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z 39N3TED STATES ENV9ROF1MENT"AL PROTEC °rit7Fi AGENCY 

~ Q WASi-lIiVGYON, D.C. 20464 

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0 

OFFIGE OF 

AIR APJD RADIATION 

Dave Moody, Ph.D., Manager 

Carlsbad Field Office 

P.O. Box 3090 

Carlsbad, NM 88221 

Dear Dr. Moody: 

We have been reviewing the Department of Energy's (DOE) submittal for its 

remote-handled (RH) shielded container planned change request (EPA Docket: II-B2-31). 

In this request, DOE is proposing to emplace lead-lined waste containers (steel drums) 

with RH waste in disposal rooms in addition to plaeing RH waste in room walls as is 

presently approved. In our review we have identified doeuments that we need for our 

technical review. The attachrnent contains a list of documents that we request you 

provide to us. 

We have also listed in the attachment a few issues that need additional 

development or documentation. For example, in DOE's 1995 RH TRU Study 

(DOE/CAO 95-1095) developed for the original certification, DOE took credit for the 

emplacement of RH canisters in the wali of the disposal room. In that study credit was 

applied to the solubilities (discussed on page 27 of the report) and intrusion probability 

(discussed on page 40 of the report; see comment 9). EPA believes it is prudent for DOE 

to assure that the introduction of RH waste into the rooms does not negatively influence 

these credits in performanee assessment (PA), in the lines of reasoning used for the credit, 

or even assumptions related to repository performance. ' Thus, DOE needs to examine 

documents in which DOE may have taken credit for RH in the walls and explain how 

they affect the current PA. EPA will also continue to look for areas affected as well. 

If you have any questions on this topic, please contact Tom Peake at (202) 343- 

9765. 

InternetAddress(URL)a httpd/www.e[ra.gov 

Recycled/Recycla4le 0 Pdnted with Vegetable Oil 8ased Inks on 100%Postconsumer, Process Chlorine Free Recycied Paper 
Enclosure 

cc: Electronic Distribution 

Frank Marcinowski, DOEIEM 

George Basabilvazo, DOE/CBFO 

Russ Patterson, DOE/CBFO 

Ava Holland, DOE/CBFO 

Roger Nelson, DOE/CBFO 

Casey Gadbury, DOE/CBFO 

 Mario Chavez, SNL 

Dave Kessel, SNL 

Bev Crawford, LANL 

Tim Burns, LANL 

Steve Zappe, NMED 

EPA Docket 
ATTACHMENT 

April 2008 

First Completeness Comments on the Department of Energy's (DOE) 

submittal for its remote-handled (RH) shietded container planned change request 

1. Burns 2005 is cited in Crawford and Taggart 2007 as the sonrce of information on 

masses of some CPR materials. We were not able to locate this document on the 

CREL system and would like a copy for review. 'rhe same comment applies to 

Donner 2007. 

2. Footnote 1, page 5 of Crawford and Taggart 2007 indicates that there are "87 RH 

waste streams" while Seetion 2.2.1 of Dunagan et al. 2007 states that there are 

"77 RH waste streams." The 2004 Baseline Inventory Report (DOE/"1'R1J-2006- 

3344) also lists 77 waste streams in Table B-2. Please clarify the reason for this 

differenee. 

3. Section 5.1 of Crawford and Taggart 2007 state that activity eoncentrations were 

multiplied by gamma faetors from Shleien 1992 to identify dominant gamma 

emitters. Can DOE provide spreadsheets or other documentation that describe the 

procedures used? 

4. Section 5.1 of Crawford and Taggart aiso notes that Microshieid 6.02 was used to 

determine the maximum activity loadings for shielded containers to establish the 

maximum aetivity that would result in a dose rate of < 200 mremlhr. Can DOE 

supply spreadsheets or other doeumentation thatpresent details ofthe procedures 

used? How was eonversion from exposure (mR/hr) to dose (mrem/hr) 

accomplished? 

Section 6.2 of Crawford and Taggart 2007 states that the masses of lead and steel 

in the shielded eontainers were obtained from "Shielded Container Project 

Guidance." Please provide this documentation. 

6. Where are the input/output files for the Microshield calculations located? How do 

we obtain eopies of selected ealculations? We note that the example catculations 

used in Attachment 2 of Crawford and Taggart 2007 does not include any signoff 

that the calculations have been checked. Provide information that Microshield 

has been qualified for its intended use and documentation verifying that these 

calculations were performed adequately. 

Seetion 5.1 of Crawford and Taggart 2007 provides no referenee to the data 

source used to determine the dominant gamma emitters. Please provide us with a 

reference and a copy of the cited document. 

8. Sections 6.3 and 6.4 of Crawford and Taggart 2007 provides no reference as to 

the source of data in Tables 9 and 10. Please provide us with a reference and a 
copy of the eited document. We note that the waste stream volumes in Table 10 

are different from the waste stream volumes in DOE 2006. Please explain the 

source of the differences. 

9. From 1995 RH "I'RU Study (DOE/CAO 95-1095) 

- Solubilities diseussed on page 27 (RH Study 1995), Item I takes credit for RH 

emplacement canisters plaeed in the walls, "provide a barrier to the transport of 

radionuclides". In the conclusions on page 27 it states; "...(2) the RH-TRU waste 

 paekageandcontiguration; which wil1 F'imit brine accessibilityto waste during the 

period when RI-I radionuclides are present in high concentrations." It would seem 

appropriate that using the new emplacement configuration this reasoning needs to 

be revisited. Does any of the new documentation provided sufficient information 

to deal with this adequately? 

- Intrusion Probability: It states on page 40 of DOE/CAO 95-1095 (RH Study 

1995); "The probability for the RH-TRU aetivity level (5) is based on the relative 

area of RH-TRU waste emplacement to the total waste emplacement area." It 

also states; "the intrusions into the lower probability RI I-TRU canister must be 

calculated and the release from this intrusion must be significant in comparison to 

intrusions calculated for the range of activity of [contact-handled] CH-TRU. The 

identical CCDFs indicate that there were no significant consequences from 

intrusions into RH-TRU canisters compared to the CH-TRU activity levels." 

When one considers the new RH waste configuration it seems like this analysis 

needs to be redone. Does any of the new documentation provided sufficient 

infonnation to deal with this adequately? 

Are there other "historical" issues, such as assumptions, reasoning, or 

commitments previously made that may influence taking RH originally planned to 

be placed in the walis of rooms and plaeing this RH waste in shielded containers 

onto the floor of a disposal room? 

10. Stakeholders have voiced concerns about the possibility of the shielded container 

lead melting and not being fully protective if subjected to high temperatures that 

may be encountered with a fire. EPA believes that DOE should respond to this 

issue. We understand that lead melts at 621.5°F (327.5 °C). Would a frre in the 

repository increase the shielded container internal temperature sufficiently to melt 

lead as postulated by stakeholders? 

11. DOE has published an inventory update and that some of the inventory 

information has changed since the shielded container analysis was conducted. 

EPA believes it is appropriate to compare the new inventory data to the inventory 

data used in the calculations done to support the shielded container change request 

to determine the impact of these changes and their effect on the candidate waste 

calculation. Therefore, EPA expects DOE to compare the new inventory to the 
inventory used in the shielded container change request ealculations and 

determine the impact of these inventory changes. 

12. EPA plans to visit DOE/SNL in the near future to evaluate the shielded container 

performance assessment calculations (SCPA) done to support the shielded 

container change request. EPA will examine all aspects of these calculations to 

conflrm that they were performed properly. In addition, the Agency will verify 

that correct and qualified computer codes, parameter values, input tiles, and 

appropriate scripts were used to perform the SCPA calculations. Please provide 

 the appropriatemodeling{PA andMicroshield) documents: 

13. A key issue controlling the shipment of RH waste in shielded containers is the 

Land Withdrawal Act (LWA) requirement that the surface dose of CH waste be 

200 mrem/hr or below. EPA has been observing the implementation of 

procedures used at waste generator sites to measure the surface doses of drums. 

EPA has observed that the characterization procedure is comparable but 

implemented slightly differently between the sites. We noted at Savannah River 

Site (SRS) that the bottom of the container is actually measured by tilthlg or 

lifting with equipment, but at Los Alamos National Laboratory (LANL) they do 

not measure the bottom of the container for safety reasons. From these visits we 

have developed some initial questions. For example, how will DOE assure that 

measurements of surface dose are adequately consistent from site to site? We are 

coneerned that an errant drum may be disposed at W IPP and have to be removed 

at a later date. 

How will instrument and measurement error be ineorporated into the 

measurement process? How is this handled in current procedures? How will hot 

spots (close to one side or the bottom of the shielded container) be handled at 

each site? For example, if a CH drum has a measurement of 190 mrem/hr, given 

the potential errors, how is it treated now? We understand that for CH waste 

these issues are part of the work every day, but it seems that the limit of 200 

mrem/hr may be approached more often with RH waste. EPA believes that it is 

important that, for RH waste to be shipped and handled as CH waste at WIPP, a 

shielded container would have to be below the surface dose requirements of the 

LWA. 

References: 

Burns 2005. Estimates ofCellulose, Plastie, and Rubber Based TWBID, Revision 2.1, 

Data Version D.4.1.6, Los Alamos National Laboratory , Carlsbad NM, INV-0607-01- 

46-26. 

Crawford and Taggart 2007. Analysis of RH TR U Wastes for Containment in Lead 

Shielded Containers. Los Alamos National Laboratory, Carlsbad Operations. INV-SARO8, Revision 0. 
DOE 2006. Transuranic Waste Baseline Inventory Report-2004. DOE/TRU-2006-3344. 

Donner 2007. Specification for the RH-TRU Drum Handling Bag. Wa.shington TRU 

Solutions. CarlsbadNM, Specification E-1-473. 

Dunegan et al. 2007. Analysis Report for the Shielded Container Performance 

Assessment, Revision 1.0. Sandia National Laboratories. 

RH Study 1995. Remote-Handled Transuranic Waste Study. DOE/CAO 95-1095. 

October 1995 

Sellmer T. 2007. Final Container Design, Shielded Container. Washington TRU 

Solutions. Carlsbad NM. ERMS 547052. 

Shleien, Bernard 1992. The Health Physics and Radiologicad Flandbook, Scinta, Inc.