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

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT:

ADDITION OF CONTACT-HANDLED TRANSURANIC WASTE TO TH E 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 2013ii 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 Lo ad 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 W aste Treatment Project

Contact-Handled Waste Characterization Program Attachment B: List of Documents Cited by EPA during the T1 Evaluationiii 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 amendediv

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 form1

1.0 INTRODUCTION

This report supports the U.S. Environmental Protect ion Agency’s (EPA’s) approval of the proposed Tier 1 (T1) change to the EPA-approved tra nsuranic (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). Thi s approval allows AMWTP to characterize contact-handled (CH) debris [Summary C ategory Group (SCG) S5000] waste from the Los Alamos National Laboratory (LANL) for addit ion to AMWTP’s EPA-approved waste characterization program 1 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 inspec tion 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 nond estructive assay (NDA) and nondestructive examination (NDE) systems for charac terizing CH retrievably-stored SCG S3000 and SCG S5000 waste and newly-generated SCG S5000 w aste. The baseline report defined
inclusion of wastes from sources other than Mound S ite, Rocky Flats Environmental Technology Site [or Rocky Flats Plant (RFP)], Battelle Columbu s Laboratories, and Bettis Atomic Power Laboratory (hereafter referred to as “Bettis”) as a n AK T1 change that requires EPA approval before implementation. Wastes from the DOE sites li sted above were specifically evaluated as part of the baseline inspection.

EPA conducted a phased continued compliance inspect ion of AMWTP in October–November 2012 and February 2013, concluding in April 2013 th at the Idaho Treatment Group (ITG) has successfully implemented the CH TRU waste character ization 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 a nd WIPP waste characterization operations at AMWTP. Specifically, ITG is responsible for all ope rations 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,” th e terms “AMWTP” and “AMWTP-ITG” refer to the same entity and only “AMWTP” is used i n this report.

1 AMWTP’s EPA-approved waste characterization progra m includes the supercompaction and the directship processes. AMWTP indicated that the LANL-gener ated CH debris waste will be added to supercompacte d Waste Stream BN510.2. However, as AMWTP processes a nd characterizes approved feedstock waste for supercompaction, the new supercompacted waste strea m 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 super compacted-waste characterization program, including all iterations of the supercompacted Waste Stream BN510 .X. See section 6.4, Item (2), for additional infor mation.2

On May 30, 2013, the Carlsbad Field Office (CBFO) r equested 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 limite d 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 cr oss-reference available historical waste generation and disposal records supporting inclusio n of LANL debris waste. EPA’s approval is limited to CH debris waste generated by LANL that w as initially included in a WIPP-approved LANL debris waste stream as documented by the Centr al Characterization Program (CCP) at LANL in a CBFO-approved AK summary report (AKSR) an d a CBFO-approved Waste Stream Profile Form (WSPF). AMWTP will characterize these containers and incorporate them in the active supercompacted waste stream for WIPP emplace ment. Some of the LANL-generated debris containers may be direct-shipped to WIPP upo n characterization by AMWTP. EPA did not identify any findings or concerns during this r eview. Based on this evaluation, EPA approves the addition of LANL-generated debris CH waste to A MWTP’s EPA-approved program.

This evaluation did not consider the following wast e characterization activities:

• Use of EPA-approved NDA and NDE processes to charac terize these wastes. Upon completing NDA and NDE batch data reports (BDRs) fo r 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 con tinued 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 dra ft 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 LA NL-generated waste to WIPP:

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

• RPT-TRUW-07, “Determination of Radioisotopic Conten t 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 str eams as defined in RPT-TRUW-93, “Acceptable Knowledge Document for Los Alamos Natio nal Laboratory Debris Waste,” has been added to the list of approved waste sources. T here are no substantive changes to the AK T2 designations. EPA made one substantive change to ha rmonize the NDA T1 designations with all other EPA approved sites to clarify that recalibrat ion of EPA-approved NDA equipment is a T1 change, due to the fundamental importance of this p rocess. Table 1 shows the substantive T1 changes in bold text. T1 and T2 changes that were i nitiated during the baseline approval remain3

in effect. The language in Table 1 regarding AK doc umentation applies to all AMWTP waste streams, including load-managed and direct-shipped waste streams.

This approval allows AMWTP to characterize the phys ical and radiological contents of LANL
CH debris waste containers from WIPP-certified LANL -CCP waste streams using the equipment, processes and procedures that EPA approv ed as part of the baseline approval (see EPA Docket No A-98-49; II-A4-66, October 3, 2006) a nd 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 L ANL 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 websit e and by sending emails to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3).4Table 1. Tiering of CH TRU Waste CharacterizationProcesses Implemented by AMWTP(Based on March 28–30 and April 11–13, 2006, Baseline Inspection and Subsequent T1 Evaluations, Updated September 2013)Process ElementsAMWTP CH Waste Characterization Processes – T1 ChangesAMWTP CH Waste Characterization Processes – T2 Changes*Acceptable Knowledge,including LoadManagementAny new waste categoryAny waste from sources other than the Mound Site, Rocky FlatsEnvironmental Technology Site, Battelle Columbus Laboratories,Bettis Atomic Power Laboratory, Argonne NationalLaboratory-East, the Materials and Fuels Complex,pre-1980 INLexhumed Subsurface Disposal Area waste,and Los AlamosNational Laboratory debris.Load management of any new or unapproved waste streamNotification to EPA upon completion of or substantive modification** to:•Implementation of procedures and related documentation that formalizeNDA-AK communication requirements•AK accuracy reports (annually, at a minimum)•All final WSPFs with related attachments(e.g., CIS), including updates oradditions to waste streams within approved SCGs andsummaries ofradiological data for those containers included onthe CIS drum list•New and revised AKSRs and generator-site-specific AK documents (e.g.,RPT-TRUW-79, RPT-TRUW-89, RPT-TRUW-06, RPT-TRUW-83)•Item description code inclusion memoranda•The load management status of approved waste streams•Site procedures requiring CBFO approval•Any waste identified outside of the waste profilesincluded in the 2002Transuranic Waste Baseline Inventory Report, when applicable•RPT-TRUW-05, RPT-TRUW-07 and RPT-TRUW-12Nondestructive Assay New equipment or substantive physical modifications to EPAapproved equipment**Extension of or changes to the approved calibrationrange for EPAapproved equipment, including recalibration of EPA-approvedequipmentNotification to EPA upon substantive modification**to:•Site procedures requiring CBFO approval•Software for approved equipment•Operating ranges upon CBFO approvalReal-Time Radiography NoneNotification to EPA upon:•Substantive modification** to site procedures requiring CBFO approval•New equipment or substantive physical modifications** to EPAapproved equipmentVisual Examination andVisual ExaminationTechniqueChanges in the vendor performing visual examinationor visualexamination techniqueNotification to EPA upon:•Substantive modification** to site procedures requiring CBFO approval•Addition of a new waste category•Addition of a new procedure or site equipment identifierWIPP Waste Data System Changes to Waste Data Systemalgorithms specific to loadmanagementNotification to EPA upon substantive modification**to:•Site procedures requiring CBFO approvalNew T1s, T2s and significant modifications to existing T1s or T2s are inboldtext; T1s or T2s that were only revised for styleare not shown in bold.* 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 documentation of them, excluding changes thatare solely related to the environment, safety and health; nuclear safety; or the Resource Conservationand Recovery Act; or that are editorial in natureor are required toaddress 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 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 and incorpor ated 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 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 evaluations 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. When evaluating proposed T1 changes for approval, EPA may conduct a site evalua tion to observe implementation of the change or can opt to conduct a desktop review of in formation provided specific to a change. DOE may choose to characterize and dispose of any p reviously approved TRU waste using processes, procedures or equipment implemented as T 2 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 c hanges to verify their adequacy.

3.0 PURPOSE OF THIS REPORT

This report presents the technical basis for and re sults of EPA’s evaluation of the addition of LANL CH TRU debris waste to AMWTP’s baseline approv al as a T1 change. EPA’s approval of LANL debris waste for characterization for emplacem ent at the WIPP has been conveyed to DOE separately by letter. EPA will also announce th e 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 t hese 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 88221-30906

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 proces ses 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 E PA-approved program for supercompacted
CH debris waste. This evaluation does not address t he characterization of physical and radiological contents by AMWTP which will occur fol lowing the EPA approval of the subject T1 change request. This evaluation also did not add ress AK, NDA and NDE procedural adequacy; AMWTP procedural compliance; and NDA and NDE equipment because EPA evaluated these elements during its continued compl iance 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 t he AMWTP personnel contacted, with their affiliations and functions. This list includes pers onnel present during teleconferences conducted as part of this evaluation.

Table 2. Tier 1 Evaluation Personnel

6.0 TECHNICAL EVALUATION OF ACCEPTABLE KNOWLEDGE AND LO AD
MANAGEMENT

6.1 Waste-Generating Activities

LANL-CCP has been characterizing CH TRU debris wast e using EPA-approved characterization processes since 2007. Due to commitments with the s tate of New Mexico and recent budgetary constraints, CBFO has determined that the most effi cient 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 su percompacted waste stream or for direct shipment. All waste subject to this T1 review origi nated at LANL and will be shipped to AMWTP in compliance with the AMWTP offsite waste ac ceptance criteria. The waste will be boxed prior to shipment to AMWTP and will not be un packed prior to processing in the
AMWTP boxlines.

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

Name Affiliation & Function Rajani Joglekar Lead Inspector, EPA Kira Darlow Technical Evaluator – Acceptable Knowle dge, SC&A Steve Carpenter Acceptable Knowledge Expert, ITG George Byram TRU Programs Manager, ITG Jerry Wells Observer, DOE/ID Marcus Pinzel Observer, DOE/CBFO7

• LA-MHD01.001: mixed heterogeneous debris from Techn ical 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 re packaging and below-grade retrieval operations; generated 1978–present (Refer ences 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 w ell 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 (Referenc es P1841A and Reference Set
P1988A: Reference D059 for LANL-CCP AKSR CCP-AK-LAN L-010).

• LA-MHD09.001: heterogeneous debris waste from TA-50 (radioactive waste treatment) waste treatment and associated facility and equipme nt maintenance, D&D and waste repackaging operations; generated November 1977–pre sent (Reference P1842A).

6.2 Documents Provided

EPA evaluated the AMWTP documentation that supporte d 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 follo wing elements related to the use of AK for
CH waste characterization:

• Waste identification and description, including rad iological and physical characteristics, and verification that the subject debris waste is s uitable 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 o rigin 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 fac ility.8

6.4 Technical Evaluation

(1) The acceptable knowledge reports and related docume ntation were assessed and found to be adequate.

AMWTP prepares multiple documents that together sum marize 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 t o the LANL debris waste streams and the LANL-CCP AKSRs and WIPP-approved WSPFs, all reprodu ced 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-refere nced sources. AMWTP assigned source document tracking numbers to the whole set of sourc e documents: one tracking number for all controlled source documents [Unclassified Controlle d 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 documen t number. EPA finds this method of compiling the AK documents acceptable.

According to procedure MP-TRUW-8.13, information fr om the generator-site-specific AK document is used to update other AMWTP summary repo rts. AMWTP provided the following reports to EPA as evidence of this process:

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

• RPT-TRUW-06, Revision 14, “Acceptable Knowledge Bas eline 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 Summ ary for Supercompacted Debris Waste (BN510.1).”

These reports and their supporting source documents contain the information required by the WIPP waste analysis plan 4 and WIPP waste acceptance criteria (WAC). 5 AMWTP revised each document to address LANL CH debris waste, as discus sed below. The waste stream definition

3 AMWTP, “Collection, Review, and Management of Acce ptable Knowledge Documentation,” MP-TRUW-8.13, Revision 24, Idaho Falls, Idaho, Dece mber 12, 2011.

4 New Mexico Environment Department, “Waste Isolatio n Pilot Plant Hazardous Waste Facility Permit,” Waste Analysis Plan, Santa Fe, New Mexico, June 29, 2010.

5 U.S. DOE CBFO, “Transuranic Waste Acceptance Crite ria for the Waste Isolation Pilot Plant,” DOE/WIPP-02-3122, Revision 7.2, Carlsbad, New Mexic o, June 13, 2011.9

and documentation of physical and radiological comp onents 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-T RUW-05, contains detailed information about the physical characteristics of all wastes ha ndled 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 i n 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 i s 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 informati on 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-0 5 will include a corrected reference list and accurate citations. Notification to EPA upon th e availability of a revised RPT-TRUW-05 continues to be a T2 change (see Table 1).

RPT-TRUW-07 presents radiological information for E PA-approved offsite waste generators (e.g., RFP, Mound Site, Battelle Columbus Laborator ies, Bettis, the Hanford Site) and AMWTP’s supercompacted and newly-generated (not sup ercompacted) wastes. RPT-TRUW-07, Revision 19a, includes Chapter 11 and Appendix I th at address LANL debris waste; AMWTP also revised parts of other sections of this docume nt 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 fr om a wide variety of generators at LANL. EPA reviewed RPT-TRUW-07, Revision 19a, and found t hat 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 a vailability 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 fo r TRU IDCs that are characterized and certified by AMWTP. AMWTP updated RPT-TRUW-12 (to d raft Revision 21) to include the chemical composition of each IDC for the LANL debri s waste. RPT-TRUW-12, Revision 21, adequately addresses LANL debris waste. Notificatio n 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, includ ing 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 abo ut 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 processe s 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 i s 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 Mate rials and Fuel Complex (MFC)-generated feedstock. The LANL debris feedstock will be incorp orated 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 approv ed 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 diffe rence 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 th roughout this report.

The BN510.1 newly-generated CH debris waste stream is produced from supercompaction of 55- gallon containers of debris waste. The supercompact ed 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 wa s generated at multiple sites, including AMWTP, RFP, Bettis, Hanford Site, and various non-A MWTP INL facilities. Some of the waste-generating activities were Pu pit production; depleted uranium (DU) component fabrication; enriched uranium (EU) processing; supp ort operations including recovery, treatment, maintenance, laboratory analysis, and machining of non-nuclear weapon components; R&D; special-order work; fabrication of 238 Pu heat sources and manufacture of radioisotopic thermoelectric generators; D&D activities; and mate rials development. The LANL CH debris waste was generated during Pu recovery operations a t four related areas of LANL, as described in section 6.1. All four areas supported LANL’s mis sion of nuclear weapons R&D, which included processing Pu-bearing materials for Pu rec overy. These activities are similar to those already contributing to Waste Stream BN510.1 (Refer ences P1839A, P1840A, P1841A and P1842A).

Waste Stream BN510.1 includes a wide variety of deb ris, 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 prima rily iron-based metals or alloys, followed by cellulosics, plastic and other inorganic materia ls, and a wide variety of debris. Estimated WMPs for each subject waste stream indicate that th e primary waste categories for the LANL
IDCs are:

• LA-007: iron-based metals or alloys, other inorgani c materials, plastic, rubber and other metals (Reference P1839A).

• LA-008: plastic, other inorganic materials, cellulo sics, iron-based metals or alloys and other metals (References P1840A and Reference Set P 1988A: 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 P184 1A 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 composition s similar to that of Waste Stream
BN510.1. Addition of the LANL CH debris waste to Wa ste Stream BN510.1 would have minimal impact on the overall assignments of WMPs.

Waste Stream BN510.1 is primarily composed of weapo ns-grade Pu, with lesser amounts of heat-source Pu, fuels-grade Pu, DU and EU. Common r adionuclides in Waste Stream BN510.1
include 238 Pu, 239 Pu, 240 Pu, 241 Pu (or americium-241), uranium-235 ( 235 U) and 238 U. The two most prevalent radionuclides are expected to be 239 Pu and 240 Pu in most containers; however, due to commingling of wastes, the most prevalent radionucl ides 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 P u and everything in between. Wastes were commingled as they were generated, so each containe r 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 241 Pu and 238 Pu, followed by 239 Pu and 240 Pu. 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, R eference C179 for LANL-CCP AKSR CCP-AK-LANL-006, and Reference M019 for LANL-C CP AKSR CCP-AK-LANL009).

AMWTP expects to supercompact all LANL CH debris wa ste. The waste will be verified to be debris prior to shipment to AMWTP. AMWTP will not a ccept 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 LA NL will be compactable. If noncompactable waste is identified, AMWTP managemen t 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 supp ort the development of direct-shipped AKSRs, if necessary, and verified that the debris w aste 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 r equirements 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 defens e in origin. DOE guidance defines waste as defense in origin if it was generated in whole o r part by one of the atomic energy defense12

activities listed in section 10101(3) of the Nuclea r 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 “def ense nuclear waste and material by products management” and one of these three WSPFs also state s 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 develo pment” (Reference P1852A). As stated in Item (2), LANL’s primary mission has been nuclear w eapons R&D, which all four areas supported. Each of the areas also performed nondefe nse 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 S et P1988A: References C040, C057 and D041 for LANL-CCP AKSR CCP-AK-LANL-006; Re ferences C021, D020, D025 and D029 for LANL-CCP AKSR CCP-AK-LANL-009; and Ref erence 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 constitue nt elements from reactor fuel, and these waste
streams do not contain irradiated fuel elements wit hdrawn 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 Re ference Set P1987A: References D070 and D102 for LANL-CCP AKSR CCP-AK-LANL-004; Reference S et P1988A: References D023, M015 and P118 for LANL-CCP AKSR CCP-AK-LANL-006; Re ferences D020, D028 and D029 for LANL-CCP AKSR CCP-AK-LANL-009; and References D 058, 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), AMW TP will prepare IDC inclusion memoranda documenting the evaluations performed on each new IDC to be included in the supercompacted waste stream. These memoranda will d ocument that the IDCs meet the requirements of the LWA restrictions with respect t o defense waste, SNF and HLW. Notification to EPA upon completion of or revision to IDC inclus ion 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 p ayload 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 Welfar e,” Chapter 108, “Nuclear Waste Policy Act of 1982. ”

7 Public Law 102-579, The Waste Isolation Pilot Plan t 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 a lpha 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 sele cted for payload management must include an estimate of the total waste volume and percentag e of the waste volume that is above and below 100 nCi/g of TRU alpha activity. Each drum se lected for payload management must also contain at least one TRU isotope whose activity exc eeds the lower limit of detection of the radioassay system used to characterize the waste, a nd each drum may only be overpacked into a payload container with other containers from the sa me TRU waste stream.

AMWTP includes WAC payload documentation in RPT-TRU W-07 instead of in individual AKSRs. Supercompacted waste is payload managed beca use 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 de bris 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 availabili ty of a revised RPT-TRUW-07 remains a T2 change. In the event that AMWTP receives any CH deb ris containers from LANL with low TRU alpha activity, notification to EPA of its disposit ion is necessary.

7.0 FINDINGS AND CONCERNS

The EPA evaluation team did not identify any findin gs or concerns during this T1 evaluation. There are no open issues related to this T1 evaluat ion.

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 sho ws the substantive T1 changes in bold text. T1 and T2 changes that were initiated during the ba seline approval remain in effect; these are listed as applicable in section 6.0. The language i n 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 de bris (SCG S5000) waste from LANL for addition to the AMWTP waste characterization progra m using the equipment, processes and procedures that EPA approved during the October 200 6 baseline approval (see EPA Docket No A-98-49: II-A4-66, October 3, 2006) and verified du ring the continued compliance inspection of October–November 2012 and February 2013 (see EPA Do cket 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 strea m 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 b y generating BDRs for these LANL
debris wastes. The NDA and NDE BDRs must be submitt ed 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 an d 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-A4-174B-1 ATTACHMENT B

LIST OF DOCUMENTS CITED BY EPA DURING THE T1 EVALUA TION

P1839A, Central Characterization Program, Acceptabl e 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, Acceptabl e Knowledge Summary Report for Los Alamos National Laboratory, Chemistry and Metallurg y Research (CMR) Facility, Waste Streams: LA-MHD03.001, LA-CIN03.001, CCP-AK-LANL-00 9, Revision 7, February 7, 2012

P1841A, Central Characterization Program, Acceptabl e 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) Wast e 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 da tes

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 Sou rce Documents Classified as Unclassified Controlled Nuclear Information for Acceptable Knowl edge Summary Reports: CCP-AK-LANL004, CCP-AK-LANL-006, CCP-AK-LANL-009 and CCP-AK-LA NL-010, disk containing copies of select documents provided to EPA August 2 1, 2013

P1988A: Set of Unclassified Central Characterizatio n Program Source Documents for Acceptable Knowledge Summary Reports: CCP-AK-LANL-0 04, CCP-AK-LANL-006, CCPAK-LANL-009 and CCP-AK-LANL-010, copies of discs pr ovided to EPA May 30, 2013

RPT-TRUW-05, Waste Matrix Code Reference Manual, Ad vanced Mixed Waste Treatment Project, Revision 32, July 16, 2013

RPT-TRUW-06, Acceptable Knowledge Baseline Document for AMWTP Waste, Revision 14, July 5, 2012B-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, Advan ced Mixed Waste Treatment Project, Revision 21, draft provided to EPA July 22 , 2013

RPT-TRUW-83, Acceptable Knowledge Summary for Super compacted 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, a nd 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 Refere nce Set P1988A

D005, Los Alamos National Laboratory TA-50/21/63 Wa ste Management Operations Safety Analysis Report, TA-50 Radioactive Liquid Waste Tre atment Facility, LA-UR-94-1141, LANL P2010-2580, WASTEMGMT-REPORT-002, Revision 1, Octob er 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 Recommendation s, A. Neuls et al, LA-9427, LANL, August 1982, provided to EPA in Reference Set P1987 A

D025, Future Radioactive Liquid Waste Streams Study , Alfredo Rey, LA-12667-MS, LANL, November 1993, provided to EPA in Reference Set P19 87A

D070, Interim Status Waste Analysis Plan for Mixed Waste, IT Corporation, LANL, Draft, September 1992, provided to EPA in Reference Set P1 987A

D078, Acceptable Knowledge Information Summary for LANL Transuranic Waste Streams, LANL, AK-00-019, September 22, 2003, provided to EP A 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 Ref erence Set P1988A

C057, Commingling of Defense and Nondefense TRU Was te, Charles L. Foxx, TWCP-887, August 21, 1997, provided to EPA in Reference Set P 1988AB-3

C179, Evaluation of Volume and Calculation of Indiv idual and Total Radionuclide Masses and Activities for Waste Stream LA-MHD01.001, Jim Schoe n, 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 P 1988A

D025, Acceptable Knowledge Report for Debris Waste Streams Containing Pu-239, LANL, TWCP-AK-2.1-015, Revision 3, April 10, 2003, provid ed 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, J anuary 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, pr ovided 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 Wa ste Characterization Acceptable Knowledge Information Summary, LANL-Project 2010, T WCP-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, Revis ion 0 Draft, June 28, 2004, provided to
EPA in Reference Set P1988A

M019, CMR Container Databases - Drum List, Radionuc lides, and EPA HWNs, Query provided by Andy Montoya - NMT-7, December 16, 2003, provide d to EPA in Reference Set P1988A

M020, LANL Generator Container Documentation (RSWDs and TWSRs), LANL, Various dates, provided to EPA in Reference Set P1988AB-4

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

D058, Los Alamos National Laboratory Transuranic Wa ste 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 Pl utonium 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 P198 8A

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