DOCKET NO: A-98-49; II-A4-178 

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT: 

ADDITION OF CONTACT-HANDLED TRANSURANIC WASTE TO THE ADVANCED 

MIXED WASTE TREATMENT PROJECT APPROVED PROGRAM: 

LOS ALAMOS NATIONAL LABORATORY DEBRIS WASTE 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

September 2013
ii 

TABLE OF CONTENTS 

Section Page

Abbreviations and Acronyms ........................................................................................................ iii

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

2.0 Purpose of Tier 1 Evaluations ..............................................................................................5

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

4.0 Scope of This Tier 1 Evaluation ..........................................................................................6

5.0 Tier 1 Evaluation Personnel .................................................................................................6

6.0 Technical Evaluation of Acceptable Knowledge and Load Management ...........................6

6.1 Waste-Generating Activities ....................................................................................6

6.2 Documents Provided ................................................................................................7

6.3 Waste Characterization Element Description ..........................................................7

6.4 Technical Evaluation ...............................................................................................8

7.0 Findings and Concerns .......................................................................................................13

8.0 Conclusions ........................................................................................................................13

LIST OF TABLES 

Table 1. Tiering of CH TRU Waste Characterization Processes Implemented by AMWTP ........ 4

Table 2. Tier 1 Evaluation Personnel ............................................................................................. 6

ATTACHMENTS 

Attachment A: Approval Summary for Advanced Mixed Waste Treatment Project 

Contact-Handled Waste Characterization Program 

Attachment B: List of Documents Cited by EPA during the T1 Evaluation 
iii 

ABBREVIATIONS AND ACRONYMS

AK acceptable knowledge 

AKSR acceptable knowledge summary report 

AMWTP Advanced Mixed Waste Treatment Project 

ANLE Argonne National Laboratory-East 

BDR batch data report 

CBFO Carlsbad Field Office 

CCP Central Characterization Program 

CFR Code of Federal Regulations 

CH contact-handled 

CIS characterization information summary 

CMR Chemistry and Metallurgy Research 

D&D decontamination and decommissioning 

DOE U.S. Department of Energy 

DP Delta Prime 

DU depleted uranium 

EPA U.S. Environmental Protection Agency 

EU enriched uranium 

HLW high-level waste 

ID Idaho 

IDC item description code 

INL Idaho National Laboratory 

ITG Idaho Treatment Group, LLC 

LANL Los Alamos National Laboratory 

LWA Land Withdrawal Act, as amended 
iv 

MFC Materials and Fuels Complex 

nCi/g nanocuries per gram 

NDA nondestructive assay 

NDE nondestructive examination 

NWPA Nuclear Waste Policy Act of 1982 

Pu plutonium 

R&D research and development 

RFP Rocky Flats Plant 

SCG summary category group 

SDA Subsurface Disposal Area 

SNF spent nuclear fuel 

T1 Tier 1 

T2 Tier 2 

TA technical area 

TRU transuranic 

U uranium 

WAC waste acceptance criteria 

WAP waste analysis plan 

WIPP Waste Isolation Pilot Plant 

WMC waste matrix code 

WMP waste material parameter 

WSPF waste stream profile form 
1 

1.0 INTRODUCTION 

This report supports the U.S. Environmental Protection Agency’s (EPA’s) approval of the 

proposed Tier 1 (T1) change to the EPA-approved transuranic (TRU) waste characterization 

program at the U.S. Department of Energy’s (DOE’s) Advanced Mixed Waste Treatment Project 

(AMWTP) at the Idaho National Laboratory (INL). This approval allows AMWTP to 

characterize contact-handled (CH) debris [Summary Category Group (SCG) S5000] waste from 

the Los Alamos National Laboratory (LANL) for addition to AMWTP’s EPA-approved waste 

characterization program1

 for emplacement 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-AMWTP-03.06-8 of the waste characterization program 

at AMWTP on March 28–30 and April 11–13, 2006. EPA’s October 2006 baseline approval 

applied to (a) CH retrievably-stored SCG S3000 and SCG S5000 waste and (b) newly-generated 

SCG S5000 CH waste. The AMWTP baseline final inspection report (see EPA Docket No. A98-49; II-A4-66, dated October 2006) documents EPA’s approval of the acceptable knowledge 

(AK) and load management processes and several nondestructive assay (NDA) and 

nondestructive examination (NDE) systems for characterizing CH retrievably-stored SCG S3000 

and SCG S5000 waste and newly-generated SCG S5000 waste. The baseline report defined 

inclusion of wastes from sources other than Mound Site, Rocky Flats Environmental Technology 

Site [or Rocky Flats Plant (RFP)], Battelle Columbus Laboratories, and Bettis Atomic Power 

Laboratory (hereafter referred to as “Bettis”) as an AK T1 change that requires EPA approval 

before implementation. Wastes from the DOE sites listed above were specifically evaluated as 

part of the baseline inspection. 

EPA conducted a phased continued compliance inspection of AMWTP in October–November 

2012 and February 2013, concluding in April 2013 that the Idaho Treatment Group (ITG) has 

successfully implemented the CH TRU waste characterization processes, procedures and 

equipment at AMWTP that EPA approved in the October 2006 baseline approval and in 

subsequent tiering changes listed in Attachment A. 

One of the differences between AMWTP and the other DOE facilities is that a single contractor 

is responsible for both waste handling operations and WIPP waste characterization operations at 

AMWTP. Specifically, ITG is responsible for all operations at AMWTP, whereas CCP is 

responsible for the WIPP waste characterization at LANL but not the waste management 

operations. Therefore, while there is a significant difference between the entity represented by 

“LANL” and the entity represented by “LANL-CCP,” the terms “AMWTP” and “AMWTP-ITG” 

refer to the same entity and only “AMWTP” is used in this report. 

 

1

 AMWTP’s EPA-approved waste characterization program includes the supercompaction and the directship processes. AMWTP indicated that the LANL-generated CH debris waste will be added to supercompacted 

Waste Stream BN510.2. However, as AMWTP processes and characterizes approved feedstock waste for 

supercompaction, the new supercompacted waste stream will be designated as Waste Stream BN510.3, BN510.4, 

etc., and AWMTP will inactivate the previous BN510 designation. AMWTP may add EPA-approved LANLgenerated CH debris waste to the EPA-approved supercompacted-waste characterization program, including all 

iterations of the supercompacted Waste Stream BN510.X. See section 6.4, Item (2), for additional information. 
2 

On May 30, 2013, the Carlsbad Field Office (CBFO) requested EPA’s approval of the addition 

of LANL CH debris waste to the AMWTP’s EPA-approved supercompacted-waste 

characterization program as a T1 change. EPA limited the scope of this review to the AK and 

load management processes. The review was necessary to determine whether AMWTP’s AK 

documentation and records adequately include and cross-reference available historical waste 

generation and disposal records supporting inclusion of LANL debris waste. EPA’s approval is 

limited to CH debris waste generated by LANL that was initially included in a WIPP-approved 

LANL debris waste stream as documented by the Central Characterization Program (CCP) at 

LANL in a CBFO-approved AK summary report (AKSR) and a CBFO-approved Waste Stream 

Profile Form (WSPF). AMWTP will characterize these containers and incorporate them in the 

active supercompacted waste stream for WIPP emplacement. Some of the LANL-generated 

debris containers may be direct-shipped to WIPP upon characterization by AMWTP. EPA did 

not identify any findings or concerns during this review. Based on this evaluation, EPA approves 

the addition of LANL-generated debris CH waste to AMWTP’s EPA-approved program. 

This evaluation did not consider the following waste characterization activities: 

• Use of EPA-approved NDA and NDE processes to characterize these wastes. Upon 

completing NDA and NDE batch data reports (BDRs) for these waste containers, 

AMWTP must provide a few representative BDRs along with the quarterly submission of 

Tier 2 (T2) changes. EPA has required submission of NDA and NDE BDRs for those CH 

TRU wastes EPA approved as a T1 since the baseline approval of October 2006. 

• AK procedural adequacy, AMWTP procedural compliance, or drum or data traceability. 

EPA evaluated these elements as part of AMWTP’s continued compliance evaluation, 

which occurred on October 30–November 1, 2012. (See EPA Docket No. A-98-49; IIA4-173.) 

EPA reviewed several reports supporting addition of LANL CH debris waste to AMWTP’s 

EPA-approved program [section 6.4, Item (1)] in draft form. EPA expects final versions of the 

following documents containing accurate information about the LANL CH debris waste to be 

submitted to EPA prior to shipment of any of the LANL-generated waste to WIPP: 

• RPT-TRUW-05, “Waste Matrix Code Reference Manual.” 

• RPT-TRUW-07, “Determination of Radioisotopic Content in TRU Waste Based on 

Acceptable Knowledge.” 

• RPT-TRUW-12, “AMWTP Waste Stream Designations.” 

Based on this evaluation, there is one substantive change to the AK T1 designations: LANL 

debris waste from WIPP-certified LANL-CCP waste streams as defined in RPT-TRUW-93, 

“Acceptable Knowledge Document for Los Alamos National Laboratory Debris Waste,” has 

been added to the list of approved waste sources. There are no substantive changes to the AK T2 

designations. EPA made one substantive change to harmonize the NDA T1 designations with all 

other EPA approved sites to clarify that recalibration of EPA-approved NDA equipment is a T1 

change, due to the fundamental importance of this process. Table 1 shows the substantive T1 

changes in bold text. T1 and T2 changes that were initiated during the baseline approval remain 
3 

in effect. The language in Table 1 regarding AK documentation applies to all AMWTP waste 

streams, including load-managed and direct-shipped waste streams. 

This approval allows AMWTP to characterize the physical and radiological contents of LANL 

CH debris waste containers from WIPP-certified LANL-CCP waste streams using the 

equipment, processes and procedures that EPA approved as part of the baseline approval (see 

EPA Docket No A-98-49; II-A4-66, October 3, 2006) and verified during the continued 

compliance inspection of October–November 2012 and February 2013 (see EPA Docket No A98-49; II-A4-173, April 25, 2013). When available, AMWTP must provide representative NDA 

and NDE BDRs for direct-shipped or supercompacted LANL CH debris waste to EPA for review 

along with AMWTP’s quarterly T2 change submission. 

This report serves as EPA’s public notification of the approval of this T1 change. This 

information will be provided through the EPA website and by sending emails to the WIPPNEWS 

list, in accordance with 40 CFR 194.8(b)(3).
4

Table 1. Tiering of CH TRU Waste Characterization Processes Implemented by AMWT

(Based on March 28–30 and April 11–13, 2006, Baseline Inspection and Subsequent T1 Evaluations, Upda

Process Elements AMWTP CH Waste Characterization Processes – T1 Changes AMWTP CH Waste Characterizatio

Acceptable Knowledge, 

including Load Management 

Any new waste category Any waste from sources other than the Mound Site, Rocky Flats 

Environmental Technology Site, Battelle Columbus Laboratories, 

Bettis Atomic Power Laboratory, Argonne National Laboratory-East, the Materials and Fuels Complex, pre-1980 INLexhumed Subsurface Disposal Area waste, and Los Alamos 

National Laboratory debris. 

Load management of any new or unapproved waste stream 

Notification to EPA upon completion of or 

• Implementation of procedures and relat

NDA-AK communication requirements

• AK accuracy reports (annually, at a min

• All final WSPFs with related attachmen

additions to waste streams within approradiological data for those containers in

• New and revised AKSRs and generator

RPT-TRUW-79, RPT-TRUW-89, RPT

• Item description code inclusion memora

• The load management status of approve

• Site procedures requiring CBFO approv

• Any waste identified outside of the was

Transuranic Waste Baseline Inventory R

• RPT-TRUW-05, RPT-TRUW-07 and R

Nondestructive Assay New equipment or substantive physical modifications to EPAapproved equipment** 

Extension of or changes to the approved calibration range for EPAapproved equipment, including recalibration of EPA-approved 

equipment

Notification to EPA upon substantive modi

• Site procedures requiring CBFO approv

• Software for approved equipment 

• Operating ranges upon CBFO approval 

Real-Time Radiography None Notification to EPA upon: 

• Substantive modification** to site proc

• New equipment or substantive physical 

approved equipment 

Visual Examination and Visual Examination Technique 

Changes in the vendor performing visual examination or visual 

examination technique 

Notification to EPA upon: 

• Substantive modification** to site proc

• Addition of a new waste category • Addition of a new procedure or site equ

WIPP Waste Data System Changes to Waste Data System algorithms specific to load 

management 

Notification to EPA upon substantive modi

• Site procedures requiring CBFO approv

New T1s, T2s and significant modifications to existing T1s or T2s are in bold text; T1s or T2s that were only revised for style are not shown in 

* AMWTP will report all T2 changes to EPA every three months. ** “Substantive modification” refers to a change with the potential to affect AMWTP’s CH waste characterization processes or documentatio

are solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act; or that are editori

address administrative concerns. EPA may request copies of new references that DOE adds during a document revision. 
5 

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 and incorporated into the AMWTP CH baseline final 

report (see EPA Docket No. A-98-49; II-A4-66). 

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 

evaluations 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. When evaluating proposed T1 

changes for approval, EPA may conduct a site evaluation 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. EPA reviews T2 changes on a quarterly basis and will conduct continued 

compliance inspections to evaluate implemented T2 changes to verify their adequacy. 

3.0 PURPOSE OF THIS REPORT 

This report presents the technical basis for and results of EPA’s evaluation of the addition of 

LANL CH TRU debris waste to AMWTP’s baseline approval as a T1 change. EPA’s approval of 

LANL debris waste for characterization for emplacement at the WIPP 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). 

DOE documents that EPA reviewed for this evaluation are cited in different sections throughout 

the report and are listed in Attachment B. 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 
6 

4.0 SCOPE OF THIS TIER 1 EVALUATION 

The scope of this T1 evaluation was the compilation of AK to support the addition of LANL CH 

debris waste to the AMWTP baseline approval as a T1 change. EPA, therefore, limited the scope 

of this review to the AK and load management processes to determine whether AMWTP’s AK 

document for LANL-generated waste (RPT-TRUW-93) and compiled records are sufficient to 

support inclusion of the LANL debris waste in the EPA-approved program for supercompacted 

CH debris waste. This evaluation does not address the characterization of physical and 

radiological contents by AMWTP which will occur following the EPA approval of the subject 

T1 change request. This evaluation also did not address AK, NDA and NDE procedural 

adequacy; AMWTP procedural compliance; and NDA and NDE equipment because EPA 

evaluated these elements during its continued compliance evaluation of AMWTP on October 30–

November 1, 2012, and February 26, 2013 (EPA Docket No. A-98-49; II-A4-173). 

5.0 TIER 1 EVALUATION PERSONNEL 

EPA and its support personnel conducted interviews with AMWTP personnel by telephone. 

Table 2 lists the EPA evaluation team members and the AMWTP personnel contacted, with their 

affiliations and functions. This list includes personnel present during teleconferences conducted 

as part of this evaluation. 

Table 2. Tier 1 Evaluation Personnel 

6.0 TECHNICAL EVALUATION OF ACCEPTABLE KNOWLEDGE AND LOAD 

MANAGEMENT 

6.1 Waste-Generating Activities 

LANL-CCP has been characterizing CH TRU debris waste using EPA-approved characterization 

processes since 2007. Due to commitments with the state of New Mexico and recent budgetary 

constraints, CBFO has determined that the most efficient way to characterize LANL CH debris 

waste for emplacement at WIPP is to send a portion of the waste to AMWTP for 

supercompaction and incorporation in the BN510.2 supercompacted waste stream or for direct 

shipment. All waste subject to this T1 review originated at LANL and will be shipped to 

AMWTP in compliance with the AMWTP offsite waste acceptance criteria. The waste will be 

boxed prior to shipment to AMWTP and will not be unpacked prior to processing in the 

AMWTP boxlines. 

The initial shipments from LANL-CCP to AMWTP will include waste from four WIPPapproved CH debris waste streams: 

Name Affiliation & Function 

Rajani Joglekar Lead Inspector, EPA 

Kira Darlow Technical Evaluator – Acceptable Knowledge, SC&A 

Steve Carpenter Acceptable Knowledge Expert, ITG 

George Byram TRU Programs Manager, ITG 

Jerry Wells Observer, DOE/ID 

Marcus Pinzel Observer, DOE/CBFO 
7 

• LA-MHD01.001: mixed heterogeneous debris from Technical Area (TA)-55 (Plutonium 

Facility Building 4) plutonium (Pu) extraction and recovery research and development 

(R&D)/fabrication and associated recovery, facility and equipment maintenance, 

decontamination and decommissioning (D&D), waste repackaging and below-grade 

retrieval operations; generated 1978–present (References P1839A and Reference Set 

P1988A: References D025 and D041 for LANL-CCP AKSR CCP-AK-LANL-006). 

• LA-MHD03.001: mixed heterogeneous debris from TA-3 [Chemistry and Metallurgy 

Research (CMR)] chemical and metallurgical research and associated analytical 

chemistry, hot cell and maintenance operations that primarily support Pu recovery and 

processing at TA-55 and its predecessor TA-21, as well as repackaging operations; 

generated 1971–present (Reference P1840A). 

• LA-MHD04.001: heterogeneous debris from the TA-21 [Delta Prime (DP) West Facility] 

Pu processing and associated operations (e.g., D&D); TA-21 was the predecessor to TA55; generated October 1971–September 2011 (References P1841A and Reference Set 

P1988A: Reference D059 for LANL-CCP AKSR CCP-AK-LANL-010). 

• LA-MHD09.001: heterogeneous debris waste from TA-50 (radioactive waste treatment) 

waste treatment and associated facility and equipment maintenance, D&D and waste 

repackaging operations; generated November 1977–present (Reference P1842A). 

6.2 Documents Provided 

EPA evaluated the AMWTP documentation that supported inclusion of the LANL CH debris 

waste in AMWTP’s approved characterization program. Attachment B lists all documentation 

cited in this report. 

6.3 Waste Characterization Element Description 

EPA limited the scope of the T1 review to the following elements related to the use of AK for 

CH waste characterization: 

• Waste identification and description, including radiological and physical characteristics, 

and verification that the subject debris waste is suitable for inclusion in supercompacted 

Waste Stream BN510.2.2

• Sufficiency of AK reports, including integration of source documents. 

• Verification that the subject waste is of defense origin and is not high-level waste (HLW) 

or spent nuclear fuel (SNF). 

• Load management. 

 

2

 AMWTP intends to incorporate the LANL debris waste into supercompacted debris Waste Stream 

BN510.2 [see Item (1)] for shipment to the WIPP facility. 
8 

6.4 Technical Evaluation 

(1) The acceptable knowledge reports and related documentation were assessed and found to 

be adequate. 

AMWTP prepares multiple documents that together summarize the available information for 

LANL CH TRU debris waste. As stated in procedure MP-TRUW-8.13, Revision 24,3 AMWTP’s 

AK characterization process begins with development of generator-site-specific AK documents. 

In the case of this T1 request, AMWTP prepared one AK document: RPT-TRUW-93, Revision 

0. RPT-TRUW-93 includes a very short introduction to the LANL debris waste streams and the 

LANL-CCP AKSRs and WIPP-approved WSPFs, all reproduced in full. AMWTP physically 

incorporated the LANL-CCP source documents into the AMWTP AK record as compact discs 

containing electronic copies of all LANL-CCP-referenced sources. AMWTP assigned source 

document tracking numbers to the whole set of source documents: one tracking number for all 

controlled source documents [Unclassified Controlled Nuclear Information (UCNI)] and a 

second number for all unclassified source documents (Reference Sets P1987A and P1988A, 

respectively). Individual LANL-CCP source documents are identifiable in the AMWTP AK 

record first by the reference set (P1987A or P1988A), then by the LANL-CCP AKSR number, 

and finally by the LANL-CCP-assigned source document number. EPA finds this method of 

compiling the AK documents acceptable. 

According to procedure MP-TRUW-8.13, information from the generator-site-specific AK 

document is used to update other AMWTP summary reports. AMWTP provided the following 

reports to EPA as evidence of this process: 

• RPT-TRUW-05, Revision 32, “Waste Matrix Code Reference Manual.” 

• RPT-TRUW-06, Revision 14, “Acceptable Knowledge Baseline Document for AMWTP 

Waste.” 

• RPT-TRUW-07, draft Revision 19a, “Determination of Radioisotopic Content in TRU 

Waste Based on Acceptable Knowledge.” 

• RPT-TRUW-12, draft Revision 21, “AMWTP Waste Stream Designations.” 

• RPT-TRUW-83, Revision 3, “Acceptable Knowledge Summary for Supercompacted 

Debris Waste (BN510.1).” 

These reports and their supporting source documents contain the information required by the 

WIPP waste analysis plan4

 and WIPP waste acceptance criteria (WAC).5 AMWTP revised each 

document to address LANL CH debris waste, as discussed below. The waste stream definition 

 

3

 AMWTP, “Collection, Review, and Management of Acceptable Knowledge Documentation,” 

MP-TRUW-8.13, Revision 24, Idaho Falls, Idaho, December 12, 2011. 

4

 New Mexico Environment Department, “Waste Isolation Pilot Plant Hazardous Waste Facility Permit,” 

Waste Analysis Plan, Santa Fe, New Mexico, June 29, 2010. 

5

 U.S. DOE CBFO, “Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant,” 

DOE/WIPP-02-3122, Revision 7.2, Carlsbad, New Mexico, June 13, 2011. 
9 

and documentation of physical and radiological components are discussed in Item (2) below. The 

defense origin of the waste and the absence of SNF and HLW are discussed in Item (3) below. 

The WMC (waste matrix code) reference manual, RPT-TRUW-05, contains detailed information 

about the physical characteristics of all wastes handled by AMWTP, including low-level waste, 

listed by generator site item description code (IDC) and WMC. RPT-TRUW-05 includes 

information for all four waste streams identified in RPT-TRUW-93 and identifies the AMWTP 

IDC assigned to each waste stream. Waste Stream LA-MHD01.001 is assigned IDC LA-007; 

LA-MHD03.001 is assigned IDC LA-008; LA-MHD04.001 is assigned IDC LA-009; and, LAMHD09.001 is assigned IDC LA-010. EPA reviewed RPT-TRUW-05, Revision 32, and found 

that the report adequately summarized the information provided in the LANL-CCP AKSRs and 

WIPP-approved WSPFs but did not accurately cite the references for this information. AMWTP 

provided a statement that Revision 33 of RPT-TRUW-05 will include a corrected reference list 

and accurate citations. Notification to EPA upon the availability of a revised RPT-TRUW-05 

continues to be a T2 change (see Table 1). 

RPT-TRUW-07 presents radiological information for EPA-approved offsite waste generators 

(e.g., RFP, Mound Site, Battelle Columbus Laboratories, Bettis, the Hanford Site) and 

AMWTP’s supercompacted and newly-generated (not supercompacted) wastes. RPT-TRUW-07, 

Revision 19a, includes Chapter 11 and Appendix I that address LANL debris waste; AMWTP 

also revised parts of other sections of this document to include LANL waste, as necessary. The 

LANL radiological information presented in RPT-TRUW-07 is general and reflects AMWTP’s 

determination that the LANL CH debris originated from a wide variety of generators at LANL. 

EPA reviewed RPT-TRUW-07, Revision 19a, and found that the report adequately summarizes 

the information provided in the LANL-CCP AKSRs that are included as attachments to RPTTRUW-93, Revision 0. Notification to EPA upon the availability of a revised RPT-TRUW-07 

remains a T2 change (see Table 1). See Item (4) for additional information about payload 

management. 

RPT-TRUW-12 documents all TRU IDCs handled by AMWTP, identifies chemical constituents 

and documents hazardous waste number assignments for TRU IDCs that are characterized and 

certified by AMWTP. AMWTP updated RPT-TRUW-12 (to draft Revision 21) to include the 

chemical composition of each IDC for the LANL debris waste. RPT-TRUW-12, Revision 21, 

adequately addresses LANL debris waste. Notification to EPA upon the availability of a revised 

RPT-TRUW-12 continues to be a T2 change (see Table 1). 

Information about all AMWTP-generated waste, including supercompacted Waste Stream 

BN510.1, is presented in RPT-TRUW-06 (the AMWTP AK document). RPT-TRUW-83 (the 

Waste Stream BN510.1 AKSR) includes information about all feed material inputs to the 

supercompacted waste stream. EPA examined RPT-TRUW-06, Revision 14, and RPT-TRUW83, Revision 3, to ensure that the proposed T1 LANL waste fits within the definition of Waste 

Stream BN510.1. Notification to EPA upon the availability of a revised RPT-TRUW-06 or RPTTRUW-83 remains a T2 change (see Table 1). 
10 

(2) Information regarding the waste-generating processes and radiological and physical 

characteristics was evaluated to determine whether wastes were appropriately identified 

for inclusion in supercompacted Waste Stream BN510.2. EPA determined that the 

information was adequate for this purpose. 

AMWTP indicated that, before LANL-generated waste is used as feedstock, Waste Stream 

BN510.1 will cease and a new WSPF, “BN510.2,” will be developed to account for the addition 

of new hazardous waste numbers associated with Materials and Fuel Complex (MFC)-generated 

feedstock. The LANL debris feedstock will be incorporated as a change notice into Waste 

Stream BN510.2 [or possibly Waste Stream BN510.3 if the pre-1980 INL-exhumed Subsurface 

Disposal Area (SDA) wastes are processed and approved before the LANL waste]. AMWTP is 

still developing the documentation for Waste Stream BN510.2 and was unable to provide EPA 

with documentation describing it. The primary difference between Waste Streams BN510.1 and 

BN510.2 is the hazardous waste numbers used, which does not impact EPA’s approval. 

Accordingly, EPA evaluated documentation related to Waste Stream BN510.1 during this T1 

evaluation, and both waste streams are mentioned throughout this report. 

The BN510.1 newly-generated CH debris waste stream is produced from supercompaction of 55-

gallon containers of debris waste. The supercompacted Waste Stream BN510.1 is a single waste 

stream consisting of material with similar chemical matrices, physical form, and hazardous 

constituents. The AMWTP BN510.1 feedstock debris was generated at multiple sites, including 

AMWTP, RFP, Bettis, Hanford Site, and various non-AMWTP INL facilities. Some of the 

waste-generating activities were Pu pit production; depleted uranium (DU) component 

fabrication; enriched uranium (EU) processing; support operations including recovery, treatment, 

maintenance, laboratory analysis, and machining of non-nuclear weapon components; R&D; 

special-order work; fabrication of 238Pu heat sources and manufacture of radioisotopic 

thermoelectric generators; D&D activities; and materials development. The LANL CH debris 

waste was generated during Pu recovery operations at four related areas of LANL, as described 

in section 6.1. All four areas supported LANL’s mission of nuclear weapons R&D, which 

included processing Pu-bearing materials for Pu recovery. These activities are similar to those 

already contributing to Waste Stream BN510.1 (References P1839A, P1840A, P1841A and 

P1842A). 

Waste Stream BN510.1 includes a wide variety of debris, including paper, personal protective 

equipment, metal and glass, leaded gloves and other items. Estimated waste material parameters 

(WMPs) indicate that the waste stream mass is primarily iron-based metals or alloys, followed 

by cellulosics, plastic and other inorganic materials, and a wide variety of debris. Estimated 

WMPs for each subject waste stream indicate that the primary waste categories for the LANL 

IDCs are: 

• LA-007: iron-based metals or alloys, other inorganic materials, plastic, rubber and other 

metals (Reference P1839A). 

• LA-008: plastic, other inorganic materials, cellulosics, iron-based metals or alloys and 

other metals (References P1840A and Reference Set P1988A: Reference M020 for 

LANL-CCP AKSR CCP-AK-LANL-009). 
11 

• LA-009: iron-based metals or alloys, other metals, cellulosics, rubber and aluminumbased metals or alloys and plastic (References P1841A and Reference Set P1988A: 

Reference D059 for LANL-CCP AKSR CCP-AK-LANL-010). 

• LA-010: iron-based metals or alloys, other metals, aluminum-based metals or alloys, 

cellulosics, rubber and plastic (Reference P1842A).

The LANL CH debris wastes have physical compositions similar to that of Waste Stream 

BN510.1. Addition of the LANL CH debris waste to Waste Stream BN510.1 would have 

minimal impact on the overall assignments of WMPs. 

Waste Stream BN510.1 is primarily composed of weapons-grade Pu, with lesser amounts of 

heat-source Pu, fuels-grade Pu, DU and EU. Common radionuclides in Waste Stream BN510.1 

include 238Pu, 239Pu, 240Pu, 241Pu (or americium-241), uranium-235 (235U) and 238U. The two most 

prevalent radionuclides are expected to be 239Pu and 240Pu in most containers; however, due to 

commingling of wastes, the most prevalent radionuclides in some containers may be a 

combination of any two of the common radionuclides. The LANL CH debris waste is a mixture 

of everything from weapons-grade to reactor-grade Pu and everything in between. Wastes were 

commingled as they were generated, so each container of the above-listed debris waste streams is 

expected to be a different mixture of radionuclides, with the two most prevalent radionuclides 

expected to be 241Pu and 238Pu, followed by 239Pu and 240Pu. The expected radionuclide content 

of the LANL debris is within the range of expected radionuclides for Waste Stream BN510.1 

(References RPT-TRUW-07, RPT-TRUW-83, RPT-TRUW-93, Reference Set P1988A: 

Reference C096 for LANL-CCP AKSR CCP-AK-LANL-004, Reference C179 for LANL-CCP 

AKSR CCP-AK-LANL-006, and Reference M019 for LANL-CCP AKSR CCP-AK-LANL009). 

AMWTP expects to supercompact all LANL CH debris waste. The waste will be verified to be 

debris prior to shipment to AMWTP. AMWTP will not accept non-debris waste from LANL and 

would send any non-debris waste back to LANL if it were inadvertently shipped to AMWTP. 

AMWTP expects that all debris waste shipped from LANL will be compactable. If 

noncompactable waste is identified, AMWTP management will decide how to handle it at that 

time, either by direct shipment or return to LANL. EPA determined that AK information 

presented in reviewed documents is adequate to support the development of direct-shipped 

AKSRs, if necessary, and verified that the debris waste fits within Waste Stream BN510.1. 

Notification to EPA upon completion of or revision to AKSRs and WSPFs, including those for 

supercompacted waste streams and any direct-shipped waste streams, continues to be a T2 

change (see Table 1). See Item (4) for additional requirements related to payload management of 

direct-shipped waste. 

(3) The acceptable knowledge document was examined and indicates that data are available 

to determine that the wastes are defense in origin and are not high-level waste or spent 

nuclear fuel. 

TRU waste to be emplaced in the WIPP must be defense in origin. DOE guidance defines waste 

as defense in origin if it was generated in whole or part by one of the atomic energy defense 
12 

activities listed in section 10101(3) of the Nuclear Waste Policy Act of 1982 (NWPA).6 The 

WIPP Land Withdrawal Act (LWA), as amended,7 prohibits the disposal of SNF and HLW as 

defined by the NWPA at the WIPP. 

Each LANL-CCP AKSR and WSPF included in RPT-TRUW-93 addresses the defense 

determination and the absence of SNF or HLW for the associated waste streams. Three of the 

WSPFs indicate that the waste was generated by “defense nuclear waste and material by products 

management” and one of these three WSPFs also states that the waste was “generated as a 

consequence of defense research and development and defense nuclear material production 

activities” (References P1853A, P1854A and P1855A). The fourth WSPF indicates that the 

waste was generated by “defense research and development” (Reference P1852A). As stated in 

Item (2), LANL’s primary mission has been nuclear weapons R&D, which all four areas 

supported. Each of the areas also performed nondefense work, but the wastes from defense and 

nondefense activities were commingled in the final waste containers and segregation of the 

defense waste is not possible. (UCNI Reference Set P1987A: References D005, D022, D025 and 

D078 for LANL-CCP AKSR CCP-AK-LANL-004; Reference Set P1988A: References C040, 

C057 and D041 for LANL-CCP AKSR CCP-AK-LANL-006; References C021, D020, D025 

and D029 for LANL-CCP AKSR CCP-AK-LANL-009; and Reference D059 for LANL-CCP 

AKSR CCP-AK-LANL-010). 

The processes that generated the subject wastes are described in section 6.1. These operations did 

not involve separation or reprocessing of constituent elements from reactor fuel, and these waste 

streams do not contain irradiated fuel elements withdrawn from a reactor or pieces thereof. 

Therefore, the wastes are not SNF and not HLW, were not historically managed as HLW and are 

eligible for disposal at WIPP as TRU waste (UCNI Reference Set P1987A: References D070 and 

D102 for LANL-CCP AKSR CCP-AK-LANL-004; Reference Set P1988A: References D023, 

M015 and P118 for LANL-CCP AKSR CCP-AK-LANL-006; References D020, D028 and D029 

for LANL-CCP AKSR CCP-AK-LANL-009; and References D058, D059 and D060 for LANLCCP AKSR CCP-AK-LANL-010). 

As a result of an EPA concern identified during the 2012–2013 AMWTP continued compliance 

inspection (EPA Docket No. A-98-49; II-A4-173), AMWTP will prepare IDC inclusion 

memoranda documenting the evaluations performed on each new IDC to be included in the 

supercompacted waste stream. These memoranda will document that the IDCs meet the 

requirements of the LWA restrictions with respect to defense waste, SNF and HLW. Notification 

to EPA upon completion of or revision to IDC inclusion memoranda remains a T2 change (see 

Table 1). 

(4) Load management was found to be acceptable. 

The WIPP WAC allows payload management in which a payload container may include drums 

that measure less than 100 nanocuries per gram (nCi/g) of TRU alpha activity so long as the 

 

6

 U.S. Code, Title 42, “The Public Health and Welfare,” Chapter 108, “Nuclear Waste Policy Act of 1982.” 

7

 Public Law 102-579, The Waste Isolation Pilot Plant Land Withdrawal Act, October 30, 1992, as 

amended by Public Law 104-201, September 23, 1996. 
13 

payload in total is greater than 100 nCi/g of TRU alpha activity. The WAC defines a payload 

container as “the outermost container [(e.g., drum, Standard Large Box 2, standard waste box, 

10-drum overpack, canister)] for TRU waste material that is placed in a reusable Type B 

shipping container (e.g., TRUPACT-II, TRUPACT-III, HalfPACT, RH-TRU 72-B, or 10-160B) 

for transport.” The AKSR for each waste stream selected for payload management must include 

an estimate of the total waste volume and percentage of the waste volume that is above and 

below 100 nCi/g of TRU alpha activity. Each drum selected for payload management must also 

contain at least one TRU isotope whose activity exceeds the lower limit of detection of the 

radioassay system used to characterize the waste, and each drum may only be overpacked into a 

payload container with other containers from the same TRU waste stream. 

AMWTP includes WAC payload documentation in RPT-TRUW-07 instead of in individual 

AKSRs. Supercompacted waste is payload managed because the 100-gallon drum in which 

supercompacted drums are placed is considered to be the payload container. AMWTP updated 

RPT-TRUW-07 (to Revision 19a) to include LANL CH debris waste even though AMWTP does 

not anticipate receiving any containers of LANL CH debris that are below 100 nCi/g of TRU 

alpha activity. Notification to EPA upon availability of a revised RPT-TRUW-07 remains a T2 

change. In the event that AMWTP receives any CH debris containers from LANL with low TRU 

alpha activity, notification to EPA of its disposition is necessary. 

7.0 FINDINGS AND CONCERNS 

The EPA evaluation team did not identify any findings or concerns during this T1 evaluation. 

There are no open issues related to this T1 evaluation. 

8.0 CONCLUSIONS 

Changes to Tiering

Table 1 was modified to update the list of approved waste sources to include LANL debris waste 

and to clarify the NDA T1 designations. Table 1 shows the substantive T1 changes in bold text. 

T1 and T2 changes that were initiated during the baseline approval remain in effect; these are 

listed as applicable in section 6.0. The language in Table 1 regarding AK documentation applies 

to all AMWTP waste streams, including load-managed and direct-shipped waste streams. 

Approval

This T1 approval allows AMWTP to characterize CH debris (SCG S5000) waste from LANL for 

addition to the AMWTP waste characterization program using the equipment, processes and 

procedures that EPA approved during the October 2006 baseline approval (see EPA Docket No 

A-98-49: II-A4-66, October 3, 2006) and verified during the continued compliance inspection of 

October–November 2012 and February 2013 (see EPA Docket No A-98-49; II-A4-173, April 25, 

2013). EPA’s approval is limited to CH debris waste generated by LANL that was initially 

included in a WIPP-approved LANL debris waste stream as documented by LANL-CCP in a 

CBFO-approved AKSR and a CBFO-approved WSPF. AMWTP must confirm the AK using the 

EPA-approved NDA and NDE processes and procedures by generating BDRs for these LANL 

debris wastes. The NDA and NDE BDRs must be submitted when available for EPA to review 

along with AMWTP’s quarterly T2 change submission. 
A-1 

ATTACHMENT A 

APPROVAL SUMMARY FOR ADVANCED MIXED WASTE TREATMENT PROJECT 

CONTACT-HANDLED WASTE CHARACTERIZATION PROGRAM 

Approved Activity EPA Inspection Number, 

Approval Dates EPA Docket Number 

AMWTP CH Baseline Approval EPA-AMWTP-03.06-8 

October 2006 A-98-49; II-A4-66 

T1 Change – Addition of Four Hanford Legacy Debris 

Waste Streams to the BN510 Super-Compacted Debris 

Waste Stream 

June 2010 A-98-49; II-A4-127 

Unannounced Continued Compliance Inspection March 2011 A-98-49; II-A4-143 

T1 Change – Addition of ANLE-generated SCG S3000 and 

S5000 CH Waste and MFC-generated SCG S5000 CH 

Waste 

January 2013 A-98-49; II-A4-169 

Continued Compliance Inspection April 2013 A-98-49; II-A4-173 

T1 Change – Addition of Pre-1980 INL-Exhumed SDA 

SCG S3000 and S5000 Waste July 2013 A-98-49; II-A4-174 
B-1 

ATTACHMENT B 

LIST OF DOCUMENTS CITED BY EPA DURING THE T1 EVALUATION 

P1839A, Central Characterization Program, Acceptable Knowledge Summary Report for Los 

Alamos National Laboratory, TA-55 Mixed Transuranic Waste, Waste Streams: LAMHD01.001, LA-CIN01.001, LA-MIN02-V.001, LA-MIN04-S.001, CCP-AK-LANL-006, 

Revision 12, December 12, 2012 

P1840A, Central Characterization Program, Acceptable Knowledge Summary Report for Los 

Alamos National Laboratory, Chemistry and Metallurgy Research (CMR) Facility, Waste 

Streams: LA-MHD03.001, LA-CIN03.001, CCP-AK-LANL-009, Revision 7, February 7, 2012 

P1841A, Central Characterization Program, Acceptable Knowledge Summary Report for Los 

Alamos National Laboratory, TA-21 DP West Facility, Waste Streams: LA-MHD04.001, LAMSG04.001, CCP-AK-LANL-010, Revision 6, February 14, 2013 

P1842A, Central Characterization Program Acceptable Knowledge Summary Report for Los 

Alamos National Laboratory TA-50 Mixed Transuranic Waste, Waste Streams: LA-MIN03-

NC.001 LA-CIN02.001 LA-MHD09.001, CCP-AK-LANL-004, Revision 11, April 8, 2013 

P1852A, Central Characterization Project (CCP) Waste Stream Profile Form for LAMHD01.001, LA-MHD01.001, April 5, 2005 

P1853A, Central Characterization Program (CCP) LANL WSPF LA-MHD03.001 with 

applicable change notices, LA-MHD03.001, various dates 

P1854A, Central Characterization Program (CCP) LANL WSPF LA-MHD04.001, LAMHD04.001, May 13, 2008 

P1855A, Central Characterization Program (CCP) LANL WSPF LA-MHD09.001, LAMHD09.001, August 1, 2011 

P1987A: Set of Central Characterization Program Source Documents Classified as Unclassified 

Controlled Nuclear Information for Acceptable Knowledge Summary Reports: CCP-AK-LANL004, CCP-AK-LANL-006, CCP-AK-LANL-009 and CCP-AK-LANL-010, disk containing 

copies of select documents provided to EPA August 21, 2013 

P1988A: Set of Unclassified Central Characterization Program Source Documents for 

Acceptable Knowledge Summary Reports: CCP-AK-LANL-004, CCP-AK-LANL-006, CCPAK-LANL-009 and CCP-AK-LANL-010, copies of discs provided to EPA May 30, 2013 

RPT-TRUW-05, Waste Matrix Code Reference Manual, Advanced Mixed Waste Treatment 

Project, Revision 32, July 16, 2013 

RPT-TRUW-06, Acceptable Knowledge Baseline Document for AMWTP Waste, Revision 14, 

July 5, 2012 
B-2 

RPT-TRUW-07, Determination of Radioisotopic Content in TRU Waste Based on Acceptable 

Knowledge, Advanced Mixed Waste Treatment Project, Revision 19a, draft provided to EPA 

June 18, 2013 

RPT-TRUW-12, AMWTP Waste Stream Designations, Advanced Mixed Waste Treatment 

Project, Revision 21, draft provided to EPA July 22, 2013 

RPT-TRUW-83, Acceptable Knowledge Summary for Supercompacted Debris Waste 

(BN510.1), Advanced Mixed Waste Treatment Project, Revision 3, September 17, 2012 

RPT-TRUW-93, Acceptable Knowledge Document for Los Alamos National Laboratory Debris 

Waste, Revision 0, May 8, 2013 

References Cited in LANL-CCP AKSR CCP-AK-LANL-004 (Reference P1842A): 

C096, Evaluation of Volume, Period of Generation, and Calculation of Individual and Total 

Radionuclide Masses and Activities for Waste Stream LA-MHD09.001, James M. Schoen, 

P2010-2622, June 1, 2009, provided to EPA in Reference Set P1988A 

D005, Los Alamos National Laboratory TA-50/21/63 Waste Management Operations Safety 

Analysis Report, TA-50 Radioactive Liquid Waste Treatment Facility, LA-UR-94-1141, LANL 

P2010-2580, WASTEMGMT-REPORT-002, Revision 1, October 1995, provided to EPA in 

Reference Set P1987A 

D022, The Los Alamos Controlled Air Incinerator for Radioactive Waste, Volume I: Rationale, 

Process, Equipment, Performance, and Recommendations, A. Neuls et al, LA-9427, LANL, 

August 1982, provided to EPA in Reference Set P1987A 

D025, Future Radioactive Liquid Waste Streams Study, Alfredo Rey, LA-12667-MS, LANL, 

November 1993, provided to EPA in Reference Set P1987A 

D070, Interim Status Waste Analysis Plan for Mixed Waste, IT Corporation, LANL, Draft, 

September 1992, provided to EPA in Reference Set P1987A 

D078, Acceptable Knowledge Information Summary for LANL Transuranic Waste Streams, 

LANL, AK-00-019, September 22, 2003, provided to EPA in Reference Set P1987A 

D102, Acceptable Knowledge Summary Report for Waste Streams TA-55-43, TA-55-44, TA55-45, TA-55-46 and TA-55-47, J. Musgrave, Revision 0, September 20, 2001, provided to EPA 

in Reference Set P1987A 

References Cited in LANL-CCP AKSR CCP-AK-LANL-006 (Reference P1839A): 

C040, Interview with J. Foxx re: P/S Codes PB, PuBe, CC, MB, MS, FF, BF, and other issues, 

TWCP-4162, October 12, 2000, provided to EPA in Reference Set P1988A 

C057, Commingling of Defense and Nondefense TRU Waste, Charles L. Foxx, TWCP-887, 

August 21, 1997, provided to EPA in Reference Set P1988A 
B-3 

C179, Evaluation of Volume and Calculation of Individual and Total Radionuclide Masses and 

Activities for Waste Stream LA-MHD01.001, Jim Schoen, P2010-2793, March 12, 2010, 

provided to EPA in Reference Set P1988A 

D023, TA-55 Plutonium Facility Acceptable Knowledge Report, TWCP-AK-2.1-008, Revision 

2, May 14, 2001, provided to EPA in Reference Set P1988A 

D025, Acceptable Knowledge Report for Debris Waste Streams Containing Pu-239, LANL, 

TWCP-AK-2.1-015, Revision 3, April 10, 2003, provided to EPA in Reference Set P1988A 

D041, Acceptable Knowledge Information Summary for LANL Transuranic Waste Streams, 

AK-00-019, Revision 1, September 22, 2003, provided to EPA in Reference Set P1988A 

M015, Managing Radioactive Waste, LIR404-00-05.2, January 5, 1999, provided to EPA in 

Reference Set P1988A 

P118, Acceptable Knowledge Documentation, TWCP-QP-1.1-021, Revision 0, April 22, 1997, 

provided to EPA in Reference Set P1988A 

References Cited in LANL-CCP AKSR CCP-AK-LANL-009 (Reference P1840A): 

C021, Memorandum to Ed Wilmont, Pu 238 Waste at TA-55, DOE-CBFO, 

CBFO:OOM:RPD:JGW:04-0453:UFC:5822, May 20, 2004, provided to EPA in Reference Set 

P1988A 

D020, CMR Basis for Interim Operations (UCNI), NMT Division, LA-CP-98-142, Revision 1, 

September 1, 1998, provided to EPA in Reference Set P1988A 

D025, TA-55 Plutonium Facility Acceptable Knowledge Report - Process Acceptable 

Knowledge Report for Plutonium-238 Operations at TA-55, John Musgrave – TWCP, TWCPAK-2.1-009, Revision 0, August 7, 2001, provided to EPA in Reference Set P1988A 

D028, Los Alamos National Laboratory Transuranic Waste Characterization Acceptable 

Knowledge Information Summary, LANL-Project 2010, TWCP-PLAN-0.2.7-001, Revision 7, 

February 28, 2003, provided to EPA in Reference Set P1988A 

D029, LANL Project 2010 Acceptable Knowledge Report-Acceptable Knowledge Operations 

Report for CMR, LANL-Project 2010, AK-00-022, Revision 0 Draft, June 28, 2004, provided to 

EPA in Reference Set P1988A 

M019, CMR Container Databases - Drum List, Radionuclides, and EPA HWNs, Query provided 

by Andy Montoya - NMT-7, December 16, 2003, provided to EPA in Reference Set P1988A 

M020, LANL Generator Container Documentation (RSWDs and TWSRs), LANL, Various 

dates, provided to EPA in Reference Set P1988A 
B-4 

References Cited in LANL-CCP AKSR CCP-AK-LANL-010 (Reference P1841A): 

D058, Los Alamos National Laboratory Transuranic Waste Characterization Acceptable 

Knowledge Information Summary (AKIS), TWCP-PLAN-0.2.7-001, Revision 7, February 28, 

2003, provided to EPA in Reference Set P1988A 

D059, Acceptable Knowledge Operations Report for Plutonium Processing at the TA-21 DP 

West Facility (Draft Report), C. Smith, P2010-0608; TWCP 23596; AK-00-23, Revision 0, 

July 8, 2004, provided to EPA in Reference Set P1988A 

D060, Acceptable Knowledge Information Summary for LANL Transuranic Waste Streams, 

C. Smith, AK-00-019, Revision 1, September 22, 2003, provided to EPA in Reference Set 

P1988A