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 OF WASTE STREAM ID-EBR-S5000 (LOT 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 2014
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TABLE OF CONTENTS

Section Page

1.0 Introduction..........................................................................................................................1

2.0 Purpose of Tier 1 Evaluation ...............................................................................................2

3.0 Purpose 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 Examination................................................................................. 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

ATTACHMENTS

Attachment A: Approval Summary for INL RH Waste Characterization Program

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

Attachment C: List of DOE Personnel Present at Evaluation
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ABBREVIATIONS AND ACRONYMS

AK acceptable knowledge

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 Program

CFR Code of Federal Regulations

Ci curie

cm2square 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 nonconformance report

NDA nondestructive assay

NDE nondestructive examination
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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 and 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 Implementation Plan

WIPP Waste Isolation Pilot Plant
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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 the U.S. Department of Energy’s (DOE’s) Idaho National Laboratory (INL). In 

January 2007, EPA approved the Central Characterization Program (CCP)1to characterize 

remote-handled (RH) waste at INL. Using the EPA-approved waste characterization processes 

discussed 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-INL-CCP-RH-6.06-8 of the CCP waste characterization 

program at INL on June 12–16 and August 9 and 29, 2006. The INL-CCP baseline final 

inspection report (see EPA Docket No. A-98-49; II-A4-72; January 12, 2007) documents EPA’s 

approval of the acceptable knowledge (AK), radiological characterization using dose-to-curie 

(DTC), visual examination (VE) and real-time radiography (RTR) processes specific to INLCCP’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 RH transuranic (TRU) waste characterization processes, procedures and

equipment at INL that EPA approved in the January 2007 baseline approval and in subsequent 

tiering changes listed in Attachment A.

On October 1, 2013, 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-EBRS5000”). Consistent with the streamlined approach 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 of revised information and specific clarifications, EPA concluded that the INL-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 IDEBR-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 Program 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 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-A4-175; July 16, 2013) remain in effect and are listed as applicable 

in sections 6.1–6.3.

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

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

WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3). 

2.0 PURPOSE OF TIER 1 EVALUATION

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

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

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

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

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

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

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

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

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

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

destined for disposal at the WIPP. 

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

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

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

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

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

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

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

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

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

risk of subsequent EPA disapproval.

In November 2012, DOE, DOE 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 finalized 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 

not 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 quarterly 
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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 

inspections when setting the scope and evaluating site-specific T1 changes. EPA conducted a 

continued compliance inspection of INL-CCP in May 2013, and concluded in July 2013 (see 

EPA Docket No. A-98-49; II-A4-175) that INL-CCP continues to adequately implement the RH 

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

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

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluation of a T1 change to add Waste Stream IDEBR-S5000 to the EPA-approved waste characterization program, as described in CCP-AKINL-600, Revisions 0 and 1; CCP-RC-INL-601, Revisions 0 and 1; and CCP-AK-INL-602, 

Revisions 1 and 2. EPA’s approval decision regarding the addition of Waste Stream ID-EBRS5000 has been conveyed to DOE separately by letter. EPA will also announce the decision on 

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

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 documents can be requested from the following 

address:

Manager, National TRU Program

Carlsbad Field Office

U.S. Department of Energy

P O Box 3090

Carlsbad, NM 88221-3090

4.0 SCOPE OF THE TIER 1 EVALUATION

The scope of EPA’s T1 evaluation consists of the AK and NDE processes 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 of 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. 
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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 INL-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 via 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 Experimental 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)2operated EBR-I with four 

distinct loadings: three were fueled with enriched uranium (EU), i.e., uranium enriched in 235 

(

235U), and the final loading was fueled with plutonium (Pu). The U.S. Atomic Energy 

Commission (DOE’s predecessor) retired EBR-I in April 1964 (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 and base slab were natural uranium (NU) metal 

clad in stainless steel. From October 1965 to October 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 approximately 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 uses ANL.

Name Affiliation & Function 

Scott Smith INL-CCP, AK Expert

Derek Ott URS, Radiological Characterization Technical Expert

Steve Schafer CCP, AK Expert
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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 the two predominant radionuclides by mass are 238U and 235U, over 95 percent of 

the total activity in the waste stream is due to strontium-90 (90Sr), yttrium-90, cesium-137 

(

137Cs), barium-137m, cobalt-60, iron-55, and 239Pu (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 the base slab materials, which are packaged directly in a 55-gallon drum. The waste 

components 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 INL-CCP documentation that supported the addition of Waste Stream IDEBR-S5000. INL-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 Report A98-49; 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 materials
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technical adequacy of the information supporting the evaluation of 21 waste containers in Waste 

Stream ID-EBR-S5000.

Waste Characterization Element Description

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

 Identification of the Waste Characterization Program Implementation Plan (WCPIP)

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waste characterization process.

 Adequacy of the certification plan. 

 Adequacy 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 methodology, 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-INL-600, Revisions 0 and 1) and

Certification Plan (CCP-AK-INL-602, Revisions 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) generated 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 disassembled outer blanket components 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). All 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 waste stream and were 

constructed of NU clad in stainless steel. The waste containers may also contain 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 waste 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 Mexico, September 19, 2012.
7

cloth rags; plastic bags, sleeves, disks and woven drum lifting bags; rubber gaskets; and metal 

waste cans and drums (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, the blanket 

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 final 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). All 

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 ID-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 the waste characterization pathway and that 

documentation of the approach is 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 adequately 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), respectively. 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 

components.

INL-CCP used the ORIGEN2.2 computer code to quantify the radionuclides in the components 

of each drum based on their mass. INL-CCP gathered most of the ORIGEN2.2 input from AK 

records, and derived the remaining component using established neutron flux data as a starting 

point, with minor adjustments. INL-CCP personnel compared the ORIGEN2.2 results to an ANL

study to confirm that the correct neutron flux had been identified (Reference P4085). EPA 

approved the AK qualification for the general class 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 Stream IDEBR-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. INLCCP used mass data identified in the AK record to complete the radiological characterization for 

each drum (References P4084 and U4041). Per the WCPIP and 40 CFR Part §194.22(b), any AK 
8

data used directly in radiological characterization must be qualified per one of four methods. 

After discussing this requirement with EPA, INL-CCP decided to perform 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 defined and documented. The technical 

adequacy and implementation of the radiological characterization pathway are discussed in 

section 6.2.

INL-CCP plans to characterize the physical components of Waste Stream ID-EBR-S5000 using 

RTR or VE. This approach was adequately 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 the 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 Land Withdrawal Act (LWA) 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, including 

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, determines 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 quantities 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 not contain SNF or HLW.

(4) EPA examined the 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:

 Maintaining available fuel supplies, which was important to the naval reactors 

development process.

 Producing pure Pu, which was important for defense nuclear materials production.
9

 Producing more fuel than it consumed, which was important to reducing 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 decommissioning 

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, at a minimum, the certification plan will include:

 A description of AK qualification and/or characterization methods selected to meet the

DQOs, including the justification for the selection of the methods.

 A description of the quality assurance objectives for each selected method.

 A detailed description for 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 (CCP-AK-INL-602, Revision 2) and found that the 

document adequately addresses 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 

between Revisions 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 “to 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 Revision 26, CCP

modified the AK tracking spreadsheet content requirements to include the Off-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 changes 
10

impacts the RH waste characterization process. 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 evaluated the data 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 atomic energy defense activities, is not HLW, and is not SNF.

These are addressed in CCP-AK-INL-600, Revision 0, and CCP-AK-INL-602, Revision 1, as

discussed above in Items (3) and (4), respectively.

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

 TRU Waste Determination: Waste must contain more than 100 nanocuries of TRU

isotopes per gram of waste.

 RH Waste Determination: Surface dose rate must be equal to or greater than 200 millirem

per hour and less than 1,000 rem per hr.4

 Activity 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 Section 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 supported 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 technically 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 negligible.
11

Summary of Acceptable Knowledge Findings and Concerns

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

addition of Waste Stream ID-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-EBRS5000 and finds that all requirements have 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 requires changing the established radionuclide scaling factors 

remains a T1 change. T1 and T2 changes that were initiated during the baseline approval remain 

in effect.

6.2 Radiological Characterization

Waste Characterization Element Description

EPA evaluated the 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 

characterization program. 

During this RH evaluation, 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 provided by fuel 

suppliers and experimenters.

 Determination of average neutron fluxes 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. 

 Uncertainty analysis.

Each of these is discussed in the sections that follow.

Technical Evaluation

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

Stream ID-EBR-S5000, as described in the Radiological Characterization Technical Report 

(CCP-RC-INL-601, Revisions 0 and 1) and calculation packages.
12

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

and found them to be adequate.

The radiological characterization process for Waste Stream ID-EBR-S5000 uses computer 

modeling and iterative computations to determine the radionuclide content of the outer blanket 

bricks, control rods and base slab. The average radionuclide content per component was 

calculated and these values were used to directly calculate the radionuclide content of each drum. 

EPA 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 adequate and appropriately documented. Consistent with the T1 and T2 

designations that were established during the baseline approval, any new RH waste stream not 

approved to date or the addition of containers to Waste Stream ID-EBR-S5000 that requires a 

radiological characterization process different from what is documented in CCP-RC-INL-601, 

Revision 1, remains a T1 change. Similarly, any change to CCP-RC-INL-601 that requires 

CBFO approval remains a T2 change.

Figure 1. Radiological Characterization Flow Diagram for Waste Stream ID-EBR-S5000

(2) EPA found the 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 base slab and base slab inserts using ORIGEN2.2. This simulated isotope generation 

and depletion within the masses of NU of these three components with the ultimate goal of 

determining their radionuclide contents. The input 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 VE) 

on each drum to determine 

components in each drum

Source: Based on CCP-RC-INL-601, Revision 1
13

composition, 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 fluxes 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 missing neutron fluxes based on a known

quantity of 239Pu in the outer blanket that corresponded 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 calculations 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 compared well with the calculated 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, bracing and lifting slings, as expected. However, on closer 

examination INL-CCP observed that the control rod drum contained extraneous hardware that 

was not accounted for in AK, which prevented confirmation of the control rod weights as was 

done for the brick and base slab drums. Given that the weight of the uranium in the control rods 

was extracted 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 confirmation to the 

weight of the uranium to the control rods. Specifically, the weight of uranium given in ANL5095 (Reference P4085) is acceptable for all 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 the observed 

weights were used in the determination of TRU alpha activity concentration, as listed in CCPRC-INL-601, Revision 1. INL-CCP documented this in a memorandum from Derek Ott dated 

December 13, 2013. Upon reviewing 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 radionuclide contents for each of these three components of Waste 

Stream ID-EBR-S5000 is based on INL-RH-121, as discussed below.

Outer Blanket Bricks

INL-CCP determined the radionuclide contents in the outer blanket bricks based on the average 

neutron flux according to the following steps:

 The 239Pu quantities from ANL-5095 were based on radiochemical analyses 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 neutron 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 239Pu reported in ANL-5095 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-5095, including a specific core power density of 18.1 

kilowatts per kg, which resulted in an average core flux of 1.24x1014 neutrons per square 

centimeter per second (neutrons/cm2/s).

 For “calibration,” INL-CCP used ORIGEN2.2 to irradiate the outer blanket with an 

average neutron flux of 5.64x1012 neutrons/cm2/s, a flux 22 times less than that of the 

reactor core, resulting in a 0.24% relative difference in 239Pu compared to ANL-5095.

 The agreement of ORIGEN2.2 and ANL-5095 with respect to 239Pu and ratios of 

240Pu/239Pu and ruthenium-106/137Cs established that INL-CCP’s flux approximation 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 x1012

neutrons/cm2/s, NU for the control rods composition, and a generated energy of 6,577 

MWh, which was the total energy generated by the three EU core loadings and one Pu

core loading.

5

 INL-CCP calculated the average contents of 233U, 234U, 235U, 238U, 238Pu, 239Pu, 240Pu, 

241Pu, 242Pu, 241Am, 90Sr and 137Cs in a single brick.

Control rods

INL-CCP determined the average neutron 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 the curves from ANL-5095 at 485 MWh, depicting the 239Pu distribution 

in parts per million (ppm) of NU in the seven brick layers of the EBR-I outer blanket

with radial distance as measured in weight percent to conduct a regression analysis and 

present the ratio of 239Pu concentration to the average 239Pu concentration in the outer 

blanket as a function of radial distance (x) as measured in weight percent: 

f(x) = 0.0002x2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 whole brick to be 0.18386.

 INL-CCP calculated the average neutron flux in the control rods as the ratio predicted, 

i.e., 1.3306 times the brick average neutron flux of 5.64x1012 neutrons/cm2/s, resulting in 

the average flux in the control rods of 7.50x1012 neutron/cm2/s. INL-CCP used the 

estimated average neutron flux for calibration, comparing the total Pu in the control rods 

estimated by ORIGEN2.2 with what was reported in ANL-5095.

 INL-CCP used ORIGEN2.2 for calibration and irradiated the control rods with an 

average neutron flux rate of 7.50x1012 neutron/cm2/s, resulting in an estimated 239Pu 

 

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% relative difference when compared to the ANL5095 value of 0.95 g.

 The proximity of the 239Pu 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, incorporating the average flux of 7.50x1012 neutrons/cm2/s, NU

composition, and a total generated energy of 6,577 MWh.

 INL-CCP calculated the average contents of 233U, 234U, 235U, 238U, 238Pu, 239Pu, 240Pu, 

241Pu, 242Pu, 241Am, 90Sr and 137Cs for a single control rod.

Base Slab

INL-CCP estimated the average neutron flux and the average radionuclide content in the base 

slab according to the following steps:

 INL-CCP used the 239Pu content of the base slab and the outer blanket bricks from ANL5095 with the NU mass in the base slab without insert in the outer blanket bricks to 

derive the 239Pu concentrations in ppm of NU in the two components.

 INL-CCP calculated the ratio of 239Pu in the base slab to the outer blanket bricks as 0.88.

 Using the assumption that the ratio of the measured 239Pu 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 outer blanket bricks (5.64x1012 neutrons/cm2/s) to derive the average 

neutron flux in the base slab of 4.96x1012 neutrons/cm2/s.

 Using ORIGEN2.2 and the average neutron flux in the base slab resulted in 1.06 g of 

239Pu, compared to the ANL-5095 value of 1.05 g, a relative difference of 0.95%. The 

agreement of the ORIGEN2.2 and ANL-5095 values demonstrates the reasonableness 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, incorporating the average neutron flux of 

4.96x1012 neutrons/cm2/s, NU for the base slab composition, and a total generated energy 

of 6,577 MWh.

 INL-CCP calculated the average radionuclide contents of 233U, 234U, 235U, 238U, 238Pu, 

239Pu, 240Pu, 241Pu, 242Pu, 241Am, 90Sr and 137Cs per kg of the base slab.

INL-CCP documented development of the average neutron flux and average radionuclide

contents of the three waste components in INL-RH-121. EPA independently verified the “1.3306 

ratio” developed to estimate 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 the 239Pu concentration in the control rods as:

PuControl Rods = 0.95  0.1862x106 = 5.102 ppm
16

EPA calculated the 239Pu ratio in the bricks as:

PuBricks = 12.48g  3.2533x106 = 3.836 ppm

The 239Pu ratio in the control rods versus the bricks presented in INL-RH-121 of 1.3306 is 

similar to the ratio derived above, i.e., 5.102/3.836, which equals 1.3300, verifying the 

methodology to estimate the average neutron 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-EBRS5000.

(3) EPA evaluated the remote-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 containers were clearly RH, i.e., each had an external contact dose rate in excess of 200 

millirem per hour. 

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

Attachment 1 to CCP-RC-INL-601, Revision 1, contains revised Waste Container Radiological 

Characterization Records for the 21 drums of EBR waste. All containers are clearly TRU waste, 

i.e., each has a TRU alpha activity concentration in excess of 100 nanocuries per gram (nCi/g).

The TRU Alpha Activity Concentration for the control rods 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 the technical basis and documentation of total measurement uncertainty 

and found them to be adequate.

The development of total measurement uncertainty (TMU) for Waste Stream ID-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 

masses of bricks, control rods, and base slab were obtained.

 Uncertainties in 239Pu values – uncertainties in the 239Pu content reported in ANL-5095

used to derive the average neutron fluxes in the outer blanket bricks, control 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 

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

were simply added. For example, the TMU for 239Pu is derived by taking the square root of (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 which 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 inserted 

halfway during the operation of the reactor. 

A general treatment of TMU for Waste Stream ID-EBR-S5000 is presented in CCP-RC-INL601, Revisions 0 and 1, section 6, and the detailed treatment is provided in INL-RH-122. The 

overall uncertainties are consistent with what EPA has observed for RH determinations at other 

RH TRU generator sites. Table 6-10 of CCP-RC-INL-601, Revisions 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 evaluation, EPA approves the addition of Waste Stream ID-EBRS5000 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 not approved under the baseline or subsequent T1 evaluations or addition of 

containers to an approved waste stream that requires changing the established radionuclide 

scaling factors remains a T1 change. T1 and T2 changes that were initiated during the baseline 

approval remain in effect.

6.3 Nondestructive Examination

EPA performed a records-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 Visual Examination and Real Time Radiography 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 previous 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 were complete and generated in accordance 
18

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 operators 

did not identify 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 personnel 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 the 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 adequate.

EPA reviewed the following written and audio/visual training records for selected RTR 

operator/Independent Technical Reviewer personnel:

 NDE Training Container Inventory Sheets for container Nos. 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. 

INLRHRTR12019 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 Training 

containers NDE-Training-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 

considers the issue closed.

(4) EPA reviewed the visual examination characterization records and found them to be 

adequate.

EPA reviewed BDR Nos. 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 and 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 reviewed training records for selected operators and determined that VE operators were 

trained in accordance with INL-CCP procedures and that training records were complete and 
19

available for review. EPA also determined that VE Experts had been appointed as required 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 evaluation.

Nondestructive Examination Approval

Based on the results of this evaluation, EPA approves the addition of Waste Stream ID-EBRS5000 and finds that all requirements have been met. Based on this evaluation, there are no 

changes to the RTR or VE T1 or T2 designations. T1 and T2 changes that were initiated during 

the baseline approval remain in effect.

7.0 FINDINGS AND CONCERNS

Summary of Findings and Concerns

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

Waste Stream ID-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 during 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-A4-175; July 16, 2013) remain in 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 IDEBR-S5000 (Lot 5B), consistent with the limitations specified in this report. INL-CCP may 

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

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

ATTACHMENT A

APPROVAL SUMMARY FOR INL-CCP REMOTE-HANDLED WASTE 

CHARACTERIZATION PROGRAM

Approved Activity EPA Inspection Number, 

Approval Dates EPA Docket Number

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

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

T1 Change – Approval of WIPP Waste Information 

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

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

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

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

T1 Change – Approval of High-Range Gamma Probe 

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

T1 Change – Approval of Visual Examination 

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

T1 Change – Addition of Twelve Containers to Waste 

Stream ID-ANLE-S5000 and Addition of Waste 

Stream ID-HFEF-S5400-RH

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Addition of Lot 1B to Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

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

T1 Change – Addition of Lot 4A to Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Addition of Lot 2 to Waste Stream 

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

Continued Compliance Inspection July 16, 2013 A-98-49; II-A4-175
B-1

ATTACHMENT B

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION

C4124, Evaluation of Volume, Period Generation, 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 Package: Determination of EBR-I Reportable Radionuclides, D. Ott, INL-RH123, Revision 0, October 22, 2013

CCP Calculation Package: Determination of Gross and Net Weights of Drums, D. Ott, INL-RH154, Revision 0, October 1, 2013

CCP Calculation Package: EBR-I Reactor Components Uncertainty Analysis, D. Ott, INL-RH122, 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-600, Central Characterization Program 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-602, Central Characterization Program 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, Revision 1, 

September 18, 2013, Revision 2, February 13, 2014

CCP-RC-INL-601, Central Characterization Program 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 Radiological Characterization, Waste Stream: LA-MHDO3.002, LANLRH-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, 

December 20, 2013
B-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 Documentation 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, Revision 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 Reevaluation of EBR-I Components Currently Stored at RSWF, Michel Hall, ECAR-1105,

Revision 0, July 9, 2010

P4085, Determination of the Conversion Ratio of the Experimental Breeder Reactor by 

Radiochemical Methods, Milton Levenson, 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. Novick, 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 February 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, 2013
B-3

RTR BDR No. INLRHRTR12019 plus audio/visual recordings for selected containers 

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 IDEBR-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 2010
C-1

ATTACHMENT C

LIST OF DOE PERSONNEL PRESENT AT EVALUATION

Name Affiliation Audit Function/Expertise

Marcus A. Pinzel U.S. DOE DOE Observer

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 Expert

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