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 P ROGRAM

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 2014i TABLE OF CONTENTS

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

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

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

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

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

................................................... ....................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 Diagra m for Waste Stream IN-ID-BTO-030....... 13

ATTACHMENTS
Attachment A: Approval Summary for INL-CCP Remote-H andled Waste

Characterization Program Attachment B: List of DOE Personnel Present at Eva luation Attachment C: List of Documents Reviewed by EPA du ring T1 Evaluationii 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 Cent er LANL-CO Los Alamos National Laboratory Carlsbad Off ice

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 plutoniumiii

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 Characterizatio n 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 form4

1.0 INTRODUCTION
This report supports the U.S. Environmental Protect ion Agency’s (EPA’s) approval of a Tier 1 (T1) change to add Waste Stream IN-ID-BTO-030 to th e approved characterization program at the U.S. Department of Energy’s (DOE’s) Idaho Natio nal 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-A 4-72). 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 Pilo t Plant (WIPP).
EPA conducted continued compliance inspections of I NL-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 (C BFO) requested EPA approval of a T1 change to include Waste Stream IN-ID-BTO-030. EPA l imited the scope of this T1 evaluation to the components of acceptable knowledge (AK) and rad iological characterization specific to the addition of Waste Stream IN-ID-BTO-030. Because the re were no new equipment or additional new processes on site at INL as part of the T1 requ est, EPA conducted a desktop review of this change and then met with INL-CCP personnel in Denve r, Colorado, on December 3–5, 2013. EPA did not identify any findings or concerns durin g this evaluation. Subsequent to the desktop review, INL-CCP revised several documents and calcu lation packages and provided them to EPA in August 2014, 2 as discussed in section 6.0 of this report. Attach ment C is a list of all documents reviewed, including batch data reports (B DRs) and calculation packages.
As a result of this evaluation, EPA did not make an y changes to the INL-CCP RH T1 and Tier 2 (T2) designations 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) remai n 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-0 30 using the EPA-approved system of controls. This approval also includes any additiona l 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-appr oved 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 f or 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 consumi ng and resulted in considerable delay in processing this T1 evaluat ion, 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 throu gh the EPA website and by emails to the WIPPNEWS list, in accordance with Title 40 of the C ode of Federal Regulations [40 CFR 194.8(b)(3)].

2.0 PURPOSE OF TIER 1 EVALUATIONS
Certain changes to the waste characterization activ ities from the date of the site’s baseline inspection must be reported to and, if applicable, approved by EPA according to the tiering requirements set forth in 40 CFR 194.8 regulations and incorporated into the INL-CCP RH baseline final report (see EPA Docket No. A-98-49; II-A4-72).
Under the changes to 40 CFR 194.8 promulgated in th e July 16, 2004, Federal Register notice (Vol. 69, No. 136, pages 42571–42583), EPA must per form a single baseline inspection of a TRU waste generator site’s waste characterization p rogram. The purpose of EPA’s baseline inspection is to approve the site’s waste character ization program, based on the demonstration that the program’s components, with applicable cond itions and limitations, can adequately characterize TRU wastes and comply with the regulat ory requirements imposed on TRU wastes destined for disposal at the WIPP.
Following EPA’s baseline approval, EPA is authorize d to evaluate and approve changes, if necessary, to the site’s approved waste characteriz ation program by conducting additional inspections under the authority of 40 CFR 194.24(h) . Changes requiring EPA notification and approval prior to implementation (T1) and those req uiring post-implementation notification (T2) are identified in the site-specific baseline inspec tion reports and subsequent T1 evaluation reports. When evaluating proposed T1 changes for ap proval, EPA may conduct a site inspection to observe implementation of the change or can opt to conduct a desktop review of information provided specific to a change. DOE may choose to ch aracterize and dispose of any previously approved TRU waste using processes, procedures or e quipment implemented as T2 changes at risk of subsequent EPA disapproval.

3.0 PURPOSE OF THIS REPORT
This report presents the results of EPA’s evaluatio n of a T1 change to add Waste Stream 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 f or and results of EPA’s approval decision. EPA’s approval decision regarding the addition of W aste 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 radi ological characterization approach used to characterize the four RH TRU 55-gallon drums in Was te Stream IN-ID-BTO-030. Sections 6.1 and 6.2 of this report detail the AK and radiologic al 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 pe rsonnel 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 Know ledge, SC&A Rose Gogliotti Technical Evaluator – Radiological C haracterization, SC&A Patrick Kelly Technical Evaluator – Radiological C haracterization, SC&A Amir Mobasheran* Technical Evaluator – Radiologica l 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 perso nnel 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 lis ted in Attachment B.

Table 2. DOE Tier 1 Evaluation Personnel

6.0 TECHNICAL EVALUATION
Waste-Generating Activities and Packaging Configura tion
Analysis of post-irradiated nuclear fuel assemblies from the NNPP generated Waste Stream INID-BTO-030. Specifically, this Summary Category Gro up (SCG) S3000 (homogenous solids) waste stream consists of solidified particulate mat ter 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-41 4 cans. BAPL solidified the fines using Portland cement and water between 1987 and 1988. BAPL then s hipped the resulting solid, monolith

3 BAPL is located in West Mifflin, Pennsylvania.

4 The BAPL IN-41 can is a stainless steel cylinder w ith 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 Techni cal Expert Thomas Clements CWI-INL, TRU Project Manager (Evalu ation 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 stor age and later transferred them to Idaho Nuclear Technology and Engineering Center (INTEC) f or 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-ende d 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 call s “Lot 3.”
Documents, Batch Data Reports and Calculation Packa ges Provided
EPA evaluated the INL-CCP documentation that suppor ted 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 modif ications to these documents with EPA during the December 2013 meeting in Denver, Colorad o, and provided approved revised documents incorporating necessary changes to EPA in August 2014. EPA reviewed the revised documents prior to completing this report. Specific ally, the primary documents supporting AK and radiological characterization required revision s and these revisions took approximately seven months to complete due to the public utterance proc ess 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 evalua tion, including BDRs and calculation packages, are cited in different sections throughou t the report and are listed in Attachment C. Any of these documents can be requested from the fo llowing address:
Manager, National TRU Sites and Transportation Divi sion 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 an d AK process and associated information during the continued compliance inspect ion in May 2013. Therefore, EPA limited the scope of this AK evaluation to those elements n ecessary to assess the technical adequacy of the information supporting the addition of Waste St ream 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 Ho t 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 ele ments listed below.

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

• Identification of the Waste Characterization Progra m Implementation Plan (WCPIP) 7 waste characterization process.

• Adequacy of the certification plan and other WCPIP documentation.

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

• Role of AK in the characterization methodology, inc luding 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) an d related attachments.

Technical Evaluation
(1) EPA examined the waste stream determination for Was te 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 str eam is adequately defined.
As described in section 6.0 of this report, Waste S tream IN-ID-BTO-030 contains solidified particulate matter and pieces produced by sectionin g, 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 was te stream’s two predominant radionuclides by mass are thorium-232 (76.92%) and uranium-235 ( 235 U) (21.16%). The two predominant radionuclides by activity are cesium-137 ( 137 Cs) (17.73%) and yttrirum-90 (17.51%) (References CCP-AK-INL-590, Revision 4, and C127, C206, C207, C 208, 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 t o 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 Mex ico, September 19, 2012.9

(2) INL-CCP identified the waste characterization pathw ay, and documentation of the approach is adequate.
The certification plan for Waste Stream IN-ID-BTO-0 30 (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 certific ation plan also presents quality assurance objectives (QAOs) and data quality objectives relat ed to container acceptance criteria, physical properties acceptance criteria, physical form, surf ace dose rate, TRU alpha activity concentration, radionuclide activity and waste orig in.
The certification plan indicates that INL-CCP sampl ed the 13 IN-41 cans during two separate events. INL-CCP performed the first event to suppor t Resource Conservation and Recovery Act (RCRA) 8 constituent analysis required by the waste analysi s plan (WAP). 9 When the Advanced Mixed Waste Treatment Project’s (AMWTP’s) Analytica l Chemistry Laboratory (ACL) at INL determined that eight samples were required for rad ionuclide 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 requi rements 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 revis ion with respect to sampling representativeness and RH determination QAOs for precision, accuracy a nd completeness. The certification plan also required revision to address AK QAOs associate d with defense, HLW and SNF determinations. INL-CCP provided the March 2014 rev ision of the certification plan (CCP-AKINL-592, Revision 2) on July 31, 2014, and EPA dete rmined that it addressed all pertinent issues as well as other editorial and technical clarificat ions.
EPA did not identify any concerns regarding INL-CCP ’s documentation of the characterization pathway. Notification to EPA of availability of a r evised certification plan remains a T2 change.
(3) EPA examined the waste stream information that supp orts the absence of spent nuclear fuel or high-level waste in this waste stream and f ound it to be adequate.
The WIPP Land Withdrawal Act prohibits the disposal of SNF and HLW as defined by the Nuclear Waste Policy Act at the WIPP. Waste Stream IN-ID-BTO-030 consists of solidified fuel fines, swarf 10 and other fragments generated through destructive examination of test specimens of spent fuel from various sources. The waste is no t 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, U2 01, 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 Env ironment Department.

10 Swarf is material produced by a cutting or grinding proc ess.10

EPA did not identify concerns regarding INL-CCP’s d ocumentation of the absence of SNF and HLW in Waste Stream IN-ID-BTO-030.
(4) EPA examined the information supporting that the wa ste stream is defense in origin and found it to be adequate.
Revision 3 of the AKSR provided evidence to demonst rate that Waste Stream IN-ID-BTO-030 contains materials from atomic energy activities as sociated 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 unclearregarding 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 ade quately 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 knowl edge procedure and related attachments and found them to be adequate.

CCP-TP-005 includes several attachments that docume nt AK requirements. EPA found that the indicated waste generation dates differed between t he AKSR, Revision 3; CCP-TP-005, Attachment 8, “Waste Containers List”; and other re ferences. 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 review ed 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 rega rding INL-CCP’s implementation of the appropriate AK attachments for Waste Stream IN-ID-B TO-030.
(6) EPA examined the acceptable knowledge summary repor t, associated source documents and reference list and found them to be adequate.
Upon initial evaluation, EPA determined that the AK SR, 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 determinati on process.

• More thoroughly reference the HFEF repackaging proc ess.

• Better describe the location and activities associa ted 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 ref erence list and found them to be adequate. EPA compared CCP-TP-005, Attachment 1; CCP-TP-005, Attachment 4; and the AKSR11

reference list to determine whether the AK referenc e 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 ade quacy 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 an d attachments and found them to be adequate.

EPA’s review of the draft WSPF indicated that it co ntained several inconsistencies and errors, including waste stream volume, footnotes and docume nt citations. The draft Characterization Reconciliation Report (CRR) also contained several errors, including identification of the SCG, citations for the defense determination, nondestruc tive examination citations and BDR identification. Despite their draft status, EPA det ermined that the number of errors in the WSPF and CRR showed inattention to detail. INL-CCP revis ed 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 ade quacy 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 Concer ns The EPA evaluation team did not identify any AK-rel ated 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 approv es 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 o f any new waste stream not approved under the baseline or subsequent T1 evaluations or additi on 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 fi nal 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 informa tion during the continued compliance inspection in May 2013. Therefore, EPA limited the scope of this radiological characterization evaluation to those elements necessary to assess th e technical adequacy of the information supporting characterization of Waste Stream IN-ID-B TO-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 characterizati on program:

• Overall radiological characterization.

• Collection of representative cored samples.

• Evaluation of measurement data to support the scali ng factor development.

• Adequacy of the modeling approach, using MicroShiel d ®

.

• Development of the DTC correlation and determinatio n of radionuclides within each drum.

• Uncertainty analysis.

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

Technical Evaluation
EPA evaluated the adequacy of the radiological char acterization process specific to Waste Stream IN-ID-BTO-030, as described in CCP-RC-INL-59 1, Revisions 0 and 1, and supporting calculation packages.
(1) EPA evaluated the overall radiological characteriza tion process and its documentation and found them to be adequate.
The radiological characterization process for Waste Stream IN-ID-BTO-030 uses sampling and laboratory analysis to determine 137 Cs-based scaling factors, MicroShield ® modeling, gamma dose measurements and density measurement to execut e the DTC method. The EPA evaluation team prepared a flow diagram to reflect this proces s, 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 wer e 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 characteriz ation 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 change13

Figure 1. Radiological Characterization Flow Diagra m for Waste Stream IN-ID-BTO-030
(2) EPA found the sampling of this waste stream to be r epresentative, technically adequate and appropriately documented.
Considering the nature of the RH waste as originati ng from fuel specimens representing a variety of fuel types, INL-CCP developed a sampling and ana lysis 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 o f sampling BDRs IDRH1101 (5 Model the 1-m dose rate using MicroShield ® as a function of waste density to develop a 137 Cs DTC correlation based on a 1-Ci source of 137 Cs Find the mean of 1-m dose rate measurements taken at 0 ̊, 90 ̊, 180 ̊ and 270 ̊ from each drum surface

Determine 137 Cs 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 activities14

samples) and IDRH1201 (3 samples), EPA found that I NL-CCP met the objective of obtaining representative samples. EPA did not identify any co ncerns regarding the representativeness of the sampling of containers in Waste Stream IN-ID-BT O-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-C CP 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. T he ACL reported radionuclide concentrations in units of picocuries per gram for 137 Cs, cobalt-60, europium-154, strontium-90, 233 U, 234 U, 235 U, 236 U, 238 U, plutonium-238 ( 238 Pu), 239 Pu, 240 Pu, 241 Pu, 242 Pu, americium-241, curium-242 ( 242 Cm), 244 Cm and 245 Cm. Due to the limitations of alpha spectrometry, w hich does not allow adequate separation of 233 U/ 234 U and 235 U/ 236 U, the ACL reported concentrations for these radionuclides as the sum of each pair. The AC L 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 sca ling factors for Waste Stream IN-ID-BTO030.
(4) EPA evaluated the development of scaling factors an d found it to be adequate.
The generation of radionuclide scaling factors is d ocumented 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 memor andum dated February 25, 2013. Based on the ACL analytical data, INL-CCP determined that 137 Cs was the largest gamma emitter and contributed at least 95% of the 1-meter (m) dose ra te. 11 INL-CCP used 137 Cs 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 a ctivities to 137 Cs activity for each sample using a log-normal distribution. For each radionucl ide of interest, INL-CCP used the geometric mean of its scaling factors to represent the scalin g factor for the radiological characterization of the waste stream. EPA reviewed the documentation su pporting the scaling factor calculations and found it to be technically adequate and appropr iately documented. EPA did not identify any concerns regarding the technical development and do cumentation 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 do se rate in rem, which, while technically incorrect, is commonly use d. Additionally, gamma measurements which technical ly represent exposure in roentgens (R) or milliroentge ns (mR) are commonly misstated in rem. In this repo rt, the terms “dose” and “dose rate” are used in place of the tec hnically correct term “dose equivalent” or “dose eq uivalent rate,” and the terms “R” and “rem” are used interchangeabl y

. 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 the m to be adequate.
The modeling for the development of the DTC correla tion 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 137 Cs uniformly distributed within the waste in seven con figurations of waste packaging that reflect best-estimate and bounding configurations. These in cluded three-container and four-container configurations and a no-lid configuration and resul ted in a representative DTC factor of 96 milliroentgens per hour per curie to be used for al l four drums.
EPA’s initial review of the assumptions used to mod el the waste configurations in INL-RH-127, Revision 0, indicated an error in the source-to-det ector distance. INL-CCP provided INL-RH127and the MicroShield ® modeling attachments to correct the errors and oth er minor changes. EPA determined that the modeling adequately represe nts 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 determi ned 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 sing le set of scaling factors for all four drums, successful achievement of all measurement acceptanc e criteria, and the review of the BDR data validation under CCP-TP-504, Revision 15. EPA did n ot 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 contai ners in Waste Stream INL-ID-BTO-030 in radiological survey reports that INL-CCP collect ed in April 2013. EPA reviewed the RH determinations for all four 55-gallon drums. All dr ums had contact dose rates of greater than 3000 milliroentgens per hour, which meets the RH re quirement 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 fo und 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 concentratio n greater than 100 nanocuries per gram, as required to meet the definition of TRU waste. EPA i s 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 (T MU) for Waste Stream IN-ID-BTO-030 is based on the propagation of uncertainties contribut ed by various aspects of the radiological characterization process. These aspects are assumed to be independent, allowing them to be16

added in quadrature. 12 The TMU determination included uncertainty contrib utions of the following:

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

• 137 Cs activity measurement (dose rate measurement) – i nstrument and distance measurement uncertainties and uncertainty in the do se contribution of other gammaemitting radionuclides.

• Scaling factor determination – uncertainty in sampl e data.
A general treatment of TMU for Waste Stream IN-ID-B TO-030 is presented in CCP-RC-INL591, Revision 1, and the detailed treatment is prov ided in INL-RH-128. Table 7-3 of CCP-RCINL-591, Revision 1, provides an example TMU calcul ation. The overall uncertainties are consistent with what EPA has observed for RH determ inations at other RH TRU generator sites. EPA did not identify any concerns regarding the tec hnical adequacy or documentation of TMU for Waste Stream IN-ID-BTO-030.
Summary of Radiological Characterization Findings a nd Concerns
EPA did not identify any radiological characterizat ion-related findings or concerns relative to the addition of Waste Stream IN-ID-BTO-030 during this T1 change evaluation.
Radiological Characterization Approval
Based on the results of this evaluation, EPA approv es 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 desig nations. Characterization of any new waste stream not approved under the baseline or subsequen t 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 prese nted in Table 1 of the final report for EPA’s 2014 continued compliance inspection of INL-CCP (se e 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 findin gs or concerns relative to the addition of Waste Stream IN-ID-BTO-030 during this T1 change ev aluation.

12 Adding in quadrature is a standard statistical tec hnique that allows one to consider the square root of the sum of the squares of the contributors to uncertain ty, resulting in a lower value than what would be o btained if the values were simply added. For example, considering Table 7-3 of CCP-RC-INL-591, the TMU for 239 Pu 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 indiv idual uncertainty values (i.e., 90.5%).17

8.0 CONCLUSIONS
Changes to Tiering
As a result of this evaluation, EPA did not make an y changes to the INL-CCP RH T1 and T2 designations that were established during the basel ine approval and modified during subsequent T1 evaluations and continued compliance inspections . The tiering designations presented in Table 1 of the final report for EPA’s 2014 continue d compliance inspection of INL-CCP (see EPA Docket No. A-98-49; II-A4-190; July 15, 2014) remai n in effect and are listed as applicable in sections 6.1 and 6.2.
Approval
EPA concluded that the waste characterization proce sses 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 relativ e to this T1 evaluation
Based on the results of this evaluation, EPA approv es this T1 change to add Waste Stream INID-BTO-030, consistent with the limitations specifi ed in this report. INL-CCP may continue to characterize previously approved RH TRU waste consi stent 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 Febru ary 12, 2007 A-98-49; II-A4-80 T1 Change – Approval of K Cell Wastes January 1, 20 08 A-98-49; II-A4-97 T1 Change – Approval of High-Range Gamma Probe for DTC April 11, 2008 A-98-49; II-A4-98 T1 Change – Approval of Visual Examination Technique September 22, 2009 A-98-49; II-A4-118 T1 Change – Addition of Twelve Containers to Waste Stream ID-ANLE-S5000 and Addition of Waste Stream ID-HFEF-S5400-RH February 1, 2010 A-98-49; II-A4-122

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

2013 Continued Compliance Inspection July 16, 2013 A-98-49; II-A4-175T1 Change – Approval of Waste Stream ID-EBRS5000 April 16, 2014 A-98-49; II-A4-183T1 Change – Addition of Lot 5C to Waste Stream IDHFEF-S5400-RH July 15, 2014 A-98-49; II-A4-186T1 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-A4-190B-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 Technic al 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 ObserverC-1 ATTACHMENT C

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUAT ION
Analytical Chemistry Laboratory Data Packages: ADL1 2027A, January 24, 2013, Alpha Spectrometry; ADL12027B, January 10, 2013, Radio st rontium; ADL12027G, January 10, 2013, Gamma Spectrometry; ADL12027I, February 14, 2013, I nductively Coupled Plasma-Mass Spectrometry; ADL12027L, January 17, 2013, Liquid S cintillation 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 Mate rial Description and History of Thirteen Sludge Containers, D.I. Battista, WAPDOLO(MEL)O-860 , March 17, 1989
C207, Letter to ANL, Re: Shipping Information, West inghouse Electric Corporation, BAPL, no author cited, December 21, 1988
C208, Letter to Manager, Pittsburgh Naval Reactor O ffice, 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, 1 988
C313, Email from Greg Smith to Lisa Watson, Re: Lot 3 sample material (with attached sample tracking spreadsheet titled "RCRA Samples”), Greg S mith, July 1, 2013
CCP Calculation Package: Determination of Reportabl e Radionuclides, D. Ott, INL-RH-126, Revision 0, October 3, 2013
CCP Calculation Package: DTC Spreadsheet Lot 3 Soli dified Bettis Waste, D. Ott, INL-RH-129, Revision 0, August 26, 2013; Revision 3, April 22, 2014
CCP Calculation Package: INL Lot 3 Uncertainty Anal ysis, 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, Septem ber 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 Ac ceptable Knowledge Summary Report for Bettis Laboratory Remote-Handled Transuranic Wa ste Stored at Idaho National Laboratory Waste Stream IN-ID-BTO-030, Revision 3, July 31, 20 13; Revision 4, March 31, 2014C-2

CCP-AK-INL-592, Central Characterization Program RH TRU Certification Plan for 40 CFR Part 194 Compliance for Bettis Laboratory Remote-Ha ndled 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, Rev ision 1, March 23, 2011
CCP-RC-INL-591, Central Characterization Program Re mote-Handled Transuranic Radiological Characterization Technical Report for Bettis Labora tory Remote-Handled Homogeneous Waste Stored at the Idaho National Laboratory, Waste Stre am: IN-ID-BTO-030, Revision 0, July 18, 2013; Revision 1, March 25, 2014
CCP-RC-INL-595A, Central Characterization Program R adiological Sampling and Analysis Plan for Bettis Laboratory Remote-Handled Transuran ic 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 Co mmunication (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 K nowledge Documentation Checklist, Waste Stream IN-ID-BTO-030, David Ams, July 31, 201 3
CCP-TP-005, Revision 25, Attachment 4, Acceptable K nowledge 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 Contai ners List, David Ams, July 31, 2013
CCP-TP-005, Revision 25, Attachment 15, CCP TRU Was te Correlation and Surrogate Summary Form, Waste Stream IN-ID-BTO-030, Correlati ve Stream BT-T001, Lisa Watson, July 31, 2013
CCP-TP-005, Revision 26, Attachment 13, CCP Waste S tream Characterization Checklist, Unsigned Draft, provided November 29, 2013
CCP-TP-504, Central Characterization Program DTC Su rvey Procedure for Remote-Handled Transuranic Waste, Revisions 13, 14 and 15
Characterization Reconciliation Report, Unsigned Dr aft, file dated November 28, 2013
Characterization Reconciliation Report, Unsigned Dr aft, file dated December 3, 2013
Dose-to-curie Batch Data Report INLRHDTC13009, Sept ember 12, 2013C-3

DR008, Attachment 11, Acceptable Knowledge Source D ocument 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 Rep ackaged 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 Pr ogram, Naval Reactors, July 31, 1998
Post-Sampling Memorandum, Analysis of Sample Data f or 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, d ated 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 F orms 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, Ce ll 12, Start date February 25, 1982 through March, 1985
U256, Bettis Experimental Facilities, Bettis Hot La boratory, November 1978
U277, RH TRU Container Repackaging Datasheet – HFEF IDBLANL880107 and HFEF IDBLANL880164, Form-880 Revision 7, November 7, 201 1
U366, Excerpt from Occupational Logbook for RH Soli d Sampling conducted by CCP at INL, June 20, 2013
Waste Stream Profile Form, Waste Stream IN-ID-BTO-0 30 and Summation of Aspects, Unsigned Draft, files dated November 28, 2013, and December 3, 2013