DOCKET NO: A-98-49; II-A4-130

WASTE CHARACTERIZATION REPORT

EPA TIER 1 EVALUATION

OF THE CENTRAL CHARACTER IZATION PROJECT (CCP)

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

WASTE STREAM ID-INTEC-RH

December 8-9, 2009, January 12-13, 2010, and February 17, 2010

U.S. Environmental Protection Agency

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

August 2010i 

### TABLE OF CONTENTS

Section Page

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

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

2.0 Purpose of Tier 1 Evaluation .............................................................................................. 2

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

4.0 Evaluation of New RH Wast e Stream ID-INTEC-RH ....................................................... 3

4.1 Acceptable Knowledge ........................................................................................... 4

4.2 Radiological Characterization............................................................................... 16

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

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

6.1 Approval ............................................................................................................... 21

6.2 Tiering Changes.................................................................................................... 21



### ATTACHMENTS

Attachment A: Approval Summary for INL- CCP RH Waste Characterization Program

Attachment B: Listing of Documents Reviewed

Attachment C: Approval Summary for Idaho National Laboratory Remote-Handled Waste Sampling at Argonne National Laboratory

Attachment D: Approval Summary for Idaho National Laboratory Remote-Handled Waste Sampling at Idaho National Laboratoryii ACRONYMS

AERHDH Argonne East Remote-Handled Debris Waste

AK acceptable knowledge

AKE acceptable knowledge expert

AKSR acceptable knowledge summary report

ALARA as low as reasonably achievable

Am americium

ANL Argonne National Laboratory

ANL-E Argonne National Laboratory– East

BDR batch data report

CBFO Carlsbad Area Field Office

CCP Central Characterization Project

CFR Code of Federal Regulations

CH contact-handled

Ci curie

COC chain-of-custody

CRR Characterization R econciliation Report

Cs cesium

CSSF Correlation and Surrogate Summary Form

CTAC Carlsbad Technica l Assistance Contractor

CTP Confirmatory Test Plan

CWI CH2M-WG Idaho, LLC

DOE U.S. Department of Energy

DQO data quality objective

DR discrepancy resolution

DTC dose-to-curie

EPA U.S. Environmental Protection Agency

FR Federal Register

g gram
g/cm 3 grams per cubic centimeter

HAER Historic American Engineering Recordiii HFEF Hot Fuel Examination Facility

HLW high-level waste

ICP-MS Inductively Coupled Plasma – Mass Spectrometry

ID Idaho

ILTSF Intermediate Level Transuranic Storage Facility

INL Idaho National Laboratory

INEEL Idaho National Engineeri ng and Environmental Laboratory

INEL Idaho National Engineering Laboratory

INTEC Idaho Nuclear Technology and Engineering Center

ITR Independent Technical Reviewer

IWMF INTEC Waste Management Facility

L liter

LLW low-level waste

LOQI List of qualified individuals

LWR light-water reactor

m meter

m 3 cubic meters

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

MFC Materials and Fuel Complex

MFP mixed fission products

ml milliliter

mR/hr/Ci milli Roentgen per hour per curie

NCR non-conformance report

NDA nondestructive assay

NOD Nuclear Operations Division

OJT/SME (SP) On the job training/Subject Matter Expert

ORIGEN Oak Ridge Isotope Generation

ORNL Oak Ridge National Laboratory

Pu plutonium

PUREX plutonium-uranium extraction

QA quality assurance

QAO quality assurance objectiveiv RAF Remote Analytical Facility

RCRA Resource Conservation and Recovery Act

RH remote-handled

RPD Relative Percent Difference

RTR real-time radiography

RWMC Radiological Wast e Management Complex

SCG Summary Category Group

SNF spent nuclear fuel

SPM Site Project Manager

Sr strontium

STR Site Technical Representative

T1 Tier 1

T2 Tier 2

TAN Test Area North

TBD to be determined

TID Tamper Indicating Device

TMU total measurement uncertainty

TRU transuranic

U uranium

VE visual examination

WCPIP Waste Characterization Pr ogram Implementation Program

WIPP Waste Isolation Pilot Plant

WIR waste incidental to reprocessing

WMP waste material parameter

WSPF Waste Stream Profile Form

WTS Washington TRU Solutions

WWIS WIPP Waste Information System1 1.0 EXECUTIVE SUMMARY

This report supports the U.S. Environmental Protection Agency ’s (EPA’s) approval of the retrievably-stored, remote-handled (RH) tr ansuranic (TRU) debris (S5000) waste stream ID-INTEC-RH from the U.S. Department of Energy’s (DOE’s) Idaho National Laboratory (INL). It also supports EPA’s approval of an RH waste sampling process implemented at the Argonne National Laboratory-East (ANL-E) a nd a radiochemical analysis procedure implemented at INL.

On October 2, 2009, the Carlsbad Field Office ( CBFO) requested that EPA review a proposed Tier 1 (T1) change addressing the fo llowing three INL RH waste streams:

• The addition of twelve cont ainers to an approved RH TR U waste stream, Waste Stream ID-ANLE-S5000. EPA approved this waste stream in January 2007 as part of the baseline approval; however, the additi on of containers is a T1 change.

• New RH Waste Stream ID-HFEF 1 -S5400-RH, Lot 1A with 28 casks

• New RH Waste Stream ID-INTEC 2 -RH, consisting of two containers

On December 8-9, 2009, EPA met in Washington, DC, with the Ce ntral Characterization Project (CCP) personnel at INL responsib le for characterizing the subject waste streams to discuss the waste characterization approach and informati on gathered to prepare acceptable knowledge documentation and quantify radiolog ical and physical cont ents of the three waste streams. In February 2010, the EPA approved the first two wast e streams as two separate T1 changes (See EPA Report A-98-49; II-A4-122). EPA, however, di d not approve the last waste stream, as EPA needed to evaluate waste sampling and radioc hemical analysis methods used to generate radiological information necessary for developing scaling factors. EPA inspected these two processes earlier this year, and th is report presents the results of these evaluations as the basis for approval.

The INL RH baseline approval specified a certain number of containers and stipulated that any addition of new containers to the approved wast e stream requires CBFO to submit a T1 change request and obtain EPA appr oval prior to disposal of any such wastes at the Waste Isolation Pilot Plant (WIPP). The CCP is responsible for ch aracterizing the above waste stream using the system of controls that EPA ev aluated during the baseline insp ection conducted in July 2006 and approved in January 2007. A summary of EPA’s approval of the INL RH TRU waste characterization program is in cluded as Attachment A.

The INL-CCP had used radiological data for generating scaling factors in support of the ID-INTEC-RH waste stream that required samp ling the two INTEC waste containers and performing radiochemical analysis using proces ses/procedures not previously evaluated or approved by EPA. EPA raised one AK concer n which was adequately addressed. This

1 HFEF is the Hot Fuel Examination Facility at the Ma terials and Fuel Complex, formerly known as Argonne National Laboratory-West, which is now part of INL.

2 INTEC is the Idaho Nuclear Technology and Engineering Center.2 inspection report, therefore, presents the re sults of the T1 evaluation of Waste Stream

ID-INTEC-RH.

EPA determined that all proce sses/procedures implemented fo r waste sampling and analysis must be first evaluated for technical adequacy before EPA can assess use of the scaling factors and approve the subject waste stream. EPA completed the on-site evaluation of the INL analytical laboratory and sample collection and analysis at ANL-E 3 and INL in February and January 2010, respectively (see Appendices C and D for the results of these evaluations). EPA did not identify any concerns during the evalua tion of sample collecti on at ANL-E or sample analysis at INL, and no issues remain open relative to this T1 change. EPA determined that the procedures and processes used by INL-CCP fo r the addition of new RH Waste Stream IDINTEC-RH were technically adequate . By virtue of having inspect ed both the sample collection process and ANL-E and the INL analytical labo ratory, EPA’s approval of Waste Stream IDINTEC-RH as a T1 change incl udes approving these two processes for use in supporting the development of radionuclide scaling factors for RH TRU wastes.

2.0 PURPOSE OF TIER 1 EVALUATION

Certain changes 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 Code of Federal Regulations (CFR) 194.8 regulations and incorporated in the INL-CCP RH Baselin e 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 disposal 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. CBFO may choose to charac terize 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 ev aluate implemented T2 changes to verify adequacy.

3 ANL-E is the former name of the DOE site that is now called Argonne Na tional Laboratory (ANL).3 3.0 SCOPE OF THE TIER 1 EVALUATION

This T1 evaluation encompassed INL RH Waste Stream ID-INTEC-RH. The RH wastes that were the subject of this T1 evaluation are heterogeneous debris that INL-CCP plans to characterize for disposal at WIPP. The eval uation of Waste Stream ID-INTEC-RH included two waste characterization areas, Acceptable Knowle dge (AK) and radiological characterization, each of which is addressed separately in this report. Additionally, EPA evaluated processes and procedures implemented to sample RH debris waste and analyze them to measure their radionuclide content as separate visits to ANL on February 17, 2010, and the INTEC Laboratory at INL on January 14, 2010, respectively (see A ppendices C and D, respectively). Personnel who participated in the primary T1 evaluation are listed in Table 1, al ong with each person’s affiliation and function during the evaluation.

Table 1. T1 Evaluation Participants

Name Affiliation & Function Rajani Joglekar EPA Headquarters, Lead Inspector
Ed Feltcorn EPA Headquarters, Inspector
Lindsey Bender EPA Headquarter, Inspector
Connie Walker SC&A, Technical Evaluator – AK
Patrick Kelly SC&A, Technical Evalua tor – Radiological Characterization
Amir Mobasheran SC&A, Technical Eval uator – Radiological Characterization
Kevin Peters CCP, AK
Scott Smith CCP, AK
Mark Doherty CCP, AK
Irene Quintana CCP, SPM
Jene Vance* CCP, Technical Support for Radiological Characterization
David Moody CCP, Technical Support for Radiological Characterization
Jessie Klingensmith CCP, Technical Sup port for Radiological Characterization
Mike Sensibaugh CCP, Technical Support for Radiological Characterization
Thomas Clements CWI-INL, Observer
Joe Harvill WTS/CCP, Observer
Kira Darlow SC&A, Observer
Jim Oliver CTAC, Observer
*Jene Vance did not attend the evaluation in Washington, DC, but was involved in several discussions with EPA technical personnel by telephone prior to the Washington meeting

in December.

4.0 EVALUATION OF NEW RH WA STE STREAM ID-INTEC-RH

Waste Stream ID-INTEC-RH consists of two 30- gallon drums of RH TRU heterogeneous debris wastes overpacked in 55-gallon drums (approximately 0.4 m 3 ) and stored and characterized at the INTEC facility at INL. The wastes them selves consist of bags, bottles, containers, equipment/tools, hardware, hoses, rags or towels, etc. These materials were generated from an experimental actinide partitioning study conducted in the A-Line of the Remote Analytical Facility (RAF) and packaged in October 1978. A total of two 30-ga llon drums of RH TRU waste was generated and these drums are the subject of this T1 evaluation.4 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-INTEC-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

• Identification of high-level wa ste (HLW), TRU versus low-level waste (LLW), and spent nuclear fuel (SNF)

• Compiling AK documentation and assembly of required information, including the AK Summary and adequacy of Waste Characte rization Program Implementation Program (WCPIP) AK process implementation

• AK data traceability

• AK source document sufficiency

• WCPIP Interpretation including AK qualificatio n, and Certification Plan/Confirmatory Test Plan (CTP) preparation/adequacy

• Characterization Reconciliati on Report (CRR) adequacy

• Correlation and Surrogate Summary Form (CSSF) and Contact-Handled (CH)-RH

correlation

• Personnel training

• Waste Stream Profile Form (WSPF) adequacy and compliance with WCPIP requirements

• Non Conformance Reports (NCRs) and AK discrepancy resolutions (DR)

• AK accuracy

• Defense determination

• Load management

• Data Quality Objectives (DQOs) at tained through AK Qualification5 Documents, Waste Containers, and Batch Data Reports Reviewed

Several attachments, source documents, required forms, and other data were provided to EPA and were examined as part of this T1 inspection. The full listing is presented in Attachment B,

and the list of BDRs examined is presented in Table 2 below.

Table 2. Batch Data Reports Examined

Drum Number VE BDR Number DTC BDR

IDIC000000427 RHINLVW090001 RHINLDTC09004

IDIC000000460 RHINLVW090001 RHINLDTC09004

Waste Stream ID-INTEC-RH was generated in the RAF, located in Building CPP-627 at INTEC

of the INL. The waste is stored at IN TEC pending characteriza tion, certification and canisterization activities. RH TRU waste rep ackaging operations are conducted at INTEC in Building CPP-659, the New Waste Calcining Facilit y. Most of the DQOs for this waste stream were achieved through AK, although solid sampling and analysis data were obtained to support the development of radionuc lide scaling factors.

The AK evaluation presented in this section asse sses the AK process and activities related to the determination of physical and radiological wa ste composition, up to, but not including, model parameter determination and input and determination of scaling factors.

Technical Evaluation

(1) Waste Stream ID-INTEC-RH was examined with respect to waste stream definition and was found to be adequately defined.

The WCPIP defines a waste stream as “waste material generated from a single process or activity, or as waste with similar physical, ch emical, and radiological properties.” INL-CCP

describes the ID-INTEC-RH Waste Stream as follows:

Waste stream ID-INTEC-RH consists of two 30-gallon drums overpacked in 55- gallon drums (approximately 0.4 cubic mete rs) of RH TRU heterogeneous debris waste generated from an experimental ac tinide partitioning study conducted in the A-Line of the RAF and packaged in October 1978. The waste is primarily contaminated with fissile materials and mixed fission products (MFP). Based on the generator reported radionuclide s, U-238 and U-235 are the two most prevalent radionuclides by mass. Pu- 241, Cs-137, and Pu-238 account for more than 99 percent of the total acti vity for the reported isotopes....

To determine that the waste str eam was appropriately defined, se veral references were reviewed and the AK expert (AKE) was interviewed to dete rmine the waste generation processes, as well as physical and radiological characteristics of the waste. Data reviewed indicate that the waste was generated during a very specific process. The RAF was used for an actinide partitioning study conducted in June of 1978, wherein 35 small two-inch pieces of H.B. Robinson Fuel Rod

E-14 were sectioned and transferred from Test Area North (TAN) to one of the A-line cells6 (presumably Cell 9) for study. The purpose of th e study was to develop an actinide partitioning scheme for radioactive liquid waste to meet higher recovery levels of plutonium (Pu), neptunium, americium (Am), curium, and uran ium (U). The AK Su mmary Report (AKSR) CCP-AK-INL-500, Revision 0 provides detailed info rmation regarding seve ral aspects of the actinide partitioning. From a radiological perspe ctive, INL-CCP representatives stated that almost all radiological constituents within the waste stream were obtained from the single H.B. Robinson Fuel Rod E-14, which wa s composed almost entirely of 238 U by weight. In contrast, over 87% of the activity is attributable to 241 Pu, with lesser quantities of 238 U and cesium-137 ( 137 Cs). Several source documents (e.g., P019, P020, U001) were examined to verify that the radiological composition of the solidif ied material in the two drums is consistent with the AKSR.

INL-CCP stated that the debris within this stre am contained extraneous vials and other debris that may have come from genera l cell activitie s unrelated to the E-14 diss olution. This analysis

affected how INL-CCP chose to obtain additiona l radiological information (e.g. swipe samples from debris), as well as the SNF-HLW analysis [see Item (4), below]. With respect to the physical composition of the waste, AK data suggest that the waste steam includes both solidified organic sludges, as well as debr is. INL-CCP stated that although solidified organics are present in the waste, the debris component composes over 50% of the material in each drum, and

therefore the drum is considered an S5000 wast e. The AKSR and relate d references provided information to adequately define the waste stre am, assuming it is limited to the two containers presented in the AKSR. Applicability of the S5000 summary category group (SCG) assignment

to the waste stream is addre ssed in Item (3), below.

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

INL-CCP assumes that Waste Stream ID-INTEC-RH obtained its radiologi cal signature from a single H.B. Robinson Fuel Rod, number E-14. The AKS R states that dissolution of this fuel rod was associated with an actinide partitioning stud y that was conducted in the RAF, wherein halfinch pieces of the sectione d Fuel Rod E-14 (assembly B-05) underwent dissolution. After dissolution, the solution was extracted to remove U and Pu using the PUREX 4 process, and the resulting organic phase from this extraction wa s solidified in the RAF and placed in the two

containers of this waste stream. INL-CCP us ed information presented in AK source documents (e.g., P019, P020, P022) to determine container-sp ecific radiological information and to assign the distributions presented in Table 4 of the AKS R. As shown in this table, the predominant radionuclides by weight are 238 U (98.75%) and 235 U (0.49%), while the predominant radionuclides by activity are 241 Pu (87.64%) and 137 Cs (8.61%) (P019).

AKE analyzed available AK data, including histor ical inventory data, m easured E-14 fuel pin concentration data, historic isotopic distribution informa tion, ORIGEN calculations, mass balance data, burn-up data, and other informa tion, to develop a reco mmended 2008 radionuclide list (by mass and activity), as we ll as proposed scaling factors (U 001). INL-CCP stated that the calculations, assumptions, and uncertainties asso ciated with this report were technically

4 PUREX is the name of a plutonium-uranium extraction process that was widely used in the production of nuclear materials for the weapons program throughout the DOE complex.7 incorrect, so waste sampling was performed to gather the best data for scaling factor development.

The AKSR did not address the 10 EPA-tracked radionuclides in detail commensurate with

AKSRs for other RH sites. EPA examined the in formation presented and concluded that the data presented were sufficient, because the waste stre am is limited to two containers and the data obtained are representative of the anticipated radionuclide distribution based on sampling and analysis.

(3) The physical characteristics of the waste stre am were evaluated and were found to be adequately described.

The AKSR states that, “Waste Stream ID-INTEC- RH consists predominantly of organic and inorganic debris.” However, the AKSR also states, “[As-generated] container specific documentation for each of the drums [in Wast e Stream ID-INTEC-RH] is limited. Waste packaging logs are not available and radiography of the drums is not possible since x-rays cannot penetrate the lead lining. Preliminary examin ation of the waste was conducted and the drum contents appear consistent with the actinide partitioning study.” Seve ral AK source documents state only that the conten ts of the containers are sludges, SN F, solidified material, or a similar identifier, implying that the waste stream was originally assigned to the S3000 SCG, not the S5000 SCG. However, other references, incl uding historic repackaging information (U035), showed that the stream contains signifi cant quantities of debris, as follows:

Drum IDIC000000427 waste consists of:

(1) 4-liter (L) Poly Nalgene bottle (half filled with reddish brown solid residue)

(1) l,000-milliliter (ml) Poly bottle (empty and broken)

(4) Rags/Terri wipes and miscel laneous yellow plastic from bag

(3) Blue rubber tubing (1-2 feet in length)

(2) Red rubber tubing (1-2 feet in length)

(1) Clear rubber tubing (2 feet in length)

(2) Lead bricks (Note: The 4-L bottle was located on top of the two lead bricks for shielding purposes)

(4) 1/4-inch lead disks (two on the top and tw o on the bottom of the drum). No official

measurements were taken on the lead disks

(2) 1/4 inch thick lead liner inside the drum

Drum IDIC000000460 waste consists of:

(1) 4-L Poly Nalgene bottle with no mark ings on the bottle (Containing solid white residue). The bottle was brittle and broke during repackaging.

(19) 40-ml empty glass bottles (brown in co lor) with septum lids. NOTE: Markings were present on several of the bo ttles, such as 0620 WC114, 06150410 WC114.8 (4) 1/4-inch lead disks (two on the top a nd two on the bottom of the drum). Note: Operator assumes there are two disks on the bot tom; was not verified by the Operator to have two disks on the bottom. Operator coul d only see the lead disk and assumed from the thickness that two lead disks were present.

(1) Plastic drum liner and plastic bag.

(2) 1⁄4-inch thick lead liner inside the drum. Operator verified th e lead thickness to be

1/4-inch.

The photograph below, which was included in INL-CCP-AK-551, Revision 0, shows the general configuration of mate rial in Drum IDIC000000460.

INL-CCP used the above information, among other da ta, and concluded that the waste stream is composed of greater than 50 percent hetero geneous organic and i norganic debris, thus warranting the assignment of waste matrix code S5400, Heterogeneous Debris. INL-CCP also states in the AKSR that “[alt hough the waste stream] is compri sed of more than 50 percent heterogeneous debris, any drum may include n early any percentage of the waste material parameters [WMPs] listed in S ection 5.4.1.2, except that no indivi dual drum will contain greater than 50 percent homogeneous solids (References C013, U031, U032, U033, and U035).” Data

examined did not indicate the presence of residual liquids.

Although the SCG is defined by the volume percen t of material, the mass percent calculations presented in the AKSR associated with WMP analys es show that the waste stream is composed of over 95% inorganic waste by mass, the vast ma jority of which is metals. Actual organic matrices (sludges) compose about 1.5 % of the stream by mass. The WMP calculations in the AKSR were based upon data available in the AK record.

EPA’s analyses showed that phys ical attributes of the waste can be ascertained through the AK record, and specifically those records obtained du ring recent repackaging. These data, together9 with the INL-CCP VE results, verify that each of the containers falls under the S5000 SCG [see Item (5), below, for additional information].

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

EPA examined the information presented in th e AKSR pertaining to the identification of SNF and HLW. The discussion addressed the pres ence/absence of SNF and HLW in Section 5.4.5

and cited several references that address SNF/HLW determination. INL-CCP AK personnel

indicated that the discussion was intended to ad dress two components of the waste stream: the organic solids (from an actinide partitioning study) and small vials/debris waste in the drums that originated from other sources. The AKSR a ddresses SNF and HLW, but does not clearly distinguish between the two different components that are addressed usin g different arguments. EPA expects that this discussion will be expande d in revisions of the AK SR to better delineate these aspects. INL-CCP stated that LLW is not expected, which was verified during dose-tocurie (DTC) measurem ent activities.

(5) Sufficiency of the AKSR and implementation of AK as required in Attachment A of the WCPIP were evaluated and were found to be adequate.

Attachment A of the WCPIP specifies that the following be included in the AKSR:

• Executive summary

• Waste stream identification summary

• AK data and information description

• Program information

• Waste stream information

• Qualification of AK information

• Container-specific information

Attachment A mandates a process that should be followed to collect and analyze AK data,

similar to that used for CH waste. Both th e content of the AKSR and the sufficiency of AK implementation were assessed.

The AKSR includes the required data, and the AK pr ocess used to obtain and evaluate the data was comparable to the CH process. Since th e current AKSR meets basic requirements of the WCPIP, modifications to the AKSR, particularly with respect to radiological information, would

be of interest to EPA. Notification of changes to the AKSR is a T2 change.

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

Data traceability was examined for drum Nos. IDIC000000427 and IDIC000000460 (referred to as drum Nos. 427 and 460, respectively) to establ ish the historical AK record for each drum.10 Select references were examined to obtain drum history, starting with ol der reference data and ending with current INL-CCP BDRs . Reference U028 (1978) is an early document that contains drum transfer information pertaining to drum transfer to the Radioactive Waste Management Complex (RWMC) at INL. The Radioactive Wast e Form shows that two drums were generated in October 1978 in Building 627, and were composed of “spent nuclear fuel.” These drums were then apparently transferred to the RWMC. Reference P018 is the Intermediate Level Transuranic Storage Facility Drum Retrieval Report, which indicates that drum 427 was retrieved from vault 6A in September 2005, and was subsequently placed in

ISC/SO # TRU ISC-0155 at the I LTSF Storage Pad. Drum 460 was retrieved from vault 9A in September 2009 and was placed in ISC/SO # TRU ISC-0151.

References P004 and P007 provide profiles for dr um Nos. 460 and 427, respectively, included in the site’s “Integrated Waste Tracking Syst em.” These forms show general container information, including drum data and historic ra diological information. INL-CCP indicated that

both these drums underwent “fast scan” after the retrieval even t and were also opened for preliminary visual examination. Reference U033 indicates that the drums underwent fast scan in June 2007, where the presence of lead lining in the drums was noted. Subsequently, the drums were repackaged. Reference U035 presents the re sults of the drum repackaging, which identified

the contents of the two drums. Drum No. 427 included a 4-L Poly Nalgene bottle filled with reddish brown solid residue), a 1,000-ml poly bottle that was empty and broken, as well as various rags, wipes, tubing, and lead bricks and disks. Drum No. 460 contained a 4-L Poly Nalgene bottle with no markings on the bottle that contained solid white residue—the bottle was brittle and apparently broke duri ng the process. The drum also contained empty glass bottles and

lead disks.

Lastly, drums underwent VE and DTC proce sses as documented in BDRs RHINLVW090001 and RHINLDTC09004 (2009). VE data for drum No. 427 indicates it is composed of 80% organics by volume (not by mass, as used in th e waste material parameter calculations), and includes various waste materials such as pl astic bagging, plastic tubing, paper towels, metal/copper wire, lead sheeting, lead brick, and some solidified organic sludge in a 4-liter bottle. Similarly, VE data for drum 460 is also composed of 80% organi c waste, and includes a plastic spoon, 4-L bottle in pieces, plastic bags , lead discs and lead sheeting, and 15 small and broken glass bottles. Note that these data suggest the waste is 80% organic material (debris) by volume, while the WMP calculations showed that the stream is composed primarily of metals (lead) by weight. As a result of this analysis, EPA verified that the drums were traceable from the building of origin through wa ste retrieval/storage events, to final waste characterization

activities.

(7) Sufficiency of AK Source Documents and Related Document Tracking was evaluated and found to be adequate.

AK supporting documents are presented in the AKS R reference listing and Attachment 4 of CCP-TP-005. INL-CCP representa tives provided an updated version of Attachment 4 that included all AK references, specifically those presented in the CCP-AK-INL-551, Revision 0. The AKSR did not include all applicable references within its own refere nce list, but this is11 typical because the AKSR is a dynamic document. EPA will examine the reference listing in CCP-INL-550, Revision 0 as part of the T2 analysis of changes to the AKSR.

(8) Interpretation of WCPIP, with respect to contents of the Certification Plan and CTP, was evaluated, including content a nd technical adequacy of the CTP and was found to be adequate.

EPA’s RH approval letter indicated that sites must generate a Ce rtification Plan that explains

how RH waste characterization will take place at each site, as we ll as a CTP when this plan is required as part of AK Qualification. EPA’s in tent was that the sites present, somewhere, exactly how characterization is to take place on a waste stream basi s, followed by a detailed plan explaining implementation of confirmatory testing when this is to take place.

The WCPIP requires the following to be included in the CTP:

• A description of the waste stream or waste stream lots to which the plan applies

• A description of the confirmatory testing proposed, including the percentage of waste containers that will be subj ect to confirmatory testing

• An explicit description of the waste ch aracterization DQOs and quality assurance objectives (QAOs) that will be satisfie d with the data being qualified

• A description of the DQOs and QAOs that wi ll not be confirmed with the data being qualified and an explanation of how compliance with those DQOs and QAOs will be

demonstrated

• A description of how the tested subpopulation will be represen tative of the waste stream

or waste stream lot

INL-CCP elected to combine th e Certification Plan and CTP in CCP-AK-INL-552, Revision 0.

The document includes the above bulleted items. Also in this document, INL-CCP states the following with respect to the characterization process:

Acceptable Knowledge (AK) will be used to document that each RH TRU waste Data Quality Objective (DQO), with th e exception of the payload container based parameters, have been met ...This Plan will id entify the strategy that the Central Characterization Project (CCP) will use to qualify the AK information available for Waste Stream ID-INTEC-RH.

CCP-AK-INL-552, Revision 0 states that the WCPIP allows combin ations of strategies to qualify AK and indicates that the following DQOs were addressed us ing the listed qualification methodologies:

• Defense Determination (which can be dete rmined only through AK and does not require qualification as per the WCPIP)

• TRU Waste Determination which is to be qua lified by DTC which uses characterization data obtained through solid sampling and swipe sampling for scaling factor determination12 • RH Waste Determination, which is to be qualified using measurement data

• Activity Determination, which is to be qualified by DTC (measurement)

• Residual Liquids, qualified by performance of VE on each container

• Physical Form, qualified by performance of VE

The combination of strategies used by INL-CCP concurs with the requirements of the WCPIP.

Notification of modifications to CCP- AK-INL-552, Revision 0 is a T2 change.

EPA determined through evaluati on that the sampling and analysis performed to obtain scaling factors were conducted by INL-CCP using charac terization processes de scribed in the WCPIP that had not been approved by EPA. EPA c oncluded that since INL-CCP has used unapproved processes to generate radiological data, EPA could not consider this waste stream for approval until processes similar to those used by INL-CC P had been evaluated. INL-CCP informed EPA that the processes used for RH waste sa mpling at the Argonne National Laboratory and radiochemistry work done at INL on other RH waste streams are representative of what was implemented for the subject waste stream. EPA decided to observe the ANL and INL implemented processes for RH waste and pe rformed inspections on February 16-17, 2010 at ANL (See Attachment C) and on January 14, 2010 at INL (See Attachment D).

(9) Content and technical ad equacy of the CRR were evaluated and found to be adequate.

The content of the CRR was examined to see wh ether 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, including,

but not limited to:

• Specification of applicable site and waste stream

• A listing of each DQO

• Data from the AK record that addresses each DQO

• AK source document references th at support/provide the data

• A listing of AK record DRs, if any, that are relevant to each DQO

• Documentation, including specific references , of how the AK data for each DQO were qualified, such as batch data reports, corrobor ative data, proceedings of a peer review,

etc.

• Radiography and/or visual examination summar y to document that liquids greater than 1 percent are absent from the waste and to confirm AK concerning the physical properties

of the waste

• A summary presentation of radiological measur ement data used to meet the DQOs and to

confirm AK

• A complete AK summary13 • A complete listing of all container identific ation numbers used to generate the WSPF,

cross-referenced to ea ch batch data report

• A listing of AK discrepancies generated by an AK qualification process and the corresponding resolutions

• Signature of the Site Project Manager (SPM)

INL-CCP provided an Excel version of the CRR th at included the above in formation, but did not include the signature of the SPM. INL-CCP provided a full copy of the CRR (pdf version) following the inspection that me t the requirements of the WCPIP. Although not anticipated because of the limited waste stream size, notificati on of availability of a revised CRR is a Tier 2 change.

(10) Use of a CSSF was evaluated and was found to not apply to these wastes.

Completion of a CSSF is required when AK from a related CH waste stream is used in the RH waste characterization process. The INL-CCP repr esentative indicated th at CH data were not used in this manner, so a CSSF was not prepared for this waste stream.

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

Scott Smith (AKE) prepared the AKSR, and Mark Doherty (SPM) prepared the Certification Plan/CTP. The AKE Qualification Cards were ex amined to determine whether both individuals’ training was up to date. Neither document indicated that the AKE s had read required materials pertinent to INL. Apparently, the process has changed so that the Qualification Cards are not kept up-to-date; instead an e-ma il verification method is used to ensure each individual receives and completes site-specific readi ng. Documentation that both individuals have read the required

AK Source Documents was sent to EPA via e-mail following the inspection. It should be noted

that documentation examined did not indicate that individuals are trained to EPA requirements, nor are they trained with resp ect to radiological characteriza tion 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 was examined and was found to be adequate.

INL-CCP representatives provided a draft of the WSPF, without requ ired signatures or attachments. The WSPF included a section, which stated that “testing” was not applicable, but the stream underwent sampling and an alysis during scaling factor development, so this portion of the form will likely be completed when the WSPF is formalized beyond the draft phase. Notification of availability of the final WSPF is a T2 change.

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

INL-CCP stated that no DR Forms related to EPA compliance issues have been prepared for this waste stream. However, a DR related to Resource Conservation and Recovery Act (RCRA) compliance was available for review. This DR dealt with historic management of the waste14 stream as non-hazardous, and INL-CCP’s dete rmination that the stream should be RCRAhazardous (D008-lead, and D018-benzene). The fo rm was complete and showed that INL-CCP prepares appropriate documentation to capture identified discrepancies and their resolution.

(14) AK accuracy was assessed and 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 to be assessed in three areas: r eassignment of the waste to a different SCG; reassignment of the waste to a different waste stream; and 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 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 stream is a T2 change.

(15) Defense determination arguments were examined and found to be adequate.

The radiological characteristics of the ID-INTEC -RH waste stream originated primarily from

H.B. Robinson Fuel Pin E-14. This fuel was not defense-related, but CCP makes the argument that the actinide separation te sts performed on this pin would serve a broad purpose, including those related to defense. INL-CCP also argue d that the waste was contaminated with other radiological materials from the cell that were defe nse related, but little su pport for this argument was provided. As a result, EPA had the following concern:

EPA Concern INL-RH-AK-09-001CR, Item 2: EPA AK Concern 1The AK Summary Defense Determination assumes that the cell(s) in which the HB Robinson Fuel Rod E-14 studies took place are also c ontaminated with material from other defense-related activities. However, the AK Summary does not reference documents that sufficiently

describe the other defense-relate d activities. This information is required to show that the INTEC waste is co-contaminated by defense waste.

CCP Response: CCP responded with a new text that would be added when the Section 4.1.4 of the AKSR is revised. The revised paragr aph states that the subject waste stream is commingled with other defense waste (References C012, C016, and U035). INL-CCP

concluded that AK indicates th at the fuels processed were defense fuels, including Navy

reactor fuel. Incidental cont amination of the materials in the waste stream from these

fuels occurred since decontamination of th e cells was not conducted before actinide portioning study in the same cell. In addition, incidental contamination occurred at the waste end of the cell prior to waste packaging. Also, commingling of waste occurred when empty sample bottles from routine Remote Analytical Facility were packaged with the actinide separation waste.

Status of Concern: The AKSR defense determination a ssumes that the cell(s) in which the HB Robinson Fuel Rod E-14 studies took pl ace are also contaminated with material15 from other defense-related activities due to incidental contamin ation and commingling with defense materials. The argument based on incidental contamination and commingling is possible based on data in th e AK Record, so CCP adequately addressed

EPA’s concern. The concern is closed.

(16) Load management was assessed a nd was found to not apply to these wastes.

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

(17) Attainment of DQOs through AK qualification was evaluated.

As a result of the analysis presented in Items 1-16, above, EPA was able to assess how each DQO will be addressed. The following DQOs must be addressed as per the WCPIP:

• Defense determination

• TRU waste determination

• RH waste determination

• Activity determination (total and activity per canister, including quantification and

identification of 10 EPA radionuclides)

• Residual liquids

• Physical form, including metals , cellulose, plastic and rubber

When evaluated as a whole, the CCP- AK-INL-500, CCP-AK-INL-551, CCP-AK-INL-552, and supporting source documents presented in Attachme nt A of this report indicate that DQOs, as specified in the WCPIP, have been met.

Concerns and Findings

The EPA Inspection Team identified one AK c oncern and no AK finding relative to the two containers in the ID-INTEC-RH waste stream, wh ich were the subject of this T1 change

evaluation. The AK concern wa s adequately addressed.

Tiering Changes

No new T1 or T2 changes have been added as a result of this evaluation.

Conclusions

During this T1 change evaluation, EPA examined whether several technical elements associated

with Waste Stream ID-INTEC-RH were technica lly valid. Based on the results of this evaluation, EPA is approving the T1 request for Waste Stream ID-INTEC-RH, consistent with

the limitations discussed above.16 4.2 Radiological Characterization

RH Characterization Overview

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

measurement data. As has been the case at all the RH TRU waste characterization sites that EPA has previously approved, RH ra diological characterization relie s on the development of scaling

factors that correlate an easil y measured parameter like a wast e container’s external exposure (dose) rate with isotopic di stributions for specific TRU radi onuclides. The development of radionuclide scaling factors for INTEC wastes is essentially the same as what EPA evaluated and approved during the INL-CCP baseline inspection.

The characterization methods used for the INL-CCP INTEC RH wastes 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 eval uation, EPA examined the following elements of the INL-CCP radiological characterization program:

• Development of a DTC correlation as a func tion of waste density using MCNP5 based on each drum’s measured external exposure (dos e) rate, assuming the main contributors to the external exposure was 137 Cs

• Derivation of radionuclide scaling factors for quantification of the 10 WIPP-tracked radionuclides as supported by calculation packag es and the destructive assay of swipe and waste samples

The radiological characterization proce ss is summarized in Figure 1, below.17 The development of the 137 Cs scaling factors was supported pr imarily by the application of Inductively Coupled Plasma – Mass Spectrometr y (ICP-MS) and radiometric (alpha and gamma spectrometry) results from the collection and anal ysis of one smear and two grab samples from

each of the two drums of INTEC waste. Thes e activities are summar ized in CCP-AK-INL-551 and presented in deta il in calculation packages INL-RH -91, INL-RH-92 and INL-RH-93. Evaluations of the sample collect ion and analyses can be found in Attachments C and D of this
report.

Documents Reviewed

The list provided in Attachment B includes a ll documents related to the INL-CCP RH TRU radiological characterization pr ogram that were examined to support this T1 evaluation.

Technical Evaluation

(1) The development of radionuclide scaling factors was evaluated and was found to be technically adequate and appropriately documented. Figure 1: Flow Diagram of Characteri zation Process for INTEC RH-TRU Drums Locate and retrieve records

relevan t to the waste strea m

Develop a sampling plan

for the waste stream

Sample the two drums (smear and grab [solid] samples)

Analyze the representative samples

Determine the scaling factors

with res p ect to Cs-137 Use MCNP5 for shielding calculations

Using the loaded-drum model, find the mean 1 meter gamma dose rate based on a 1-Ci Cs-137 source and a constant waste density

Use the single DTC conversion/correlation factor (mR/hr/Ci) for cu rie-content calculations

Determine the Radionuclides Activities:

Find the mean gamma dose rate at 1 m from the

surface of a drum based on four measurements made

Divide the mean measured dose rate by the DTC
conversion factor to find the Cs

- 137 activity in Ci

Multiply the Cs-137 activity by the scaling factors to

find the activities of other radionuclides of interes t Determine the Scaling Factors: Determine the DTC Conversion Factor:18 EPA evaluated the following:

• 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 co rrelated to the radionuclides whose physical half-lives are such that they could be responsible fo r the measured external dose rate, i.e., 137 Cs, cobalt60 and europium-152

• Contributions of the short-lived radionuclides (i.e., physical half- lives less than two years) to the total measured dose rate

• The calculated results are used to develop th e scaling factors and convert the measured

external dose rates obtained via DTC to radionuclide-specific 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 strontium-90 ( 90 Sr)]

• The determination of the contribution of a ll radionuclides to the radiological hazard 5

• 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 tw o drums of INTEC waste

The details of the scaling factor development relied heavily on the analysis of the analytical results of the smear and waste samples. CCP-AK-INL-551 presents an overview of this approach, including the application of each analytical technique to specific radionuclide(s). For example: alpha spectrometry data were used to support development of the 238 Pu scaling factors;

ICP-MS data were used to support the scaling factors for 239 Pu, 240 Pu and the U isotopes, since they cannot be adequately separated by alpha spectrometry; and the scaling factor for 90 Sr was based on chemical separation and counting by ga s proportional counting. These activities are summarized in CCP-AK-INL-551 and more fully documented in INL-RH-91 and INL-RH-93.

There are no issues rela ted to the technical ad equacy or documentation of radionuclide scaling

factors for the two drum s of INTEC wastes.

5 Although the determination of a waste container’s radiolog ical hazard is not an EPA requirement, this information may be useful in understanding other aspects of a container’s radiological characterization.19 (2) The technical basis of the DTC correlati on and its documentation were evaluated and found to be unchanged from what EPA had in spected 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 di spersed uniformly throughout the waste

• The waste matrix’s density is assumed to be unity (one), beca use photon attenuation is more influenced by material density, as opposed to specific composition or atomic

number

• Waste densities range from 0.1 gram s per cubic centimeter (g/cm 3 ) to 2.1 g/cm 3 , but an assumed value of 1.2 g/cm 3 was assumed for DTC calculatio ns (corresponding to a net sample mass of 4.8 kilograms)

CCP-AK-INL-551 addressed waste pack aging issues and other concerns that were specific to the

INTEC waste. Most notable of these were the eff ects of two layers of qua rter-inch lead shielding (see CCP-AK-INL-551, Figure 5.1), de tailed in calculation pack age INL-RH-97. There are no

issues related to the technical adequacy or documentation of radi onuclide scaling factors for the

two drums of INTEC wastes.

(3) Technical aspects and docu mentation of the radiological characterization process were evaluated and found to be acceptable.

CCP-AK-INL-551 is the main docum ent that describes the radiol ogical characteri zation process

that INL-CCP used for the INTEC wastes. This document is supported by a series of calculation packages, which were reviewed in the process of evaluating these wastes. These packages had been prepared and reviewed initially by Je ne Vance, Jim Holderness, Dave Moody, Jesse Klingensmith and Larry Porter to support the INTEC wastes, as we ll as several RH baselines that had been previously evaluated by EPA. These packages documented the following:

• Application and verifi cation of Microshield ®

• Evaluation of all potential contributors to a container’s dose rate including contributions

of short-lived radionuclides

• Potential sources of uncerta inty for the INTEC wastes

• Statistical treatment of the radiometric data in support of radionuclide-specific scaling

factors

• Information input checks for INTEC wastes

• Technical development of scaling factors

• Technical derivation of the DTC approach and documentation of the DTC spreadsheet20 The EPA evaluation team revi ewed these packages and Revision 0 of CCP-AK-INL-551 in advance of the formal T1 evaluation meeting at EPA headquarters. Several documents had been reviewed previously to support other RH TRU programs. During EPA’s review and subsequent discussions with the authors, th e EPA evaluation team had the opportunity to discuss technical concerns and apparent disc repancies with INL-CCP personnel and to question INL-CCP personnel regarding a variety of technical aspects related to these wastes. None of the calculation packages required serious modificat ions. The EPA evaluation team found that CCP-AK-INL-551 adequately documented the radi ological characterization process for INTEC wastes, and the calculation packages described above and listed in A ttachment B adequately supported the activities u pon which the radiological characteri zation of the two drums of INTEC

wastes was based. There were no issues related to the documentation of technical aspects of the INL-CCP radiological characterizati on approach for the INTEC wastes.

(4) The collection and analysis of samples were evaluated and were found to be adequate.

The collection of the one swip e and two bulk material samples from each of the two INTEC containers and their analyses were evaluated as se parate activities in support of this T1 change. The results of these evaluations are presented in Attachments C and D of this report. There were no concerns relative to the sample collection or analyses of the two INTEC samples in support of the development of radionuclide- specific scaling factors.

(5) The technical basis and derivation of To tal Measurement Uncertainty (TMU) were evaluated and were found to be adequate.

The development of TMU for the two drums of INTEC wastes 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 TMU determination in cluded contributions of the following:

• Drum weight measurement

• Dose rate measurement uncertainty

• Scaling factor uncertainty, which includes the contribution of sa mple collection and analysis

• MCNP5 code and modeling issues

• Contributions of other gamma emitters

• Uncertainty in reported campaign inventories

The treatment of TMU is summarized in CCP-AK -INL-551 and presented in further detail in Calculation Package No. INL-RH- 96, INTEC Debris Waste Uncertainty Analysis. The principal source of uncertainty (50% for a density of 1.2 g/cm 3 ) for all radionuclides is the variability in the waste configuration uncertainty i.e., the physical location and size of the waste-bearing bottles and the dispersion of material within the drum. However, the Pu isotopes and 90 Sr have individual contributions that exceed 50%, ba sed on the uncertainty from partitioning these radionuclides that was derived from the variability of the ICP-MS data. There were no concerns regarding the technical derivation and docum entation of TMU for the INL-CCP INTEC RH

wastes.21 (6) RH and TRU determinations were a ssessed and were found to be adequate.

The determination that the RH containers meet th e definition of TRU wast es and RH waste were examined during the baseline insp ection. Both of these aspects are directly involved with the DTC measurement at the 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 documenta tion-related concerns regarding the TRU and RH determin ations for INL INTEC 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.

Tiering 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.

5.0 FINDINGS AND CONCERNS

S ummary of Concerns and Findings

The EPA inspection team identified one AK concer n which is closed. No findings were made related to AK or radiological ch aracterization. There are no open c oncerns resulting from this T1

evaluation.

6.0 CONCLUSIONS

EPA concluded that the waste ch aracterization processes of AK a nd radiological characterization proposed for use to characterize RH TRU (ID- IN TEC-RH) wastes from INL-CCP are adequate. There are no open issues rela tive to this T1 evaluation.

6.1 Approval

The T1 change that was evaluated consisted of the waste characterization techniques of AK and radiological characterization as applied to Waste Stream ID-INTEC -RH. Based on the results of this evaluation, EPA approves these components of the T1 change. INL-CCP is approved to characterize these RH TRU wastes, consistent with the limitations specified in this report.

6.2 Tiering Changes

Based on the results of this T1 evaluation, ther e are no substantive changes to the T1 or T2 designations assigned to AK or radiological characterization during the baseline approval.A-1 

### ATTACHMENT A

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 Real Time Radiography February 2007 A-98-49; II-A4-80 Tier 1 Change – Approval of K Cell Waste 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-A4-72 Tier 1 Change – Approval of Visual Examination Technique September 2009 A-98-49; II-A4-118 Tier 1 Change – Approval of M- 4 Cell Waste and Waste Stream IDHFEF-S5400-RH, Lot 1A January 2010 A-98-49; II-A4-122

Tier 1 Change – Approval of Waste Stream ID-MFC-S5400-RH June 2010 A-98-49; II-A4-126B-1 

### ATTACHMENT B

LISTING OF DOCUMENTS REVIEWED

• CCP Waste Stream Characterization Checklis t, Waste Stream Number: ID-INTEC-RH, Lot #, provided December 7, 2009

• CCP-AK-INL-550, Central Characterization Project Acceptable Knowledge Summary Report for Stored Remote-Handled Transurani c Debris from the Idaho Nuclear Technology and Engineering Center at the Idaho National Laboratory, Waste Stream ID-INTEC-RH, Revision 0, January 8, 2009

• CCP-AK-INL-551, Central Characterization Project Radiological Characterization Technical Report for the Idaho Nuclear Technology and E ngineering Center (INTEC) Remote-Handled Transuranic Debris Waste, Revision 0, October 20, 2009

• CCP-AK-INL-552, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance and Confirmati on Test Plan for INL Waste Stream: ID-INTEC-RH, Revision 0, April 2, 2009

• CCP-TP-005 Attachment 1, Acceptable K nowledge Documentation Checklist, ID-INTEC-RH, provided December 8, 2009

• CCP-TP-005 Attachment 4, Acceptable Know ledge Source Document Reference List, INTEC, provided December 8, 2009

• CCP-TP-005 Attachment 6, Waste Form, Waste Material Parameter, Prohibited Items and Packaging, and related WMP memora ndum, INTEC, provided December 8, 2009

• CCP-TP-504, CCP Dose-to-Curie Survey Procedur e for Remote-Handled Transuranic Waste, Revision 7, Effective Date: August 20, 2008

• Characterization Reconciliati on Report Waste Stream ID-IN TEC-RH (spreadsheet and pdf signed cover sheet), provided December 7, 2009

• DOE/WIPP-02-3122, Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant, Revision 6.3, effective date February 5, 2009

• DOE/WIPP-02-3214, Remote-Handled TRU Waste Characterization Program Implementation Plan, Revision 0D

• Draft Waste Stream Profile Form, Waste St ream ID-INTEC-RH, provided December 7 and December 23, 2009

• Inter-Office Correspondence, Draft, From C. M. Gomez

, to M. Sensibaugh, Re: Acceptable Knowledge Accuracy Report: Idaho Nuclear Technology and Engineering Center at Idaho Nuclear Technology and Engineering Center at Idaho National Laboratory, Waste Stream Number ID-INTEC-RH, Lot 1, October 12, 2009B-2 • Memorandum to Irene Quintana, CCP Project Ma nager from J. Klingensmith, Re: Analysis of Sample Data for RH TRU Debris Waste Generated from the INTEC at INL, December 2, 2009

• C001, E-mails to John D. Baker and John H. Meikrantz, Re: INTEC RH TRU Waste Information, John A. McCray, August 8, 2005

• C010, E-mail to Lea Ann Allen, Re: Fast Scan Report, Raj Bhatt, July 18, 2007

• C011, EDF for the Review of ILTSF Mixe d Waste, SMB-02-91, S. M. Burns, January 17, 1991

• C012, INTEC Interview, Scott Smith, April 17, 2008

• C013, INTEC Follow-up Interview, Scott Smith, TBD

• C014, E-mails to Raj Bhatt, Douglas B. Hendr icks, John D. Harris, Casey W. McCray, Joe Saye, Re: WIR Determination from Jason C. Orme, November 3, 2008

• C015, Memo to Irene Quintana, Re: Analysis of Sample Data for RH TRU Debris Waste Generated from the INTEC at INL, J. Klingensmith, December 2, 2009

• C016, Memo from Scott Smith, AKE to CCP Records, Defense Determination for INTEC RH TRU Waste, December 16, 2009

• DR001, Waste Stream ID-INTEC-RH, Historical and Current RCRA Characterization and Assignment of EPA Hazardous Waste Numbers, Undated

• P001, Carolina Power & Light Co. (H.B. R obinson Steam Electric Plant, Unit No. 2), Exemption Amendment, L-S Document 485327, 59 FR 12993, Docket Number 50-261, March 18, 1994

• P004, Integrated Waste Tracking System C ontainer Profile, IDIC000000460 Solidified Fuel Sludge, Matthew Allen, Paul R. Smith, Joel R. Hitz, July 9, 2007

• P007, Integrated Waste Tracking System C ontainer Profile, IDIC000000460 Solidified Fuel Sludge, Matthew Allen, Paul R. Smith, Joel R. Hitz, July 9, 2007

• P015, Characterization of Transuranic Solid Waste from a Plutonium Processing Facility, LA-5993-MS, Ray Mulkin, June 1975

• P018, ILTSF Drum Retrieval Completion Report, ICP/EXT-05-00886, Revision 0, Idaho Completion Project, January 2006

• P019, Waste Characterization for INEL Remote-H andled/Special-Case Stored Transuranic Waste, WM-PD-85-014, Dennis A. Peterson, November 1985

• P020, Engineering Design File, Radiological Pr operties of Remote-Handled Transuranic Waste Inventory, EDF-4687, Revision 0 and Revision 1, Cecilia Hoffman, April 26, 2004 and May 20, 2005

• P022, Applied Nuclear Data Research and Deve lopment, LA-9647-PR, E.D. Arthur, et al., April 1983B-3 • P025, Engineering Design File, Crosswalk fo r the Remote-Handled Transuranic Waste Inventory, EDF-4699, Revision 1, Cecilia Hoffman, December 13, 2004

• P039, Characteristics of Comm ercial Nuclear Materials Stored in the TAN Pool, INEL/INT-98-00767, R.K. McCardell, September 1998

• P041, INEL Waste Management Plan for FY- 1978 Idaho National Engineering Laboratory, IDO-10051, Nuclear Fuel Cycle Division, August 1977

• P043, Study of Bidentate Compoun ds for Separation of Actini des from Commercial LWR Reprocessing Waste, ICP-1180, L.D. McIsaac, J. D. Baker, J.F. Krupa, R.E. LaPointe, D.H. Meikrantz, N.C. Schroeder, May 1979

• P045, Engineering Evaluation/Cost Analysis for the Decontaminati on and Decommissioning of Building CPP-627, the Remote Analyti cal Facility, DOE/NE-ID-11157, Revision 1, INEEL, April 2004

• P046, Process Description and Operating History for the CPP-601/-640/-627 Fuel Reprocessing Complex at the Idaho National Engineering and Envir onmental Laboratory, INEEL/EXT-99-00400, E.P. Wagner, June 1999

• P048, Characteristics of Nucl ear Materials Stored in the MTR Canal, Volume I, INEEL/INT-98-00768, 3 rd Draft, R.K. McCardell, October 1998

• P049, Characteristics of Nucl ear Materials Stored in the MTR Canal, Volume II, INEEL/INT-98-00768, 3 rd Draft, R.K. McCardell, October 1998

• P051, Characterization and Shipping Records fo r Remote-Handled (RH) Transuranic (TRU)

Waste Stored at the Radioactive Waste Mana gement Complex (RWMC) – (Part 4, page 38), 3460-94-084, H.D. Killian and S.K. McDermott, September 1994

• P056, AK Summary Documenta tion AK TRU Packaging, RP T-456, DRAFT, Revision 0, Idaho Cleanup Project, October and November 2007

• P057, Engineering Design File, CPP-1617 Fi re Area Evaluation, EDF-4684, Nancy Makey, April 26, 2004

• P058, Technical Procedure, CPP-1617 Wa ste Handling and Operations, TPR-7318, Radioactive Waste Management Co mplex at INTEC, February 1, 2007

• P059, Estimated Radiological Inventory Sent from the Idaho Nuclear Technology and Engineering Center to the Subsurf ace Disposal Area from 1952 through 1993, ICP/EXT-03-00967 (Revision 0), INEEL-EXT- 05-00967 (Revision 1), James A. Vail, Michael L. Carboneau, Glen R. Longhurst, March 2004 and December 2005

• P060, Safety Analysis Report for the INTEC Waste Management Facility (IWMF), SAR-103 Addendum A, Idaho Cleanup Project, December 20, 2006

• P061, Decontamination Cell Operation, TPR- 7298, Revision 7, Idaho Cleanup Project, June 4, 2008

• P062, Packet of Material Safety Data Sheets (i ncludes Nochar, Fiberset, Primafloc C-3, and diatomaceous earth), Various datesB-4 • P063, Engineering Design File, Baseline Esti mate of the Volume of Remote-Handled

Transuranic Waste Stored at the Radio active Waste Management Complex, EDF-4379, Revision 0, Cecilia R. Hoffman, March 29, 2004

• P068, A Survey of NRTS Waste Manageme nt Practices, Volume II, ICP-1042, Allied Chemical Corporation, September 1971

• P069, Removal Action Work Plan for the Decontamination and Decommissioning of Building CPP-627, Remote Analytical Faci lity, DOE/NE-ID-11158, Revision 0, INEEL,

June 2004

• P072, Historic American Engineering Records, Idaho National Laboratory, Idaho Chemical Processing Plant, Fuel Reprocessing Complex, INL/EXT- 06-11969, HAER Number ID-33-H, Susan Stacy, Julie Braun, December 2006

• P076, Remote and Service Analysis Group Oper ating Manual, PTR-729, B.R. Hunter, G.A. Huff, Editors, November 1964

• P111, WIR Citation Determination Check list for INTEC CPP-627, File Numbers IDIC000000427 and IDIC000000460, INL, October 31, 2008

• P112, INEL Transuranic Waste A cceptance Criteria Fuel Proce ssing and Waste Operations Division, 100-10074, Revision 4, Revision 3, Revision 2, Revision 1, July 1987, March 1986, February 1984, and April 1980

• P113, Engineering Design File, Preliminar y Radiological Assessment on INTEC RH TRU Drums, Yale D. Harker, EDF-8050, Revision 0, November 17, 2008

• P114, WIR Citation Determination Checklis t, WIR Citation Documentation for Contaminated Job Waste, Doug Hendricks, Jo e McKaig, Jason Orme, File Number 4181Q, November 18, 2008

• U001, Engineering Design File, Radiologi cal Assessment on INTEC RH TRU Drums IDIC000000427 and IDIC000000427, EDF-8050, Yale D. Harker, Undated

• U005, Pictures of CPP Fluorinel Equipment Used in Experiments with H.B. Robinson Waste,
Undated

• U006, RH TRU RTR Prescreen for Rep ackaging/AK Worksheet for IDIC000000427 and IDIC000000460, Greg Lamb, Chris G. Davis, August 14, 2007

• U024, Abstract, Executive Summary, and Table of a Draft Report on Acceptable Knowledge on INTEC RH TRU Drums (Lead-Lined), Undated

• U028, Radioactive Waste Form, October 13, 1978

• U029, INTEC Health Physics Log Sheet, June 21, 1978

• U031, Videos of Visual Inspection of Drum IDIC000000427-DVD #1 (4 files) and DVD #2 (1 file), July 30, 2008

• U032, Videos of Visual Inspection of Drum IDIC000000460-DVD #1 (1 file) and DVD #2 (1 file), July 30, 2008B-5 • U033, RH TRU Drum Repackaging Datasheet Form 880 on IDIC000000427 and IDIC000000460, FRM-880, July 29, 2008

• U035, RH TRU Inventory on Drums IDIC000000427 and IDIC000000460, Vince Daniel, July 30, 2008

• U040, INTEC RH TRU Character ization, Radiochemistry & Gamma Spectroscopy, David W. Moody, INL-RH-91, Revision 0, October 1, 2009

• U041, INTEC RH TRU Characteri zation, Mass Spectrometry Da ta Analysis Input Check, David W. Moody, INL-RH-92, Revision 0, October 1, 2009

• U042, INTEC RH TRU Character ization, INTEC Cs-137 Scaling Factor Development, David W. Moody, INL-RH-93, Revision 0, October 1, 2009

• U044, INTEC RH TRU Characteri zation, 95% Hazard Calculation for INTEC Debris, Jesse J. Klingensmith, INL-RH- 95, Revision 1, December 5, 2009

• U045, INTEC RH TRU Characteri zation, INTEC Debris Waste Un certainty Analysis, Jesse J. Klingensmith, INL-RH- 96, Revision 1, December 5, 2009

• U047, INTEC RH TRU Characteri zation, ID-INTEC-RH Dose-to- Curie (DTC) Calculations, Jesse J. Klingensmith, INL-RH -98, Revision 1, December 6, 2009

• U613, MCNP5 Analysis for DTC Uncertain ty, James H. Holderness, ORNL-RH-13, Revision 0, April 19, 2008

• U649, ORIGEN2.2 Calculations for HFEF Debris , J.J. Klingensmith, INL-RH-62, Revision 0, August 19, 2009

• U843, Scaling Factor Development, Jim Ho lderness, INL-RH-02, Revision 0, June 5, 2006

• U845, MCNP Sensitivity Studies, James H. Holderness, INL-RH-04, Revision 0, May 8, 2006

• U846, INL Cs-137 Dose-to-Curie Correlation Uncertainty, Jim Holderness, INL-RH-05, Revision 0, May 8, 2006C-1 

### ATTACHMENT C

APPROVAL SUMMARY FOR ID AHO NATIONAL LABORATORY

REMOTE-HANDLED WASTE SAMPLING

AT ARGONNE NATIONAL LABORATORY

1.0 SUMMARY AND SCOPE

On February 16-17, 2010, the U.S. Environmenta l Protection Agency (EPA) conducted a followup Tier 1 (T1) change evaluation of the collect ion of remote-handled (RH) transuranic (TRU) debris waste samples at Argonne National Laborator y (ANL). This evaluation was performed in

accordance with 40 Code of Federal Regulations 194.8(b) to evaluate the adequacy, implementation and effectiveness of techni cal processes implemented by the Central Characterization Project (CCP) at ANL (ANL-CCP). EPA’s ev aluation included a review of: sampling technique(s) to obtain representative waste samples, personnel qualifications/training (by review of records and conducting interviews), laborat ory chain of custody, quality assurance/quality control record s and non conformance procedures. The scope of this T1 followup evaluation included the collect ion of samples from Idaho National Laboratory (INL)-CCP

waste stream ID-INTEC-RH that were anal yzed at the Idaho Nuclear Technology and Engineering Center (INTEC) Laboratory at INL. Since the sampling event at INL was limited and EPA was not able to observe it directly, the sampling of RH debris from ANL was used as a surrogate for the INTEC RH debris waste sampli ng. By observing sample collection of RH TRU debris waste at ANL, EPA was able to evalua te and approve this technique for generating radiometric data to support th e development of radionuclide-sp ecific scaling factors. The sampling and analysis of the two containers at IN TEC provided analytical da ta that were used in large part to generate radionucli de-specific scaling fact ors that were then part of the Dose-toCurie (DTC) process whereby IN L-CCP certified these containers for shipment to the Waste Isolation Pilot Plant (WIPP).

As discussed earlier in the report, EPA f ound it necessary to evaluate the sampling and radiometric analyses of an RH waste stream si milar to the INTEC waste. This led to EPA’s evaluation and approval of the sample collection activities at ANL as described in this attachment and the sample analyses conducted at the INTEC Laboratory at INL, as described in

Attachment D.

With this report, EPA approves th e collection and analys is of RH TRU debris waste samples for the purpose of generating analytic al data to support the develo pment of radionuclide-specific scaling factors to characterize RH TRU wastes for WIPP. EPA’s evaluation was limited in scope to the collection of RH TRU samples in a hot cell using manipulators and applies to the collection of liquid, solid, or sw ipe (smear) samples. While the sampling that was observed occurred at ANL, EPA considers this activity to be representa tive of RH TRU sampling and EPA will evaluate sample collection at other Department of Energy facilities at its discretion in the

future.C-2 2.0 PARTICIPANTS IN THE TIER 1 EVALUATION

EPA observed the sample collection activities at ANL described in this report. All individuals who were present for the evaluation are listed in Table C-1, below.

Table C-1. ANL Sampling Evaluation Participants

Name Affiliation & Function Lindsey Bender EPA Headquarters, Lead Inspector
Patrick Kelly SC&A, Technical Evaluator
Irene Quintana CCP-WTS, SPM
Kaushik Joshi DOE Argonne Site Office, Observer
Andrew Gabal DOE Argonne Site Office, Observer
Spenser Pattee CCP-WTS, Waste Sampler

Daniel Pancake ANL-NOD
F. Wesley Root CCP-WTS
Mike Sensibaugh CCP-WTS
Ronnie Lee WTS/CCP, Observer
John Falkenberg ANL, Sample Collector (Hot Cell Manipulator)
Ken Wesolowshi ANL, Sample Collector (Hot Cell Manipulator)
Vivian Sullivan ANL-Analytical Chemistry Laboratory
James Rhoades DOE CBFO, Observer
Devin Hodge NOD Project Manager, Observer

3.0 EVALUATION OF RH TRU DEBRIS WASTE SAMPLING

The EPA evaluation team toured the 205 K Wing, a small hot cell facility at ANL. Its primary function currently is to suppor t the packaging of RH TRU wa stes for WIPP. Hot Cell B contained the fluid to be sampled, and the external radiation field within the cell was as high as 200 rem per hr. The activities observed included collecting liquid samples from a large container within the hot cell. All sample collection wa s performed by two operators using manipulators: John Falkenberg and Ken Wesolowshi. Both in dividuals were listed on the current List of Qualified Individuals (LOQI) and training for bot h operators was appropriately documented. All sample collection-related activ ities were recorded in Op erational Logbook RH-ANLE-WS.001, 2010, K Wing Hot Cells Building 205, ANL. Prior to beginning sample colle ction, the operators confirmed that they had the current revisions of the following documents:

• CCP-TP-509

• CCP-TP-512, CCP Remote-Handled Waste Sampling

• CCP-AK-ANLE-500, Central Characterization Project Acceptable Knowledge Summary Report for Argonne Remote-Handled Debris Waste, Waste Stream: AERHDM

• CCP-AK-ANL-505A, Central Characterization Pr oject Sampling and Analysis Plan for Argonne Remote-Handled Wast e, Waste Stream: AERHDM

EPA observed that the operators noted that they were collecting liquid samples by transferring fluid from a large container to small nalgene sa mple bottles. The collection was not volumetric,C-3 meaning there was no attempt to transfer a pred etermined volume of fluid. The only goals were to fill a sample bottle past a certain height to ensure there was adequate volume for all required analyses and to ensure that th e external radiation from each sa mple container was less than 5 millirem per hour at 30 centimeters to comply with an internal as low as reasonably achievable (i.e., ALARA) criterion. The la rge container holding the fluid to be sampled was connected to a pump and tygon-type tubing to tran sfer the sample. The operators were adept at manipulating all aspects of the equipment to effectively transfer fluid from the large container to each sample bottle. As required, the operato rs initiated an Attachment 1 form from CCP-TP-512 for each sampling event. EPA also observed that the ope rators initiated a Chai n-of-Custody (COC) form for each sample. A Tamper Indicating Device (TID) was not affixed to the sample for logistical and ALARA reasons, and the operators stated that the TIDs would be affixed the following day. The samples that were collected were transferre d from the hot cell to a secure storage area under

COC.

4.0 CONCERNS OR FINDINGS

There were no concerns or finding relative to the collection of RH TRU debris waste samples at ANL and there are no open issues relative to this activity.

5.0 APPROVAL OF RH TRU DEBRIS WASTE SAMPLING

Based on the results of this evaluation, EPA a pproves the collection of RH TRU debris samples for the purpose of supporting radionuc lide-specific scaling factors.D-1 

### ATTACHMENT D

APPROVAL SUMMARY FOR ID AHO NATIONAL LABORATORY

REMOTE-HANDLED WASTE SAMPLING ANALYSIS

AT IDAHO NATIONAL LABORATORY

1.0 SUMMARY AND SCOPE

This report supports the U.S. Environmental Protection Ag ency’s (EPA’s) approval of retrievably-stored, remote-handled (RH) tran suranic (TRU) debris (S5000) from a new waste stream from the Idaho National Laboratory (IN L). Specifically, this approval supports the

addition of new RH Waste Stream ID-INTEC-RH.

As discussed earlier in the report, EPA f ound it necessary to evaluate the sampling and radiometric analyses of RH waste stream sim ilar to the INTEC waste. This led to EPA’s evaluation and approval of the sa mple analyses conducted at th e INTEC laboratory at INL as described in this attachment, and the sample collection activi ties at Argonne National Laboratory (ANL) as described in Attachment C.

On January 14, 2010, EPA conducted a follow-up T1 change evaluation of the collection and analysis of RH TRU debris wast e samples at the INTEC Laboratory at INL. This evaluation was performed in accordance with 40 Code of Federal Regulations 194.8(b) to evaluate the adequacy, implementation and effectiveness of technical processes impl emented by the Central Characterization Project (CCP) at INL (INL-CCP). EPA’s evaluation included review of sampling technique(s) to obtain representative waste samples, personnel qualifications/training (by review of records and conducting interviews), laborat ory chain of custody, quality assurance/quality control records, non conformance procedures, analytical procedures for the separation and measurement of radionuclides, and records of instrument calibration. The scope of this T1 follow-up evaluation included the colle ction of samples and analysis of samples from

INL-CCP waste stream ID-INTEC-RH. Since th e sampling event at INL was limited and EPA was not able to observe it directly, EPA evalua ted the records that do cumented the sampling. Additionally, EPA evaluated the co llection of RH TRU debris samples from ANL as a surrogate for the INTEC RH debris waste sampling, as desc ribed in Attachment C to this report. The sampling and analysis of the two containers at IN TEC provided analytical da ta that were used in large part to generate radionucli de-specific scaling fact ors that were then part of the Dose-toCurie (DTC) process whereby IN L-CCP certified these containers for shipment to the Waste Isolation Pilot Plant (WIPP).

With this report, EPA approves the two containe rs of RH TRU waste from waste stream IDINTEC-RH. In addition, EPA approves the IN TEC Laboratory for the analysis of RH TRU debris waste samples for the purpose of generating analytical data to supp ort the development of radionuclide-specific scaling factors to ch aracterize RH TRU wastes for WIPP.D-2 2.0 PARTICIPANTS IN THE TIER 1 EVALUATION

EPA observed the records that documented the sampling of waste stream ID-INTEC-RH and the INTEC analytical laboratory where the sample s were analyzed. All individuals who were present for the evaluation are listed in Table D-1, below.

Table D-1. INTEC-INL Sampling and Analysis Evaluation Participants

Name Affiliation & Function Lindsey Bender EPA Headquarters, Lead Inspector
Patrick Kelly SC&A, Technical Evaluator
Dorothy Gill SC&A, Technical Evaluator

R.J. Nick Wade CTAC-CBFO
Irene Quintana INL, QA
Fred Dunhour DOE Argonne Site Office, Observer
Tom Clements CWI-RH/CH Programs
Shelly Sailer CWI, Laboratory QA Officer
Jeff Lang INTEC Laboratory manager
Mark Sherik RH TRU Programs
Mike Sensibaugh CCP-WTS

Tom Johnson CH TRU STR

James Rhoades DOE-CBFO

3.0 EVALUATION OF RH TRU DEBRIS WASTE SAMPLING AND ANALYSIS

3.1 Sampling

The sampling of the two INTEC canisters o ccurred on March 11 and 12, 2009, and EPA did not

observe this event. EPA did evaluate the re cords that documented the sampling at the INTEC Laboratory as part of this T1 evaluation on January 14, 2010, and found them to be adequate.

Documents and Records reviewed:

• CCP-AK-INL-555, CCP Sampling and Analysis Plan for TRU Debris from INTEC at INL,

Revision 0

• CCP-TP-512, CCP Remote-Handled Wa ste Sampling, Revisions 1 and 2

• Sampling personnel training records

• CCP RH Program - INL List of Qualified Indi viduals (LOQI) for the dates the samples were collected: 3-11-2009, 1:03 PM; 3-12-2009, 1: 44 PM; 3-23-2009, 8:38 AM; 3-30-2009, 10:43 AM; 1-6-2010, 10:06 AM

• Sampling Batch Data Report (BDR) No. IDRH0903

• Supporting Data Package No. ALD09003R

• Supporting Data Package No. ALD09008ID-3 On March 11 and 12, 2009, containers ID IC000000427 and IDIC000000460 were sampled in accordance with the CCP-AK-INL-555, CCP Sampling and Analysis Plan for TRU Debris from INTEC at INL and CCP-TP-512, CCP Remote-H andled Waste Sampling. The individuals collecting the samples were all listed on the curren t LOQI, as indicated above. A total of 5 solid and 4 smear samples were taken, including a co-lo cated (duplicate) sample and field blanks. Chain-of-Custody (COC) forms were generated on each day of sampling and Tamper Indicating Devices (TIDs) were used to secure each samp le. These samples were delivered, and custody transferred, to the laboratory on Marc h 16, 2009. The COC forms requested gamma spectrometry, alpha spectrometry, and Inductive ly Coupled Plasma – Mass Spectrometry (ICPMS) analyses for the samples. All records were in order and EPA did not identify any concerns or findings associated with sampling of the drums IDIC000000427 and IDIC000000460 from waste stream ID-INTEC-RH. A copy of the checkli st used in this evaluation is included as

Addendum 1 to this attachment.

3.2 Analysis

EPA evaluated the INTEC Laboratory by examini ng personnel qualificati ons/training (by review of records and conducting interviews), quality as surance/quality control records, analytical procedures for the separation and measurement of radionuclides, and records of instrument calibration, and found it to be adequate.

Documents and Records reviewed:

• MCP, Analytical Sample Management, Revision 9,

• ACMM-3200, Selective Actinide Separati on by Phase Extraction, Revision 15

• ACMM-2803, Determination of Elements and Is otopes by Inductively Coupled Plasma Mass Spectrometry, Revision 2

• ACLP.3-30, Calibration and Use of the Perkin Elmer 3100R Liquid Scin tillation Counter,

Revision 2

• ACMM-3946, Determination of Plutonium-241 by Liquid Scintillation Counting, Revision 3

• ACLP-3.40, Calibration and Use of Alpha Sp ectrometers Using Alphavision, Revision 2

• ACMM-3993, Gamma Spectroscopy, Revision 9

• ACLP-3.15, Germanium and LEPS Detector Calibration and Pe rformance Testing Using the SUN SPARCstation 2, Revision 0

• ACLP-3.20, Calibration and Use of Tennelec Gas Flow Proportional Counters, Revision 2,

• ACMM-3384, Radiochemistry Determination By Solid Phase Extraction and Gas-Flow Proportional Counting, Revision 6

• BDRs ALD09007I, ALS09008I, ALD09007I_S DP, and ALD09008I_SPD, ALD09003R, ALD09004R, ALD09003R_SDP, ALD09004R_SDP

• Various logbooks for sample prep aration and analysis by ICP-MSD-4 During the January 14, 2010 on-site vi sit, EPA performed the following:

• Verified the completeness and adequacy of prep arative and analytical procedures used to analyze the two samples from waste stream ID-INTEC-RH

• Verified that the procedures in use at the time of the on-site visit we re the current revisions

• Interviewed analysts to verify technical and compliance-related knowledge and training

• Reviewed BDRs to verify sample preparati on, instrument calibration, sample results, and acceptable quality control samples

• Verified that data had been reviewed at the Independent Technical Reviewer (ITR) and Site Project Manager (SPM) level

• Reviewed training records (LOQI)

EPA did not identify any issues associated with the analysis of the two samples taken from drum

Nos. IDIC000000427 and IDIC000000460 from INL- CCL waste stream ID-INTEC-RH.

4.0 CONCERNS OR FINDINGS

There were no concerns or findings relative to the collection a nd analysis of RH TRU debris waste samples from INL-CCP waste stream ID-IN TEC-RH, and there are no open issues relative to this activity.

5.0 APPROVAL OF RH TRU DEBRIS WASTE SAMPLING

Based on the results of this evaluation, EPA approves RH TRU waste stream ID-INTEC-RH and the collection and analysis of RH TRU debris samples by the INTEC laboratory for the purpose of supporting radionuclide-spe cific scaling factors.D-5ADDENDUM 1 - SAMPLING CHECKLISTCCP-INL-AK-555, REVISION 0, CCP SAMPLINGAND ANALYSIS PLAN FOR RH TRU CHECKLISTEPA Inspection No.: INL T1Sampling ChecklistInspection Date: January 14, 2010Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresObjective Evidence/CommentsEstablishment of DQOs Section1.1.1.1DQOs from WCPIPPrecision – duplicate RPDAccuracy – sampling cross contaminationRepresentativeness – use of sampling planCompleteness - # valid samplesComparability – compliance with WCPIPThe sampling plan (CCP-AK-INL-555) requires theDQOs stated in the WCPIP to be met. The SPM checklistreviews if accuracy, precision, representativeness,completeness and comparability DQOs were met for eachsampling batch. The DQOs are met if:•Equipment blanks are free of contamination(accuracy)•RPD criteria are met (precision)•Use of an approved sampling plan(representativeness)•Completeness is≥90% (completeness)•Use of an approved sampling procedure(comparability)The sampling procedure used for the 2 drums in this wastestream was CCP-TP-512, Revision 1, CCP RemoteHandled Waste Sampling. At the time of the SPM review,Revision 2 of this procedure was in force, having beenapproved for use on April 16, 2009.Objective evidence:1.CCP-AK-INL-555, Revision 0, CCP Sampling andAnalysis Plan for TRU Debris from INTEC at INL2.CCP-TP-512, Revisions 1 and 2, CCP RemoteHandled Waste SamplingSampling Sections2.0 and 3.0•Smear sampling (in plastic container)•Scoop sample of solid (2-5 g, plasticcontainer)•Each container sampled 3 times eachWaste Stream ID-INTEC-RH consists of two 55-gallondrums with 30-gallon inner containers. ContainerIDIC000000427 was sampled on March 11, 2009, andcontainer IDIC000000460 was sampled on March 12,2009. The sampling batch numbers for these sampleswere IDRH0901 and IDRH0903.D-6CCP-INL-AK-555, REVISION 0, CCP SAMPLINGAND ANALYSIS PLAN FOR RH TRU CHECKLISTEPA Inspection No.: INL T1Sampling ChecklistInspection Date: January 14, 2010Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresObjective Evidence/CommentsSamples were taken as required by the sampling plan andincluded field blanks, smears and solids. Two solidsamples and 1 smear were taken from each container, anda solid collocated sample was taken from containerIDIC000000427.Objective evidence:1.CCP-AK-INL-555, Revision 0, CCP Sampling andAnalysis Plan for TRU Debris from INTEC at INL2.CCP-TP-512, Revisions 1 and 2, CCP RemoteHandled Waste Sampling3.Sampling BDR IDRH0903Quality control Section 4.2Attachment1•Duplicates (collocated), 1 per batch•Smear samples of equipment•Sampling sequence:FB (smear)FB (smear)1st drum: 3 samples either smear or solid,FD2nddrum: 3 samples either smear or solidThe two samples in waste streams, IDIC000000460 andIDIC000000427 were sampled on consecutive days andincluded in 1 sampling BDR IDRH0903. Separate Chainof-Custody (COC) formswere generated for eachsampling event. The COC numbers wereCOCIDRH09031 and COCIDRH09032.The sampling sequence for container IDIC000000427was:FB smear, manipulatorFB smear, scoopSmear (from drum – bottom)Solid (from 4-liter plastic container)Solid (from 4-liter plastic container)Solid (from 4-liter plastic container, collocated)In accordance with the sampling plan, the collocatedsample (duplicate) should have been identified with a “D”suffix on the identification number. The “D” was omittedand CCP initiated NCR-RHINL-0201-09 to address thisissue. The NCR was correctly documented and its finaldisposition was “use as is.”NCR-RHINL-0507-09 was initiated by CCP becausesample ID03110903 was misidentified as a solid. TheD-7CCP-INL-AK-555, REVISION 0, CCP SAMPLINGAND ANALYSIS PLAN FOR RH TRU CHECKLISTEPA Inspection No.: INL T1Sampling ChecklistInspection Date: January 14, 2010Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresObjective Evidence/CommentsNCR was properly documented and the mistake wascorrected on the applicable records.Container IDIC000000460 was appropriately sampled onMarch 12, 2009, with the following sampling sequence:Smear (from drum bottom, glass container)Solid (from 4-liter plastic container)Solid (from 4-liter plastic container)Sample Tracking Forms, Attachment 1 of CCP-TP-512,were used to record sampling information, and these wereincluded in the sampling BDR. Samples were securedusing TIDs and the TID numbers were recorded on thetracking forms and COC. All forms reviewed had beencompleted as required.Objective evidence:1.CCP-AK-INL-555, Revision 0, CCP Sampling andAnalysis Plan for TRU Debris from INTEC at INL2.CCP-TP-512, Revisions 1 and 2, CCP RemoteHandled Waste Sampling3.Sampling BDR IDRH09034.NCR-RHINL-0201-095.NCR-RHINL-0507-09COC and sample handling Section 4.3•COC form from CCP-TP-512 for sampling•Laboratory COC procedure after transfer tolabChain-of-Custody (COC) forms were used for thesesamples, COC numbers COCIDRH09031 andCOCIDRH09032. Samples were transferred to thelaboratory on March 16, 2009. Analyses requested on theCOC forms were gamma, alpha and ICP-MS.Upon receipt in the laboratory, the samples were logged inand assigned laboratory tracking numbers. Althoughformal COC procedures were used for the samples,analysts were required to sign a log before accessingsamples. Sample management was performed inaccordance with the laboratory quality assurance plan,QAP-103.D-8CCP-INL-AK-555, REVISION 0, CCP SAMPLINGAND ANALYSIS PLAN FOR RH TRU CHECKLISTEPA Inspection No.: INL T1Sampling ChecklistInspection Date: January 14, 2010Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresObjective Evidence/CommentsObjective evidence:1.CCP-AK-INL-555, Revision 0, CCP Sampling andAnalysis Plan for TRU Debris from INTEC at INL2.CCP-TP-512, Revisions 1 and 2, CCP RemoteHandled Waste Sampling3.Sampling BDR IDRH09034.QAP-103, Analytical Laboratories Quality AssurancePlan for Environmental TestingBatch Data Reporting Section 4.4•Sample #s – IDMMDDYY followed byconsecutive # beginning “01”•Data reporting requirements from WCPIP,Section 3.5.3•CCP-TP-512 – review, verification andvalidation of dataSamples were labeled as required by the sampling plan,except that a “D” suffix was not applied to the collocatedsample. NCR-RHINL-0201-09 was generated to addressthis issue. The NCR was correctly documented and itsfinal disposition was “use as is.” The sampling BDRprovided to EPA for review, BDR # IDRH0903, containedall the required attachments from the sampling procedure(CCP-TP-512, Attachments 1-5). The BDR was reviewedat data generation and project levels as required and thecompleted checklists were included in the BDR.Objective evidence:1.Sampling BDR IDRH09032.NCR-RHINL-0201-093.CCP-TP-512, Revisions 1 and 2, CCP RemoteHandled Waste SamplingNon-conformancesBDR IDRH0903 has 2 NCRs:NCR-RHINL-0201-09 was initiated to address incorrectnumbering of the collocated sample from containerIDIC000000427. The NCR was correctly documentedand its final disposition was “use as is.”NCR-RHINL-0507-09 was initiated by CCP becausesample ID03110903 was misidentified as a solid. TheNCR was properly documented and the mistake wascorrected on the applicable records on August 13, 2009.Objective evidence:D-9CCP-INL-AK-555, REVISION 0, CCP SAMPLINGAND ANALYSIS PLAN FOR RH TRU CHECKLISTEPA Inspection No.: INL T1Sampling ChecklistInspection Date: January 14, 2010Establishment of RequiredTechnical Elements in ProceduresY/NLocationExecution of ProceduresObjective Evidence/Comments1.CCP-AK-INL-555, Revision 0, CCP Sampling andAnalysis Plan for TRU Debris from INTEC at INL2.CCP-TP-512, Revisions 1 and 2, CCP RemoteHandled Waste Sampling3.Sampling BDR IDRH09034.NCR-RHINL-0201-095.NCR-RHINL-0507-09Sampling procedure Section 4.5•CCP-TP-512This procedure provides instructions for sampling, sampletransfer and sampling BDR preparation and review.EPA’s review of this procedure determined it containedadequate instructions and information to ensure samplingwas performed in a technically correct manner.Objective evidence:1.CCP-TP-512, Revisions 1 and 2, CCP RemoteHandled Waste SamplingTraining Section 4.5•Trained personnel (CCP-TP-512 & CCP-INLAK-555)CCP’s current List of Qualified Individuals (LOQI) wasreviewed on March 11 and 12, 2009, to ensure onlytrained and qualified personnel were used to performsampling. EPA determined from review of trainingrecords that personnel responsible for sampling for BDRIDRH0903 were appropriately trained.EPA also reviewed the LOQIfor 1/6/10, and the qualifiedindividuals remained as on the 2009 list but with theaddition of another OJT/SME (SP)Objective evidence:1.LOQI, dated 3/12/09, 3/30/09 and 1/6/10