EBR - S5000 contains TRU debris wastes generated from EBR - I decommissioning operations. Therefore, EBR - I operations are the only activities that EPA assessed for defense - related activities. EBR - I was the first liquid metal fast breeder reactor and was designed and built to establish the validity of the fast breeder reactor theory. The EBR - I program had several achievements that were essential to defense nuclear operations , including:  M aintaining available fuel supplies , which was important to the naval reactors development process .  Producing pure Pu , which wa s important for defense nuclear materials production.9

 Producing more fuel than it consumed, which was important to r educing defense nuclear waste and managing materials by - products.  Measurement of nuclear parameters , which aided the design of more advanced defense reactor systems and fuel materials. Therefore, the TRU debris in Waste Stream ID - EBR - S5000 generated from d ecommissioning the EBR - I reactor are contaminated with materials from atomic energy defense activities associated with naval reactor development, defense nuclear materials productions, defense nuclear waste and materials by - products management, and defense research and development activities ( References P049, P777, P778, P881, P4078, P4081, P4082, P4084, P4090 and U552). (5) EPA examined the certification plan and found it to be complete. The WCPIP states that , a t a minimum, the c ertification p lan will include:  A d escription of AK qualification and/or characterization methods selected to meet the DQOs, including the justification for the selection of the methods.  A d escription of the quality assurance objectives for each selected method.  A detailed description f or any characterization and testing method not included in the WCPIP.  A summary of the program documents to be prepared during the characterization and/or qualification methods selected for the waste stream. EPA examined the revised certification plan (CC P - AK - INL - 60 2 , Revision 2) and found that the document adequately address es each of the four components listed above and also includes descriptions of how AK accuracy will be assessed for each of the DQOs. The document is complete. (6) EPA evaluated revisions to the acceptable knowledge procedure and found them to be adequate. The AK procedure, CCP - TP - 005, is currently on Revision 26. EPA last evaluated the adequacy of the AK procedure when the current revision was Revision 24. EPA evaluated the differences bet ween Revision s 24, 25 and 26. The record of revision within the procedure states that CCP revised the document first “to incorporate Nuclear Waste Partnership (NWP) transition changes and to implement the Permit Modification Request Class 2 approved by New Mexico Environment Department (NMED) dated March 13, 2013,” and then “t o clarify the evaluation of nondestructive assay (NDA) results by the site project manager (SPM) and acceptable knowledge expert (AKE). Also, to incorporate changes as a result of CAR - LANL - 0003 - 13.” The changes made between Revision 24 and Revision 25 are editorial or relate to aspects of the process outside EPA’s purview. EPA found Revision 25 to be adequate. In R evision 26, CCP modified the AK tracking spreadsheet content requirement s to include the Of f - site Source Recovery Project defense determination in response to the Los Alamos National Laboratory corrective action report and modified the AK - NDA comparison results . Neither of these changes10

impact s the RH waste characterization pr ocess. EPA found Revision 26 to be adequate for RH waste characterization and will evaluate Revision 26 from the contact - handled waste characterization perspective during a future contact - handled T1 evaluation or continued compliance inspection. (7) EPA evalua ted the d ata quality objectives and found them to be adequately met. The WCPIP identifies the following DQOs that must be addressed: Defense Waste, HLW, and SNF Determination (Regulatory Basis: LWA): This ensures that the waste stream was generated by atom ic energy defense activities, is not HLW, and is not SNF. These are addressed in CCP - AK - INL - 60 0, Revision 0 , and CCP - AK - INL - 602 , Revision 1, as discussed above in Items ( 3 ) and ( 4 ), respectively. Radioactive Properties (Regulatory Basis: LWA, EPA Certifica tion of the WIPP):  TRU Waste Determination: Waste must contain more than 100 nanocuries of TRU isotopes per gram of waste.  RH Waste Determination: Surface dose rate must be equal to or greater than 200 millirem per hour and less than 1,000 rem per hr. 4  Act ivity Determination: The total waste inventory can be no more than 5.1 million curies ( Ci ) of RH TRU; activity limit per canister is 23 Ci per liter; and all radionuclides important to release calculations must be tracked. These three DQOs are addressed in CCP - RC - INL - 601 , Revision 0 , as discussed in Se ction 6.2 below. Physical Properties (Regulatory Basis: EPA Certification of the WIPP):  Liquids: The absence of liquids in excess of one percent must be confirmed.  Physical Form: The physical form of the waste must be determined to delineate the waste stream as required by the final certification rule. These two DQOs are addressed in CCP - AK - INL - 600, Revision 0, and confirmed by NDE, as discussed in Section 6.3 . EPA determined that the documents cited above supp orted that all DQOs were achieved either through AK, radiography, visual examination or the radiological characterization process.

4 Rem or millirem is a unit of dose equivalent, which is often commonly called dose or when it is expressed per unit time, a dose rate . The criterion for RH determination is expressed in terms of a dose rate in rem, which, while tec hnically incorrect, is commonly used. In this report, the terms dose and dose rate are used in place of the technically correct term dose equivalent or dose equivalent rate . The actual difference among these values for the purpose of this report is negligi ble.11

Summary of Acceptable Knowledge Findings and Concerns The EPA evaluation team did not identify any AK - related findings or co ncerns relative to the addition of Waste Stream ID - EBR - S5000 during this T1 change evaluation. Acceptable Knowledge Approval Based on the results of this evaluation, EPA approves the addition of Waste Stream ID - EBR S5000 and finds that all requirements hav e been met. Based on this evaluation, there are no changes to the AK T1 or T2 designations. Characterization of any new waste stream not approved under the baseline or subsequent T1 evaluations or addition of containers to an approved waste stream that req uires changing the established radionuclide scaling factors remains a T1 change. T1 and T2 changes that were initiated during the baseline approval remain in effect. 6.2 Radiological Characterization Waste Characterization Element Description EPA evaluated t he radiological characterization of INL - CCP RH Waste Stream ID - EBR - S5000 in terms of its technical adequacy, as supported by the program’s documents, procedures and controls, and the knowledge and understanding of the personnel involved in the RH waste chara cterization program. During this RH evalua tion, the EPA team evaluated the following elements of the INL - CCP radiological characterization program:  Overall radiological characterization.  Adequacy of modeling approach, using ORIGEN2.2 and information provi ded by fuel suppliers and experimenters .  Determination of average n eutron flux es and radionuclide inventories in each of the three reactor components using ORIGEN2.2 .  Calculation of the radionuclide content of each waste sub - component in the drums.  Unce rtainty analysis. Each of these is discussed in the sections that follow. Technical Evaluation EPA evaluated the adequacy of the radiological characterization process specific to Waste Stream ID - EBR - S5000 , as described in the Radiological Characterization Technical Report ( CCP - RC - INL - 60 1 , Revisions 0 and 1 ) and calculation packages .12

(1) EPA evaluated t he overall radiological characterization process and its documentation and found them to be adequate. The radiological characterization process for Waste Stream I D - EBR - S5000 uses computer modeling and iterative computations t o determine the radionuclide content of the outer blanket bric ks, control rods and base slab . T he average radionuclide content per c omponent was calculated and these values were used to directl y calcul ate the radionuclide content of each drum. E PA prepared a flow diagram to accurately reflect this process, shown in Figure 1 below. EPA determined that the radiological characterization process for Waste Stream ID - EBR - S5000 was technically adequat e and appropriately documented. Consistent with the T1 and T2 designations that were established during the baseline approval , a ny new RH waste stream not approved to date or the addition of containers to Waste Stream ID - EBR - S5000 that require s a radiologi cal characterization process different from wha t is documented in CCP - RC - INL - 601 , Revision 1, remains a T1 change. Similarly, a ny change to CCP - RC - INL - 601 that requires CBFO approval remains a T2 change.

Figure 1 . Radiological Ch aracterization Flow Diagram for Waste Stream ID - EBR - S5000 (2) EPA found t he modeling approach to be technically adequate and appropriately documented. INL - CCP determined the average radionuclide content for the outer blanket bricks, each control rod, and the b ase slab and base slab inserts using ORIGEN2.2. This simulate d isotope generation and depletion within the masses of NU of these three components with the ultimate goal of determini ng their radionuclide contents. The i nput for ORIGEN2.2 consisted of fuel Locate and retrieve relevant AK records on EBR - I operating characteristics

Calculate the activity in each drum Model three reactor components in ORIGEN2.2

Perform NDE (RTR or V E) on each drum to determine components in each drum Source: Based on CCP
- RC - INL - 601, Revision 113

c omposition, irradiation history, average operating neutron flux corresponding to the reactor components, and reactor core specific power and reactor shutdown date. In other words, the input data would include the burnup, the average operating neutron fluxe s in the component, and the mass of the components. Except for the average operating neutron fluxes, the other values were available in AK. INL - CCP developed the mi ssing neutron fluxes based on a known quantity of 239 Pu in the outer blanket that correspond ed to a known time during the first EU core loading. Tables 4 - 5, 4 - 8 and 4 - 12 of CCP - RC - INL - 601, Revisions 0 and 1 , provide the per - unit radionuclide contents of the three waste components. EPA questioned the adequacy of the weights used for INL - CCP’s calc ulations that were based entirely on AK . In response, INL - CCP weighed six drums, four containing bricks, one containing the base slab and one containing control rods. The weights of the four brick drums and the base slab drum compare d well with the calcula ted values . However, the drum containing control rods showed a significant discrepancy between the measured and calculated weights. INL - CCP reviewed the loading records for these drums, which showed that the drums loaded with brick contained only bricks, b racing and lifting slings , as expected . Howe ver, on clos er examination INL - CCP observed that the control rod drum contained e xtraneous hardware th at was not accounted for in AK, which prevented confirmation of the control rod weights as was done for the b rick and base slab drums . G iven that the weight of the uranium in the control rods was extr acted from the same AK as the weight of the uranium in the bricks and base slab , and that the brick and base slab weights were confirmed, INL - CCP extended the confir mation to the weight of the uranium to the control rods . Specifically, the weight of uranium given in ANL 5095 (Reference P4085) is acceptable for a ll components . Accordingly, the activity estimates that INL - CCP provided in CCP - RC - INL - 601, Revision 0 were not changed , with the exception of the drums containing control rods. INL - CCP weighed the control rod drums and th e observed weights were used in the determination of TRU alpha activity concentration, as listed in CCP RC - INL - 601, Revision 1 . INL - CCP docume nted this in a memorandum from Derek Ott dated December 13, 2013. Upon r eviewing the memorandum and Revision 1 of CCP - RC - INL - 601, EPA was satisfied with the adequacy of the weights for all three components of EBR wastes. Development of the average radionuc lide contents for each of these three components of Waste Stream ID - EBR - S5000 is based on INL - RH - 121 , as discussed below . Outer Blanket B ricks INL - CCP determined the radionuclide contents in the outer blanket bricks based on t he average neu t ron flux accord ing to the following steps:  The 239 Pu quantities from ANL - 50 9 5 were based on radio chemical analyse s of samples from the three reactor components after 485 megawatt - hours (MWh) of reactor operations during the Mark I core residency , which ended after 3,500 MWh of operation.  INL - CCP estimated that the average neu t ron flux in the EBR - I core would be approximately 22 times that in the outer blanket , based on data from ANL - 5059 .  INL - CCP used ORIGEN2.2 to determine the average flux that would produce the quantity of 239 Pu reported in ANL - 50 9 5 starting with a neutron flux ratio of 22/1 .14

 INL - CCP used ORIGEN2.2 to determine the average core flux using the EBR - I Mark I core parameters from ANL - 50 9 5 , including a specific core power density of 18.1 kilowatts per kg, whi ch resul ted in an average core flux of 1.24x10 14 neutrons per square centimeter per second (neutrons/ cm 2 /s ) .  For “calibration,” INL - CCP used ORIGEN2.2 t o irradiate the outer blanket with an average neutron fl ux of 5.64x10 12 neutrons/cm 2 /s, a flux 22 times less than that of t he reactor core, resulting in a 0.24% relative difference in 239 Pu c ompared to ANL - 50 9 5 .  Th e agreement of ORIGEN2.2 and ANL - 5095 with respect to 239 Pu and ratios of 240 Pu/ 239 Pu and ruthenium - 106/ 137 Cs establ ished th at INL - CCP’s flux appr oximati on was reasonable .  INL - CCP used ORIGEN2.2 to determine the radionuclide content of the outer blanket bricks at the end of reactor life, incorporating the average neutron flux of 5.64 x10 12 neutrons/cm 2 /s, NU for the control rods composition, and a g enerated energy of 6 , 577 MWh, which was the total energy generat ed by the three EU core loa dings and one Pu core loading . 5  INL - CCP calculated t he average contents of 233 U, 234 U, 235 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 241 Pu, 242 Pu, 241 Am , 90 Sr and 137 Cs in a sing le brick . Control r ods INL - CCP determined t he average neu t ron flux at the position of the control rods and calculated the radionuclides content of the control rods according to the following steps:  INL - CCP used t he curves from ANL - 5095 at 485 MWh, depictin g the 239 Pu distribution in parts per million ( ppm ) of NU in the seven brick layers of the EBR - I outer blanket with radial distance as measure d in weight percent to conduct a regre ssion analysis and present the ratio of 239 Pu concentration to the average 2 39 Pu concentration in the outer blanket as a function of radial dist ance (x) as measured in weight percent : f(x) = 0.0002x 2

 0.0285x+1.787  INL - CCP calculated the ratio of the weight of a brick segment at the center of a control rod to the weight of the who le brick to be 0.18386 .  INL - CCP calculated t he average neutron flux in the control rods as the ratio predicted , i.e., 1.3306 times the brick average neutron flux of 5.64x10 12 neutrons/cm 2 /s, re sulting in the average flux in the control rods of 7.50x10 12 ne utron/cm 2 /s. INL - CCP used t he est imated average neutron flux for calibration, comparing the total Pu in the control rod s estimated by ORIGEN2.2 with w hat w as reported in ANL - 5095 .  INL - CCP used ORIGEN2.2 for calibration and irradiated the control rods with an average neutron flux rate of 7.50x10 12 neutron/cm 2 /s, resulting in an estimated 239 Pu

5 The first three loadings were Mark I, Mark II and Mark III, and were all EU. The fourth loading was Mark IV, the only Pu - fueled operation.15

quantity of 0.977g and reflecting a 2.56% relativ e difference when compared to the ANL 5095 value of 0.95 g .  The proximity of the 239 Pu quantities estimated by ORIGEN2 .2 to those from ANL - 5095 demonstrates the reasonableness of INL - CCP’s representation of the average neutron flux in the control rods.  INL - CCP used ORIGEN2.2 to determine the radionuclide content of the control rods at the end of reactor life, inc orporatin g the average flux of 7.50x10 12 neutrons/cm 2 /s, NU composition, and a total generated energy of 6 , 577 MWh.  INL - CCP calculated t he average cont ents of 233 U, 234 U, 235 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 241 Pu, 242 Pu, 241 Am, 90 Sr and 137 Cs for a single control rod . Base Slab INL - CCP estimated t he average n eu t ron flux and the average radionuclide con tent in the base slab according to the following steps:  INL - CCP used t he 239 Pu co ntent of the base slab and the outer blanket bricks from ANL 5095 with the NU mass in the base slab without insert in the outer blanket bricks to derive the 239 Pu concentrations in ppm of NU in the two components.  INL - CCP calculated t he ratio of 239 Pu in the base slab to the outer blanket bricks as 0.88.  Using the assumption that the ratio of the measured 239 Pu in the base slab to the outer blanket bricks is the same as the ratio of the average neutron flux in the base slab to the outer blanket bricks, INL - CCP multiplied the concentration ratio ( 0.88 ) by the average neutron flux in the o uter bl anket bricks ( 5.64x10 12 neutrons/cm 2 /s ) to d erive the average neutron flux in the base slab of 4.96x10 12 neutrons/cm 2 /s.  Using ORIGEN2.2 and th e average neutron flux in the base slab resulted in 1.06 g of 239 Pu , compared to the ANL - 5095 value of 1.05 g, a relative differe nce of 0.95% . The agreement of the ORI GEN2.2 and ANL - 5095 values demonstrates the reasonablen ess of INL - CCP’s approach .  INL - CCP used ORIGEN2.2 to determine the radionuclide content of the base slab (without the insert) at the end of reactor life, incorporati ng the average neutron flux of 4.96x10 12 neutrons/cm 2 /s, NU for the base slab composition, and a total generated energy of 6 , 577 MWh.  INL - CCP calculated t he average radionuclide contents of 233 U, 234 U, 235 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 241 Pu, 242 Pu, 241 Am, 90 Sr and 137 Cs per kg of the base slab . INL - CCP documented d evelopment o f the average neutron flux and average radionuclide conten ts of the three waste components in INL - RH - 121. EPA independently verified the “1.3306 rat io” developed to e stimate the average neutron flux in the control rods using an approach similar to the one followed in the development of the “0.88 ratio” for the estimation of average neutron flux in the base slab. EPA calculated th e 23 9 Pu concentration in the control rod s as :

Pu Control R ods = 0.95  0.1862x10 6 = 5.102 ppm16

EPA calculated t he 239 Pu ratio in the bricks as:

Pu B ricks = 12.48g  3.2533x10 6 = 3.836 ppm The 239 Pu ratio in the control rods versus the bricks presented in INL - RH - 121 of 1.3306 is similar to the rat io derived above, i.e., 5.102/3.836, which equals 1.3300 , verifying the methodology to estimate the average ne utron flux in the base slab. EPA found that INL - CCP correctly conducted and appropriately documented the calculation of the average radionuclide contents of the three waste components for Waste Stream ID - EBR S5000 . (3) EPA evaluated the r emote - handled determinations and found them to be adequate. EPA reviewed a Radiological Survey Report for each of the 21 containers in this waste stream. All container s were clearly RH, i.e., each had a n external contact dose rate in excess of 200 m illirem per h our . (4) EPA evaluated the t ransuranic determinations and found them to be adequate. Attachment 1 to CCP - RC - INL - 601 , Revision 1, contains revised Waste Container Ra diological Characterization Records for the 21 drums of EBR waste. All containers are clearly TRU waste, i.e., each has a T RU alpha activity concentration in excess of 100 nanocuries per gram ( nCi/g ) . The TRU Alpha Activity Concentration for the control ro ds was recalculated using the revised weights and all control rod containers were clearly greater than 100 nCi/g, as documented in CCP - RC - INL - 601 , Revision 1. (5) EPA evaluated t he technical basis and documentation of t otal m easurement u ncertainty and found th em to be adequate. The development of t otal m easurement u ncertainty (TMU) for Waste Stream ID - EBR - S5000 is based on the propagation of uncertainties present in the determination of the waste stream’s radiological constituents. These aspects are assumed to be independent , allowing them to be added in quadrature. 6 The TMU determination included contributions of the following:  Total burn up uncertainty

– due to power generation in the four EBR - I core loadings.  Uncertainty in mass of the components

– due to the lack of clarity regarding how the mass es of bricks, control rods, and base slab were obtained.  Uncertainties in 239 Pu values

– un certainties in the 239 Pu content reported in ANL - 5095 used to deriv e the average neutron fluxes in the outer blanket bricks, c ontrol rods, and base slab, directly affecting the uncertainty in the ORIGEN2.2 calculations.
6 Adding in quadrature is a standard statistical technique that allows one to combine the square root of the s um of each contributor to uncertainty squared, resulting in a lower value than what would be obtained if the values were simply added. For example, the TMU for 239 Pu is deriv ed by taking the square root of (4.35%) 2 plus (8.6%) 2 plus (15.2%) 2 plus (10.7%) 2 plus (2.58%) 2 , which equals 21.0%, which is less than the value obtained by simply summing the individual uncertainty values ( i.e., 41.23%, as shown in INL - RH - 122, for an 8 - brick drum).17

 Computer code benchmark uncertainty

– due to ORIGEN2.2 benchmarking.  Drum - to - drum uncertainty

– due to lack of knowledge as to which individual bricks are in whic h drums, noting the lack of symmetry in irradiation of the outer blanket bricks in axial direction, despite the presence of symmetry in radial direction. Also, due to the lack of knowledge as to which drum would contain the control rod that had been insert ed halfway during the operation of the reactor. A general treatment of TMU for Waste Stream ID - EBR - S5000 is presented in CCP - RC - INL 601 , Revisions 0 and 1, s ection 6 , and the detailed treatment is provided in INL - RH - 122 . The overall uncertainties are cons istent with what EPA has observed for RH determinations at other RH TRU generator sites. Table 6 - 10 of CCP - RC - INL - 601 , Revision s 0 and 1 , provides an example of the TMU calculation for an 8 - brick drum. Summary of Radiological Characterization Findings and Concerns EPA did not identify any radiological characterization - related findings or concerns relative to the addition of Waste Stream ID - EBR - S5000 during this T1 change evaluation. Radiological Characterization Approval Based on the results of this evaluat ion, EPA approves the addition of Waste Stream ID - EBR S5000 and finds that all requirements have been met. Based on this evaluation, there are no changes to the radiological characterization T1 or T2 designations. Characterization of any new waste stream n ot approved under the baseline or subsequent T1 evaluations or addition of containers to an approved waste stream that requires changing the established radionuclide scaling factors remains a T1 change. T1 and T2 changes that were initiated during the base line approval remain in effect. 6.3 Nondestructive Examination EPA performed a reco rds - based, desktop T1 review of INL - CCP RH RTR and VE operations used to characterize Waste Stream ID - EBR - S5000 . Technical Evaluation (1) EPA reviewed the V isual E xamination and R ea l T ime R adiography procedures and found them to be unchanged. The procedures used to generate the data reported in the reviewed BDRs (INLRHRTR12019, INLRHVE11002, INLRHVE11003 and INLRHVE12001) are well established and have been reviewed by EPA during prev ious INL - CCP inspections. (2) EPA reviewed the real - time radiography characterization records and found them to be adequate. EPA reviewed the audio/visual and written records for selected containers from BDR No. INLRHRTR12019 and determined that the records w ere complete and generated in accordance18

with INL - CCP procedures. Operators had properly examined each container’s contents and entered characterization data into an electronic data sheet. The RTR operator determined that the waste matched the waste stream description and verified the waste matrix code. RTR o perators did not ident ify any prohibited items in containers from BDR No. INLRHRTR12019 . RTR operators performed an image quality check prior to each RTR event for BDR No. INLRHRTR12019 . INL - CCP RTR per sonnel performed the required quality control examinations, in the form of an independent observation and replicate scan, for BDR No. INLRHRTR12019 . INL - CCP RTR personnel reviewed the data at the data generation and SPM level and recorded the reviews on t he appropriate forms from the applicable INL - CCP procedures. INL - CCP has not issued any nonconformance reports ( NCRs ) for the containers reported in BDR No. INLRHRTR12019 . (3) EPA reviewed the real - time radiography training records and found them to be adequa te. EPA reviewed the following written and audio/visual training records for selected RTR operator/I ndependent Technical Reviewer personnel:  NDE Training Container Inventory Sheets for contain er N os. NDE - Training - 17 and NDE - Training - 21 .  Training Container Evaluation Data Sheets for selected operators .  Audio/visual recordings of training/test examinations for selected personnel .  Qualification Cards for selected personnel .  List of qualified individuals (LOQI) for dates covering the time periods when BDR No. I NLRHRTR12019 was generated . The above records demonstrated that RTR personnel were trained in accordance with INL - CCP procedures and that training records were complete. EPA previously identified RTR T raining containers NDE - Trai ning - 17 and NDE - Training - 21 in EPA Concern INL - CCP - CC - 2013 - 02CR (see EPA Docket No. A - 98 - 49; II - A4 - 175) . However, INL - CCP addressed this concern and EPA consider s the issue closed. (4) EPA reviewed the visual examination characterization records and found them to be adequate. EPA reviewe d BDR No s . INLRHVE11002, INLRHVE11003 and INLRHVE12001 and determined that characterization records were complete and properly processed in accordance with applicable procedures. INL - CCP VE personnel reviewed the data at the data generation and SPM level a nd recorded the reviews on the appropriate forms from the applicable CCP procedures. INL - CCP has not issued any NCRs for the containers reported in these BDRs. (5) EPA reviewed the visual examination training records and found them to be adequate. EPA reviewe d training records for selected operators and determined that VE operators were trained in accordance with INL - CCP procedures and that training records were complete and19

available for review. EPA also determined that VE E xpert s had been appointed as requir ed and that these appointments had been documented. Summary of Nondestructive Examination Findings and Concerns EPA did not identify any RTR - or VE - related findings or concerns relative to the addition of Waste Stream ID - EBR - S5000 during this T1 change eva luation. Nondestructive Examination Approval Based on the results of this evaluation, EPA approves the addition of Waste Stream ID - EBR S5000 and finds that all requirements have been met. Based on this evaluation, there are no changes to the RTR or VE T1 o r T2 designations. T1 and T2 changes that were initiated during the baseline approval remain in effect. 7.0 FINDINGS AND CONCERN S Summary of Findings and Concerns The EPA i nspection t eam did not identify any findings or concerns relative to the addition of Was te Stream ID - EBR - S5000 during this T1 change evaluation. 8.0 CONCLUSIONS Changes to Tiering As a result of this evaluation, EPA did not make any changes to the INL - CCP RH T1 and T2 designations that were established during the baseline approval and modified du ring subsequent T1 evaluations and continued compliance inspections. The tiering designations presented in Table 1 of the final report for EPA’s 2013 continued compliance inspection of INL
- CCP (see EPA Docket No. A - 98 - 49; II - A4 - 1 7 5; July 16, 2013 ) remain i n effect and are listed as applicable in sections 6.1

– 6. 3 . Approval EPA concluded that the waste characterization processes of AK , radiological characterization and NDE used to characterize RH TRU Waste Stream ID - EBR - S5000 are adequate, as evidenced by the records evaluated. There are no open issues relative to this T1 evaluation . Based on the results of this evaluation, EPA approves this T1 change to add Waste Stream ID EBR - S5000 ( Lot 5B ) , consistent with the limitations specified in this report. I NL - CCP ma y continue to characterize previously approved RH TRU waste consistent with the restrictions specified with the approvals listed in Attachment A to this report.A - 1 ATTACHMENT A APPROVAL SUMMARY FOR I NL - CCP R EMOTE - H ANDLED WASTE

CHARACTERIZATION PROGRAM Appr oved Activity EPA Inspection Number, Approval Dates EPA Docket Number INL - CCP RH Baseline Approval EPA - INL - CCP - RH - 6.06 - 8, January 12, 2007 A - 98 - 49; II - A4 - 72 T1 Change

– Approval of WIPP Waste Information System January 17, 2007 A - 98 - 49; II - A4 - 74 T1 Chan ge – Approval of Visual Examination January 25, 2007 A - 98 - 49; II - A4 - 75 T1 Change

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

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

– Approval of High - Range Gamma Probe for DTC April 11, 2008 A - 98 - 49; II - A4 - 98 T1 Change

– Approval of Visual Examination Technique September 22, 2009 A - 98 - 49; II - A4 - 118 T1 Change

– Addition of Twelve Containers to Waste Stream ID - ANLE - S5000 and Addition of Waste Stream ID - HFEF - S5400 - RH February 1, 2010 A - 98 - 49; II - A4 - 122 T1 Change

– Approval of Waste Stream ID - MFC - S5400 - RH June 8, 2010 A - 98 - 49; II - A4 - 126 T1 Change

– Approval of Waste Stream ID - INTEC - S5400 - RH August 17, 2010 A - 98 - 49; II - A4 - 130 T1 Change

– Addition of Lot 1B to Waste Stream ID - HFEF - S5400 - RH August 23, 2010 A - 98 - 49; II - A4 - 131 T1 Change

– Approval of Waste Stream IN - ID - NRF - 153 November 1, 2010 A - 98 - 49; II - A4 - 135 T1 Change

– Approval of Waste Stream ID - RTC - S3000 November 1, 2010 A - 98 - 49; II - A4 - 137 Continue d Compliance Inspection March 16, 2011 A - 98 - 49; II - A4 - 142 T1 Change

– Addition of Lot 4A to Waste Stream ID - HFEF - S5400 - RH March 23, 2011 A - 98 - 49; II - A4 - 145 T1 Change

– Approval of Waste Stream IN - ID - NRF - SPC March 12, 2012 A - 98 - 49; II - A4 - 159 T1 Change

– Addition of Lot 2 to Waste Stream ID - ANLE - S5000 July 25, 2012 A - 98 - 49; II - A4 - 163 Continued Compliance Inspection July 16, 2013 A - 98 - 49; II - A4 - 1 75B - 1 ATTACHMENT B LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION C4124, Evaluation of Volume, Period Gen eration, and Estimated Repackaging Volume for Waste Stream ID - EBR - S5000, Scott Smith, November 5, 2010 CCP Calculation Package: Characterization Spreadsheet for Lot 5B EBR - I Components, D. Ott, INL - RH - 124, Revision 0, October 2, 2013 CCP Calculation Packag e: Determination of EBR - I Reportable Radionuclides, D. Ott, INL - RH 123, Revision 0, October 22, 2013 CCP Calculation Package: Determination of Gross and Net Weights of Drums, D. Ott, INL - RH 154, Revision 0, October 1, 2013 CCP Calculation Package: EBR - I Re actor Components Uncertainty Analysis, D. Ott, INL - RH 122, Revision 0, October 1, 2013 CCP Calculation Package: INL Lot 5B Activity in EBR - I Bricks, Control Rods and Slab, D. Ott, INL - RH - 121, Revision 0, October 1, 2013 CCP - AK - INL - 6 00, Central Characteriz ation Pro gram Acceptable Knowledge Summary Report for Remote - Handled Transuranic Debris Waste from Experimental Breeder Reactor at the Idaho National Laboratory , Waste Stream: ID - EBR - S5000 , Revision 0, February 8, 2011, and Revision 1, January 15, 2014 CCP - AK - INL - 6 02, Central Characterization Pro gram RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance for Remote - Handled Transuranic Debris Waste from Experimental Breeder Reactor at the Idaho National Laboratory, Waste Stream: ID - EBR - S5000 , Revisio n 1, September 18, 2013, Revision 2, February 13, 2014 CCP - RC - INL - 6 01, Central Characterization Pro gram Remote - Handled Transuranic Radiological Characterization Technical Report for Remote - Handled Transuranic Debris Waste from Experimental Breeder Reactor at the Idaho National Laboratory , Revision 0 , September 25, 2013, Revision 1, March 7, 2014 Determination of the Conversion Ratio of the Experimental Breeder Reactor by Radiochemical Methods, Milton Levenson, ANL - 5059, December 23, 1953 M036, LANL RH TRU R adiological Characterization, Waste Stream: LA - MHDO3.002, LANL RH - 25, March 30, 2006 Memorandum to Irene Joo, ERB Base Slab Inserts, Derek Ott, December 20, 2013 Memorandum to Irene Joo: Qualification of EBR Brick and Control Rod Weights, Derek Ott, Decemb er 20, 2013B - 2

P049, Estimated Radiological Inventory Sent from Argonne National Laboratory - West to the Subsurface Disposal Area from 1952 through 1993, Michael L. Carboneau and James A. Vail, INEEL/EXT - 02 - 01385, Revision 0, April 2004 P089, AK Summary Docume ntation AK TRU Packaging Idaho Cleanup Project, RPT - 456, DRAFT, Revision 0, October 2007 and November 2007 P115, Decontamination Cell Operations in CPP - 659, Idaho Cleanup Project, TPR - 7298, Revision 7, June 4, 2008, Revision 11, June 3, 2009 P4072, System Design Description, Radioactive Scrap and Waste Facility Storage Liner System, Idaho National Laboratory, SDD - 225 , Rev ision 0, June 16, 2008 P4078, EBR - I, Mark - III - Design Report, R.E. Rice, R.N. Curran, F.D. McGinnis, M. Novick, F.W. Thalgott, ANL - 5836 , March 1958 P4081, The Birth of Nuclear - Generated Electricity , not dated P4082, Decontamination and Decommissioning of the EBR - I Complex, Final Report, E.W. Kendall, O.K. Wang, ANCR - 1242 , July 1975 P4084, Engineering Calculations and Analysis Report: Source Term Calculations for the Re evaluation of EBR - I Components Currently Stored at RSWF, Michel Hall, ECAR - 1105 , Rev ision 0, July 9, 2010 P4085, Determination of the Conversion Ratio of the Experimental Breeder Reactor by Radiochemical Methods, Milton Levens on, ANL - 5095 , December 23, 1953 P4090, EBR - II, Sixteen Years of Operation, Argonne National Laboratory - West, ANL - 001, May 1980 P777, Terminal Report for the Mark IV (Plutonium) Loading in EBR - I, R.R. Smith, C.B. Doe, R.O. Haroldsen, F.D. McGinnis, M. Novic k, ANL - 6865 , April 1965 P778, The Breeding Ratio of Plutonium Loading in EBR - I, R.R. Smith, R.O. Haroldsen, R.E. Home, R.G. Matlock, ANL - 6789 , February 1964 P838, Casting of Blanket Bricks, Ring, Plug, and Control Rods for the Experimental Breeder Reactor (CP - 4), Robert E. Macherey, ANL - 5009, not dated P881, Safety Analysis Report, EBR - I Mark - IV R.O. Haroldsen, F.D. McGinnis, M. Novick, R.R. Smith, and F.W. Thalgott, ANL - 6411 , February 1963 P954, Experimental Breeder Reactor Project, Report for Period Febru ary 1, 1950 thru March 31, 1951, H.V . Lichtenberger , ANL - 4554, April 1, 1951 Radiological Survey Report, RH - TRU Contact Gamma/Neutron Radiation Survey, various drums, April 9, 2013B - 3

RTR BDR No. INLRHRTR12019 plus audio/visual recordings for selected contain ers Source Term Calculations for the Re - Evaluation of EBR - I Components Currently Stored at RWWF, Engineering Calculations and Analysis Report, ECAR - 1105, 7/9/2010 Three RTR operator Qualification Cards Three RTR operator training DVDs and evaluation data sheets Three VE operator Qualification Cards Training drum inventory, container Nos. 17 and 21 U293, RH TRU Container Repackaging Datasheets for EBR - I Canisters in Waste Stream ID EBR - S5000, INL CWI, FRM - 880, March 30, 2011 U4041, EBR - II High Level Waste Facility Storage Logsheets for Storage Holes QQ - 36, QQ - 09, PP - 15, 00 - 26, 00 - 10, NN - 28, NN - 03, FF - 46, FF - 43, FF - 45, FF - 32, DD - 45, DD - 51, 1990 U552, Compilation of MFC Liner Documents , various authors, various dates Various LOQI, dated between 2011 and 2012 VE BDR Nos. INLRHVE11002, INLRHVE11003 and INLRHVE12001 Visual Examination Expert appointment letters, dated 2009 and 2010C - 1 ATTACHMENT C LIST OF DOE PERSONNEL PRESENT AT EVALUATION Name Affiliation Audit Function/Expertise Marcus A. Pinzel U.S. DOE DOE Ob server Derek Ott URS Radiological Characterization Technical Expert Ed Gulbransen NWP - Areva TRU Project Manager Thomas L. Clements, Jr. CWI - INL DOE Observer Douglas M. Pruitt DOE - ID DOE Observer Jason Montoya LANL - CO AK Expert David Ams LANL - CO AK Ex pert Patsy Gilbert LANL - CO Site Docs Scott Smith INL - CCP AK Expert Lisa Watson INL - CCP AK Expert Irene Joo CCP RH Support Steve Schafer CCP AK Expert Kevin Peters SRS - CCP AK Expert Tom Morgan CBFO DOE Observer