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

WASTE CHARACTERIZATION REPORT 

EPA TIER 1 EVALUATION 

OF THE CENTRAL CHARACTERIZATION PROJECT (CCP) 

REMOTE-HANDLED TRANSURANIC WASTE 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 2010
TABLE 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 Waste 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 INL-CCP RH Waste Characterization Program 

Attachment B: Listing of Documents Reviewed 

i
ACRONYMS 

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 Reconciliation 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/cm3 grams per cubic centimeter 

HFEF Hot Fuel Examination Facility 

HLW high-level waste 

ii
ID Idaho 

IFR integral 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 Transport 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 Waste Management Complex 

SCG Summary Category Group 

SF Scaling Factor 

SNF spent nuclear fuel 

SPM Site Project Manager 

iii
iv

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 Program 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 zirconium 
1.0 EXECUTIVE SUMMARY 

This report supports the U.S. Environmental 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 addition 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 Waste Isolation Pilot Plant (WIPP). 

The Central Characterization Project (CCP) is responsible for characterizing the above wastes 

using the system of controls, which EPA evaluated 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 approval 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 evaluation and no open issues remain relative to this T1 change. EPA 

has not identified any tiering changes during the course of this evaluation, 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 evaluation. Therefore, this report includes an up-to-date tiering table as 

Table 1 of this report. EPA determines that the procedures and 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 waste 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.

1
2

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Revised 

RH Process Elements INL-CCP RH Process - T1 Changes INL-CCP RH Pr

Acceptable Knowledge (AK) Addition of containers to approved waste streams 

Any new waste streams not approved under this baseline Substantive modification(s)3 that have the potential to affect the 

characterization process: CCP-AK-INL-500, CCP-AK-INL-501, or CCP-AK-INL-502 Load management for any RH waste stream 

Notification to EPA when AKSRs, RadCertification Confirmation Test Plans (501, and CCP-INL-AK-502) updates arNotification to EPA when changes to Arevisions have been made (e.g., CRR)4 

Notification to EPA when a Correlation completed for each of the RH containerbased upon measured dose rates that prNotification to EPA once waste stream any modifications to the WSPF, includicompleted Notification to EPA that the final Dose-complete for RH containers numbers 72Reference P030 AK accuracy reports (prepared annu

Radiological Characterization, including Doseto-Curie (DTC) Application of new scaling factors for isotopic determination other than those documented in CCP-AK-INL-501 

Use of any alternate radiological characterization procedure other than DTC with established scaling factors as documented in CCPTP-504 or substantive modification of the DTC procedure3 

Any new waste stream not approved under this baseline or addition of containers to Waste Stream ID-ANLE-S5000 that requires changing the established radionuclide scaling factors 

Notification to EPA upon completion oTP-504 that require CBFO approval 

Visual Examination of audio/video media (VE) Use of VE to characterize additional debris waste streams or 

waste from other Summary Waste Categories 

None 

Real-Time Radiography (RTR) Any new S5000 waste stream other than ID-ANLE-S5000 or 

wastes from an S3000 or S4000 waste stream Notification to EPA prior to addition of a new RTR unit(s) 

Notification to EPA upon completion require CBFO approval 

WIPP Waste Data System, WDS (previously known as WWIS) 

None Changes made to WDS procedure(s) 

Notes: 1 This table has been modified by deleting the references to specific sections of the baseline inspection report where each T1 or T2 element is discussed; addition2007 baseline inspection appear in bold. 2 INL-CCP will report all T2 changes to EPA every three months. 3 Substantive modification refers to a change with the potential to affect INL-CCP’s RH WC process, e.g., the use of an inherently different type of measuremen

probe as described in CCP-TP-504. 

4 Excluding changes that are editorial in nature or are required to address administrative concerns. 
2.0 PURPOSE OF TIER 1 EVALUATION 

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

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

requirements set forth in 40 CFR 194.8 regulations and incorporated 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 baseline 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 site’s waste characterization program, based on the 

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

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

TRU wastes destined for disposal at the WIPP. 

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

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

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

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

notification, are identified in the site-specific baseline inspection reports. When evaluating 

proposed T1 changes for approval, EPA may conduct a site inspection to observe first-hand the 

implementation of the change, or can opt to conduct a “desktop” review of information provided 

specific to a change. DOE may choose to characterize and dispose of, at risk of subsequent EPA 

disapproval, any previously approved TRU waste 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 addition of the following INL RH waste stream: 

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

The evaluation of this waste stream included four waste characterization areas: 1) AK, 2) 

radiological characterization, 3) RTR, 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 these areas were relevant. Accordingly, VE and 

RTR were assessed and the results of these assessments are included in this report. Personnel 

who participated in the T1 evaluation are listed in Table 2, along with each person’s affiliation 

and function during the evaluation. 

3
Table 2. T1 Evaluation Participants 

Name Affiliation & Function 

Edward Feltcorn Lead Inspector, U. S. EPA 

Rajani Joglekar Inspector, U. S. EPA 

Kira Darlow Technical Evaluator – Acceptable Knowledge, SC&A 

Connie Walker Technical Evaluator – 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 Characterization Subject Matter Expert, CCP 

 

4.0 EVALUATION OF NEW RH WASTE 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 drums from March to April, 

1988. From August 14-17, 2009, the cans were repackaged 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, bottles/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 September 1987 to March 1988. The waste is currently 

stored at the Idaho Nuclear Technology and Engineering Center (INTEC) Radioactive Mixed 

Waste Staging Facility (RMWSF), Building CPP-1617. 

Fuel pins examined in the Analytical Laboratory 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 (RERTR) 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 consist of the waste generated during the examination 

of 15 fuel elements from the fast breeder fuel program (three from subassembly X421 and 12 

from subassembly X423), four fuel elements from LWBR, and three (un-irradiated) 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 subassembly X423, the burnup 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 smaller and generally contain significantly less fuel 

material. The contribution of the three RERTR fuel plates was reduced by a factor of 8.6 to a 

statistically equivalent basis, increasing the total number of fuel pins examined by 0.35 (35%). 

4
The scope of this T1 evaluation includes eight 55-gallon drums from Waste Stream ID-MFCS5400-RH. These eight drums were originally four 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 eight 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 inspection. The listing of all 

documentation examined is in Attachment B, and the list of batch data reports (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 examined 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 respect to the use of AK for waste 

characterization: 

 Definition and identification 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 traceability 

 AK source document sufficiency 

 The Certification Plan/Confirmatory Test Plan (CTP) and DQOs attained through AK 

Qualification (for RH waste) 

 Correlation and Surrogate Summary Form (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, and radiological properties.” The 

waste stream examined, ID-MFC-S5400-RH, is a heterogeneous debris waste stream generated 

in the hot cells of the L&O Building Analytical Laboratory during a discrete time period. EPA 

examined the information in the AKSR to determine whether the single process argument and/or 

commonality of physical, chemical, and radiological properties argument were valid for this 

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

(2) The radiological characteristics of the waste stream were evaluated, and were found to be 

adequate. 

The AKSR provides a description of the processes that produced the relevant radionuclides, 

including descriptions of the specific fuel elements. Using the radiological information provided 

by generators on waste packaging logs, INL-CCP was able to compile information about 

individual waste cans to determine the radiological 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-tracked radionuclides, for the 48 cans, as reported by the waste 

generators. According to the information provided by the waste generators, 239Pu and 235U are 

the two most prevalent radionuclides by mass, and 239Pu, 144Ce, 95Nb, 137Cs, and 95Zr account for 

over 99% of the total activity for the reported isotopes. 

However, examination of the AKSR, AK source documents, and CCP-AK-INL-541 leads to 

questions about consistency between the documented radionuclide-contributing fuel elements 

and the fuel elements utilized to determine the radiological characterization data inputs. AK 

source documents list fuel elements that definitely contributed radionuclides to this waste stream, 

6
but were not mentioned in the AKSR or used in radiological characterization (C214, U009). The 

AKSR mentions fuel elements that should have been examined in the Analytical Laboratory 

during the time when Waste Stream ID-MFC-S5400-RH was produced, 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 the waste stream generation period and the fuel elements used in 

radiological characterization. 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 4th 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 liquids in excess of 1%. EPA reviewed the information provided 

by INL-CCP in support of the applied WMC (S5400) 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, equipment/tools, hardware, rags, and tubing. The 

waste stream may also contain less than 50 percent 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 approximately 60% inorganic and 40% organic material, 

with other inorganic materials and plastics making 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 prohibited items in the cans which as part of the 

waste processing/repackaging would be removed and/or remediated and any liquid would be 

absorbed. INL-CCP indicated during this T1 review 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 place prior to placement in the 

new drums. The Drum Repackaging Data Sheets (Reference U287), which were provided 

during the review, document this discovery and the subsequent remediation. RTR and VE were 

used to verify the absence of liquids and other prohibited items in the repackaged drums (BDRs 

RHINLVE090093 and INLRHRTR09009). AK source document U287 is not currently in the 

AKSR reference list and EPA expects it to be added as the reference list 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 following 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 examination of fuel pins, no SNF is present in the 

waste stream. 

HLW is defined in the NWPA as “the highly radioactive 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 Analytical Laboratory, the waste is not HLW. 

INL-CCP reports that based on generator-reported radionuclide data, the estimated average TRU 

alpha concentration in Waste Stream ID-MFC-S5400-RH is greater than 100 nCi/g, thus meeting 

the criteria of TRU waste. Radiological characterization activities performed 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 arguments 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 programs at MFC facilities – EBR-II and TREAT 

reactors as well as the Hot Fuel Examination 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 Facility (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 primarily supporting the integral fast reactor 

(IFR) program, whose primary objective was to develop more efficient and 

environmentally sound reactor fuels and enhance nuclear non-proliferation. 

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

8
(6) Sufficiency of the AKSR and implementation of the AK process were evaluated and were 

found to be adequate. 

Attachment A of the WCPIP mandates a process that should be followed to collect and analyze 

AK data, similar to the process 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 areas 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 reported in the AK source documents. After approval of 

CCP-AK-INL-540, Revision 1, the four 55-gallon drums were repackaged into eight 30-gallon 

drums containing 6 cans each and overpacked into 55-gallon drums. Also, during 

characterization activities, RTR scans indicated that the waste stream was packaged in 1-gallon 

cans instead of 2-gallon cans, which has 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 during radiological characterization. EPA discussed 

this issue with INL-CCP AK personnel, who subsequently 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 4th 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 traceability: IDAWANL880064A and B, 

IDAWANL880134A and B, IDAWANL880068A and B, and IDAWANL880065A and B. 

INL-CCP indicated that these drums originated from 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 Information, 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 

9
The Integrated Waste Tracking System (IWTS) (References U034-U037) is a site-specific 

system used by INL to track waste movement and to document general radiological information 

about the container. The original container Identification Numbers were obtained from this 

reference and the drum repackaging sheets, and were 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 Analytical 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 paperwork 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 each drum and can be traced from the point of 

generation through INL-CCP drum management. 

(8) Sufficiency of AK support documents and related document tracking 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 documents. Subsequent to the inspection, and as a 

result of EPA’s concerns, INL-CCP increased the 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 sites must generate a Certification Plan 

that explains how RH waste characterization will take place at each site, as well as a CTP when 

this plan is required as part of the AK qualification process. EPA’s intent was that the sites 

specify and document exactly how characterization is to take place on a waste stream basis, 

followed by a detailed plan explaining implementation 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% examination 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 included in this plan, because it will be met 

through actual measurements. The DQOs for TRU waste determination and activity level will be 

met based on isotopic ratios derived from Oak Ridge Isotope Generation (ORIGEN) modeling 

and confirmed by LANL mass spectrometry measurement data. The same process has been used 

at other RH sites and EPA has previously examined 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 applicability of this information to the ID-MFC-S5400-RH waste stream. 

10
INL-CCP-AK-582 states that the fuel pins contributing to the MFC waste are sufficiently similar 

to those used to develop the LANL mass spectrometry 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, specifically) and, as such, had similar fuel types, 

common sponsors or experimenters, and an identical reactor (EBR-II) as did LANL. The 

remaining 20% of the fuel pins were irradiated in the Shippingport LWBR and share common 

sponsors and experimenters as the LANL work. Based on this information, EPA concluded that 

INL-CCP demonstrated applicability of the LANL mass spectroscopy 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 whole, CCP-AK-INL-540, Revision 1, CCP-AK-INL-541, 

Revision 1, CCP-AK-INL-542, Revision 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, Revision 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 information from a related CH waste stream is used 

in the RH waste characterization process. The INL-CCP representatives indicated 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 Qualification 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 individuals are trained to EPA requirements, nor are they trained with 

respect to radiological characterization 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 the final WSPF is a T2 change. 

The content of the CRR was examined to ensure that this report reflected requirements of 

CCP-TP-506, CCP Preparation of the Remote-Handled Transuranic Waste Acceptable 

Knowledge Characterization Reconciliation Report. Specifically, the CRR was evaluated to 

determine the completeness and adequacy of its contents, as required in the WCPIP. 

11
INL-CCP representatives provided a pdf version of the CRR that was finalized for audit purposes 

only. This form included the necessary information, but did not include 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 this waste stream that dealt with the assignment 

of hazardous waste numbers to a previously non-hazardous waste stream. INL-CCP 

representatives did not indicate that there were any other 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 correct process is in place. 

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

AK accuracy was assessed with respect to the required contents, as presented in the WCPIP. The 

WCPIP requires AK accuracy be assessed in three areas: reassignment of the waste to a different 

SCG; reassignment of the waste to a different waste stream; and waste stream-specific 

assessment of radiological parameter accuracy. INL-CCP provided a draft AK accuracy report 

that indicated no discrepancies 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 placed 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 the 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 determined 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 findings or concerns relative to AK for the 

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

evaluation. 

Tiering Changes 

Based on the results of this T1 evaluation, there are no changes to the T1 and T2 designations 

that were assigned to AK for INL-CCP during the baseline and subsequent T1 approvals. 

12
4.2 Radiological Characterization 

EPA examined the radiological characterization 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. 

Radiological Characterization Overview

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

measurement data. As has been the case at the six RH TRU waste characterization sites that 

EPA has previously approved, RH radiological characterization relies on the development of 

scaling factors that correlate an easily measured parameter like a waste container’s external 

exposure (dose) rate with isotopic distributions for specific TRU radionuclides. The 

development of radionuclide scaling 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 137Cs scaling factors was supported by the following 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 examinations conducted in the 

L&O Building Laboratory over the time-period of interest and the nature of examination 

activities. 

 AK source documents (Experiment design records and ANL-W files): This information 

provided relevant pre-irradiation fuel composition information and burnup data collected 

for each of the identified fuel pins. 

 Westinghouse letter NRFE-LWBRE-1083, as documented 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 the fuel pins in the fast breeder program and confirm the 

analyses using the ORIGEN2.2 computer code. 

 ORIGEN2.2 computer code output: This information 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 approach, as supported by the program’s documents, procedures, and 

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

characterization program. During this T1 evaluation, EPA examined the following elements of 

the INL-CCP radiological characterization program: 

 Development of DTC relationships as a function of waste density using Monte Carlo NParticle Transport Code (MCNP5) based on each drum’s measured external exposure 

(dose) rate, assuming the main contributor to the external exposure was 137Cs 

 Derivation of radionuclide scaling factors for quantification of the 10 WIPP-tracked 

radionuclides, as supported by calculation packages and ORIGEN2.2 computer code. 

13
Figure 1, below, provides a flow diagram for the Radiological Characterization 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 fuel 

pins involved. Then, gather preirradiation fuel composition information 

and burnup data for each of the 

identified fuel pins. 

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 each 

radionuclide 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 Radiological Characterization of 

RH TRU Debris Waste from MFC (ID-MFC-S5400-RH) 

(CCP-AK-INL-541) 

14
Technical 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 fuel and general distribution of contaminants associated with 

this waste stream were evaluated and found to be adequate. 

The Argonne-West Analytical Laboratory Waste Canister 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 description, waste origin and masses), the type of 

waste packaged within each can, and the subassemblies associated with the waste. There were 

no concerns regarding the technical adequacy and 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 reactor provided the fuel batch numbers, isotopic distribution, and 

elemental weights. The source document for the 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 “Quality Assurance Certification/As Built for X423” 

and “Reconstruction of the Irradiation History of Experiment X423.” There were no concerns 

regarding the technical adequacy and 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. 

(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, respectively. The Westinghouse letter NRFE-LWBRE1083, as documented in the source document entitled, “Derivation of Burnup and Composition 

for Thorium Pins” (U856), provided information on the LWBR fuel elements. The RERTR 

plates were un-irradiated. There were no concerns regarding the technical adequacy and 

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. 

(4) The development of radionuclide scaling factors was evaluated and was found to be 

technically adequate and appropriately documented. 

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

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

15
external dose rate, assuming the measured dose rate can be correlated to a known constituent, 

i.e.,137Cs, considered to be the dominant contributor 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 137Cs, and the activities of other reportable 

radionuclides using their 137Cs-based scaling factors. 

The ORIGEN2.2 computer code was used to develop 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 RERTR fuel elements from the HFEF-W at Oak 

Ridge National Laboratory (ORNL) were un-irradiated. 

Scaling factors were determined by dividing the total activity of each radionuclide for the EBR-II 

and LWBR fuel rods by its associated total 137Cs activity. A single set of 137Cs-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 137Cs (Ci/Ci 137Cs)

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 statistical metrics, namely mean and standard 

deviation values for each measured radionuclide 

 The appropriateness of the choice of physical constants and radionuclide-specific 

attributes (specific activity, physical half-life, decay heat, neutron cross-sections, photon 

transition probabilities, etc.) and the technical correctness of the values assigned to each 

attribute 

 Isotopic activity values are correlated to the radionuclide whose physical half-lives 

possibly contribute to the measured external dose rate, i.e., 137Cs 

 Contributions of the short-lived radionuclides 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 development and routine assays performed via 

DTC 

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

external dose rates obtained via DTC to radionuclide activity levels 

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

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

 The determination of the contribution of all radionuclides to the radiological hazard2

 Shielding and other calculations supporting the scaling factors performed using MCNP5

to derive the appropriate DTC 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 waste stream ID-MFC-S5400-RH. 

(5) The technical basis of the DTC correlation and its documentation were evaluated and found 

to be unchanged from what EPA had inspected and approved previously, 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 dispersed uniformly throughout the waste 

 The waste matrix’s density is considered to be unity (one), because 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/cm3

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

TRU waste in terms of mR/hr for a 1-curie source of 137Cs. Figure 6-2 in CCP-AK-INL-541, 

Revision 1, shows a plot of dose rate as a function of waste density at a distance of 1 meter for 

137Cs. 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 information, specifically: cask identification number; 

container gross weight; estimated fill percentage; and results of the four dose rate measurements 

that are obtained via the application of DTC procedure CCP-TP-504. An example Waste Drum 

DTC Conversion Record (spreadsheet) is included as Table 6-4 in CCP-AK-INL-541, Revision 

1. There were no concerns regarding the technical basis of the DTC correlation and its 

documentation for the INL-CCP MFC wastes. 

 2

 Although the determination of a waste container’s radiological 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 documentation of the radiological characterization process were 

evaluated and found to be acceptable. 

CCP-AK-INL-541, Revision 1, is the main document 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 incorporate the MCF wastes, as listed above. These packages 

documented the following: 

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

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

 Potential sources of uncertainty 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 reviewed 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 concerns 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 the 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 supported the activities upon which the radiological 

characterization of MFC wastes was 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 Total 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 determination of the radiological constituents of RH 

TRU waste. These aspects are assumed to be independent, which allows them to be added in 

quadrature. The TSFU determination included contributions of the following: 

 Drum weight measurement 

 Measurement uncertainty 

 Scaling factor uncertainty 

 MCNP5 code and modeling issues 

18
 Contributions 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 sources of uncertainty in the 137Cs scaling factors result from: 137Cs 

activity uncertainty, ORIGEN2.2 benchmark 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 Uncertainty 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 assessed 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 inspection. Both of these aspects are directly involved with the 

DTC measurement at INTEC, as was observed during the baseline inspection. 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 documentation-related concerns 

regarding the TRU and RH determinations for INL MFC wastes. 

Summary of Radiological Characterization

Findings and Concerns 

The EPA inspection team did not identify any findings or concerns related to radiological 

characterization. There are no open concerns related to radiological characterization resulting 

from this T1 evaluation. 

19
Tiering Changes 

Based on the results of this T1 evaluation, there are no changes to the T1 and T2 designations 

assigned to radiological characterization during the baseline approval. 

4.3 Real-Time Radiography (RTR) 

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

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

EPA reviewed one RTR BDR for containers from Waste Stream ID-MFC-S5400-RH to verify 

that RTR data had been generated in accordance with procedure CCP-TP-508, Revision 3, CCP 

RH Standard Real-Time Radiography Inspection Procedure. 

BDR INLRHRTR09009 contained 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 performed 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 rigid liner, waste matrix code and layers of 

confinement. Attachment 2 of CCP-TP-508 recorded the absence of prohibited items and that 

the physical form of the waste was consistent with 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 two 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 evaluation. However, upon examination of 

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

reviewed one VE BDR for containers from Waste 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 packaged in, namely IDAWANL880064A and 

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

20
21

that it contained various debris items and was classified as an “organic material” container. This 

was packaged into a 55-gallon drum, also IDAWANL880064A, 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 classified 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 audio/visual recording is required for this type of VE. No 

prohibited items were packaged into the containers and the operators verified that the waste 

matched the Waste Stream Description/Waste Matrix 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 three 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 characterization processes of AK, radiological characterization, 

RTR, and VE proposed for use by INL-CCP to characterize RH TRU wastes from the hot cells 

of the Analytical Laboratory at the MFC are adequate. There are no open issues 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, there 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 included in Table 7, below. 
22 

Table 7. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Revised 

RH Process Elements INL-CCP RH Process - T1 Changes INL-CCP RH Pro

Acceptable Knowledge (AK) Addition of containers to approved waste streams 

Any new waste streams not approved under this baseline Substantive modification(s)3 that have the potential to affect the 

characterization process: CCP-AK-INL-500, CCP-AK-INL-501, or CCP-AK-INL-502 Load management for any RH waste stream 

Notification to EPA when AKSRs, RadiCertification Confirmation Test Plans (e501, and CCP-INL-AK-502) updates are Notification to EPA when changes to AK revisions have been made (e.g., CRR)4 

Notification to EPA when a Correlation completed for each of the RH containers based upon measured dose rates that preNotification to EPA once waste stream dany modifications to the WSPF, includincompleted Notification to EPA that the final Dose-tcomplete for RH containers numbers 72Reference P030 AK accuracy reports (prepared annua

Radiological Characterization, including Doseto-Curie (DTC) Application of new scaling factors for isotopic determination other than those documented in CCP-AK-INL-501 

Use of any alternate radiological characterization procedure other than DTC with established scaling factors as documented in CCPTP-504 or substantive modification of the DTC procedure3 

Any new waste stream not approved under this baseline or addition of containers to Waste Stream ID-ANLE-S5000 that requires changing the established radionuclide scaling factors 

Notification to EPA upon completion of TP-504 that require CBFO approval 

Visual Examination of audio/video media (VE) Use of VE to characterize additional debris waste streams or 

waste from other Summary Waste Categories 

None 

Real-Time Radiography (RTR) Any new S5000 waste stream other than ID-ANLE-S5000 or 

wastes from an S3000 or S4000 waste stream Notification to EPA prior to addition of a new RTR unit(s) 

Notification to EPA upon completion orequire CBFO approval 

WIPP Waste Data System, WDS (previously known as WWIS) 

None Changes made to WDS procedure(s) t

Notes: 1 This table has been modified by deleting the references to specific sections of the baseline inspection report where each T1 or T2 element is discussed; addition2007 baseline inspection appear in bold. 2 INL-CCP will report all T2 changes to EPA every three months. 3 Substantive modification refers to a change with the potential to affect INL-CCP’s RH WC process, e.g., the use of an inherently different type of measuremen

range probe as described in CCP-TP-504. 

4 Excluding changes that are editorial in nature or are required to address administrative concerns. 
ATTACHMENT A 

APPROVAL SUMMARY FOR INL RH WASTE CHARACTERIZATION PROGRAM 
Approval 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-1 
ATTACHMENT B 

LISTING OF DOCUMENTS REVIEWED FOR THIS EVALUATION
Listing 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 Project Acceptable Knowledge Summary Report 

for Remote-Handled Transuranic Debris Waste 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 the 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 Test 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 Containers for Waste Stream ID-MFC-S5400-RH, 

September 18, 2008 

Characterization Reconciliation 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. Gomez to M. Sensibaugh, Acceptable Knowledge 

Accuracy Report: Materials and Fuel Complex at the Idaho National Laboratory Waste 

Stream Number ID-MFC-S5400-RH, Lot 1, April 15, 2010 

P-TS Screenshots/Traceability Information 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 Cover Sheet INLRHRTR09009; Attachment 5, 

BDR Table of Contents; CCP-TP-500, Revision 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-1 
VE BDR RHINLVE090003: CCP-TP-500, Revision 8, Attachment 3, SPM Checklist for BDR 

RHINLVE090003; Attachment 4, BDR Cover 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 Report Operational Training for RH TRU Debris Waste from 

the Materials and Fuels Complex at the Idaho National Laboratory Waste Stream IDMFC-S5400-RH, August 2009 

Davis, Chris, Remote-Handled Real-Time Radiography Operator/Independent Technical Review 

Qualification Card, September 2, 2009 

Davis, Chris, Visual Examination Operator/Independent Technical Reviewer Remote-Handled 

Waste (All Sites) Qualification Card, January 21, 2009 

Kline, Ken, Visual Examination Operator/Independent Technical Reviewer Remote-Handled 

Waste (All Sites) Qualification 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-Handled Waste – RTR System Idaho National 

Laboratory, March 31, 2008 

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

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

Parmer, Brett, Visual Examination Operator/Independent Technical Reviewer Remote-Handled 

Waste (All Sites) Qualification Card, January 21, 2009 

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

Smith, Scott, Acceptable Knowledge Expert Qualification Cards, December 3, 2002 

Smith, Scott, Acceptable Knowledge Expert Training Card for Idaho National Laboratory and 

Oak Ridge National Laboratory, February 4, 2010 

C002, Interview of Pam Crane, Analytical Laboratory, re.: Analytical Laboratory Mission and 

Objectives, Scott Smith, August 31, 2005 

 

 B-2 
C028, Argonne National Laboratory Intra-Laboratory 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 Distribution, re: Design Review 

of Lead IFR Fuel Elements, RG. Pahl, June 14, 1984 

C050, Argonne National Laboratory Intra-Laboratory Memo to E.M. Franklin, re: Inspection of 

Subassembly X419, E.K. Hemsley, July 22, 1985 

C072, Packet of Letters Including: Argonne National 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 Measurements on X4211T108, T128, T225, R. Villarreal, 

November 24, 1987 

C127, Argonne National Laboratory Intra-Laboratory Memo to W.N. Beck, re: NDT Review of 

Sixty-one (61) IFR Fuel Elements from ANL Scheduled for Experimental S/A X419, G.K. 

Whitham, February 11, 1985 

C200, Argonne National Laboratory Intra-Laboratory 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 Bevin 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 , Historical and Current RCRA Characterization and 

Assignment of EPA Hazardous Waste Numbers, Michael J. Papp, September 23, 2008 

 

 B-3 
P001, The Defense Programs Origin of Transuranic 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 and 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 and associated paperwork, HFEF-9 cask, W.R. 

Sovereign, March 11, 1988 

U009, Radioactive Waste Disposal Request and associated paperwork, HFEF-10 cask, W.R. 

Sovereign, April 4, 1988 

U010, Radioactive Waste Disposal Request and 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, Matthew 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, Matthew 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, Matthew 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 -Between Areas, 0873, October 15, 1986 

U196, Design Description and Safety Analysis 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-4 
 

 B-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 Characterization, Data Culled Used as Input for ORIGEN2 

Calculations, J. Klingensmith, INL-RH-51, November 5, 2008 

U249, Argonne National Laboratories-West (ANL-W) Materials and Fuels Complex (MFC) RH 

TRU Radiological Characterization, ORIGEN2 Input Files 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 Characterization, Calculated Scaling Factors for the Constituents of the 

ANL-W Debris Waste Stream, J. Klingensmith, INL-RH-54, November 7, 2008 

U254, Argonne National Laboratories-West (ANL-W) Materials and Fuels Complex (MFC) RH 

TRU Radiological Characterization, Uncertainty in the Calculated Radionuclide Content in 

the ANL-W Debris Waste Stream, J. Klingensmith, 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 Laboratories-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 Uncertainty, 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 for Thorium Pins, Jene Vance, INl-RH-15, 

Revision 0, May 8, 2006