DOCKET NO: A-98-49; II-A4-191 

EPA eDocket NO: EPA-HQ-OAR-2001-0012-0442 

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT 

EPA TIER 1 EVALUATION 

OF THE CENTRAL CHARACTERIZATION PROGRAM 

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM 

FOR THE IDAHO NATIONAL LABORATORY: 

ADDITION OF WASTE STREAM IN-ID-BTO-030 

U.S. Environmental Protection Agency 

Radiation Protection Division 

Center for Waste Management & Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

November 2014
i 

TABLE OF CONTENTS 

Section Page 

Abbreviations and Acronyms ......................................................................................................... ii

1.0 Introduction ..........................................................................................................................4

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

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

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

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

5.1 EPA Evaluation Personnel ...................................................................................... 6

5.2 DOE Evaluation Personnel ..................................................................................... 6

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

6.1 Acceptable Knowledge ........................................................................................... 7

6.2 Radiological Characterization ............................................................................... 11

7.0 Findings and Concerns .......................................................................................................16

8.0 Conclusions ........................................................................................................................17

 

TABLE OF TABLES 

Table 1. EPA Tier 1 Evaluation Team Members ............................................................................ 6

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

TABLE OF FIGURES 

Figure 1. Radiological Characterization Flow Diagram for Waste Stream IN-ID-BTO-030....... 13

ATTACHMENTS 

Attachment A: Approval Summary for INL-CCP Remote-Handled Waste 

Characterization Program 

Attachment B: List of DOE Personnel Present at Evaluation 

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

ABBREVIATIONS AND ACRONYMS 

ACL Analytical Chemistry Laboratory (AMWTP) 

AK acceptable knowledge 

AKSR acceptable knowledge summary report 

AMWTP Advanced Mixed Waste Treatment Project 

BAPL Bettis Atomic Power Laboratory 

BDR batch data report 

CBFO Carlsbad Field Office 

CCP Central Characterization Program 

CFR Code of Federal Regulations 

Ci curie 

Cm curium 

CRR Characterization Reconciliation Report 

Cs cesium 

CWI CH2M-WG Idaho 

DOE U.S. Department of Energy 

DOE-ID U.S. Department of Energy Idaho Field Office

DTC dose-to-curie 

EPA U.S. Environmental Protection Agency 

HFEF Hot Fuel Examination Facility 

HLW high-level waste 

INL Idaho National Laboratory 

INTEC Idaho Nuclear Technology and Engineering Center 

LANL-CO Los Alamos National Laboratory Carlsbad Office 

m meter 

MEL Materials Evaluation Laboratory (BAPL) 

MFC Materials and Fuels Complex (INL) 

mR milliroentgen 

mR/hr milliroentgens per hour 

NNPP U.S. Naval Nuclear Propulsion Program 

NWP Nuclear Waste Partnership 

Pu plutonium 
iii 

QAO quality assurance objective 

R roentgen 

RH remote-handled 

SCG Summary Category Group 

SF scaling factor 

SNF spent nuclear fuel 

SPM Site Project Manager 

SRS-CCP Savannah River Site Central Characterization Program 

T1 Tier 1 

T2 Tier 2 

TMU total measurement uncertainty 

TRU transuranic 

U uranium 

WAP waste analysis plan 

WCPIP Waste Characterization Program Implementation Plan 

WIPP Waste Isolation Pilot Plant 

WSPF waste stream profile form 
4 

1.0 INTRODUCTION 

This report supports the U.S. Environmental Protection Agency’s (EPA’s) approval of a Tier 1 

(T1) change to add Waste Stream IN-ID-BTO-030 to the approved characterization program at 

the U.S. Department of Energy’s (DOE’s) Idaho National Laboratory (INL). In January 2007, 

EPA approved the Central Characterization Program (CCP)1 to characterize remote-handled 

(RH) waste at INL (see EPA Docket No. A-98-49; II-A4-72). Using the EPA-approved waste 

characterization processes discussed in this report, INL-CCP may characterize Waste Stream INID-BTO-030 for disposal at the Waste Isolation Pilot Plant (WIPP). 

EPA conducted continued compliance inspections of INL-CCP in May 2013 and May 2014, 

concluding in both instances that INL-CCP continued to adequately implement the RH 

transuranic (TRU) waste characterization processes, procedures and equipment at INL that EPA 

approved in the January 2007 baseline approval and in subsequent tiering changes listed in 

Attachment A. 

On September 30, 2013, the Carlsbad Field Office (CBFO) requested EPA approval of a T1 

change to include Waste Stream IN-ID-BTO-030. EPA limited the scope of this T1 evaluation to 

the components of acceptable knowledge (AK) and radiological characterization specific to the 

addition of Waste Stream IN-ID-BTO-030. Because there were no new equipment or additional 

new processes on site at INL as part of the T1 request, EPA conducted a desktop review of this 

change and then met with INL-CCP personnel in Denver, Colorado, on December 3–5, 2013. 

EPA did not identify any findings or concerns during this evaluation. Subsequent to the desktop 

review, INL-CCP revised several documents and calculation packages and provided them to 

EPA in August 2014,2

 as discussed in section 6.0 of this report. Attachment C is a list of all 

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

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

(T2) designations that were established during the baseline approval and modified during 

subsequent T1 evaluations and continued compliance inspections. The tiering designations 

presented in Table 1 of the final report for EPA’s 2014 continued compliance inspection of INLCCP (see EPA Docket No. A-98-49; II-A4-190; July 15, 2014) remain in effect and are listed as 

applicable in sections 6.1 and 6.2. 

Based on the information provided, EPA is approving INL-CCP’s characterization of four 55-

gallon drums comprising of Waste Stream IN-ID-BTO-030 using the EPA-approved system of 

controls. This approval also includes any additional drums that may be added to Waste Stream 

IN-ID-BTO-030 in the future, provided they have the same pedigree as the original four 

containers and are characterized using the EPA-approved processes discussed in this report. 

 

1

 The Central Characterization Program was formerly known as the Central Characterization Project, and 

both names are used in the documentation reviewed for this evaluation. 

2

 All revised documents required a review by the U.S. Naval Nuclear Propulsion Program (NNPP) using 

Public Utterance, a process similar in nature to a classification review. This process is time consuming and resulted 

in considerable delay in processing this T1 evaluation, see page 7 of this report. 
5 

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

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

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

194.8(b)(3)]. 

2.0 PURPOSE OF TIER 1 EVALUATIONS 

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

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

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

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

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

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

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

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

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

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

destined for disposal at the WIPP. 

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

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

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

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

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

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

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

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

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

risk of subsequent EPA disapproval. 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation of a T1 change to add Waste Stream IN-IDBTO-030 to the EPA-approved waste characterization program, as described in CCP-AK-INL590, Revisions 3 and 4; CCP-RC-INL-591, Revisions 0 and 1; and CCP-AK-INL-592, Revisions 

1 and 2. This report presents the technical basis for and results of EPA’s approval decision. 

EPA’s approval decision regarding the addition of Waste Stream IN-ID-BTO-030 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). 

4.0 SCOPE OF THE TIER 1 EVALUATION 

The scope of EPA’s T1 evaluation is the AK and radiological characterization approach used to 

characterize the four RH TRU 55-gallon drums in Waste Stream IN-ID-BTO-030. Sections 6.1 

and 6.2 of this report detail the AK and radiological characterization technical elements assessed 

during this evaluation. 
6 

5.0 EVALUATION PERSONNEL 

5.1 EPA Evaluation Personnel 

The EPA evaluation team members consisted of the personnel listed in Table 1 with their 

technical areas of expertise. 

Table 1. EPA Tier 1 Evaluation Team Members 

Name Affiliation & Function 

Ed Feltcorn Lead Inspector, EPA 

Connie Walker Technical Evaluator – Acceptable Knowledge, SC&A 

Rose Gogliotti Technical Evaluator – Radiological Characterization, SC&A 

Patrick Kelly Technical Evaluator – Radiological Characterization, SC&A 

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

*Participated remotely in Denver 2013 evaluation. 

5.2 DOE Evaluation Personnel 

EPA and its support personnel conducted interviews with INL-CCP waste characterization 

personnel in several disciplines. The INL-CCP personnel contacted during the T1 evaluation in 

Denver, Colorado, are listed in Table 2 with their affiliations and areas of expertise or function. 

All DOE personnel present at the evaluation are listed in Attachment B. 

Table 2. DOE Tier 1 Evaluation Personnel 

6.0 TECHNICAL EVALUATION 

Waste-Generating Activities and Packaging Configuration

Analysis of post-irradiated nuclear fuel assemblies from the NNPP generated Waste Stream INID-BTO-030. Specifically, this Summary Category Group (SCG) S3000 (homogenous solids) 

waste stream consists of solidified particulate matter and pieces (fines) produced by sectioning, 

grinding, mounting, and polishing of metallographic fuel specimens. These fines were 

subsequently solidified in the Bettis Atomic Power Laboratory’s (BAPL’s)3 Materials Evaluation 

Laboratory (MEL) from 1977 to 1985. BAPL initially placed the fines in containers and 

subsequently transferred them to 13 IN-414 cans. BAPL solidified the fines using Portland 

cement and water between 1987 and 1988. BAPL then shipped the resulting solid, monolith 

 

3

 BAPL is located in West Mifflin, Pennsylvania. 

4

 The BAPL IN-41 can is a stainless steel cylinder with an approximate diameter of 5 inches, length of 16 

inches, and wall thickness of 0.25 inches. 

Name Affiliation & Function 

Lisa Watson INL-CCP, AK Expert 

Derek Ott URS, Radiological Characterization Technical Expert 

Thomas Clements CWI-INL, TRU Project Manager (Evaluation Observer) 

Irene Joo URS, CCP RH Support/SPM 

Marcus Pinzel CBFO, RH Staff (Evaluation Observer) 
7 

wastes to the INL Materials and Fuels Complex (MFC)5 for venting and repackaging into two 

Hot Fuel Examination Facility (HFEF) liners.6 INL transferred the two liners to the Intermediate

Level Transuranic Storage Facility for interim storage and later transferred them to Idaho 

Nuclear Technology and Engineering Center (INTEC) for final repackaging and 

characterization. 

At INTEC in November 2011, INL repackaged the HFEF liners into four 30-gallon drums and 

overpacked the 30-gallon drums into four 55-gallon drums. Three of the 55-gallon drums contain 

three IN-41 cans plus a dummy schedule 40 open-ended pipe; one 55-gallon drum contains four 

IN-41 cans (Reference CCP-AK-INL-590, Revision 4). These four 55-gallon drums constitute 

Waste Stream IN-ID-BTO-030, which INL-CCP also calls “Lot 3.” 

Documents, Batch Data Reports and Calculation Packages Provided 

EPA evaluated the INL-CCP documentation that supported the addition of Waste Stream IN-IDBTO-030. EPA’s review identified several technical issues that necessitated the revision of 

several documents. INL-CCP discussed proposed modifications to these documents with EPA 

during the December 2013 meeting in Denver, Colorado, and provided approved revised 

documents incorporating necessary changes to EPA in August 2014. EPA reviewed the revised 

documents prior to completing this report. Specifically, the primary documents supporting AK 

and radiological characterization required revisions and these revisions took approximately seven 

months to complete due to the public utterance process discussed in footnote 1. The affected 

documents were CCP-AK-INL-590, CCP-AK-INL-592, CCP-RC-INL-591, INL-RH-127, INLRH-129 and DTC BDR INLRHDTC13009. 

The DOE documents that EPA reviewed for this evaluation, including BDRs and calculation 

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

Any of these documents can be requested from the following address: 

Manager, National TRU Sites and Transportation Division 

Carlsbad Field Office 

U.S. Department of Energy 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

6.1 Acceptable Knowledge 

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

information during the continued compliance inspection in May 2013. Therefore, EPA limited 

the scope of this AK evaluation to those elements necessary to assess the technical adequacy of 

the information supporting the addition of Waste Stream IN-ID-BTO-030. 

 

5

 The INL MFC was formerly known as Argonne National Laboratory-West. 

6

 “HFEF liners” are RH containers specific to the Hot Fuel Examination Facility (HFEF) at MFC, as 

described in Docket No. A-98-49; II-A4-122. 
8 

Waste Characterization Element Description 

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

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

characteristics. 

• Identification of the Waste Characterization Program Implementation Plan (WCPIP)7

waste characterization process. 

• Adequacy of the certification plan and other WCPIP documentation. 

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

or spent nuclear fuel (SNF). 

• Role of AK in the characterization methodology, including radionuclide scaling factors. 

• Adequacy of the AK procedure and its implementation, including attachments and AK 

accuracy reports. 

• Adequacy of the acceptable knowledge summary report (AKSR) and associated source 

documents. 

• Adequacy of the waste stream profile form (WSPF) and related attachments. 

Technical Evaluation 

(1) EPA examined the waste stream determination for Waste Stream IN-ID-BTO-030 and 

found it to be adequate.

Waste Stream IN-ID-BTO-030 is defined in the AKSR (CCP-AK-INL-590). At the December 

2013 meeting in Denver, EPA reviewed Revision 3 of the AKSR and determined that it required 

revision to support the waste stream determination [see Item (6), below]. Upon review of the 

revised document, EPA determined that the waste stream is adequately defined. 

As described in section 6.0 of this report, Waste Stream IN-ID-BTO-030 contains solidified 

particulate matter and pieces produced by sectioning, grinding, mounting, and polishing of 

metallographic specimens at BAPL. The final volume of wastes in these four containers intended 

for shipment to WIPP is 0.832 cubic meters. The waste stream’s two predominant radionuclides 

by mass are thorium-232 (76.92%) and uranium-235 (235U) (21.16%). The two predominant 

radionuclides by activity are cesium-137 (137Cs) (17.73%) and yttrirum-90 (17.51%) (References 

CCP-AK-INL-590, Revision 4, and C127, C206, C207, C208, C209, C210, C313, U212, U213, 

U217, U221, U236, U277 and U366). 

EPA did not identify any concerns regarding INL-CCP’s waste stream determination for Waste 

Stream IN-ID-BTO-030. 

 

7

 All references to the WCPIP in this report refer to Revision 3, unless specified otherwise. 

U.S. Department of Energy, Carlsbad Field Office, “Remote Handled TRU Waste Characterization Program 

Implementation Plan,” Revision 3, Carlsbad, New Mexico, September 19, 2012. 
9 

(2) INL-CCP identified the waste characterization pathway, and documentation of the 

approach is adequate. 

The certification plan for Waste Stream IN-ID-BTO-030 (CCP-AK-INL-592) describes the 

characterization pathway, which uses a combination of AK, sampling and analysis, dose-to-curie 

(DTC), and nondestructive examination. The certification plan also presents quality assurance 

objectives (QAOs) and data quality objectives related to container acceptance criteria, physical 

properties acceptance criteria, physical form, surface dose rate, TRU alpha activity 

concentration, radionuclide activity and waste origin. 

The certification plan indicates that INL-CCP sampled the 13 IN-41 cans during two separate 

events. INL-CCP performed the first event to support Resource Conservation and Recovery Act 

(RCRA)8 constituent analysis required by the waste analysis plan (WAP).9 When the Advanced 

Mixed Waste Treatment Project’s (AMWTP’s) Analytical Chemistry Laboratory (ACL) at INL 

determined that eight samples were required for radionuclide analyses, INL-CCP selected three 

additional containers at random, bringing the total radionuclide samples to eight. The AMWTP 

ACL analyzed these eight samples using a variety of analytical techniques, as discussed in 

section 6.2. INL-CCP met the characterization requirements for physical parameters and 

prohibited items using radiography. 

EPA determined that Revision 1 of the certification plan outlined the characterization approach 

however, did not adequately address all aspects of laboratory analysis and AK QAOs. 

Specifically, the certification plan required revision with respect to sampling representativeness 

and RH determination QAOs for precision, accuracy and completeness. The certification plan 

also required revision to address AK QAOs associated with defense, HLW and SNF 

determinations. INL-CCP provided the March 2014 revision of the certification plan (CCP-AKINL-592, Revision 2) on July 31, 2014, and EPA determined that it addressed all pertinent issues 

as well as other editorial and technical clarifications. 

EPA did not identify any concerns regarding INL-CCP’s documentation of the characterization 

pathway. Notification to EPA of availability of a revised certification plan remains a T2 change. 

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

fuel or high-level waste in this waste stream and found it to be adequate. 

The WIPP Land Withdrawal Act prohibits the disposal of SNF and HLW as defined by the 

Nuclear Waste Policy Act at the WIPP. Waste Stream IN-ID-BTO-030 consists of solidified fuel 

fines, swarf10 and other fragments generated through destructive examination of test specimens 

of spent fuel from various sources. The waste is not composed of complete or intact fuel material 

and does not include any material generated through separation or reprocessing of spent fuels; 

therefore, it is not HLW (References C206, P100, U201, U212, U213, U217, U221, U236, U237 

and U256). 

 

8

 RCRA generally regulates hazardous materials. 

9

 The WAP is under the purview of the New Mexico Environment Department. 

10 Swarf is material produced by a cutting or grinding process. 
10 

EPA did not identify concerns regarding INL-CCP’s documentation of the absence of SNF and 

HLW in Waste Stream IN-ID-BTO-030. 

(4) EPA examined the information supporting that the waste stream is defense in origin and 

found it to be adequate. 

Revision 3 of the AKSR provided evidence to demonstrate that Waste Stream IN-ID-BTO-030 

contains materials from atomic energy activities associated with naval reactors and research and 

development activities. However, the AKSR, Revision 3, defense discussion did not sufficiently 

reference or address this statement and was unclear regarding comingling of defense and nondefense wastes. INL-CCP provided Revision 4 of the AKSR, which better discussed the defense 

waste generation (References U201 and U256) and adequately supported the defense 

determination for Waste Stream IN-ID-BTO-030. 

EPA did not identify any concerns regarding INL-CCP’s documentation of the defense 

determination. 

(5) EPA examined implementation of the acceptable knowledge procedure and related 

attachments and found them to be adequate. 

CCP-TP-005 includes several attachments that document AK requirements. EPA found that the 

indicated waste generation dates differed between the AKSR, Revision 3; CCP-TP-005, 

Attachment 8, “Waste Containers List”; and other references. Additionally, the CCP TRU Waste 

Correlation and Surrogate Summary Form (Attachment 15) did not reference the correct 

discrepancy resolution analysis. 

INL-CCP revised Attachments 8 and 15 and EPA reviewed draft copies of these attachments. 

The revised documents demonstrated that INL-CCP can adequately implement CCP-TP-005, 

Revision 26. EPA did not identify any concerns regarding INL-CCP’s implementation of the 

appropriate AK attachments for Waste Stream IN-ID-BTO-030. 

(6) EPA examined the acceptable knowledge summary report, associated source documents 

and reference list and found them to be adequate. 

Upon initial evaluation, EPA determined that the AKSR, Revision 3, required the following 

modifications: 

• Justify the SCG assignment. 

• Clarify the solidification process with respect to appropriate packaging configuration. 

• Better describe and justify the defense determination process. 

• More thoroughly reference the HFEF repackaging process. 

• Better describe the location and activities associated with the solidification process. 

• Improve referencing throughout. 

INL-CCP provided Revision 4 of the AKSR on July 31, 2014. EPA examined the AKSR, 

Revision 4, and associated source documents and reference list and found them to be adequate. 

EPA compared CCP-TP-005, Attachment 1; CCP-TP-005, Attachment 4; and the AKSR 
11 

reference list to determine whether the AK reference list items were all presented on Attachment 

4 and the associated checklist. EPA determined that the attachments and AKSR checklist 

adequately presented all required aspects. 

EPA did not identify any concerns regarding the adequacy of the AKSR and its reference list for 

Waste Stream IN-ID-BTO-030. Notification to EPA of availability of a revised AKSR remains a 

T2 change. 

(7) EPA examined the draft waste stream profile form and attachments and found them to be 

adequate. 

EPA’s review of the draft WSPF indicated that it contained several inconsistencies and errors, 

including waste stream volume, footnotes and document citations. The draft Characterization 

Reconciliation Report (CRR) also contained several errors, including identification of the SCG, 

citations for the defense determination, nondestructive examination citations and BDR 

identification. Despite their draft status, EPA determined that the number of errors in the WSPF 

and CRR showed inattention to detail. INL-CCP revised both documents and provided the 

revised draft WSPF and draft CRR. EPA examined both and found them to be adequate. 

EPA did not identify any concerns regarding the adequacy of the draft WSPF and draft CRR for 

Waste Stream IN-ID-BTO-030. Notification to EPA of availability of the final approved WSPF 

remains a T2 change. 

Summary of Acceptable Knowledge Findings and Concerns

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

addition of Waste Stream IN-ID-BTO-030 during this T1 change evaluation. 

Acceptable Knowledge Approval

Based on the results of this evaluation, EPA approves the addition of Waste Stream IN-ID-BTO030 and finds that all requirements have been met. Based on this evaluation, there are no changes 

to the AK T1 or T2 designations. Characterization of any new waste stream not approved under 

the baseline or subsequent T1 evaluations or addition of containers to an approved waste stream 

that requires changing the established radionuclide scaling factors remains a T1 change. The 

tiering designations presented in Table 1 of the final report for EPA’s 2014 continued 

compliance inspection of INL-CCP (see EPA Docket No. A-98-49; II-A4-190; July 15, 2014) 

remain in effect. 

6.2 Radiological Characterization 

EPA examined the DTC process and associated information during the continued compliance 

inspection in May 2013. Therefore, EPA limited the scope of this radiological characterization 

evaluation to those elements necessary to assess the technical adequacy of the information 

supporting characterization of Waste Stream IN-ID-BTO-030. 
12 

Waste Characterization Element Description 

EPA evaluated the radiological characterization of INL-CCP RH Waste Stream IN-ID-BTO-030 

in terms of its technical adequacy, as supported by the program’s documents, procedures and 

controls and by the knowledge and understanding of the personnel involved in the RH waste 

characterization program. During this RH evaluation, the EPA team evaluated the following 

elements of the INL-CCP radiological characterization program: 

• Overall radiological characterization. 

• Collection of representative cored samples. 

• Evaluation of measurement data to support the scaling factor development. 

• Adequacy of the modeling approach, using MicroShield

®. 

• Development of the DTC correlation and determination of radionuclides within each 

drum. 

• Uncertainty analysis. 

Each of these is discussed in the sections that follow. 

Technical Evaluation 

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

Stream IN-ID-BTO-030, as described in CCP-RC-INL-591, Revisions 0 and 1, and supporting 

calculation packages. 

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

and found them to be adequate. 

The radiological characterization process for Waste Stream IN-ID-BTO-030 uses sampling and 

laboratory analysis to determine 137Cs-based scaling factors, MicroShield® modeling, gamma 

dose measurements and density measurement to execute the DTC method. The EPA evaluation 

team prepared a flow diagram to reflect this process, shown in Figure 1, below. EPA determined 

that the radiological characterization process for Waste Stream IN-ID-BTO-030 was technically 

adequate and appropriately documented. 

Consistent with the T1 and T2 designations that were established during the baseline approval, 

any new RH waste stream not approved to date or the addition of containers to Waste Stream INID-BTO-030 that requires a radiological characterization process different from what is 

documented in CCP-RC-INL-591, Revision 1, remains a T1 change. Similarly, any change to 

CCP-RC-INL-591 that requires CBFO approval remains a T2 change 
13 

Figure 1. Radiological Characterization Flow Diagram for Waste Stream IN-ID-BTO-030 

(2) EPA found the sampling of this waste stream to be representative, technically adequate 

and appropriately documented. 

Considering the nature of the RH waste as originating from fuel specimens representing a variety 

of fuel types, INL-CCP developed a sampling and analysis plan, CCP-AK-INL-595A, to collect 

representative samples by collecting drill cuttings from each of the cemented sludges, as 

documented in two sampling BDRs. Based on reviews of sampling BDRs IDRH1101 (5 

Model the 1-m dose rate 

using MicroShield® as a 

function of waste density to 

develop a 137Cs DTC 

correlation based on a 1-Ci 

source of 137Cs 

Find the mean of 1-m dose 

rate measurements taken at 

0 ̊, 90 ̊, 180 ̊ and 270 ̊ from 

each drum surface 

Determine 137Cs activity 

content in each drum 

Sample waste using sampling 

plan 

Develop sampling plan to 

ensure adequate 

representation of waste’s 

radiological contents 

Samples are analyzed by the 

AMWTP ACL to determine 

radionuclide composition 

Review AK records to 

identify possible waste types 

Develop SFs unique to each 

grouping 

Apply SFs to determine 

drum’s radionuclide content 

Determine gamma emitters 

that contribute to 95% or 

greater of the dose rate 

Determine uncertainties in 

the calculated activities 
14 

samples) and IDRH1201 (3 samples), EPA found that INL-CCP met the objective of obtaining 

representative samples. EPA did not identify any concerns regarding the representativeness of 

the sampling of containers in Waste Stream IN-ID-BTO-030. 

(3) EPA found that the analytical data used to support the development of scaling factors 

were adequate for their intended use. 

The sampling and analysis plan for Waste Stream IN-ID-BTO-030 provided specific sampling 

guidelines, as discussed above in (2), above. INL-CCP submitted the eight samples to AMWTP’s 

ACL at INL. Laboratory analyses included alpha and gamma spectrometry, total beta counting 

and inductively coupled plasma-mass spectrometry. The ACL reported radionuclide 

concentrations in units of picocuries per gram for 137Cs, cobalt-60, europium-154, strontium-90, 

233U, 234U, 235U, 236U, 238U, plutonium-238 (238Pu), 239Pu, 240Pu, 241Pu, 242Pu, americium-241, 

curium-242 (242Cm), 244Cm and 245Cm. Due to the limitations of alpha spectrometry, which does 

not allow adequate separation of 233U/234U and 235U/236U, the ACL reported concentrations for 

these radionuclides as the sum of each pair. The ACL provided BDRs for each analytical 

technique. EPA reviewed the ACL BDRs and found them to be technically adequate. 

EPA did not identify any concerns regarding the use of the ACL radiometric and spectrometric 

data to support the development of radionuclide scaling factors for Waste Stream IN-ID-BTO030. 

(4) EPA evaluated the development of scaling factors and found it to be adequate. 

The generation of radionuclide scaling factors is documented in INL-RH-125, and INL-CCP 

performed the supporting calculations in the Excel® file, “Lot 3 Sample Data.” Supplemental 

information is contained in the post-sampling memorandum dated February 25, 2013. Based on 

the ACL analytical data, INL-CCP determined that 137Cs was the largest gamma emitter and 

contributed at least 95% of the 1-meter (m) dose rate.11 INL-CCP used 137Cs as the basis for the 

Waste Stream IN-ID-BTO-030 scaling factors and did not make adjustments for other gammaemitting radionuclides. 

INL-CCP calculated the ratios of the radionuclide activities to 137Cs activity for each sample 

using a log-normal distribution. For each radionuclide of interest, INL-CCP used the geometric 

mean of its scaling factors to represent the scaling factor for the radiological characterization of 

the waste stream. EPA reviewed the documentation supporting the scaling factor calculations 

and found it to be technically adequate and appropriately documented. EPA did not identify any 

concerns regarding the technical development and documentation of scaling factors for Waste 

Stream IN-ID-BTO-030. 

 

11 “Rem” or “millirem” is a unit of dose equivalent, which is often commonly called “dose.” Or, when it is 

expressed per unit time, “dose rate.” The criterion for RH determination is expressed in terms of a dose rate in rem, 

which, while technically incorrect, is commonly used. Additionally, gamma measurements which technically 

represent exposure in roentgens (R) or milliroentgens (mR) are commonly misstated in rem. In this report, the terms 

“dose” and “dose rate” are used in place of the technically correct term “dose equivalent” or “dose equivalent rate,” 

and the terms “R” and “rem” are used interchangeably. The actual differences among these values for the purpose of 

this report are negligible. 
15 

(5) EPA evaluated the MicroShield® modeling and dose-to-curie execution and found them 

to be adequate. 

The modeling for the development of the DTC correlation is documented in INL-RH-127, 

Revision 2, and INL-CCP performed the DTC execution calculations in the Excel® file “DTC for 

IN-ID-BTO-030.” Using MicroShield®, INL-CCP modeled a 1-curie (Ci) source of 137Cs 

uniformly distributed within the waste in seven configurations of waste packaging that reflect 

best-estimate and bounding configurations. These included three-container and four-container 

configurations and a no-lid configuration and resulted in a representative DTC factor of 96 

milliroentgens per hour per curie to be used for all four drums. 

EPA’s initial review of the assumptions used to model the waste configurations in INL-RH-127, 

Revision 0, indicated an error in the source-to-detector distance. INL-CCP provided INL-RH127and the MicroShield® modeling attachments to correct the errors and other minor changes. 

EPA determined that the modeling adequately represents the solidified wastes in Waste Stream 

IN-ID-BTO-030. 

INL-CCP executed DTC in accordance with CCP-TP-504, Revision 13, as documented in BDR 

No. INLRHDTC13009. Upon initial review, EPA determined that this BDR required minor 

changes. INL-CCP incorporated these in the May 28, 2014, revision which contained all 

appropriate elements, including the use of the single set of scaling factors for all four drums, 

successful achievement of all measurement acceptance criteria, and the review of the BDR data 

validation under CCP-TP-504, Revision 15. EPA did not identify any concerns regarding the 

execution and documentation of DTC for Waste Stream INL-ID-BTO-030. 

(6) EPA evaluated the remote-handled determinations and found them to be adequate. 

INL-CCP documented the RH determinations for containers in Waste Stream INL-ID-BTO-030 

in radiological survey reports that INL-CCP collected in April 2013. EPA reviewed the RH 

determinations for all four 55-gallon drums. All drums had contact dose rates of greater than 

3000 milliroentgens per hour, which meets the RH requirement of greater than 200 millirem per 

hour. EPA is satisfied that the four containers in Waste Stream INL-ID-BTO-030 meet the 

criteria for RH waste. 

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

BDR No. INLRHDTC13009 lists all four containers in Waste Stream INL-ID-BTO-030. INLCCP found each container to have a TRU concentration greater than 100 nanocuries per gram, as 

required to meet the definition of TRU waste. EPA is satisfied that containers in Waste Stream 

INL-ID-BTO-030 meet the criteria for TRU waste. 

(8) EPA evaluated the technical basis and documentation of total measurement uncertainty 

and found them to be adequate. 

The development of total measurement uncertainty (TMU) for Waste Stream IN-ID-BTO-030 is 

based on the propagation of uncertainties contributed by various aspects of the radiological 

characterization process. These aspects are assumed to be independent, allowing them to be 
16 

added in quadrature.12 The TMU determination included uncertainty contributions of the 

following: 

•

137Cs DTC correlation – waste density, MicroShield® code and modeling uncertainties. 

•

137Cs activity measurement (dose rate measurement) – instrument and distance 

measurement uncertainties and uncertainty in the dose contribution of other gammaemitting radionuclides. 

• Scaling factor determination – uncertainty in sample data.

A general treatment of TMU for Waste Stream IN-ID-BTO-030 is presented in CCP-RC-INL591, Revision 1, and the detailed treatment is provided in INL-RH-128. Table 7-3 of CCP-RCINL-591, Revision 1, provides an example TMU calculation. The overall uncertainties are 

consistent with what EPA has observed for RH determinations at other RH TRU generator sites. 

EPA did not identify any concerns regarding the technical adequacy or documentation of TMU 

for Waste Stream IN-ID-BTO-030. 

Summary of Radiological Characterization Findings and Concerns

EPA did not identify any radiological characterization-related findings or concerns relative to the 

addition of Waste Stream IN-ID-BTO-030 during this T1 change evaluation. 

Radiological Characterization Approval

Based on the results of this evaluation, EPA approves the addition of Waste Stream IN-ID-BTO030 and finds that all requirements have been met. Based on this evaluation, there are no changes 

to the radiological characterization T1 or T2 designations. Characterization of any new waste 

stream not approved under the baseline or subsequent T1 evaluations or addition of containers to 

an approved waste stream that requires changing the established radionuclide scaling factors 

remains a T1 change. The tiering designations presented in Table 1 of the final report for EPA’s 

2014 continued compliance inspection of INL-CCP (see EPA Docket No. A-98-49; II-A4-190; 

July 15, 2014) remain in effect. 

7.0 FINDINGS AND CONCERNS 

Summary of Findings and Concerns

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

Waste Stream IN-ID-BTO-030 during this T1 change evaluation. 

 

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

sum of the squares of the contributors to uncertainty, resulting in a lower value than what would be obtained if the 

values were simply added. For example, considering Table 7-3 of CCP-RC-INL-591, the TMU for 239Pu is derived 

by taking the square root of (42.7%)2

 plus (25.0%)2 plus (10.0%)2 plus (12.8%)2, which equals 52.1%, which is less 

than the value obtained by simply summing the individual uncertainty values (i.e., 90.5%). 
17 

8.0 CONCLUSIONS 

Changes to Tiering 

As a result of this evaluation, EPA did not make any changes to the INL-CCP RH T1 and T2 

designations that were established during the baseline approval and modified during subsequent 

T1 evaluations and continued compliance inspections. The tiering designations presented in 

Table 1 of the final report for EPA’s 2014 continued compliance inspection of INL-CCP (see 

EPA Docket No. A-98-49; II-A4-190; July 15, 2014) remain in effect and are listed as applicable 

in sections 6.1 and 6.2. 

Approval 

EPA concluded that the waste characterization processes of AK and radiological characterization 

used to characterize RH TRU Waste Stream IN-ID-BTO-030 are adequate, as evidenced by the 

records evaluated. There are no open issues relative to this T1 evaluation 

Based on the results of this evaluation, EPA approves this T1 change to add Waste Stream INID-BTO-030, consistent with the limitations specified in this report. INL-CCP may continue to 

characterize previously approved RH TRU waste consistent with the restrictions specified with 

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

ATTACHMENT A 

APPROVAL SUMMARY FOR INL-CCP REMOTE-HANDLED WASTE 

CHARACTERIZATION PROGRAM 

Approved Activity EPA Inspection Number, 

Approval Dates EPA Docket Number 

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

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

T1 Change – Approval of WIPP Waste Information 

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

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

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

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

T1 Change – Approval of High-Range Gamma Probe 

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

T1 Change – Approval of Visual Examination 

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

T1 Change – Addition of Twelve Containers to Waste 

Stream ID-ANLE-S5000 and Addition of Waste 

Stream ID-HFEF-S5400-RH 

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Addition of Lot 1B to Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

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

T1 Change – Addition of Lot 4A to Waste Stream 

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

T1 Change – Approval of Waste Stream 

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

T1 Change – Addition of Lot 2 to Waste Stream 

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

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

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

T1 Change – Addition of Lot 5C to Waste Stream IDHFEF-S5400-RH July 15, 2014 A-98-49; II-A4-186 

T1 Change Approval of Waste Stream ID-MFCSOLID-RH (Lot 5A) September 10, 2014 A-98-49; II-A4-188 

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

ATTACHMENT B 

LIST OF DOE PERSONNEL PRESENT AT EVALUATION 

Name Affiliation Audit Function/Expertise 

David Ams LANL-CO AK Expert 

Derek Ott URS Radiological Characterization Technical Expert 

Douglas M. Pruitt DOE-ID DOE Observer 

Ed Gulbransen NWP-Areva TRU Project Manager 

Irene Joo URS RH Support 

Jason Montoya LANL-CO AK Expert 

Kevin Peters SRS-CCP AK Expert 

Lisa Watson INL-CCP AK Expert 

Marcus A. Pinzel DOE DOE Observer 

Patsy Gilbert LANL-CO Site Docs 

Scott Smith INL-CCP AK Expert 

Steve Schafer CCP AK Expert 

Thomas L. Clements, Jr. CWI-INL DOE Observer 

Tom Morgan CBFO DOE Observer 
C-1

ATTACHMENT C 

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION 

Analytical Chemistry Laboratory Data Packages: ADL12027A, January 24, 2013, Alpha 

Spectrometry; ADL12027B, January 10, 2013, Radio strontium; ADL12027G, January 10, 2013, 

Gamma Spectrometry; ADL12027I, February 14, 2013, Inductively Coupled Plasma-Mass 

Spectrometry; ADL12027L, January 17, 2013, Liquid Scintillation Counting 

C127, Letter to Manager, Pittsburgh Naval Reactors Office, Re: Shipment of Special Nuclear 

Materials: PZA-CZC-3, E.F. Hlad, WAPD-DLO (E) F2069, December 14, 1987

C206, Letter to S.D. Harkness, Re: Request for Material Description and History of Thirteen 

Sludge Containers, D.I. Battista, WAPDOLO(MEL)O-860, March 17, 1989

C207, Letter to ANL, Re: Shipping Information, Westinghouse Electric Corporation, BAPL, no 

author cited, December 21, 1988 

C208, Letter to Manager, Pittsburgh Naval Reactor Office, Re: Advance Notification PZA-CZC1, E.F. Hlad, WAPD-OLO (E) F1857, May 11, 1987 

C209, Letter to Manager, Pittsburgh Naval Reactors Office, Re: Advance Notification: PZACZG-2, E.F. Hlad, WAPO-DLO (E) F1915, July 21, 1987

C210, Letter to Manager, Pittsburgh Naval Reactors Office, Re: Advance Notification: PZACZC-4, E.F. Hlad, WAPD-DLO (E) F3010, January 29, 1988 

C313, Email from Greg Smith to Lisa Watson, Re: Lot 3 sample material (with attached sample 

tracking spreadsheet titled "RCRA Samples”), Greg Smith, July 1, 2013 

CCP Calculation Package: Determination of Reportable Radionuclides, D. Ott, INL-RH-126, 

Revision 0, October 3, 2013 

CCP Calculation Package: DTC Spreadsheet Lot 3 Solidified Bettis Waste, D. Ott, INL-RH-129, 

Revision 0, August 26, 2013; Revision 3, April 22, 2014 

CCP Calculation Package: INL Lot 3 Uncertainty Analysis, D. Ott, INL-RH-128, Revision 0, 

October 3, 2013 

CCP Calculation Package: INL Solidified Waste from Bettis RH TRU Radiological Cs-137 DTC 

Correlation, D. Ott, INL-RH-127, Revision 0, September 3, 2013; Revision 2, January 22, 2014 

CCP Calculation Package: Scaling Factor Development for Lot 3 Drums, D. Ott, INL-RH-125, 

Revision 1, September 3, 2013 

CCP-AK-INL-590, Central Characterization Program Acceptable Knowledge Summary Report 

for Bettis Laboratory Remote-Handled Transuranic Waste Stored at Idaho National Laboratory 

Waste Stream IN-ID-BTO-030, Revision 3, July 31, 2013; Revision 4, March 31, 2014 
C-2

CCP-AK-INL-592, Central Characterization Program RH TRU Certification Plan for 40 CFR 

Part 194 Compliance for Bettis Laboratory Remote-Handled Transuranic Debris Waste Stored at 

the Idaho National Laboratory, Waste Stream: IN-ID-BTO-030, Revision 1, August 16, 2012; 

Revision 2, March 25, 2014 

CCP-RC-INL-544, Central Characterization Program RH TRU Certification Plan for 40 CFR 

Part 194 Compliance and Confirmation Test Plan, Revision 1, March 23, 2011 

CCP-RC-INL-591, Central Characterization Program Remote-Handled Transuranic Radiological 

Characterization Technical Report for Bettis Laboratory Remote-Handled Homogeneous Waste 

Stored at the Idaho National Laboratory, Waste Stream: IN-ID-BTO-030, Revision 0, July 18, 

2013; Revision 1, March 25, 2014 

CCP-RC-INL-595A, Central Characterization Program Radiological Sampling and Analysis 

Plan for Bettis Laboratory Remote-Handled Transuranic Waste Stored at Idaho National 

Laboratory, Waste Stream: IN-ID-BTO-030, Revision 1, February 06, 2013 

CCP-TP-005, Revision 24, Attachment 2, Record of Communication (see Reference C127) 

CCP-TP-005, Revision 24, Attachment 11, Acceptable Knowledge Source Document 

Discrepancy Resolution (see Reference DR008) 

CCP-TP-005, Revision 25, Attachment 1, Acceptable Knowledge Documentation Checklist, 

Waste Stream IN-ID-BTO-030, David Ams, July 31, 2013 

CCP-TP-005, Revision 25, Attachment 4, Acceptable Knowledge Information List, David Ams, 

July 31, 2013 

CCP-TP-005, Revision 25, Attachment 6, Waste Form, Waste Material Parameters, Prohibited 

Items, and Packaging, David Ams, July 31, 2013 

CCP-TP-005, Revision 25, Attachment 8, Waste Containers List, David Ams, July 31, 2013 

CCP-TP-005, Revision 25, Attachment 15, CCP TRU Waste Correlation and Surrogate 

Summary Form, Waste Stream IN-ID-BTO-030, Correlative Stream BT-T001, Lisa Watson, July 

31, 2013 

CCP-TP-005, Revision 26, Attachment 13, CCP Waste Stream Characterization Checklist, 

Unsigned Draft, provided November 29, 2013 

CCP-TP-504, Central Characterization Program DTC Survey Procedure for Remote-Handled 

Transuranic Waste, Revisions 13, 14 and 15 

Characterization Reconciliation Report, Unsigned Draft, file dated November 28, 2013 

Characterization Reconciliation Report, Unsigned Draft, file dated December 3, 2013 

Dose-to-curie Batch Data Report INLRHDTC13009, September 12, 2013 
C-3

DR008, Attachment 11, Acceptable Knowledge Source Document Discrepancy Report 

Resolution (Beryllium), Jim Luginbyl, December 19, 2011 

DTC for IN-ID-BTO-030 (lot 3).xls, October 17, 2013

Engineering Design File 10441, Configuration of Repackaged Bettis (Lot 3) Remote Handled 

Transuranic Waste, Revision 0, January 28, 2013 

Lot 3 Sample Data Rev 0.xls, October 17, 2013 

P100, The United States Naval Nuclear Propulsion Program, Naval Reactors, July 31, 1998 

Post-Sampling Memorandum, Analysis of Sample Data for INL Lot 3, from Jene Vance to Irene 

Joo, February 25, 2013 

Sampling Batch Data Reports: IDRH1101 (5 samples), IDRH1201 (3 samples) 

U201, News Release: Bettis Atomic Power Laboratory Celebrates 50th Anniversary, 

B.J. Schramm, undated 

U212, Operation Record of Met Cell Equivalent Gram Loss, NA, Book #2 and #3, various dates 

from March 3, 1982, to November 11, 1986 

U213, Grinding Equivalent Gram Loss Logbook No.1, dated February 1977 through February 

1981

U217, COW #3 Old Slow Speed COW, Waste Disposal Log Cell 12, March 17, 1980

U221, Materials Evaluation Laboratory Examination Forms for IN-41 Solidification, 

R.E. Bright, MEL 116 through MEL 14, April 14, 1987, to July 13, 1987

U236, COW Book #2, Waste Disposal Log, January 1973 through November 1979

U237, Logbook, COW (Diamond) Waste Disposal Log, Cell 12, Start date February 25, 1982 

through March, 1985

U256, Bettis Experimental Facilities, Bettis Hot Laboratory, November 1978 

U277, RH TRU Container Repackaging Datasheet – HFEF IDBLANL880107 and HFEF 

IDBLANL880164, Form-880 Revision 7, November 7, 2011

U366, Excerpt from Occupational Logbook for RH Solid Sampling conducted by CCP at INL, 

June 20, 2013 

Waste Stream Profile Form, Waste Stream IN-ID-BTO-030 and Summation of Aspects, 

Unsigned Draft, files dated November 28, 2013, and December 3, 2013