EPA DOCKET NO: A-98-49, II-A4-126

WASTE CHARACTERIZATION REPORT

EPA TIER 1 EVALUATION

OF THE CENTRAL CHARACTER IZATION PROJECT (CCP)

REMOTE-HANDLED TRANSURANIC WA STE CHARACTERIZATION PROGRAM AT THE IDAHO NATIONAL LABORATORY (INL):

ADDITION OF WASTE STREAM ID-MFC-S5400-RH

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

June 2010TABLE OF CONTENTS

Section Page

Acronyms....................................................................................................................... ................. ii

1.0 Executive Summary.............................................................................................................1

2.0 Purpose of Tier 1 Evaluation ...............................................................................................3

3.0 Scope of the Tier 1 Evaluation.............................................................................................3

4.0 Evaluation of New RH Wast e Stream ID-MFC-S5400-RH................................................4

4.1 Acceptable Knowledge ............................................................................................5

4.2 Radiological Characterization................................................................................13

4.3 Real-Time Radiography (RTR) .............................................................................20

4.4 Visual Examination (VE).......................................................................................20

5.0 Findings and Concerns.......................................................................................................21

6.0 Conclusions........................................................................................................................21

ATTACHMENTS

Attachment A: Approval Summary for IN L-CCP RH Waste Characterization Program Attachment B: Listing of Documents Reviewed

iACRONYMS

AK acceptable knowledge

AKE acceptable knowledge expert

AKSR acceptable knowledge summary report

Am americium

ANL Argonne National Laboratory

ANL-W Argonne National Laboratory– West

ATR Advanced Test Reactor

BDR batch data report

CBFO Carlsbad Area Field Office

Ce cerium

CFR Code of Federal Regulations

CH contact-handled

Ci curie

CRR Characterization R econciliation Report

Cs cesium

CSSF Correlation and Surrogate Summary Form

CTP Confirmatory Test Plan

CWI CH2M-WG Idaho, LLC

DAW dry active waste

DOE U.S. Department of Energy

DQO data quality objective

DR discrepancy resolution

DTC dose-to-curie

EBR experimental breeder reactor

EPA U.S. Environmental Protection Agency

FCF Fuel Conditioning Facility

g gram

g/cc gram per cubic centimeter

g/cm 3 grams per cubic centimeter

HFEF Hot Fuel Examination Facility

HLW high-level waste

iiID Idaho

IFR integ ral fast reactor

INL Idaho National Laboratory

INTEC Idaho Nuclear Technology and Engineering Center

IWTS Integrated Waste Tracking System

L&O Laboratory and Office

LANL Los Alamos National Laboratory

LLW low-level waste

LWA Land Withdrawal Act

LWBR light-water breeder reactor

MCNP5 Monte Carlo N-Particle Tran sport Code RSICC Computer Code Collection, Oak Ridge National Laboratory

MFC Materials and Fuel Complex

mR/hr milli Roentgen per hour

MWD/MTIHM megawatt days per metric ton of initial heavy metal

Nb niobium

nCi/g nanocurie per gram

NCR non-conformance report

NDA nondestructive assay

NRF Naval Reactors Facility

NWPA Nuclear Waste Policy Act

ORIGEN Oak Ridge Isotope Generation

ORNL Oak Ridge National Laboratory

Pu plutonium

RERTR Reduced Enrichment Research and Test Reactor

RH remote-handled

RMWSF Radioactive Mixed Waste Staging Facility

RTR real-time radiography

RWMC Radiological Wast e Management Complex

SCG Summary Category Group

SF Scaling Factor

SNF spent nuclear fuel

SPM Site Project Manager

iiiiv Sr strontium

T1 Tier 1

T2 Tier 2

TREAT Transient Reactor Test Facility

TRU transuranic

TSFU Total Scaling Factor Uncertainty

U uranium

VE visual examination

WC waste characterization

WCPIP Waste Characterization Pr ogram Implementation Program

WIPP Waste Isolation Pilot Plant

WMC waste matrix code

WMP waste material parameter

WSPF Waste Stream Profile Form

WWIS WIPP Waste Information System

Zr zirconium1.0 EXECUTIVE SUMMARY

This report supports the U.S. E nvironm ental Protection Agency’s (EPA or the Agency) approval of retrievably-stored, remote-handled (RH) transuranic (TRU) heterogeneous debris (S5400) from one additional waste stream from the Department of Energy’s (DOE) Idaho National Laboratory (INL). Specifically, this approval supports the addition of Waste Stream ID-MFCS5400-RH.

On January 19, 2010, the Carlsbad Field Office ( CBFO) requested that EPA review a proposed Tier 1 (T1) change addressing the add ition of RH Waste Stream ID-MFC-S5400-RH.

This approval is specific to eight containers. Any addition of containers to the approved waste stream requires CBFO and INL-CCP to submit a T1 change request and receive EPA approval prior to their disposal at the Wa ste Isolation Pilot Plant (WIPP).

The Central Characterization Proj ect (CCP) is responsible for ch aracterizing the above wastes using the system of controls, which EPA evalua ted during the baseline inspection conducted in July 2006 and approved in January 2007 and as described in documentation accompanying this Tier 1 request. A summary of EPA’s approva l of the INL RH TRU waste characterization program is included as Attachment A. Because there were no new equipment or processes on site at INL to examine, EPA conducted a desktop review of this change in April and May 2010.

This report presents the results of the T1 evaluation. Section 4.0 discusses EPA’s evaluation of

the addition of Waste Stream ID-MFC-S5400-RH . EPA did not identify any findings or concerns during this T1 evalua tion and no open issues remain re lative to this T1 change. EPA has not identified any tiering changes during th e course of this eval uation, however, the tiering tables provided in previous INL RH reports did not sufficiently address nondestructive examination (NDE) T1 changes. Additionally, the scope of this evaluation did not explicitly include an evaluation of NDE but it became apparent that this was needed and NDE was assessed as part of this evaluati on. Therefore, this report include s an up-to-date tiering table as Table 1 of this report. EPA de termines that the procedures a nd processes used by INL-CCP for

the characterization of Waste Stream ID-MFC -S5400-RH are adequate. EPA, therefore, approves the addition of eight containers from Waste Stream ID-MFC-S5400-RH to INL-CCP’s RH baseline approval as a T1 change. 1 The addition of any other RH debris waste other than what is described in this report to this wa ste stream remains a T1 change requiring EPA approval.

1 The scope of this T1 evaluation includes eight 55-gallon drums from Waste Stream ID-MFC-S5400-RH. These eight drums were originally 4 55-gallon drums containing 48 1 or 2- gallon cans whose contents were repackaged directly into 30-gallon drums, which were then overpacked into 55-gallon drums for a total of 8 drums.

See Section 4.0.

12Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Revised May 12, 2010)1RH Process ElementsINL-CCP RH Process - T1 ChangesINL-CCP RH Process - T2 Changes2Acceptable Knowledge (AK)Addition of containers toapproved waste streamsAny new waste streams not approved under this baselineSubstantive modification(s)3that have the potential to affect thecharacterization process: CCP-AK-INL-500, CCP-AK-INL-501,or CCP-AK-INL-502Load management for any RH waste streamNotification to EPA when AKSRs, Radiological Characterization Reports andCertification Confirmation Test Plans (e.g., CCP-INL-AK-500, CCP-INL-AK501, and CCP-INL-AK-502) updates are approved by CBFONotification to EPA when changes to AK documentation as a result of WCPIPrevisions have been made (e.g., CRR)4Notification to EPA when a Correlation or Surrogate Summary Form iscompleted for each of the RH containers in this waste stream identified as CH,based upon measured dose rates that present NDA results for assayed containersNotification to EPA once waste stream data package for debris waste stream andany modifications to the WSPF, including the CRR and AK Summary, arecompletedNotification to EPA that the final Dose-to-Curie (DTC) determination iscomplete for RH containers numbers728 through 737, as identified in AKReference P030AK accuracy reports (prepared annually, at a minimum)Radiological Characterization, including Doseto-Curie (DTC)Application of new scaling factors for isotopic determination otherthan those documented in CCP-AK-INL-501Use of any alternate radiological characterization procedure otherthan DTC with established scaling factors as documented in CCPTP-504 or substantive modification of the DTC procedure3Any new waste stream not approvedunder this baseline or additionof containers to Waste StreamID-ANLE-S5000 that requireschanging the established radionuclide scaling factorsNotification to EPA upon completion ofrevisions of CCP-AK-INL-501 or CCPTP-504 that require CBFO approvalVisual Examination of audio/video media (VE)Use of VE to characterize additional debris waste streams orwaste from other Summary Waste CategoriesNoneReal-Time Radiography (RTR)Any new S5000 waste stream other than ID-ANLE-S5000 orwastes from an S3000 or S4000 waste streamNotification to EPA prior toaddition of a new RTR unit(s)Notification to EPA upon completion ofchanges to RTR procedure(s) thatrequire CBFO approvalWIPP Waste Data System, WDS (previouslyknown as WWIS)NoneChanges made to WDS procedure(s) that require CBFO approvalNotes:1This table has been modified by deleting the references to specific sections of the baseline inspection report where each T1 orT2 element is discussed; additions to the original tiering table from the2007 baseline inspection appear inbold.2INL-CCP will report all T2 changes to EPA every three months.3Substantive modificationrefers to a change with the potential toaffect INL-CCP’s RH WC process, e.g., the use of an inherently different type of measurement instrument or the use of the high-rangeprobe as described in CCP-TP-504.4Excluding changes that are editorial in nature or are required to address administrative concerns.2.0 PURPOSE OF TIER 1 EVALUATION

Certain chan ges to the waste characterization act ivities from the date of the site’s baseline inspection must be reported to and, if a pplicable, approved by EPA according to the tiering requirements set forth in 40 CFR 194.8 regulatio ns and incorporated in the INL-CCP RH Baseline Final Report cited in Attachment A.

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004 Federal Register notice, EPA must perform a single ba seline inspection of a TRU waste generator site’s waste characterization program (Vol. 69, No. 136, pages 42571–42583, July 16, 2004). The purpose of EPA’s baseline inspection is to approve the s ite’s waste characterization program, based on the demonstration that the program’s components, w ith applicable conditions and limitations, can adequately characterize TRU wastes and comply with the regulatory requirements imposed on

TRU wastes destined for di sposal at the WIPP.

Following EPA’s baseline approval, EPA is author ized to evaluate and approve changes, if necessary, to the site’s approved waste char acterization program by conducting additional inspections under the authority of 40 CFR 194.24(h). Changes requiring EPA notification and approval prior to implementation (T1), a nd those requiring post-implementation (T2) notification, are iden tified in the site-speci fic baseline inspection reports. When evaluating proposed T1 changes for approval, EPA may conduc t a site inspection to observe first-hand the implementation of the change, or can opt to condu ct a “desktop” review of information provided specific to a change. DOE may choose to characteri ze and dispose of, at risk of subsequent EPA disapproval, any previously approved TRU wa ste using processes/procedures/equipment implemented as T2 changes. EPA reviews T2 changes on a quarterly basis and EPA may conduct continued compliance inspections to evaluate implemented T2 changes to verify adequacy.

3.0 SCOPE OF THE TIER 1 EVALUATION

This T1 evaluation encompassed the additi on of the following INL RH waste stream :

 Waste Stream ID-MFC-S5400-RH consis ting of eight 55-gallon drums

The evaluation of this waste stream included four waste characterization areas: 1) AK, 2) radiological characterization, 3) RT R, and 4) VE, each of which is addressed separately in this report. The initial scope did not explicitly identify RTR or VE as areas to be assessed, however during the evaluation it became apparent that thes e areas were relevant. Accordingly, VE and

RTR were assessed and the results of these asse ssments are included in this report. Personnel who participated in the T1 eval uation are listed in Table 2, alo ng with each person’s affiliation and function during the evaluation.

3Table 2. T1 Evaluation Participants

Name Affiliation & Function

Edward Feltcorn Lead Inspector, U. S. EPA
Rajani Joglekar Inspector, U. S. EPA

Kira Darlow Technical Evaluato r – Acceptable Knowledge, SC&A

Connie Walker Technical Evaluato r – Acceptable Knowledge, SC&A
Patrick Kelly Technical Evaluator – Radiological Characterization, SC&A

Amir Mobasheran Technical Evaluator – Radiological Characterization, SC&A
Dorothy Gill Technical Evaluator – Real Time Radiography and Visual Examination, SC&A

Scott Smith Acceptable Knowledge Expert, INL-CCP
Irene Quintana Site Project Manager, INL-CCP

Jene Vance Radiological Character ization Subject Matter Expert, CCP

4.0 EVALUATION OF NEW RH WA STE STREAM ID-MFC-S5400-RH

Waste Stream ID-MFC-S5400-RH consists of 48 cans (1-2 gallons in size) of RH TRU heterogeneous debris waste that was packaged into four 55-gallon drum s from March to April, 1988. From August 14-17, 2009, the cans were repackag ed into eight 30-gallon drums, each of which was then overpacked into a 55-gallon drum without a 90-mil rigid liner. The total volume of waste is approximately 1.7 cubic meters.

The wastes consist of bags, blotter paper, bottle s/beakers, containers, equipment/tools, hardware, rags, tubing, etc. Waste Stream ID-MFC-S5400-RH may also contain lesser amounts (less than 50 percent volume in any container) of homogeneous solids. The materials were generated from analytical chemistry operations, including destructive examinations and cell decontamination, conducted in the Materials and Fuel Complex (MFC) Laboratory and Office (L&O) Building Analytical Laboratory hot cells from Septem ber 1987 to March 1988. The waste is currently stored at the Idaho Nuclear Technology and E ngineering Center (IN TEC) Radioactive Mixed Waste Staging Facility (RMWSF), Building CPP-1617.

Fuel pins examined in the Analytical Laborat ory during this time period were from the Fast Breeder Fuel Program (EBR-II), Light Water Breeder Reactor Program (LWBR), Reduced Enrichment for Research and Test Reactors (R ERTR) Program, and the Transient Reactor Test Facility (TREAT) [see AK sections (4) and (5 ) for discussions of TRU and defense waste designations]. The contaminants mainly consis t of the waste generated during the examination

of 15 fuel elements from the fast breeder fu el program (three from subassembly X421 and 12 from subassembly X423), four fuel elements fr om LWBR, and three (un-ir radiated) fuel plates from the RERTR Program. For the fuel pins in subassembly X421, the burnup values ranged from 8.49% to 9.24%. For the fuel pins in s ubassembly X423, the bur nup values ranged from 1.9% to 5.20%. The burnup for the LWBR pins ranged from 6,413 to 12,675 megawatt days per metric ton of initial heavy metal (MWD/MTIHM). Compared to the fast breeder or light water breeder reactor fuel pins, RERTR plates are sma ller and generally contain significantly less fuel

material. The contribution of the three RERTR fu el plates was reduced by a factor of 8.6 to a statistically equivalent basis, increasing the tota l number of fuel pins examined by 0.35 (35%).

4The scope of this T1 evaluation includes eigh t 55-gallon drum s from Waste Stream ID-MFCS5400-RH. These eight drums were originally four 55-gallon dr ums containing 48 1- or 2-gallon cans whose contents were repackaged direc tly into 30-gallon drums, which were then overpacked into 55-gallon drums for a total of ei ght drums. A separate T1 change approval request will be needed for any additional drums.

Documents, Waste Containers, and Batch Data Reports Reviewed

Several attachments, source documents, required forms, and other data were provided to EPA, and relevant sources were examined as part of this T1 inspecti on. The listing of all documentation examined is in Attachment B, and th e list of batch data re ports (BDRs) examined is presented in Table 3.

Table 3. Batch Document Reports Examined

Drum Number RTR/VE BDR Number DTC BDR Number

IDAWANL880064A RHINLVE090003 INLRHDTC09009

IDAWANL880064B RHINLVE090003 INLRHDTC09009

IDAWANL880134A INLRHRTR09009 INLRHDTC09009

IDAWANL880134B INLRHRTR09009 INLRHDTC09009

IDAWANL880068A INLRHRTR09009 INLRHDTC09009

IDAWANL880068B INLRHRTR09009 INLRHDTC09009

IDAWANL880065A INLRHRTR09009 INLRHDTC09009

IDAWANL880065B INLRHRTR09009 INLRHDTC09009

4.1 Acceptable Knowledge

EPA exam ined the AK process and associated information to determine whether INL-CCP demonstrated compliance with 40 CFR 194.8 requirements for RH Waste Stream

ID-MFC-S5400-RH.

Waste Characterization Element Description

As part of the inspection, EPA reviewed the following with resp ect to the use of AK for waste

characterization:

 Definition and identificati on of the waste stream

 Radiological characteristics of the waste

 Physical composition of the waste, including the presence of liquids

 Identification of high-level waste (HLW), TRU versus low-level waste (LLW), spent nuclear fuel (SNF)

 Defense determination

 Compiling AK documentation and assembly of required information, including the AKSR and adequacy of WCPIP AK process implementation

5 AK data trac eability

 AK source document sufficiency

 The Certification Plan/Confirmatory Test Plan (CTP) and DQOs attained through AK Qualification (for RH waste)

 Correlation and Surrogate Summary Fo rm (CSSF) and CH-RH correlation

 Personnel training

 The Waste Stream Profile Form (WSPF) and Characterization Reconciliation Report (CRR) (includes compliance with WCPIP)

 Non Conformance Reports (NCRs) and AK Discrepancy Resolutions (DRs)

 AK accuracy

 Load management

Technical Evaluation

(1) Waste Stream ID-MFC-S5400-RH was examined with respect to waste stream definition and was found to be adequate.

The WCPIP defines a waste stream as consisting of “waste material generated from a single process or activity, or as waste with similar physical, chemical, a nd radiological properties.” The waste stream examined, ID-MFC-S5400-RH, is a he terogeneous debris wa ste stream generated

in the hot cells of the L&O Bu ilding Analytical Laboratory duri ng a discrete time period. EPA

examined the information in the AKSR to determ ine whether the single process argument and/or commonality of physical, chemical, and radiologi cal properties argument were valid for this

waste stream. EPA found the waste st ream justification to be adequate.

(2) The radiological characteristic s of the waste stream were ev aluated, and were found to be adequate.

The AKSR provides a description of the processe s that produced the relevant radionuclides, including descriptions of the sp ecific fuel elements. Using th e radiological information provided by generators on waste packagi ng logs, INL-CCP was able to compile information about individual waste cans to determine the radiologi cal characteristics of the whole waste stream.

Table 7 of the AKSR summarizes the radiological data, including nuclide weight and activity percentages for the 10 WIPP-trac ked radionuclides, for the 48 cans, as reported by the waste generators. According to the inform ation provided by the waste generators, 239 Pu and 235 U are the two most prevalent radionuclides by mass, and 239 Pu, 144 Ce, 95 Nb, 137 Cs, and 95 Zr account for over 99% of the total activity for the reported isotopes.

However, examination of the AKSR, AK s ource documents, and CCP-AK-INL-541 leads to questions about consistency be tween the documented radionuclide-contributing fuel elements

and the fuel elements utilized to determine th e radiological characteri zation data inputs. AK source documents list fuel elements that definitely contributed radionuclides to this waste stream,

6but were not m entioned in the AKSR or used in radiological characte rization (C214, U009). The

AKSR mentions fuel elements th at should have been examined in the Analytical Laboratory during the time when Waste St ream ID-MFC-S5400-RH was produce d, yet these are specifically excluded from the list of contributing fuel elements and are not used in radiological

characterization.

This issue was discussed with INL-CCP AK personnel. INL-CCP provided an AKSR Freeze File (C438) with text revisions to more clearly explain the differences between the fuel elements listed as being examined during th e waste stream generation period and the fuel elements used in radiological characterization. EPA finds the re sponse to be adequate and expects the AKSR Freeze File to be included in the next formal revision of the AKSR. EPA expects a formal

revision of the relevant AKSR to occur prior to the CCP’s 2010 4 th quarter submission of T2 changes to EPA for review and concurrence.

(3) Physical characteristics of the waste stream were examined, including the presence of prohibited items (liquids) and were found to be adequately addressed.

DOE is required to determine the physical form of the waste, apply the correct Summary Category Group (SCG), waste matrix code (WMC), and waste material parameters (WMP), and confirm the absence of residual liq uids in excess of 1%. EPA re viewed the information provided by INL-CCP in support of the applied WMC (S5 400) and WMP weight percentages. Waste

Stream ID-MFC-S5400-RH contains various debris material including, but not limited to, bags, blotter paper, bottles/beakers, containers, e quipment/tools, hardware, rags, and tubing. The waste stream may also contain less than 50 perc ent volume per container of homogeneous solid

waste. The AKSR included a tabulation of waste material parameters by weight indicating that the waste stream is anticipated to be approxi mately 60% inorganic and 40% organic material, with other inorganic materials and plastics maki ng up the majority of the waste stream by weight (38% and 23%, respectively).

EPA also evaluated the presence of prohibited items (liquids). The AKSR indicates that a prescreen RTR step identified liquids and other pr ohibited items in the cans which as part of the waste processing/repackaging would be removed and/or remediated a nd any liquid would be absorbed. INL-CCP indicated during this T1 re view that each of the four drums has been repackaged into two drums since approval of the current AKSR. During repackaging, every drum was found to contain liquid. Remediation of the waste took pl ace prior to placement in the new drums. The Drum Repackaging Data Sh eets (Reference U287), which were provided during the review, document this discovery and th e subsequent remediation. RTR and VE were used to verify the absence of liquids and othe r prohibited items in the repackaged drums (BDRs RHINLVE090093 and INLRHRTR09009). AK source doc ument U287 is not currently in the AKSR reference list and EPA expects it to be ad ded as the reference lis t is updated. EPA found the discussion of waste stream physical characteristics to be adequate.

7(4) The identification of HLW, TRU versus LLW , and SNF was examined and was found to be adequate.

The WIPP Land Withdrawal Act (LWA) prohibits the disposal of SNF and HLW as defined by the Nuclear Waste Policy Act (NWPA) at the WIPP. SNF is defined in the NWPA as “fuel that

has been withdrawn from a nuclear reactor fo llowing irradiation, the constituent elements of which have not been separated by reprocessing.” INL-CCP indicates that while the waste stream contains debris waste contaminated during examin ation of fuel pins, no SNF is present in the

waste stream.

HLW is defined in the NWPA as “the highly radi oactive material resulting from the reprocessing of spent nuclear fuel.” INL-CCP contends that as material within Waste Stream ID-MFC-S5400-RH is from normal operations of the Analytical Laboratory and no fuel reprocessing took place in the Analyti cal Laboratory, the waste is not HLW.

INL-CCP reports that based on ge nerator-reported radionuclide da ta, the estimated average TRU alpha concentration in Waste Stream ID-MFC-S 5400-RH is greater than 100 nCi/g, thus meeting the criteria of TRU waste. Radiological char acterization activities pe rformed on the 8 drums

identified as Waste Stream ID -MFC-S5400-RH confirmed that all 8 drums are TRU waste, and

not LLW. EPA examined the AKSR and dose-to -curie (DTC) batch data report and found the SNF, HLW, and LLW argu ments to be adequate.

(5) Waste stream defense determination was evaluated and was found to be adequate.

The WIPP LWA allows only defense related waste to be disposed of at the WIPP facility. The AKSR provides several arguments supporting the defense-related status of Waste Stream ID-MFC-S5400-RH, summarized as follows:

 The Analytical Laboratory supported program s at MFC facilities – EBR-II and TREAT

reactors as well as the Hot Fuel Examina tion Facility (HFEF), and Fuel Conditioning Facility (FCF) – all of which were involved in defense-related activities.

 The Analytical Laboratory also supported other defense-related facilities at INL [Radiological Waste Management Complex (RWMC), INTEC, Advanced Test Reactor (ATR), and Naval Reactors Faci lity (NRF)] and other defense-related DOE sites such as

LANL.

 The waste included in Waste Stream ID -MFC-S5400-RH was produced during a time period when the Analytical Laboratory was pr imarily supporting the in tegral fast reactor (IFR) program, whose primary objective was to develop more efficient and environmentally sound reactor fuels a nd enhance nuclear non-proliferation.

EPA has determined that the waste stream defense determination is adequate.

8(6) Sufficiency of the AKSR and im plementation of the AK process were evaluated and were found to be adequate.

Attachment A of the WCPIP mandates a process th at should be followed to collect and analyze AK data, similar to the proce ss used for CH waste. Both the content of the AKSR and sufficiency of AK implementation were assessed.

EPA examined the AKSR and found that several ar eas were in need of revision, in addition to the radiological characterization edits discussed in Item (2) above. The AKSR discusses Waste

Stream ID-MFC-S5400-RH in terms of four 55- gallon drums containing forty-eight 2-gallon cans of Analytical Laboratory waste, as reporte d in the AK source documents. After approval of CCP-AK-INL-540, Revision 1, the four 55-gallon dr ums were repackaged into eight 30-gallon drums containing 6 cans each and overpacked into 55-gallon drum s. Also, during characterization activities, RTR s cans indicated that the waste st ream was packaged in 1-gallon cans instead of 2-gallon cans, which ha s not been acknowledged in the AKSR.

The AKSR is supposed to be a summary of all AK. The updated information about drum configuration is AK and utilized as such duri ng radiological characte rization. EPA discussed this issue with INL-CCP AK personnel, who subs equently addressed these concerns in the AKSR Freeze File (C438). EPA finds the response to be adequate and expects the AKSR Freeze

File to be included in the next formal revision of the AKSR. EPA expects a formal revision of the relevant AKSR to occur prior to the CCP’s 2010 4 th quarter submission of T2 changes to

EPA for review and concurrence.

(7) Data traceability was examined and was found to be adequate.

EPA evaluated all eight 55-gallon drum containers for traceab ility: IDAWANL880064A and B, IDAWANL880134A and B, IDAWANL880068A and B, and IDAWANL880065A and B. INL-CCP indicated that these drums originated fro m four original drums containing 48 hot cell DAW cans. Using RH TRU Drum Repackaging Sheets, Radioactive Waste Disposal Requests, and Hot Cell DAW Can records, the specific fuel elements present in Waste Stream

ID-MFC-S5400-RH can be derived as shown in Table 4 below.

Table 4. Drum Traceability Inform ation, Waste Stream ID-MFC-S5400-RH

Repack MFC Drum

ID Number Original ANL-W

Container ID Number Analytical Laboratory Hot

Cell DAW Can Numbers Fuel Elements Listed

IDAWANL880064A

IDAWANL880064B ANL-880064 8, 10, 16, 18, 21, 28, 29, 31, 36, 37, 38, 39 X-421, X-423B, LWBR

IDAWANL880134A

IDAWANL880134B ANL-880134 1, 2, 3, 5, 6, 12, 19, 30, 41, 52, 53, 75 X-421, X-423B, TREAT, LWBR, XY-27+XY-24

IDAWANL880068A

IDAWANL880068B ANL-880068 7, 11, 14, 23, 33, 40, 42, 45; outside cans 1, 2, 3, 4 X-421, X-423B, X-423C,

RERTR

IDAWANL880065A

IDAWANL880065B ANL-880065 4, 9, 13, 15, 22, 24, 25, 26, 27, 32, 34, 35 X-421, X-423B, LWBR,

RERTR

9The Integrated W aste Tracking System (IWTS) (References U034-U037) is a site-specific system used by INL to track waste movement a nd to document general radiological information about the container. The orig inal container Identification Nu mbers were obtained from this reference and the drum repackaging sheets, and we re used to identify the corresponding hot cell DAW cans (References U006, U008-U010). These can numbers were used to identify the specific fuel assemblies analyzed by the Anal ytical Laboratory between September 1987 and March 1988; the fuel assembly IDs were then used to identify individual fuel pins as recorded in the analytical laboratory sample logbooks (U219-U221).

EPA used the above information to evaluate the type of data available for each drum, and the traceability of that information. EPA’s review indicated that pape rwork is available to trace the final INL-CCP drum to individual fuel pins. EPA concluded that the information examined suggests detailed information is available for eac h drum and can be traced from the point of generation through INL-CCP drum management.

(8) Sufficiency of AK support documents and re lated document tracki ng was evaluated and was found to be adequate.

INL-CCP provided numerous supporting documents and Attachment 4 (i.e., the full reference list), which listed all of the available support doc uments. Subsequent to the inspection, and as a result of EPA’s concerns, INL-CCP increased th e number of source documents used to generate the AKSR, updated Attachment 4 to include all pertinent references, and provided an updated AK reference list in the previously mentioned AKSR Freeze File (C348).

(9) The Certification Plan/Confirmatory Test Plan (CTP) and DQOs attained through AK Qualification (for RH waste)

EPA’s March 26, 2004, RH WCPIP letter indicated that site s must generate a Certification Plan that explains how RH waste char acterization will take place at each site, as well as a CTP when this plan is required as part of the AK qualifi cation process. EPA’s intent was that the sites specify and document exactly how characterizati on is to take place on a waste stream basis, followed by a detailed plan explaining implementati on of confirmatory testing when this is to take place.

CCP-AK-INL-542, Revision 0 states that INL-CCP would use a combination of methods to qualify AK and meet the data quality objectives (DQOs). The DQOs for residual liquids and physical form will be met through 100% examin ation using VE and/or RTR. The DQO for defense determination will be met through AK documentation which does not need to be qualified. The DQO for RH determination is not in cluded in this plan, be cause it will be met through actual measurements. The DQOs for TRU wa ste determination and activity level will be met based on isotopic ratios derived from Oak Ridge Isotope Generati on (ORIGEN) modeling and confirmed by LANL mass spectrometry measurem ent data. The same process has been used at other RH sites and EPA has previously ex amined and approved the use of the LANL mass spectrometry data used by INL-CCP to qualify the fuel pin data at INL and other RH sites, so it was not necessary to revisit the actual data. However, EPA did examine the arguments posed regarding the use and app licability of this info rmation to the ID-MFC-S 5400-RH waste stream.

10INL-CCP-AK-582 states that the fu el pins contributing to the MF C waste are sufficiently sim ilar to those used to develop the LANL mass sp ectrometry measurements, and therefore the ORIGEN model applies here as well. As presented in CCP-AK-INL-541, Revision 1, approximately 80% of the irradiated fuel pins included in the MFC examination program were from the fast breeder program (IFR program, speci fically) and, as such, had similar fuel types, common sponsors or experimenters, and an id entical reactor (EBR-II) as did LANL. The remaining 20% of the fuel pins were irradiated in the Shi ppingport LWBR a nd share common sponsors and experimenters as the LANL work. Based on this information, EPA concluded that INL-CCP demonstrated applicabil ity of the LANL mass spectrosc opy data to the INL MFC fuel examination program by showing commonality of experiments, sponsors, and other data.

EPA evaluated the Certification Plan and CTP to determine whether it included the specific

elements that the CTP must have as defined in the WCPIP and found the CTP to be complete in this regard. When evaluated as a w hole, CCP-AK-INL-540, Re vision 1, CCP-AK-INL-541, Revision 1, CCP-AK-INL-542, Revisi on 0, and the supporting source documents indicate that the DQOs, as specified in the WCPIP, have been met. Revision to CCP-AK-INL-540, Revision 1, CCP-AK-INL-541, Revisi on 1, or CCP-AK-INL-542, Revision 0 is a T2 change.

(10) Use of a CSSF was evaluated and was found to be adequate.

Completion of a CSSF is required when AK informa tion from a related CH waste stream is used in the RH waste characterization process. The INL-CCP representatives i ndicated that CH data were not used in this manner, so a CSSF was not prepared for this stream.

(11) Personnel training was evaluated and was found to be adequate.

Scott Smith is the AKE who prepared the AKSR, and Irene Quintana is the SPM who prepared the Certification Plan/CTP. The AKE Qualifica tion Cards were examined to determine whether the individual’s training was up to date. It should be noted that the documentation examined did

not indicate that INL-CCP individua ls are trained to EPA requirement s, nor are they trained with respect to radiological characteri zation aspects, both of which are required in the WCPIP. Since the WCPIP is currently under revision, EPA will examine future training against the modified

WCPIP.

(12) The WSPF and CRR (includes compliance with WCPIP) were examined and both were found to be adequate.

INL-CCP representatives provided a draft WSPF, without required signatures or attachments. Notification of availability of th e final WSPF is a T2 change.

The content of the CRR was examined to ensure that this report refl ected requirements of CCP-TP-506, CCP Preparation of the Remote -Handled Transuranic Waste Acceptable Knowledge Characterization Rec onciliation Report. Specifically, the CRR was evaluated to determine the completeness and adequacy of its contents, as required in the WCPIP.

11INL-CCP representatives provided a pdf version of the CRR t hat wa s finalized for audit purposes only. This form included the necessary inform ation, but did not incl ude any signatures. Notification of availability of a final and/or revised CRR is a Tier 2 change.

(13) NCRs and DR Forms were examined and were found to be adequate.

INL-CCP provided a single DR associated with th is waste stream that dealt with the assignment of hazardous waste numbers to a previous ly non-hazardous waste stream. INL-CCP representatives did not indicate that there were any othe r DRs available for review. The provided DR verified continued preparation of this document as part of the AK process. There

are no NCRs associated with Waste Stream ID-MFC-S5400-RH; however, EPA has reviewed sufficient numbers of NCRs prepared by INL-CCP for previously approved waste streams to be

confident that the correc t process is in place.

(14) AK accuracy was assessed and was found to be adequate.

AK accuracy was assessed with respect to the requi red contents, as presented in the WCPIP. The WCPIP requires AK accuracy be assessed in three ar eas: reassignment of the waste to a different SCG; reassignment of the wa ste to a different waste str eam; and waste stream-specific assessment of radiological parameter accuracy. INL-CCP provided a draft AK accuracy report that indicated no discrepancie s were noted, and which listed verification of AK-based DQOs. Although not explicitly stated, presentation of the DQOs in this manner shows that the SCG assignment was not modified, the drums were not pl aced in a different waste stream, and some of the general radiological parameters (i.e., TRU and RH determination) were met through implementation of the WCPIP and comparison to th e AK Record. Notification of availability of a final AK accuracy report for this waste stream is a T2 change.

(15) Load Management was assessed and was determ ined to not apply to this waste stream.

INL-CCP representatives indicated that load management will not be performed for this waste stream. Implementation of load management is a T1 change.

Summary of Acceptable Knowledge

Findings and Concerns

The EPA Inspection Team did not identify any fi ndings or concerns relative to AK for the

addition of Waste Stream ID -MFC-S5400-RH, which was the s ubject of this T1 change

evaluation.

Tiering Changes

Based on the results of this T1 evaluation, ther e are no changes to the T1 and T2 designations that were assigned to A K for INL-CCP during the baseline and subsequent T1 approvals.

124.2 Radiological Characterization

EPA exam ined the radiological characterization pr ocess and associated information to determine whether INL-CCP demonstrated compliance wi th 40 CFR 194.8 requirements for RH Waste

Stream ID-MFC-S5400-RH.

Radiological Characterization Overview

The nature of RH TRU wastes presents difficulties with resp ect to obtaining meaningful

measurement data. As has been the case at th e six RH TRU waste characterization sites that EPA has previously approved, RH radiological ch aracterization relies on the development of scaling factors that correlate an easily measur ed parameter like a waste container’s external exposure (dose) rate with isotopic distri butions for specific TRU radionuclides. The development of radionuclide scali ng factors for the MFC wastes was essentially the same as what EPA evaluated and approved during the INL- CCP baseline inspection. The development of

the 137 Cs scaling factors was supported by the fo llowing five sources of information:

 Waste packaging records (ANL-W files): This information was used to identify specific fuel pins and reactor materials involved in the destructive examina tions conducted in the L&O Building Laboratory over the time-period of interest and the nature of examination

activities.

 AK source documents (Experiment design reco rds and ANL-W files): This information provided relevant pre-irradiation fuel com position information and burnup data collected for each of the identified fuel pins.

 Westinghouse letter NRFE-LWBRE-1083, as do cumented in INL-RH-15 (U856)L: This information provided the pre- irradiation composition and burnup values for the LWBR fuel rods and pins.

 Measurement data from LANL: This information was used as confirmatory testing to qualify the input information on th e fuel pins in the fast br eeder program and confirm the analyses using the ORIGEN2.2 computer code.

 ORIGEN2.2 computer code output: This info rmation was used to determine the curie

amounts for the radionuclides of interest

The characterization methods used for the INL-CCP MFC waste were evaluated in terms of the technical adequacy of the appr oach, as supported by the program’s documents, procedures, and controls, and the knowledge and understanding of th e personnel involved in the RH waste characterization program. During this T1 eval uation, EPA examined the following elements of the INL-CCP radiological characterization program:

 Development of DTC relationships as a func tion of waste density using Monte Carlo NParticle Transport Code (MCNP5) based on each drum’s measured external exposure (dose) rate, assuming the main contri butor to the external exposure was 137 Cs

 Derivation of radionuclide scaling factors for quantification of the 10 WIPP-tracked radionuclides, as supported by calculation pa ckages and ORIGEN2.2 computer code.

13Figure 1, below, provides a flow diagram for the Radiological Charac terization of RH TRU

debris waste from MFC.

Determine the Scaling Factors (SFs): Determine the DTC Conversion Factors:

Determine the Radionuclides Activities: Locate and retrieve records.

In the absence of the sampling option (the debris waste has already been packaged), identify the sources of radiological contamination and the fuelpins involved. Then, gather preirradiation fuel composition information and burnup data for each of the

identified fuel p ins.

Make an ORIGEN2.2 run for each of the 19 irradiated fuel pins, reconstructing the radiation experiments to which the fuel pins had been subjected.

Develop the Cs-137-based scaling

factors for the radionuclides of interest by dividing the total amount of eachradionuclide by the total amount of Cs137 determined from the same outputs. Consider MCNP5 for shielding calculations to develop Cs-137-based, density dependent DTC

conversion factors.

Using the loaded-drum model, find the mean gamma dose rate at 1 meter from the drum surface, based on a 1-Ci Cs-137 source for different values of the waste density.

Develop the DTC conversion factor (mR/hr/Ci) - density relationship for Cs-137.

Find the mean gamma dose rate at 1 m from the drum surface and determine the waste density based on the actual weight of the drum contents

and the fill factor.

Decay corrections the scaling factors, if needed. Using the mean external dose rate and the DTC correlation, determine the Cs-137 content of the

drum in curies.

Multiply the Cs-137 activity by the scaling

factors to find the activities of other radionuclides

of interest.

Figure 1. Flow Diagram for the Ra diological Characterization of

RH TRU Debris Waste fr om MFC (ID-MFC-S5400-RH) (CCP-AK-INL-541)

14Technical Evaluation

The EPA inspection team evaluated the following aspects:

(1) The technical adequacy and documentation of the resources used to facilitate the identification of the types of fu el and general distribution of contaminants associated with this waste stream were evaluated and found to be adequate.

The Argonne-West Analytical Laboratory Waste Cani ster Logs and the Hot Cell dry active waste (DAW) Can records were used to identify the cans packaged within each drum and their attributes (e.g., packaging date, waste material de scription, waste origin a nd masses), the type of waste packaged within each can, and the subassemblies associated with the waste. There were no concerns regarding the technical adequacy an d documentation of the resources used for the identification of the types and general distribution of the contaminants regarding the Waste

Stream ID-MFC-S5400-RH.

(2) The technical adequacy and documentation of the resources used to identify fuel composition, burnup values, and masses, as input for the ORIGEN2.2 modeling, were evaluated and found to be adequate.

The records for the EBR-II reacto r provided the fuel batch numbers, isotopic distribution, and elemental weights. The source document for th e three identified X421 fuel pins was “Test Description for the Integral Fast Reactor Subassemblies X419, X420, and X421.” For X423 subassembly fuel pins, the source used was “Qua lity Assurance Certifica tion/As Built for X423”

and “Reconstruction of the Irradia tion History of Experiment X423.” There were no concerns regarding the technical adequacy and documentati on of the resources used for the identification of the types and general dist ribution of the contaminants regarding the Waste Stream

ID-MFC-S5400-RH.

(3) The technical adequacy and documentation of the resources used to verify irradiation values were evaluated and found to be adequate.

“Burnup measurements on X421/T108, T128, T225,” (ANL-W-C071) and “Reconstruction of the Irradiation History of Experiment X423” (ANL-W-C-174) were the source documents for X421 assembly and X423 assembly, respectivel y. The Westinghouse letter NRFE-LWBRE1083, as documented in the source document en titled, “Derivation of Burnup and Composition for Thorium Pins” (U856), provided informa tion on the LWBR fuel elements. The RERTR plates were un-irradiated. There were no c oncerns regarding the te chnical adequacy and

documentation of the resources used for the identi fication of the types and general distribution of the contaminants regarding the Waste Stream ID-MFC-S5400-RH.

(4) The development of radionuclide scaling f actors was evaluated and was found to be technically adequate and appropriately documented.

A radionuclide scaling factor provides a tech nically sound method of deriving a value for

radionuclides that are difficult to measure on the basis of an easily measurable attribute like

15extern al dose rate, assuming the measured dose rate can be correlated to a known constituent, i.e., 137 Cs, considered to be the dominant contributo r to the gamma dose rate for MFC wastes. The measured dose rate, when used in conjunction with the waste density and the DTC correlation, leads to the quantification of 137 Cs, and the activities of other reportable radionuclides using their 137 Cs-based scaling factors.

The ORIGEN2.2 computer code was used to devel op the scaling factors. Individual computer runs were made for each of the 19 unique EBR -II and LWBR fuel elements. There were no RERTR ORIGEN2.2 input data, as the three RERT R fuel elements from the HFEF-W at Oak Ridge National Laboratory (O RNL) were un-irradiated.

Scaling factors were determined by dividing the total activity of each ra dionuclide for the EBR-II and LWBR fuel rods by its associated total 137 Cs activity. A single set of 137 Cs-based scaling

factors was determined for the characterization of all the waste generated. The scaling factors are shown in Table 5, below.

Table 5. Scaling Factors for the MCF Wastes in Units of Curies of Specific Radionuclide/Curies 137 Cs (Ci/Ci 137 Cs)

Radionuclide Curie Scaling Factor

U-233 8.59E-04

U-234 1.31E-04

U-235 5.01E-06

U-238 1.83E-06

Pu-238 2.99E-03

Pu-239 6.70E-02

Pu-240 1.96E-02

Pu-241 2.85E-01

Pu-242 3.14E-06

Am-241 1.22E-02

Cs-137 1.00E+00

Sr-90 7.79E-01

EPA evaluated the following aspects:

 Activity values derived from modeling and sta tistical metrics, namely mean and standard

deviation values for each measured radionuclide

 The appropriateness of the choice of physic al constants and radionuclide-specific attributes (specific activity, phys ical half-life, decay heat, neutron cross-sections, photon transition probabilities, etc.) and the technica l correctness of the values assigned to each

attribute

 Isotopic activity values are correlated to the radionuclid e whose physical half-lives possibly contribute to the meas ured external dose rate, i.e., 137 Cs

 Contributions of the short-lived radionuc lides to the total measured dose rate

16 Appropriate decay correction according to INL-CCP procedure (CCP-TP-504) of all radionuclide values for purposes of model de velopm ent and routine assays performed via

DTC

 The calculated results used to develop the scaling factors and convert the measured

external dose rates obtained via DT C to radionuclide activity levels

 Activity and uncertainty values determined for the ten WIPP-tracked radionuclides ( 233 U,

234 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 242 Pu, 241 Am, 137 Cs and 90 Sr)

 The determination of the contribution of a ll radionuclides to the radiological hazard 2

 Shielding and other calculati ons supporting the scaling fa ctors performed using MCNP5 to derive the appropriate DT C relationships as a function of waste density for the geometry appropriate to the MFC wastes following repackaging (55-gallon drum)

 There are no issues related to the technical adequacy or documentation of radionuclide scaling factors for the wa ste stream ID-MFC-S5400-RH.

(5) The technical basis of the DTC correlation a nd its documentation were evaluated and found to be unchanged from what EPA had inspect ed and approved previ ously, and both aspects were acceptable.

The DTC correlation was based on the following assumptions:

 The waste drum is 100 percent full with waste

 The radionuclides of interest are di spersed uniformly throughout the waste

 The waste matrix’s density is considered to be unity (one), becaus e photon attenuation is more influenced by material density, as opposed to specific composition or atomic

number

 Waste densities range from 0.001 g/cc to 2.4 g/cm 3

Using MCNP5, INL-CCP developed a DTC correla tion for a 55-gallon drum filled with RH

TRU waste in terms of mR/h r for a 1-curie source of 137 Cs. Figure 6-2 in CCP-AK-INL-541, Revision 1, shows a plot of dose ra te as a function of waste density at a distance of 1 meter for

137 Cs. A DTC spreadsheet similar to the DTC spreadsheet that EPA evaluated during the baseline inspection is used for MFC wastes as well, involving the MCF scaling factors. The spreadsheet contained the required informati on, specifically: cask id entification number; container gross weight; estimated fill percentage; and results of the four dose rate measurements that are obtained via the app lication of DTC procedure CCP-T P-504. An example Waste Drum DTC Conversion Record (spreadsheet) is incl uded as Table 6-4 in CCP-AK-INL-541, Revision 1. There were no concerns regarding the te chnical basis of the DTC correlation and its

documentation for the INL-CCP MFC wastes.

2 Although the determination of a waste container’s ra diological hazard is not an EPA requirement, this information may be useful in understanding other aspects of a container’s radiological characterization.

17(6) Technical aspects and docum entation of the radiological characteriz ation process were evaluated and found to be acceptable.

CCP-AK-INL-541, Revision 1, is the main docum ent that describes the radiological characterization process that INL-CCP used for the MFC wastes. This document is supported by a series of calculation packages , some of which were reviewed in the process of evaluating the MCF wastes. These packages had been prepared and reviewed by several CCP radiological characterization team members who supported the INL-CCP RH baseline effort. Many of them

had been since revised to in corporate the MCF wastes, as listed above. These packages documented the following:

 Evaluation of all potential contribut ors to a container’s dose rate

 Contributions of short-lived radionuclides to the measured external dose rate

 Potential sources of uncer tainty for MFC wastes

 Information input checks for MFC wastes

 Technical derivation of the DTC approach and documentation of the DTC spreadsheet

The EPA evaluation team revi ewed these packages and Revision 1 of CCP-AK-INL-541 in

advance of the formal T1 evaluation. Several documents had been revised more recently and these revisions were evaluated as they were provided by INL-CCP. During these discussions, the EPA evaluation team had the opportunity to discuss all technical c oncerns and apparent discrepancies with INL-CCP personnel and to question INL-CCP personnel regarding a variety of technical aspects related to the MFC wastes. None of th e calculation packages required

serious modifications. The EPA evaluation team found that CCP-AK-INL-541 adequately documented the radiological characterization process for MCF wastes, and the calculation packages cited above adequately supporte d the activities upon wh ich the radiological

characterization of MFC wastes wa s based. There were no issues related to the documentation of technical aspects of the INL- CCP radiological characterization approach for MFC wastes.

(7) The technical basis and derivation of Tota l Scaling Factor Uncertainty (TSFU) were evaluated and were found to be adequate.

The development of TSFU for Waste Stream ID -MFC-S5400-RH is based on the propagation of uncertainties present in all aspects of the determ ination of the radiologica l constituents of RH TRU waste. These aspects are assumed to be in dependent, which allows them to be added in quadrature. The TSFU determination in cluded contributions of the following:

 Drum weight measurement

 Measurement uncertainty

 Scaling factor uncertainty

 MCNP5 code and modeling issues

18 Contribution s of other gamma emitters

 Drum-to-drum variation within each campaign

The treatment of TSFU is presented in CCP-AK-INL-541 and Calculation Package No. INL-RH-07. The principal sour ces of uncertainty in the 137 Cs scaling factors result from: 137 Cs activity uncertainty, ORIGEN2.2 be nchmark uncertainty, and drum -to-drum uncertainty. The largest single contributor to the overall uncertainty is the drum-to- drum uncertainty, as shown in Table 6, below.

Table 6. Final Scaling Factor Uncertaint y Listed by Radionuclide for MFC Wastes

Radionuclide Cs-137 Activity Uncertainty ORIGEN2.2

Benchmark Uncertainty Drum-to-Drum Uncertainty Total Uncertainty

U-233 27.0% 6.0% 97.4% 101.2%

U-234 27.0% 26.0% 50.1% 62.6%

U-235 27.0% 6.0% 56.7% 63.0%

U-238 27.0% 43.0% 66.8% 83.9%

Pu-238 27.0% 33.0% 20.0% 47.1%

Pu-239 27.0% 4.0% 103.0% 106.5%

Pu-240 27.0% 8.0% 99.2% 103.1%

Pu-241 27.0% 37.0% 58.0% 73.9%

Pu-242 27.0% 29.0% 103.8% 111.1%

Am-241 27.0% 37.0% 84.4% 96.0%

Cs-137 27.0%

- - 27.0%

Sr-90 27.0% 14.0% 12.6% 32.9%

There were no concerns regarding the technical derivation and documentation of TSFU for the

INL-CCP MFC wastes.

(8) RH and TRU determinations were asse ssed and were found to be adequate.

The determination that the RH containers meet the definition of TRU waste and RH waste was examined during the baseline insp ection. Both of these aspects are directly involved with the DTC measurement at INTEC, as was observed du ring the baseline inspec tion. These were not assessed directly during this T1 evaluation, but EPA did verify that no aspects of these two determinations had changed. There were no technical or documenta tion-related concerns regarding the TRU and RH determ inations for INL MFC wastes.

Summary of Radiological Characterization

Findings and Concerns

The EPA inspection team did not identify any fi ndings or concerns related to radiological characterization. There are no open concerns rela ted to radiological char acterization resulting

from this T1 evaluation.

19Tiering Changes

Based on the results of this T1 evaluation, ther e are no changes to the T1 and T2 designations assigned to radiological characteri zation during the baseline approval.

4.3 Real-Time Radiography (RTR)

RTR was not initially included in the scope of this T1 evaluation. However, upon exam ination

of the AK information it became clear that an assessment of RTR was necessary. Accordingly,

EPA reviewed one RTR BDR for containers fr om Waste Stream ID-MFC-S5400-RH to verify that RTR data had been generated in accord ance with procedure CCP-TP-508, Revision 3, CCP RH Standard Real-Time Radiography Inspection Procedure.

BDR INLRHRTR09009 containe d data from six drums: IDAWANL880134A and B, IDAWANL880065A and B, and IDAWANL880068 A and B. These drums were examined on August 18, 2009, and the RTR operators had perf ormed and recorded the required CCP RTR Measurement Control Report. The container data sheets recorded the audio/visual recording numbers, percent fill, presence/absence of a ri gid liner, waste matrix code and layers of

confinement. Attachment 2 of CCP-TP-508 record ed the absence of proh ibited items and that the physical form of the waste was consistent wi th the Waste Stream Description/Waste Matrix Code. All Attachments were signed and dated by an RTR operator.

Quality Control examinations were performed as required. A replicate scan was performed on container IDAWANL880134B and an Independent Observation was performed on container IDAWANL880134A. There were no NCRs generated during examination of these containers.

The BDR had been reviewed at both data generation and project level.

EPA reviewed the training records for the tw o qualified RH RTR operators. These operators are also qualified as Independent Technical Reviewers (ITRs). Their training records were complete and included evidence of the operators ’ successful completion of the required written examination and the required practical test.

EPA did not identify any issues with regard to the above BDR.

4.4 Visual Examination (VE)

VE was not initially included in the scope of this T1 evaluatio n. However, upon examination of

the AK inform ation it became clear that an assess ment of VE was necessa ry. Accordingly, EPA

reviewed one VE BDR for containers from Wast e Stream ID-MFC-S5400-RH to verify that VE data had been generated in accordance with procedure CCP-TP-500, Revision 8, CCP RemoteHandled Waste Visual Examination.

BDR RHINLVE090003 contained VE data for two 30-gallon drums that had been packaged and then placed into 55-gallon drums. The 30-gallon drums had the same container ID number as the 55-gallon drums they were finally pack aged in, namely IDAWANL880064A and

IDAWANL880064B. The VE data sheet for 30-gallon container IDAWANL880064A showed

2021 that it contained various debris ite ms and was classified as an “org anic material” container. This was packaged into a 55-gallon drum, also I DAWANL880064A, and the data sheet recorded this as a “steel” container due to the presence of the 30-gallon container. The 30- and 55-gallon

containers for IDAWANL880064B were also cla ssified as “organic material” and “steel” respectively.

The data sheets, Attachment 1 of the procedure, had been completed as required and signed by two VE operators (VEOS). No a udio/visual recording is required for this type of VE. No prohibited items were packaged in to the containers and the oper ators verified that the waste matched the Waste Stream Description/Waste Matr ix Code for this waste stream. No NCRs were initiated during the VE event and the BDR had been reviewed at both data generation and project level.

EPA reviewed the training records for the thr ee qualified RH VE operators. These operators are also qualified as Independent Technical Reviewers (ITRs). Their training records were complete and included evidence of the operators ’ successful completion of the required written examination and the required practical test.

EPA did not identify any issues with regard to the above BDR.

5.0 FINDINGS AND CONCERNS

The EPA inspection team did not identify any findings or concerns during the inspection.

6.0 CONCLUSIONS

EPA concluded that the waste ch aracterization processes of AK, radiological characterization, RTR, and VE proposed for use by IN L-CCP to ch aracterize RH TRU wastes from the hot cells of the Analytical Laboratory at the MFC are adequa te. There are no open issu es relative to this

T1 evaluation.

Approval

The T1 change that was evaluated consisted of the waste characterization techniques of AK, radiological characterization, RTR, and VE as applied to Waste Stream ID-MFC-S5400-RH consisting of 8 drums.

Based on the results of this evaluation, EPA approves these components of the T1 change. INL-CCP is approved to characterize and ship these RH TRU wastes, consistent with the limitations specified in this report.

Tiering Changes

Based on the results of this T1 evaluation, ther e are no substantive changes to the T1 or T2 designations assigned to INL-CCP during the baseline and subsequent T1 evaluations. The most up-to-date tiering table is in cluded in Table 7, below.22Table 7. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Revised May 12, 2010)1RH Process ElementsINL-CCP RH Process - T1 ChangesINL-CCP RH Process - T2 Changes2Acceptable Knowledge (AK)Addition of containers toapproved waste streamsAny new waste streams not approved under this baselineSubstantive modification(s)3that have the potential to affect thecharacterization process: CCP-AK-INL-500, CCP-AK-INL-501,or CCP-AK-INL-502Load management for any RH waste streamNotification to EPA when AKSRs, Radiological Characterization Reports andCertification Confirmation Test Plans (e.g., CCP-INL-AK-500, CCP-INL-AK501, and CCP-INL-AK-502) updates are approved by CBFONotification to EPA when changes to AK documentation as a result of WCPIPrevisions have been made (e.g., CRR)4Notification to EPA when a Correlation or Surrogate Summary Form iscompleted for each of the RH containers in this waste stream identified as CH,based upon measured dose rates that present NDA results for assayed containersNotification to EPA once waste stream data package for debris waste stream andany modifications to the WSPF, including the CRR and AK Summary, arecompletedNotification to EPA that the final Dose-to-Curie (DTC) determination iscomplete for RH containers numbers728 through 737, as identified in AKReference P030AK accuracy reports (prepared annually, at a minimum)Radiological Characterization, including Doseto-Curie (DTC)Application of new scaling factors for isotopic determination otherthan those documented in CCP-AK-INL-501Use of any alternate radiological characterization procedure otherthan DTC with established scaling factors as documented in CCPTP-504 or substantive modification of the DTC procedure3Any new waste stream not approvedunder this baseline or additionof containers to Waste StreamID-ANLE-S5000 that requireschanging the established radionuclide scaling factorsNotification to EPA upon completion ofrevisions of CCP-AK-INL-501 or CCPTP-504 that require CBFO approvalVisual Examination of audio/video media (VE)Use of VE to characterize additional debris waste streams orwaste from other Summary Waste CategoriesNoneReal-Time Radiography (RTR)Any new S5000 waste stream other than ID-ANLE-S5000 orwastes from an S3000 or S4000 waste streamNotification to EPA prior toaddition of a new RTR unit(s)Notification to EPA upon completion ofchanges to RTR procedure(s) thatrequire CBFO approvalWIPP Waste Data System, WDS (previouslyknown as WWIS)NoneChanges made to WDS procedure(s) that require CBFO approvalNotes:1This table has been modified by deleting the references to specific sections of the baseline inspection report where each T1 orT2 element is discussed; additions to the original tiering table from the2007 baseline inspection appear inbold.2INL-CCP will report all T2 changes to EPA every three months.3Substantive modificationrefers to a change with the potential toaffect INL-CCP’s RH WC process, e.g., the use of an inherently different type of measurement instrument or the use of the highrange probe as described in CCP-TP-504.4Excluding changes that are editorial in nature or are required to address administrative concerns.ATTACHMENT A

APPROVAL SUMMARY FOR INL RH WA STE CHARACT ERIZATION PROGRAMApproval Summary for INL RH Waste Characterization Program

Specific INL RH Approval Date EPA Docket Number

INL RH Baseline Approval January 2007 A-98-49; II-A4-72

Tier 1 Change – Approval of Visual Examination January 2007 A-98-49; II-A4-75

Tier 1 Change – Approval of Real Time Radiography February 2007 A-98-49; II-A4-80

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

Tier 1 Change – Approval of High Range Gamma Probe for DTC April 2008 A-98-49; II-A4-98

Tier 1 Change – Approval of Visual Examination Technique September 2009 A-98-49; II-A4-118

Tier 1 Change – Addition of Twelve Containers to Waste Stream IDANLE-S5000 and Addition of Waste Stream ID-HFEF-S5400-RH January 2010 A-98-49, II-A4-122

A-1ATTACHMENT B

LISTING OF DOCUMENTS REVI EWED FOR THIS EVALUATIONListing of Documents Reviewed for this Evaluation

AK Tracking Spreadsheet Excerpts for Waste Stream ID-MFC-S5400-RH, provided to EPA on May 6, 2010

CCP-AK-INL-540, Central Characterization Proj ect Acceptable Knowledge Summary Report

for Remote-Handled Transuranic Debris Wast e from Materials and Fuels Complex at the Idaho National Laboratory, Waste Stream ID-MFC-S5400-RH, Revision 1, August 6, 2009

CCP-AK-INL-541, Central Characterization Project Remote-Handled Transuranic Radiological Characterization Technical Report for Remote -Handled Transuranic Debris Waste from the Materials and Fuel Complex at th e Idaho National Laboratory, Revision 1, December 2, 2009

CCP-AK-INL-542, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmation Te st Plan for INL Waste Stream: ID-MFCS5400-RH, Revision 0, July 28, 2008

CCP-TP-005 Attachment 4, Acceptable Knowledge Source Document Reference List, provided May 25, 2010

CCP-TP-005 Attachment 8, Waste Containe rs for Waste Stream ID-MFC-S5400-RH, September 18, 2008

Characterization Reconciliati on Report for ID-MFC-S5400-RH, Draft for audit purposes, provided April 19, 2010

DOE WIPP 02-3214, Remote-Handled TRU Waste Characterization Program Implementation Plan, Revision 0D, October 30, 2003

Inter-Office Correspondence from C. M. Gom ez to M. Sensibaugh, Acceptable Knowledge Accuracy Report: Materials and Fuel Comple x at the Idaho National Laboratory Waste Stream Number ID-MFC-S5400-RH, Lot 1, April 15, 2010

P-TS Screenshots/Traceability Informa tion for Drums IDAWANL880064A and B, IDAWANL880134A and B, IDAWANL880068A and B, and IDAWANL880065A and B, provided to EPA on May 6, 2010

RTR BDR INLRHRTR09009: CCP-TP-508, Revision 3, Attachment 4, SPM Checklist for BDR INLRHRTR09009; Attachment 6, BDR Cove r Sheet INLRHRTR09009; Attachment 5, BDR Table of Contents; CCP-TP-500, Re vision 8, Attachment 3, ITR Checklist; Attachment 1, RTR Measurement Control Report; Attachment 2, Data Sheets for Containers IDAWANL880134A and B, IDAWANL880068A and B, and

IDAWANL880065A and B

B-1VE BDR RHINLVE090003: CCP-TP-500, Revision 8, Attachment 3, SPM Checklist for BDR RHINLVE090003; Attachment 4, BDR Cove r Sheet RHINLVE090003; Attachment 5, BDR Table of Contents; Attachment 1, Data Forms for Containers IDAWANL880064A and B; Attachment 2, ITR Checklist

Waste Stream Profile Form, Waste Stream ID-MFC-S5400-RH, Draft for audit purposes, provided April 19, 2010

Acceptable Knowledge Summary Re port Operational Training for RH TRU Debris Waste from the Materials and Fuels Complex at the Id aho National Laboratory Waste Stream IDMFC-S5400-RH, August 2009

Davis, Chris, Remote-Handled Real-Time Radi ography Operator/Independent Technical Review Qualification Card, September 2, 2009

Davis, Chris, Visual Examination Operator/I ndependent Technical Revi ewer Remote-Handled Waste (All Sites) Qualifi cation Card, January 21, 2009

Kline, Ken, Visual Examination Operator/Inde pendent Technical Reviewer Remote-Handled Waste (All Sites) Qualifi cation Card, January 21, 2009

Maynard, Caleb, Nondestructive Examination Real-Time Radiography Operator/ITP Qualification Card, March 31, 2008

Maynard, Caleb, Nondestructive Examination Real-Time Radiography Operator/ITP Qualification Card Addendum I – Remote-Ha ndled Waste – RTR System Idaho National Laboratory, March 31, 2008

Maynard, Caleb, Visual Examination Operator/Independent Technical Reviewer RemoteHandled Waste (All Sites) Qua lification Card, January 21, 2009

Neely, Hillari, Site Program Manager Qualification Cards, September 17, 2009

Parmer, Brett, Visual Examination Operator/I ndependent Technical Revi ewer Remote-Handled Waste (All Sites) Qualifi cation Card, January 21, 2009

Quintana, Irene, Site Program Manager Qualification Cards, September 17, 2009

Smith, Scott, Acceptable Knowledge Expe rt Qualification Cards, December 3, 2002

Smith, Scott, Acceptable Knowledge Expert Tr aining Card for Idaho National Laboratory and Oak Ridge National Laboratory, February 4, 2010

C002, Interview of Pam Crane, Analytical Labor atory, re.: Analytical Laboratory Mission and Objectives, Scott Smith, August 31, 2005

B-2C028, Argonne National Laboratory Intra-Laborat ory Memo to W.N. Beck, re: Technical Feasibility of Lead IFR Experiments in EBR-II, R.G. Pahl, April 27, 1984

C030, Argonne National Laboratory Intra-Laboratory Memo to D.W. Cissel, re: EBR-II Division Approval to Irradiate Three IFR Subassemblies, W.N. Beck, May 17, 1984

C033, Argonne National Laboratory Intra-Laboratory Memo to RG. Pahl, re: Assignment of

Identification Numbers for Three Lead IFR Experimental Subassemblies, J.L. Welker, June 4, 1984

C034, Argonne National Laboratory Intra-Laboratory Memo to Di stribution, re: Design Review of Lead IFR Fuel Elements, RG. Pahl, June 14, 1984

C050, Argonne National Laboratory In tra-Laboratory Memo to E.M. Franklin, re: Inspection of Subassembly X419, E.K. Hemsley, July 22, 1985

C072, Packet of Letters Including: Argonne Nationa l Laboratory Intra-Laboratory Memo to D.C. Wade, re: Response to MC&A Questions in Support of HFEF-S Fuel Reprocessing Operations, R. Villarreal, January 24, 1989

C084, Letter to Bob Pahl, re: Burnup Measur ements on X4211T108, T128, T225, R. Villarreal, November 24, 1987

C127, Argonne National Laboratory In tra-Laboratory Memo to W.N. Beck, re: NDT Review of Sixty-one (61) IFR Fuel Elem ents from ANL Scheduled for Experimental S/A X419, G.K. Whitham, February 11, 1985

C200, Argonne National Laboratory Intra-Labor atory Memo to D.C. Crawford, re: Reconstruction of the Irradiation History of Experiment X423, S.L. Hayes, SLH-94-001, July 1, 1994

C206, Letter to A.E. Wright, re: Isotopic Analyses of Irradiated IFR Fuels, R. Villarreal, M.T. Laug, December 14, 1987

C214, Telephone Interview Conducted Between CCP Personnel and John Krsul, Matt Laug, Bob Villarreal, Doug Porter, Roy Grant, and Bevi n Brush, re: Materials and Fuels Complex (MFC) Analytical Laboratory Operations and Waste Management Information, Scott Smith and Carrie Johnson, April 15, 2008

C438, Freeze File Changes for AK Summary Report CCP-AK-INL-540, Scott Smith, May 20,

2010

DR002, Waste Stream I D-MFC-S5400-RH , Histor ical and Current RCRA Characterization and Assignment of EPA Hazardous Waste Number s, Michael J. Papp, September 23, 2008

B-3P001, The Defense Programs Origin of Transura nic Waste at Argonne National Laboratory - West, H. F. McFarlane, ANL-NT-192, November 2001

P042, Analytical Laboratory Safety Analysis Report, Idaho National Laboratory, W0660-0055- KH, Revision 4, April 6, 2006

P067, Safeguards and Security Plan for IFR-EFL, R. Villarreal, May 1984

P085, Test Description for the Integral Fast Reactor Subassemblies X419, X420, and X421, R.G. Pahl, C.E. Lahm, G.E. Hudman, ANL-IFR-19, July 1985

U006, Radioactive Waste Disposal Request a nd associated paperwork, HFEF-9 cask, W.R. Sovereign, April 4, 1988

U007, RH-TRU RTR Prescreen for Repackaging/ AK Worksheet -four ANL-W containers, Greg Lamb, Chris G. Davis, August 13, 2007

U008, Radioactive Waste Disposal Request a nd associated paperwork, HFEF-9 cask, W.R. Sovereign, March 11, 1988

U009, Radioactive Waste Disposal Request a nd associated paperwork, HFEF-10 cask, W.R. Sovereign, April 4, 1988

U010, Radioactive Waste Disposal Request a nd associated paperwork, HFEF-10 cask, W.R. Sovereign, March 11, 1988

U035, Integrated Waste Tracking System Container Profile, IDAWANL880065: ANL-W Glassware, Paper, Poly, and Miscellaneous Hardware, Matthe w Allen, Paul R. Smith, Joel R. Hitz, IDAWANL880065, November 28, 2007

U036, Integrated Waste Tracking System Container Profile, IDAWANL880068: ANL-W Glassware, Paper, Poly, and Miscellaneous Hardware, Matthe w Allen, Paul R. Smith, Joel R. Hitz, IDAWANL880068, November 28, 2007

U037, Integrated Waste Tracking System Container Profile, IDAWANL880134: ANL-W Glassware, Paper, Poly, and Miscellaneous Hardware, Matthe w Allen, Paul R. Smith, Joel R. Hitz, IDAWANL880134, November 28, 2007

U086, Transfer of SS Materials -Between Areas, 0864, November 05, 1986

U133, Transfer Of SS Materials -B etween Areas, 0873, October 15, 1986

U196, Design Description and Safety Analys is for X-419, X-420, and X-421, C.E. Lahm and R.G. Pahl, December 1984

U219, AL Sample Logbook No. 20 Re: June 5,1984 - January 9, 1986, July 01, 1984

B-4B-5 U220, AL Sample Logbook No. 21 Re: Feb 1986 - May 1987, February 01, 1986

U221, AL Sample Logbook No. 22 Re: May 22, 1987 - May 12, 1988, May 01, 1987

U248, Argonne National Laboratories-West (ANL-W ) Materials and Fuels Complex (MFC) RH TRU Radiological Characte rization, Data Culled Used as Input for ORIGEN2 Calculations, J. Klingensm ith, INL-RH-51, November 5, 2008

U249, Argonne National Laboratories-West (ANL-W ) Materials and Fuels Complex (MFC) RH TRU Radiological Characteri zation, ORIGEN2 Input File s and Activity Data, J. Klingensmith, INL-RH-52, November 5, 2008

U251, Argonne National Laboratories-West (ANL-W ) Materials and Fuels Complex (MFC) RH TRU Radiological Characterizati on, Calculated Scaling Factors for the Constituents of the ANL-W Debris Waste Stream, J. Kli ngensmith, INL-RH-54, November 7, 2008

U254, Argonne National Laboratories-West (ANL-W ) Materials and Fuels Complex (MFC) RH TRU Radiological Characterizati on, Uncertainty in the Calculat ed Radionuclide Content in the ANL-W Debris Waste Stream, J. K lingensmith, INL-RH-57, November 7, 2008

U256, Argonne National Laboratories-West Materials and Fuels Complex RH TRU Radiological Characterization, Cs-137 Dose -to-Curies Correlation for ANL-W Waste Stream, Including Uncertainty Associated with Variations in Source Distribution Within Waste Drums, J. Klingensmith, INL-RH-59, Revision 1, September 23, 2009

U257, Argonne National Laboratorie s-West (ANL-W) Materials and Fuels Complex RH TRU Radiological Characterization, Isotopes in Addition to Ten WIPP-Required Reportable Isotopes Providing 95% of Measured Dose Rate Outside Waste Containers in ANL-W Debris Stream, J. Klingensmith, INL-RH-60, Revision 0, November 7, 2008

U287, RH TRU Drum Repackaging Datasheet for waste Stream ID-MFC-S5400-RH, INL CWI,

Various dates

U843, Scaling Factors Development, James H. Holderness, INL-RH- 02, Revision 0, June 5,

2006

U846, INL Cs-137 Dose-to-Curie Correlation Uncer tainty, James H. Holderness, INL-RH-05, Revision 0, May 8, 2006

U848, Uncertainty Analysis for Drums, James Holderness, INL-RH-07, Revision 0, June 5, 2006

U856, Derivation of Burnup and Composition fo r Thorium Pins, Jene Vance, INl-RH-15, Revision 0, May 8, 2006