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 PROGRAM 

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 2014
i 

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 Diagram for Waste Stream ID-TRA-W345-RH . 10

Figure 2. Outline of Confirmation Test Plan ................................................................................ 12

ATTACHMENTS 

Attachment A: Approval Summary for INL-CCP RH Waste Characterization Program 

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

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 Center 

m meter 

MCNP5 Monte Carlo N-Particle Transport Code RSICC Computer 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 Plant
4 

1.0 INTRODUCTION 

This report supports the U.S. Environmental Protection 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 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)1 to characterize RH TRU waste at INL. Using the EPAapproved waste characterization processes discussed in this report, INL-CCP may characterize 

Waste Stream ID-TRA-W345-RH debris waste for disposal 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 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 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 scope of this T1 evaluation to the components 

of acceptable knowledge (AK) and radiological characterization 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 desktop review of this change in June–October 

2014. 

EPA did not identify any findings or concerns during this evaluation. Attachment B is a list of all 

documentation reviewed, including batch data reports (BDRs) and calculation packages. 

As a result of this evaluation, EPA did not make any changes to the INL-CCP RH T1 and Tier 2 

(T2) designations established following the baseline approval and modified subsequently as 

needed as a result of EPA’s approval of previous INL-CCP RH T1 change requests and EPA’s 

annual continued compliance inspections. The tiering designations presented in Table 2 of the 

final report for EPA’s 2014 continued compliance inspection 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 that INL-CCP used the EPA-approved 

system of controls to characterize the single container in Waste Stream ID-TRA-W345-RH. This 

single container of TRU waste in Lot 8B is the subject of this T1 report, but EPA’s approval also 

includes any additional drums that might be added to Waste Stream ID-TRA-W345-RH in the 

future, provided they are characterized using the processes 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 through 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 for this evaluation. 
5 

WIPPNEWS list, in accordance with Title 40 of the Code of Federal Regulations [40 CFR 

194.8(b)(3)]. 

2.0 PURPOSE OF TIER 1 EVALUATIONS 

Certain changes to the waste characterization 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. 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation of a T1 change to add Waste Stream IDTRA-W345-RH to the EPA-approved waste characterization program. This report presents the 

technical basis for and results of EPA’s approval decision. EPA’s approval of the addition of 

Waste Stream ID-TRA-W345-RH has been conveyed to DOE separately by letter. EPA will also 

announce the decision on its website at www.epa.gov/radiation/wipp, in accordance with 40 CFR 

194.8(b)(3). 

Any of the T1 change request-specific documents mentioned in this report can be requested from 

the following address: 

Manager, National TRU Sites and Transportation Division 

Carlsbad Field Office 

U.S. Department of Energy 

P O Box 3090 

Carlsbad, NM 88221-3090 
6 

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. Sections 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 personnel listed in Table 1 with their 

affiliations and functions. EPA relied primarily on reviews of documents and information 

provided by INL-CCP. When additional information or clarifications were needed, EPA had 

discussions with Irene Joo, the CCP RH Project Manager, who served as the point of contact for 

this T1 evaluation. 

Table 1. EPA Tier 1 Evaluation Team Members 

6.0 TECHNICAL EVALUATION 

Waste-Generating Activities and Waste Overview

Waste Stream ID-TRA-W345-RH consists of a single container of heterogeneous debris that was 

generated during the examination of cross section samples in the Alpha Laboratories at the Test 

Reactor Area (TRA; now known as the Advanced Test Reactor Complex). The debris is curium244 (244Cm) oxide source material, which this report refers to as “244Cm,” “244Cm oxide neutron 

sources,” “cross section samples” and “neutron cross 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 244Cm at the time of packaging. INL-CCP 

confirmed this initial inventory value and qualified the value for use in the radiological 

characterization program as documented in CCP-CN-INL-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 and concrete shielding in a 55-gallon drum, 

and overpacked the 55-gallon drum in an 85-gallon drum. 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 Technology 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 Knowledge, SC&A 

Rose Gogliotti Technical Evaluator – Radiological Characterization, SC&A 

Patrick Kelly Technical Evaluator – Radiological Characterization, SC&A 

Amir Mobasheran Technical Evaluator – Radiological Characterization, SC&A 
7 

Packaging Configuration 

The initial 85-gallon drum waste packaging described above is not the current packaging 

configuration for this drum. However, it is important because INL-CCP performed dose-to-curie 

(DTC) for AK confirmation on the drum in this configuration. Much of the documentation refers 

to the 85-gallon drum because INL originally thought it would be the final configuration. 

During repackaging, INL-CCP opened the pipe components and emptied their contents into a 

single 1-gallon can. The can and the empty pipe components are centered in a 30-gallon drum, 

which is overpacked into a 55-gallon drum. The 55-gallon 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 supported the addition of Waste Stream IDTRA-W345-RH. INL-CCP provided CCP-AK-INL-630, Revision 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 evaluation, including BDRs and calculation 

packages, are cited in different sections throughout the report and are listed in Attachment B. 

6.1 Acceptable Knowledge 

EPA examined INL-CCP’s programmatic requirements, the AK process and associated 

information during the continued compliance inspection 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 characterization; the processes of AK 

compilation, AK verification, AK accuracy assessment and AK discrepancy resolution; 

completion and adequacy of required forms and reports; and the INL-CCP waste stream 

certification process. Therefore, EPA limited the scope 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 elements listed below. 

• Waste stream definition, including waste generation and 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).
8 

Technical Evaluation 

EPA evaluated the adequacy of AK information specific to Waste Stream ID-TRA-W345-RH, as 

described in the AK Summary Report (AKSR) (CCP-AK-INL-630, Revision 0) and associated 

source documents. 

(1) EPA examined the waste stream determination for Waste 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 radiological properties. As described in the overview 

portion of section 6.0, above, INL generated the debris waste in Waste Stream ID-TRA-W345-

RH during examination of 244Cm oxide to study neutron cross sections at the TRA Alpha 

Laboratory in 1973. The waste contained 1,112 Ci of 244Cm 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 of waste generation process and 

physical/radiological waste characteristics is adequately demonstrated. 

(2) EPA examined the waste stream information that supports the absence of spent nuclear 

fuel or high-level waste in this waste stream and found 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 244Cm oxide neutron sources at the TRA 

Alpha Laboratory. The operations related to 244Cm 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 waste stream is defense in origin and 

found it to be adequate. 

AK indicates that the cross-section samples discussed above originated from the Materials Test 

Reactor at TRA, the Experimental Breeder Reactor (EBR) – 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, DOE assumes that Waste Stream ID-TRAW345-RH is commingled with other radioactive samples 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 Concerns

The EPA evaluation team did not identify any AK-related 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 approves the addition of Waste Stream ID-TRAW345-RH and finds that all requirements have been met. 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 EPA initiated during previous approvals remain in effect. 

6.2 Radiological Characterization 

EPA examined INL-CCP’s programmatic requirements, the DTC process and associated 

information during the continued compliance inspection 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 measurement control program for RH TRU 

instruments for radiological characterization and the INL-CCP RH TRU procedures and 

technical documents for the same. Therefore, EPA limited the scope 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 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 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 confirmatory testing approach, using MCNP5 modeling and neutron DTC 

measurements. 

• Calculation of the radionuclide content of associated radionuclides. 

• RH and TRU determination. 

• 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-TRA-W345-RH, as described in the Radiological Characterization Technical Report 

(CCP-RC-INL-631, Revision 0) and calculation packages. 
10 

(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-TRA-W345-RH uses a neutronbased DTC method to confirm the 244Cm 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-W345-RH was technically adequate and 

appropriately documented. There were no concerns regarding the overall radiological 

characterization process and its documentation. 

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 IDTRA-W345-RH that requires a radiological characterization 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 Diagram 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 244Cm content from 

time of packaging 

Apply the AK radionuclide 

distributions to the calculated 

244Cm mass at date of 

manufacture 

Develop Confirmation Test 

Plan to qualify 244Cm 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 244Cm 

source material to assumed 

date of manufacture 
11 

(2) EPA found the confirmatory testing approach to be technically adequate and 

appropriately documented. 

The loading records from AK indicate that 1,112 Ci of 244Cm were packaged into the Lot 8B 

drum on June 25, 1973. This value was reported prior to the implementation of Section 5.3 of 

DOE/WIPP-02-3214, the Remote-Handled Waste Characterization 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 methods, to quantify the drum’s 244Cm content at 

the time of loading. 

INL-CCP developed a confirmation test plan (CTP), CCP-CN-INL-635, and EPA prepared a 

flow diagram to reflect this process, shown in Figure 2, below. The CTP outlines a neutron-based 

DTC approach where neutron dose2

 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 244Cm content. The DTC approach is discussed 

in additional detail in Item (3), below. 

Although not part of the CTP, INL-CCP determined that 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 each. Using MCNP5, INL-CCP estimated 

the 244Cm content of each component, the values were decay corrected3 and summed for 

comparison to the drum loading and DTC records. These steps are shown in Figure 2 as dashed 

lines because they were not included in the original testing plan. 

The CTP specifies that the DTC-derived 244Cm content would be corrected to the date of the 

initial drum loading, and the corrected value would be compared to the initial AK 244Cm 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 measurement 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 quadrature4 to derive the acceptance criterion of 32%. 

 

2 Rem or millirem is a unit of dose equivalent, which is often 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, and the terms R and rem are used interchangably.

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

3

 The decay correction is a calculation to determine the drum’s 244Cm 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 

244Cm content prior to decay over the time period from 1971 until the present. For purposes of this report, the term 

decay correction refers to the calculation of the drum’s 244Cm activity in 1971, by applying the appropriate decay 

kinetics to the drum’s current 244Cm value. 

4

 Adding in quadrature is a standard statistical technique that allows one to combine the square root of the 

sum of each value squared, resulting in a lower value than what would be obtained if the values were simply 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 measurements 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 244Cm 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 technically 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 244Cm value, the 244Cm activity 

in the disposal record is considered 

qualified

Compare neutron-based DTC values to 

the 244Cm value in the AK

Dashed lines indicate steps added to the original confirmation testing plan due to the repackaging process.

Apply DTC coefficient to 

each pipe component

Decay correct the DTC 

predicted activity within each 

component; then sum the 

components
13 

(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-CCP RH TRU waste streams characterized 

using the DTC method in that 244Cm is a neutron-emitting radionuclide. Typically, the DTC 

approach measures the gamma radiation associated with 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 measurements 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 MCNP5 to derive neutron-based DTC 

coefficients. The first and second models assumed measurements of an 85-gallon drum 

containing the 244Cm source material, steel pipe, concrete annulus and a 55-gallon drum at 

distances of 30-cm and 100-cm from the 85-gallon drum’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 grams per cubic centimeter (g/cc)] and its 

contents were assumed to be lead (11.35 g/cc). Modeling 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. Additionally, 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 corrected to the date of the disposal record. The 

decay-corrected pipe components were summed to estimate the total 244Cm content at packaging. 

The pipe components, 30-cm average 244Cm and 100-cm average 244Cm 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 associated radionuclides and found them to 

be adequate. 

INL-CCP retrieved an Aerojet Nuclear Company Progress Report dated October 1971 from AK 

which gave the radionuclide distributions in the 244Cm source material for three samples as 

shown in Table 4-1, of CCP-RC-INL-631. The radionuclide content of the 244Cm was calculated 

using the average distraction from these samples. The 244Cm activity at the date of disposal was 

then decay corrected to the assumed date of manufacture, January 15, 1968, resulting in a 

calculated activity of 1,272 Ci. The mass of 244Cm at the date of manufacture was then estimated 

using the specific activity of 81.8 Ci/g. INL-CCP applied the estimated radionuclide distribution 

to the sample and decay corrected all values to a reference date of December 30, 2013. These 

values are reported on the Waste Container Radiological 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 met the 200 mRem/hr criterion for RH 

waste. There were no concerns regarding the RH determination for the Lot 8B waste. 

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

Attachment 1 to CCP-RC-INL-631, Revision 0, contains revised Waste Container Radiological 

Characterization Records for Drum No. 10087564C. The 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 (TMU) for Waste Stream ID-TRA-W345-RH 

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. The TMU determination included contributions of the following: 

• Uncertainty in manufacture date – Assumes an earlier date of manufacture 

• Uncertainties in sample data – Based on the variability of samples used in the cross 

section measurements 

• Uncertainties in reported quantity of 244Cm – 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 provided in INL-RH-160. 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-631, Revision 0, provides an example of the 

TMU calculation for the Lot 8B drum. 

There were no concerns regarding the technical adequacy and documentation of TMU for the Lot 

8B waste. 

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-TRA-W345-RH during this T1 change evaluation. 
15 

Radiological Characterization Approval

Based on the results of this evaluation, EPA approves the addition of Waste Stream ID-TRAW345-RH 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. 

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-TRA-W345-RH 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 2 of the final report for EPA’s 2014 continued compliance inspection 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. 

Approval 

EPA’s evaluation of programmatic elements during EPA’s May 2014 Continued Compliance 

inspection of IN-CCP TRU waste characterization program supplementing this evaluation of 

specific elements, EPA concluded that the AK waste characterization process and radiological 

characterization approach used to characterize RH TRU Waste Stream ID-TRA-W345-RH 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 IDTRA-W345-RH, 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 Appendix A to this report. 
A-1

ATTACHMENT A 

APPROVAL SUMMARY FOR INL-CCP REMOTE-HANDLED WASTE 

CHARACTERIZATION PROGRAM 

Approved Activity EPA Inspection Number, 

Approval Dates EPA Docket Number 

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

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

T1 Change – Approval of WIPP Waste Information 

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

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

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

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

T1 Change – Approval of High-Range Gamma Probe 

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

T1 Change – Approval of Visual Examination 

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

T1 Change – Addition of Twelve Containers to Waste 

Stream ID-ANLE-S5000 and Addition of Waste 

Stream ID-HFEF-S5400-RH 

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Addition of Lot 1B to Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

2010 Continued Compliance Inspection March 16, 2011 A-98-49; II-A4-142 

T1 Change – Addition of Lot 4A to Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Addition of Lot 2 to Waste Stream 

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

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

T1 Change – Approval of Waste Stream ID-EBRS5000 April 16, 2014 A-98-49; II-A4-183 

T1 Change – Addition of Lot 5C to Waste Stream 

ID-HFEF-S5400-RH July 15, 2014 A-98-49; II-A4-185 

T1 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-A4-190 
B-1

ATTACHMENT B 

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION 

CCP-AK-INL-630, Central Characterization Program Acceptable Knowledge Summary Report 

for Remote-Handled Transuranic Debris from Test Reactor Area at the Idaho National 

Laboratory, Waste Stream: ID-TRA-W345-RH, Revision 0, July 25, 2013 

CCP-RC-INL-631, Central Characterization Program Remote-Handled Transuranic Radiological 

Characterization Technical Report for Remote-Handled Transuranic Debris Waste from Test 

Reactor Area at the Idaho National Laboratory, Waste 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 Transuranic 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 Source Material Inventory Confirmation 

Test Plan for Remote-Handled Transuranic Debris Waste from Test Reactor Area at the Idaho 

National Laboratory Waste Stream: ID-TRA-W345-RH, Revision 0, October 29, 2013 

P5054, Defense-Related Waste Determination for Legacy 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. Atomic Energy Commission, July 1967 

P5197, Proving the Principle, Susan M. Stacy, DOE/ID-10799, 2000 

P5235, A Comprehensive Inventory of Radiological and 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, INTECT-052-09, 5919N, date not given 

U4056, Integrated Waste Tracking System Container Profile, Container No. 10087564, not dated 

U7001, Additional RH Drum Characterization Information Discussion, date unknown