DOCKET NO: A-98-49; II-A4-194 EPA Air eDocket # EPA-HQ-OAR-2001-0012-0441

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT

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

FOR THE IDAHO NATIONAL LABORATORY: ADDITION OF WASTE STREAM ID-TRA-W345-RH (LOT 8B)

U.S. Environmental Protection Agency Radiation Protection Division Center for Waste Management & Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

November 2014i TABLE OF CONTENTS

Section Page Abbreviations and Acronyms ........................

................................................... .............................. ii
1.0 Introduction ......................................

................................................... .................................4
2.0 Purpose of Tier 1 Evaluations .....................

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

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

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

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

................................................... ..........................6
6.1 Acceptable Knowledge ..............................

................................................... .......... 7
6.2 Radiological Characterization .....................

................................................... ......... 9
7.0 Findings and Concerns .............................

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

................................................... ..............................15

TABLE OF TABLES

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

................................................... .................. 6

TABLE OF FIGURES
Figure 1. Radiological Characterization Flow Diagra m for Waste Stream ID-TRA-W345-RH . 10 Figure 2. Outline of Confirmation Test Plan .......

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ATTACHMENTS
Attachment A: Approval Summary for INL-CCP RH Wast e Characterization Program Attachment B: List of Documents Reviewed by EPA du ring T1 Evaluationii ABBREVIATIONS AND ACRONYMS
AK acceptable knowledge AKSR acceptable knowledge summary report ANL Argonne National Laboratory ANLE Argonne National Laboratory - East BDR batch data report
CBFO Carlsbad Field Office CCP Central Characterization Program CFR Code of Federal Regulations
Ci curie Ci/g curies per gram
cm centimeter
Cm curium CTP confirmation test plan DOE U.S. Department of Energy DQO Data Quality Objective
DTC dose-to-curie EBR Experimental Breeder Reactor EPA U.S. Environmental Protection Agency g/cc grams per cubic centimeter HFEF Hot Fuel Examination Facility HLW high-level waste INL Idaho National Laboratory INTEC Idaho Nuclear Technology and Engineering Cent er
m meter MCNP5 Monte Carlo N-Particle Transport Code RSICC C omputer Code Collection,

Oak Ridge National Laboratory MFC Materials and Fuels Complex mR/hr milliroentgen per hour nCi/g nanocuries per gram rem Roentgen equivalent man
RH remote-handled SC&A S. Cohen and Associates (SC&A, Inc.)iii

SNF spent nuclear fuel
T1 Tier 1
T2 Tier 2 TMU total measurement uncertainty
TRA Test Reactor Area
TRU transuranic WCPIP Waste Characterization Program Implementation Plan
WIPP Waste Isolation Pilot Plant4

1.0 INTRODUCTION
This report supports the U.S. Environmental Protect ion Agency’s (EPA’s) approval of a Tier 1 (T1) change that adds Waste Stream ID-TRA-W345-RH ( Lot 8B) to the approved remotehandled (RH) transuranic (TRU) waste characterizati on program at the U.S. Department of Energy’s (DOE’s) Idaho National Laboratory (INL). I n January 2007, EPA approved the Central Characterization Program (CCP) 1 to characterize RH TRU waste at INL. Using the EPA

approved waste characterization processes discussed in this report, INL-CCP may characterize Waste Stream ID-TRA-W345-RH debris waste for dispos al at the Waste Isolation Pilot Plant (WIPP).
EPA conducted a continued compliance inspection of INL-CCP in May 2014, concluding that INL-CCP continues to adequately implement the RH TR U waste characterization processes, procedures and equipment at INL that EPA approved i n the January 2007 baseline approval and in subsequent tiering changes listed in Attachment A. On May 30, 2014, the Carlsbad Field Office (CBFO) requested EPA approval of a T1 change to add Waste Stream ID-TRA-W345-RH (Lot 8B) (hereafter referred to as “Waste Stream ID -TRA-W345-RH”) to the INL-CCP RH waste characterization program. EPA limited the sco pe of this T1 evaluation to the components of acceptable knowledge (AK) and radiological chara cterization specific to the addition of Waste Stream ID-TRA-W345-RH. Because INL-CCP did not use new equipment or processes to characterize the subject waste, EPA conducted a des ktop review of this change in June–October 2014.
EPA did not identify any findings or concerns durin g this evaluation. Attachment B is a list of all documentation reviewed, including batch data report s (BDRs) and calculation packages.
As a result of this evaluation, EPA did not make an y changes to the INL-CCP RH T1 and Tier 2 (T2) designations established following the baselin e approval and modified subsequently as needed as a result of EPA’s approval of previous IN L-CCP RH T1 change requests and EPA’s annual continued compliance inspections. The tierin g designations presented in Table 2 of the final report for EPA’s 2014 continued compliance in spection of INL-CCP (see EPA Docket No. A-98-49; II-A4-190; July 15, 2014) remain in effect and are listed as applicable in sections 6.1 and 6.2 of this report.
Based on the information provided, EPA concluded th at INL-CCP used the EPA-approved system of controls to characterize the single conta iner in Waste Stream ID-TRA-W345-RH. This single container of TRU waste in Lot 8B is the subj ect of this T1 report, but EPA’s approval also includes any additional drums that might be added t o Waste Stream ID-TRA-W345-RH in the future, provided they are characterized using the p rocesses used for characterizing the single container in Lot 8B as discussed in this report.
This report serves as EPA’s public notification of the results of the proposed T1 change and its evaluation. This information will be provided throu gh the EPA website and by emails to the

1 The Central Characterization Program was formerly known as the Central Characterization Project, and both names are used in the documentation reviewed f or this evaluation.5

WIPPNEWS list, in accordance with Title 40 of the C ode of Federal Regulations [40 CFR 194.8(b)(3)].

2.0 PURPOSE OF TIER 1 EVALUATIONS
Certain changes to the waste characterization activ ities 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 th e July 16, 2004, Federal Register notice (Vol. 69, No. 136, pages 42571–42583), EPA must per form a single baseline inspection of a TRU waste generator site’s waste characterization p rogram. The purpose of EPA’s baseline inspection is to approve the site’s waste character ization program, based on the demonstration that the program’s components, with applicable cond itions and limitations, can adequately characterize TRU wastes and comply with the regulat ory requirements imposed on TRU wastes destined for disposal at the WIPP.
Following EPA’s baseline approval, EPA is authorize d to evaluate and approve changes, if necessary, to the site’s approved waste characteriz ation 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 req uiring post-implementation notification (T2) are identified in the site-specific baseline inspec tion reports and subsequent T1 evaluation reports. When evaluating proposed T1 changes for ap proval, 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 ch aracterize and dispose of any previously approved TRU waste using processes, procedures or e quipment implemented as T2 changes at risk of subsequent EPA disapproval.

3.0 PURPOSE OF THIS REPORT
This report presents the results of EPA’s evaluatio n of a T1 change to add Waste Stream IDTRA-W345-RH to the EPA-approved waste characterizat ion program. This report presents the technical basis for and results of EPA’s approval d ecision. EPA’s approval of the addition of Waste Stream ID-TRA-W345-RH has been conveyed to DO E 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).
Any of the T1 change request-specific documents men tioned in this report can be requested from the following address:
Manager, National TRU Sites and Transportation Divi sion Carlsbad Field Office U.S. Department of Energy P O Box 3090 Carlsbad, NM 88221-30906

4.0 SCOPE OF THE TIER 1 EVALUATION
The scope of EPA’s T1 evaluation is the AK process and radiological characterization approach used to characterize Waste Stream ID-TRA-W345-RH. S ections 6.1–6.2 of this report detail the technical elements assessed during this evaluation.

5.0 EVALUATION PERSONNEL
The EPA evaluation team members consisted of the pe rsonnel listed in Table 1 with their affiliations and functions. EPA relied primarily on reviews of documents and information provided by INL-CCP. When additional information or clarifications were needed, EPA had discussions with Irene Joo, the CCP RH Project Mana ger, who served as the point of contact for this T1 evaluation.

Table 1. EPA Tier 1 Evaluation Team Members

6.0 TECHNICAL EVALUATION
Waste-Generating Activities and Waste Overview
Waste Stream ID-TRA-W345-RH consists of a single co ntainer of heterogeneous debris that was generated during the examination of cross section s amples in the Alpha Laboratories at the Test Reactor Area (TRA; now known as the Advanced Test R eactor Complex). The debris is curium244 ( 244 Cm) oxide source material, which this report refers to as “ 244 Cm,” “ 244 Cm oxide neutron sources,” “cross section samples” and “neutron cros s section samples,” consistent with the nomenclature that INL-CCP documents use to describe it. INL-CCP Packaging documentation indicates that the drum contained 1,112 curies (Ci) of 244 Cm at the time of packaging. INL-CCP confirmed this initial inventory value and qualifie d the value for use in the radiological characterization program as documented in CCP-CN-IN L-635, Revision 0, and section 6.2, below.
In June 1973, INL initially packaged the waste with lead shot inside three capped pipe components within a six-inch diameter steel pipe in the center of a concrete annulus approximately 8 inches thick. INL placed the pipe a nd concrete shielding in a 55-gallon drum, and overpacked the 55-gallon drum in an 85-gallon d rum. From August 1973 to June 2009, INL stored the 85-gallon drum at the Radioactive Waste Management Complex. In June 2009, INL transferred the drum to the Idaho Nuclear Technolog y and Engineering Center (INTEC) for repackaging and RH waste characterization.

Name Affiliation & Function Rajani Joglekar Lead Inspector, U.S. EPA Ed Feltcorn Inspector, U.S. EPA Kira Darlow Technical Evaluator – Acceptable Knowl edge, SC&A Rose Gogliotti Technical Evaluator – Radiological C haracterization, SC&A Patrick Kelly Technical Evaluator – Radiological C haracterization, SC&A Amir Mobasheran Technical Evaluator – Radiological Characterization, SC&A7

Packaging Configuration
The initial 85-gallon drum waste packaging describe d above is not the current packaging configuration for this drum. However, it is importa nt because INL-CCP performed dose-to-curie (DTC) for AK confirmation on the drum in this confi guration. Much of the documentation refers to the 85-gallon drum because INL originally though t it would be the final configuration.
During repackaging, INL-CCP opened the pipe compone nts and emptied their contents into a single 1-gallon can. The can and the empty pipe com ponents are centered in a 30-gallon drum, which is overpacked into a 55-gallon drum. The 55-g allon drum is the final disposal configuration for the waste. INL-CCP segregated the original drums and cement and did not include them in Waste Stream ID-TRA-W345-RH.

Documents Provided
EPA evaluated the INL-CCP documentation that suppor ted the addition of Waste Stream IDTRA-W345-RH. INL-CCP provided CCP-AK-INL-630, Revis ion 0; CCP-RC-INL-631, Revision 0; CCP-CP-INL-632, Revision 0; and CCP-CN- INL-635, Revision 0, to EPA for review.

The DOE documents that EPA reviewed for this evalua tion, including BDRs and calculation packages, are cited in different sections throughou t the report and are listed in Attachment B.

6.1 Acceptable Knowledge
EPA examined INL-CCP’s programmatic requirements, t he AK process and associated information during the continued compliance inspect ion in May 2014 (see EPA Docket No. A98-49; II-A4-190; July 15, 2014). Specifically, EPA evaluated applicable CCP procedures; training for all personnel involved with RH TRU cha racterization; the processes of AK compilation, AK verification, AK accuracy assessmen t and AK discrepancy resolution; completion and adequacy of required forms and repor ts; and the INL-CCP waste stream certification process. Therefore, EPA limited the s cope of this evaluation to the technical adequacy of the information supporting the addition of Waste Stream ID-TRA-W345-RH.
Waste Characterization Element Description

EPA limited this T1 evaluation to the technical ele ments listed below.

• Waste stream definition, including waste generation and radiological and physical characteristics.

• Verification that the subject waste is of defense o rigin and is not high-level waste (HLW) or spent nuclear fuel (SNF).8

Technical Evaluation
EPA evaluated the adequacy of AK information specif ic to Waste Stream ID-TRA-W345-RH, as described in the AK Summary Report (AKSR) (CCP-AK-I NL-630, Revision 0) and associated source documents.
(1) EPA examined the waste stream determination for Was te Stream ID-TRA-W345-RH and found it to be adequate.

A waste stream is defined as waste material that is generated from a single process/activity and is similar in material, physical form, and radiologica l properties. As described in the overview portion of section 6.0, above, INL generated the de bris waste in Waste Stream ID-TRA-W345- RH during examination of 244 Cm oxide to study neutron cross sections at the TRA Alpha Laboratory in 1973. The waste contained 1,112 Ci of 244 Cm when INL originally packaged it in July 1973. The AK mentions other radionuclides that may be present in trace quantities, but does not include any other quantities. The commonality o f waste generation process and physical/radiological waste characteristics is adeq uately demonstrated.
(2) EPA examined the waste stream information that supp orts the absence of spent nuclear fuel or high-level waste in this waste stream and f ound it to be adequate.
The WIPP Land Withdrawal Act prohibits the disposal of SNF and HLW as defined by the Nuclear Waste Policy Act at the WIPP. Waste Stream ID-TRA-W345-RH includes debris generated from sample preparation and analysis of 244 Cm oxide neutron sources at the TRA Alpha Laboratory. The operations related to 244 Cm oxide did not involve reprocessing of constituent elements from reactor fuel (References U4055, U4056 and U7001). Therefore, Waste Stream ID-TRA-W345-RH does not contain SNF or HLW.
(3) EPA examined the information supporting that the wa ste stream is defense in origin and found it to be adequate.
AK indicates that the cross-section samples discuss ed above originated from the Materials Test Reactor at TRA, the Experimental Breeder Reactor (E BR) – II at Argonne National LaboratoryWest, and weapon tests at the Nevada Test Site. All three reactors had defense missions. (References P5197, U4055 and U7001). In addition, D OE assumes that Waste Stream ID-TRAW345-RH is commingled with other radioactive sample s processed in the Alpha Laboratory for research and development activities supporting arms control/nonproliferation, fusion safety (as part of an international program), and development of HLW separations technologies (References P5054, P5071 and P5235).
Summary of Acceptable Knowledge Findings and Concer ns The EPA evaluation team did not identify any AK-rel ated findings or concerns relative to the addition of Waste Stream ID-TRA-W345-RH during this T1 change evaluation.9

Acceptable Knowledge Approval
Based on the results of this evaluation, EPA approv es the addition of Waste Stream ID-TRAW345-RH and finds that all requirements have been m et. 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 facto rs remains a T1 change. T1 and T2 changes that EPA initiated during previous approvals remain in effect.

6.2 Radiological Characterization
EPA examined INL-CCP’s programmatic requirements, t he DTC process and associated information during the continued compliance inspect ion in May 2014 (see EPA Docket No. A98-49; II-A4-190; July 15, 2014). Specifically, EPA evaluated training for all personnel involved with RH TRU characterization, the INL-CCP measureme nt control program for RH TRU instruments for radiological characterization and t he INL-CCP RH TRU procedures and technical documents for the same. Therefore, EPA li mited the scope of this evaluation to the technical adequacy of the information supporting th e addition of Waste Stream ID-TRA-W345- RH.
Waste Characterization Element Description
EPA evaluated the radiological characterization of INL-CCP RH Waste Stream ID-TRA-W345- RH in terms of its technical adequacy, as supported by the program’s documents, procedures and controls, and the knowledge and understanding of th e personnel involved in the RH waste characterization program. During this RH evaluation , the EPA team evaluated the following elements of the INL-CCP radiological characterizati on program:

• Overall radiological characterization.

• Adequacy of confirmatory testing approach, using MC NP5 modeling and neutron DTC measurements.

• Calculation of the radionuclide content of associat ed radionuclides.

• RH and TRU determination.

• Uncertainty analysis.

Each of these is discussed in the sections that fol low.

Technical Evaluation
EPA evaluated the adequacy of the radiological char acterization process specific to Waste Stream ID-TRA-W345-RH, as described in the Radiolog ical Characterization Technical Report (CCP-RC-INL-631, Revision 0) and calculation packag es.10

(1) EPA evaluated the overall radiological characteriza tion process and its documentation and found them to be adequate.
The radiological characterization process for Waste Stream ID-TRA-W345-RH uses a neutronbased DTC method to confirm the 244 Cm content as reported in AK. EPA prepared a flow diagram to reflect this process, shown in Figure 1 below. EPA determined that the radiological characterization process for Waste Stream ID-TRA-W3 45-RH was technically adequate and appropriately documented. There were no concerns re garding the overall radiological characterization process and its documentation.
Consistent with the T1 and T2 designations that wer e established during the baseline approval, any new RH waste stream not approved to date or the addition of containers to Waste Stream IDTRA-W345-RH that requires a radiological characteri zation process different from what is documented in CCP-RC-INL-631, Revision 0, remains a T1 change. Similarly, any change to CCP-RC-INL-631 that requires CBFO approval remains a T2 change.

Figure 1. Radiological Characterization Flow Diagra m for Waste Stream ID-TRA-W345-RH Collect relevant AK information on the Lot 8B Waste Stream

Locate and retrieve AK records on the source activity and the radionuclide distributions at the time of disposal Obtain 244 Cm content from time of packaging

Apply the AK radionuclide distributions to the calculated
244 Cm mass at date of manufacture Develop Confirmation Test Plan to qualify 244 Cm activity reported in disposal record

Execute Confirmation Test Plan (see Figure 2)

Decay correct calculated radionuclide activities from date of manufacture to reference date If Confirmation Test Plan confirms AK, correct 244 Cm source material to assumed date of manufacture11

(2) EPA found the confirmatory testing approach to be t echnically adequate and appropriately documented.
The loading records from AK indicate that 1,112 Ci of 244 Cm were packaged into the Lot 8B drum on June 25, 1973. This value was reported prio r to the implementation of Section 5.3 of DOE/WIPP-02-3214, the Remote-Handled Waste Characte rization Program Implementation Plan or WCPIP. The WCPIP requires that information that is used to satisfy Data Quality Objectives (DQOs) must be qualified by one of four approved methods. INL-CCP used confirmatory testing, one of the four approved meth ods, to quantify the drum’s 244 Cm content at the time of loading.
INL-CCP developed a confirmation test plan (CTP), C CP-CN-INL-635, and EPA prepared a flow diagram to reflect this process, shown in Figu re 2, below. The CTP outlines a neutron-based DTC approach where neutron dose 2 rates are taken at distances of 1-meter (m) and 30

- centimeters (cm) at 90-degree rotational increments around the drum. The averages of each set of measurements were used to determine the drum’s 244 Cm content. The DTC approach is discussed in additional detail in Item (3), below.
Although not part of the CTP, INL-CCP determined th at there were three capped pipe components within the six-inch diameter steel pipe. INL-CCP unpacked the three capped pipe components and took contact dose measurements on ea ch. Using MCNP5, INL-CCP estimated the 244 Cm content of each component, the values were decay corrected 3 and summed for comparison to the drum loading and DTC records. The se steps are shown in Figure 2 as dashed lines because they were not included in the origina l testing plan.
The CTP specifies that the DTC-derived 244 Cm content would be corrected to the date of the initial drum loading, and the corrected value would be compared to the initial AK 244 Cm value of 1,112 Ci. The CTP states that the comparison would be acceptable if the two values compared within 32%. This criterion is based on: a measureme nt uncertainty of 25%; an MCNP5 modeling uncertainty of 10%; a source date uncertainty of 10 %; and, a concrete composition uncertainty of 15%. These values were combined in quadrature 4 to derive the acceptance criterion of 32%.

2 Rem or millirem is a unit of dose equivalent, which is often calle d dose or when it is expressed per unit time, a dose rate . The criterion for RH determination is expressed i n terms of a dose rate in rem, which, while technically incorrect, is commonly used. In this re port, the terms dose and dose rate are used in place of the technically correct term dose equivalent or dose equivalent rate , and the terms R and rem are used interchangably

. The actual differences among these values for the p urpose of this report are negligible.

3 The decay correction is a calculation to determine the drum’s 244 Cm content on the date stated in the AK records. It should more correctly be called a reverse decay correction since the quantity being calculated is the
244 Cm content prior to decay over the time period from 1971 until the present. For purposes of this repor t, the term decay correction refers to the calculation of the drum’s 244 Cm activity in 1971, by applying the appropriate de cay kinetics to the drum’s current 244 Cm value.

4 Adding in quadrature is a standard statistical tec hnique that allows one to combine the square root o f the sum of each value squared, resulting in a lower val ue than what would be obtained if the values were s imply added. For example, taking the square root of (25%) 2 plus (10%) 2 plus (10%) 2 plus (15%) 2 equals 32%, which is less than the value obtained by simply summing the individual uncertainty values (i.e., 60%).12

The three decay-corrected DTC-derived measurements were 1,045 Ci at 30 cm, 1,240 Ci at 100 cm and 780 Ci at contact. The average of these meas urements was 1,022 Ci. All four values were within 32% of the initial value of 1,112 Ci. Based on these data, INL-CCP concluded that the reported disposal record 244 Cm content was confirmed.
EPA reviewed the CTP and calculation package INL-RH -158, which documented the details of the confirmation process and found them to be techn ically adequate. There were no concerns regarding the technical adequacy and documentation of the confirmatory testing for the Lot 8B drum.

Figure 2. Outline of Confirmation Test Plan Examination reveals there are 3 pipe components within the container

Neutron dose rate measurements were taken at 90-degree increments around the container at distances of 30 cm and 1m Develop MCNP neutron DTC correlation at 30-cm and 100-cm from 85- gallon drum Develop neutron DTC correlation at contact with a pipe component Neutron dose rate measurements were taken at contact with each of the pipe components

Decay correct the DTC predicted activity from the average of each distance Apply DTC coefficient to average neutron dose rates at each location

If DTC values compare within 32% of the AK 244 Cm value, the 244 Cm activity in the disposal record is considered qualified Compare neutron-based DTC values to the 244 Cm value in the AK

Dashed lines indicate steps added to the original c onfirmation testing plan due to the repackaging pro cess. Apply DTC coefficient to each pipe component

Decay correct the DTC predicted activity within each component; then sum the components13

(3) EPA found the dose-to-curie modeling and execution to be technically adequate and appropriately documented.
The Lot 8B waste differs from the majority of INL-C CP RH TRU waste streams characterized using the DTC method in that 244 Cm is a neutron-emitting radionuclide. Typically, t he DTC approach measures the gamma radiation associated wi th cesium-137 and applies radionuclidespecific scaling factors to derive values for those radionuclides, as described in the DTC procedure CCP-TP-504. Accordingly, the DTC measurem ents for Lot 8B were not taken using CCP-RH-504; the DTC approach is outlined in CCP-RC- INL-631 and CCP-CN-INL-635, and documented in detail in INL-RH-157, Revision 0, as discussed below.
INL-CCP modeled three waste configurations using MC NP5 to derive neutron-based DTC coefficients. The first and second models assumed measurements of an 85-gallon drum containing the 244 Cm source material, steel pipe, concrete annulus an d a 55-gallon drum at distances of 30-cm and 100-cm from the 85-gallon dr um’s surface. The modeling assumed measurements were taken at a vertical height of 10 inches below the top of the container. The remaining model was assumed to be in contact with a source pipe component. All three components were slightly different in size, and INL -CCP averaged the three components. The pipe was assumed to be carbon steel [density 7.86 g rams per cubic centimeter (g/cc)] and its contents were assumed to be lead (11.35 g/cc). Mode ling for all three configurations is documented in INL-RH-157, Revision 0.

Four measurements were taken from the 30-cm and 100 -cm distances at each of the 90-degree increments and the measurements were averaged. Addi tionally, a contact measurement was taken for each of the pipe components. Each of the five values (three pipe component values, 30- cm average, and 100-cm average) were decay correcte d to the date of the disposal record. The decay-corrected pipe components were summed to esti mate the total 244 Cm content at packaging. The pipe components, 30-cm average 244 Cm and 100-cm average 244 Cm content were then compared to the disposal record values of 1,112 Ci according to the criterion specified in Item (2), above.
There were no concerns regarding the neutron-based DTC modeling and execution for the Lot 8B waste.
(4) EPA evaluated the assumed contributions of associat ed radionuclides and found them to be adequate.
INL-CCP retrieved an Aerojet Nuclear Company Progre ss Report dated October 1971 from AK which gave the radionuclide distributions in the 244 Cm source material for three samples as shown in Table 4-1, of CCP-RC-INL-631. The radionuc lide content of the 244 Cm was calculated using the average distraction from these samples. T he 244 Cm activity at the date of disposal was then decay corrected to the assumed date of manufac ture, January 15, 1968, resulting in a calculated activity of 1,272 Ci. The mass of 244 Cm at the date of manufacture was then estimated using the specific activity of 81.8 Ci/g. INL-CCP a pplied the estimated radionuclide distribution to the sample and decay corrected all values to a r eference date of December 30, 2013. These values are reported on the Waste Container Radiolog ical Characterization Record for the Lot 8B Drum No. 10087564C.14

There were no concerns regarding the contributions of other radionuclides for the Lot 8B waste.
(5) EPA evaluated the remote-handled determinations and found them to be adequate.
EPA reviewed a Radiological Survey Report for Drum No.10087564C and found a maximum contact gamma dose rate of 300 mR/hr and a maximum contact neutron dose rate of 200 mR/hr. Based on these, INL-CCP determined that the drum me t the 200 mRem/hr criterion for RH waste. There were no concerns regarding the RH dete rmination for the Lot 8B waste.
(6) EPA evaluated the transuranic determinations and fo und them to be adequate.
Attachment 1 to CCP-RC-INL-631, Revision 0, contain s revised Waste Container Radiological Characterization Records for Drum No. 10087564C. T he container has a TRU alpha activity concentration of 1.40E+5 nanocuries per gram (nCi/g ), clearly in excess of 100 nCi/g required of TRU waste. There were no concerns regarding the TRU determination for the Lot 8B waste.
(7) EPA evaluated the technical basis and documentation of total measurement uncertainty and found them to be adequate.
The development of total measurement uncertainty (T MU) for Waste Stream ID-TRA-W345-RH is based on the propagation of uncertainties presen t in the determination of the waste stream’s radiological constituents. These aspects are assume d to be independent, allowing them to be added in quadrature. The TMU determination included contributions of the following:

• Uncertainty in manufacture date – Assumes an earlie r date of manufacture

• Uncertainties in sample data – Based on the variabi lity of samples used in the cross section measurements

• Uncertainties in reported quantity of 244 Cm – Based on the differences between the reported values and the average of three DTC values
A general treatment of TMU for Waste Stream ID-TRA- W345-RH is presented in CCP-RCINL-631, Revision 0 and the detailed treatment is p rovided in INL-RH-160. The overall uncertainties are consistent with what EPA has obse rved for RH determinations at other RH TRU generator sites. Table 6-10 of CCP-RC-INL-631, Revision 0, provides an example of the TMU calculation for the Lot 8B drum.
There were no concerns regarding the technical adeq uacy and documentation of TMU for the Lot 8B waste.
Summary of Radiological Characterization Findings a nd Concerns
EPA did not identify any radiological characterizat ion-related findings or concerns relative to the addition of Waste Stream ID-TRA-W345-RH during this T1 change evaluation.15

Radiological Characterization Approval
Based on the results of this evaluation, EPA approv es the addition of Waste Stream ID-TRAW345-RH and finds that all requirements have been m et. 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 sub sequent T1 evaluations or addition of containers to an approved waste stream that require s changing the established radionuclide scaling factors remains a T1 change. T1 and T2 chan ges 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 findin gs or concerns relative to the addition of Waste Stream ID-TRA-W345-RH during this T1 change e valuation.

8.0 CONCLUSIONS
Changes to Tiering
As a result of this evaluation, EPA did not make an y changes to the INL-CCP RH T1 and T2 designations that were established during the basel ine approval and modified during subsequent T1 evaluations and continued compliance inspections . The tiering designations presented in Table 2 of the final report for EPA’s 2014 continue d compliance inspection of INL-CCP (see EPA Docket No. A-98-49; II-A4-190; July 15, 2014) remai n in effect and are listed as applicable in sections 6.1 and 6.2.
Approval
EPA’s evaluation of programmatic elements during EP A’s May 2014 Continued Compliance inspection of IN-CCP TRU waste characterization pro gram supplementing this evaluation of specific elements, EPA concluded that the AK waste characterization process and radiological characterization approach used to characterize RH T RU Waste Stream ID-TRA-W345-RH are adequate, as evidenced by the records evaluated. Th ere are no open issues relative to this T1 evaluation.
Based on the results of this evaluation, EPA approv es this T1 change to add Waste Stream IDTRA-W345-RH, consistent with the limitations specif ied in this report. INL-CCP may continue to characterize previously approved RH TRU waste co nsistent with the restrictions specified with the approvals listed in Appendix A to this rep ort.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 Febru ary 12, 2007 A-98-49; II-A4-80 T1 Change – Approval of K Cell Wastes January 1, 20 08 A-98-49; II-A4-97 T1 Change – Approval of High-Range Gamma Probe for DTC April 11, 2008 A-98-49; II-A4-98 T1 Change – Approval of Visual Examination Technique September 22, 2009 A-98-49; II-A4-118 T1 Change – Addition of Twelve Containers to Waste Stream ID-ANLE-S5000 and Addition of Waste Stream ID-HFEF-S5400-RH February 1, 2010 A-98-49; II-A4-122

T1 Change – Approval of Waste Stream ID-MFC-S5400-RH June 8, 2010 A-98-49; II-A4-126 T1 Change – Approval of Waste Stream ID-INTEC-S5400-RH August 17, 2010 A-98-49; II-A4-130 T1 Change – Addition of Lot 1B to Waste Stream ID-HFEF-S5400-RH August 23, 2010 A-98-49; II-A4-131 T1 Change – Approval of Waste Stream IN-ID-NRF-153 November 1, 2010 A-98-49; II-A4-135 T1 Change – Approval of Waste Stream ID-RTC-S3000 November 1, 2010 A-98-49; II-A4-137
2010 Continued Compliance Inspection March 16, 2011 A-98-49; II-A4-142 T1 Change – Addition of Lot 4A to Waste Stream ID-HFEF-S5400-RH March 23, 2011 A-98-49; II-A4-145 T1 Change – Approval of Waste Stream IN-ID-NRF-SPC March 12, 2012 A-98-49; II-A4-159 T1 Change – Addition of Lot 2 to Waste Stream ID-ANLE-S5000 July 25, 2012 A-98-49; II-A4-163

2013 Continued Compliance Inspection July 16, 2013 A-98-49; II-A4-175T1 Change – Approval of Waste Stream ID-EBRS5000 April 16, 2014 A-98-49; II-A4-183 T1 Change – Addition of Lot 5C to Waste Stream ID-HFEF-S5400-RH July 15, 2014 A-98-49; II-A4-185T1 Change – Approval of Waste Stream ID-MFCSOLID-RH September 10, 2014 A-98-49; II-A4-188

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

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUAT ION
CCP-AK-INL-630, Central Characterization Program Ac ceptable Knowledge Summary Report for Remote-Handled Transuranic Debris from Test Rea ctor Area at the Idaho National Laboratory, Waste Stream: ID-TRA-W345-RH, Revision 0, July 25, 2013
CCP-RC-INL-631, Central Characterization Program Re mote-Handled Transuranic Radiological Characterization Technical Report for Remote-Handle d Transuranic Debris Waste from Test Reactor Area at the Idaho National Laboratory, Wast e Stream: ID-TRA-W345-RH, Revision 0, May 7, 2014
CCP-CP-INL-632, Central Characterization Program RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance for Remote-Handled Trans uranic Debris Waste from Test Reactor Area at the Idaho National Laboratory, Waste Stream : ID-TRA-W345-RH, Revision 0, November 7, 2013
CCP-CN-INL-635, Central Characterization Program So urce Material Inventory Confirmation Test Plan for Remote-Handled Transuranic Debris Was te from Test Reactor Area at the Idaho National Laboratory Waste Stream: ID-TRA-W345-RH, R evision 0, October 29, 2013
P5054, Defense-Related Waste Determination for Lega cy Transuranic Waste at the ldaho National Laboratory Test Reactor Area Warm and Hot Waste Systems, Idaho Completion Project, ICP/EXT-04-00729, Revision 0, April 2005
P5071, National Reactor Testing Station, U. S. Atom ic Energy Commission, July 1967
P5197, Proving the Principle, Susan M. Stacy, DOE/I D-10799, 2000
P5235, A Comprehensive Inventory of Radiological an d Nonradiological Contaminants in Waste Buried in the Subsurface Disposal Area of the INEL RWMC During the Years 1952–1983, Idaho National Engineering laboratory, EGG-WM-10903 and INEL-95/0310, Revision 0 and Revision 1, June 1994 and August 1995
U4055, Waste Determination and Disposition Form, IN TECT-052-09, 5919N, date not given
U4056, Integrated Waste Tracking System Container P rofile, Container No. 10087564, not dated
U7001, Additional RH Drum Characterization Informat ion Discussion, date unknown