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

WASTE CHARACTERIZATION REPORT 

EPA TIER 1 EVALUATION 

OF THE CENTRAL CHARACTERIZATION PROJECT (CCP) 

REMOTE-HANDLED TRANSURANIC WASTE 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 2010
i 

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 Waste 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 Laboratory 
ii 

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 Reconciliation Report 

Cs cesium 

CSSF Correlation and Surrogate Summary Form 

CTAC Carlsbad Technical 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/cm3

 grams per cubic centimeter 

HAER Historic American Engineering Record 
iii 

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 Engineering 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 

m3

 cubic meters 

MCNP5 Monte Carlo N-Particle Transport 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 objective 
iv 

RAF Remote Analytical Facility 

RCRA Resource Conservation and Recovery Act 

RH remote-handled 

RPD Relative Percent Difference 

RTR real-time radiography 

RWMC Radiological Waste 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 Program 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 System 
1 

1.0 EXECUTIVE SUMMARY 

This report supports the U.S. Environmental Protection Agency’s (EPA’s) approval of the 

retrievably-stored, remote-handled (RH) transuranic (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) and 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 following three INL RH waste streams: 

• The addition of twelve containers to an approved RH TRU waste stream, Waste Stream 

ID-ANLE-S5000. EPA approved this waste stream in January 2007 as part of the 

baseline approval; however, the addition of containers is a T1 change. 

• New RH Waste Stream ID-HFEF1

-S5400-RH, Lot 1A with 28 casks 

• New RH Waste Stream ID-INTEC2

-RH, consisting of two containers 

On December 8-9, 2009, EPA met in Washington, DC, with the Central Characterization Project 

(CCP) personnel at INL responsible for characterizing the subject waste streams to discuss the 

waste characterization approach and information gathered to prepare acceptable knowledge 

documentation and quantify radiological and physical contents of the three waste streams. In 

February 2010, the EPA approved the first two waste streams as two separate T1 changes (See 

EPA Report A-98-49; II-A4-122). EPA, however, did not approve the last waste stream, as EPA 

needed to evaluate waste sampling and radiochemical analysis methods used to generate 

radiological information necessary for developing scaling factors. EPA inspected these two 

processes earlier this year, and this 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 waste stream requires CBFO to submit a T1 change 

request and obtain EPA approval prior to disposal of any such wastes at the Waste Isolation Pilot 

Plant (WIPP). The CCP is responsible for characterizing the above waste stream using the 

system of controls that EPA evaluated during the baseline inspection conducted in July 2006 and 

approved in January 2007. A summary of EPA’s approval of the INL RH TRU waste 

characterization program is included 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 sampling the two INTEC waste containers and 

performing radiochemical analysis using processes/procedures not previously evaluated or 

approved by EPA. EPA raised one AK concern which was adequately addressed. This 

 

1

 HFEF is the Hot Fuel Examination Facility at the Materials 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 results of the T1 evaluation of Waste Stream 

ID-INTEC-RH. 

EPA determined that all processes/procedures implemented for 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-E3

 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 evaluation of sample collection 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 for the addition of new RH Waste Stream IDINTEC-RH were technically adequate. By virtue of having inspected both the sample collection 

process and ANL-E and the INL analytical laboratory, EPA’s approval of Waste Stream IDINTEC-RH as a T1 change includes 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 activities from the date of the site’s baseline 

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

requirements set forth in 40 Code of Federal Regulations (CFR) 194.8 regulations and 

incorporated in the INL-CCP RH Baseline Final Report cited in Attachment A. 

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004 Federal Register notice, 

EPA must perform a single baseline inspection of a TRU waste generator site’s waste 

characterization program (Vol. 69, No. 136, pages 42571–42583, July 16, 2004). The purpose of 

EPA’s baseline inspection is to approve the site’s waste characterization program, based on the 

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

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

TRU wastes destined for disposal at the WIPP. 

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

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

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

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

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

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

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

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

EPA disapproval, any previously approved TRU waste using processes/procedures/equipment 

implemented as T2 changes. EPA reviews T2 changes on a quarterly basis and EPA may 

conduct continued compliance inspections to evaluate implemented T2 changes to verify 

adequacy. 

 

3

 ANL-E is the former name of the DOE site that is now called Argonne National 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 evaluation of Waste Stream ID-INTEC-RH included two 

waste characterization areas, Acceptable Knowledge (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 Appendices C and D, respectively). Personnel 

who participated in the primary T1 evaluation are listed in Table 1, along 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 Evaluator – Radiological Characterization 

Amir Mobasheran SC&A, Technical Evaluator – 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 Support 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 WASTE 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 m3

) and stored and characterized at 

the INTEC facility at INL. The wastes themselves 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-gallon 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 respect to the use of AK for waste 

characterization: 

• Definition and identification of the waste stream 

• Radiological characteristics of the waste 

• Physical composition of the waste 

• Identification of high-level waste (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 Characterization Program Implementation Program 

(WCPIP) AK process implementation 

• AK data traceability 

• AK source document sufficiency 

• WCPIP Interpretation including AK qualification, and Certification Plan/Confirmatory 

Test Plan (CTP) preparation/adequacy 

• Characterization Reconciliation 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) attained through AK Qualification 
5 

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 INTEC pending characterization, certification and 

canisterization activities. RH TRU waste repackaging operations are conducted at INTEC in 

Building CPP-659, the New Waste Calcining Facility. 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 radionuclide scaling factors. 

The AK evaluation presented in this section assesses the AK process and activities related to the 

determination of physical and radiological waste 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, chemical, 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 meters) of RH TRU heterogeneous debris 

waste generated from an experimental actinide 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 radionuclides, 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 activity for the reported isotopes.... 

To determine that the waste stream was appropriately defined, several references were reviewed 

and the AK expert (AKE) was interviewed to determine 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 cells 
6 

(presumably Cell 9) for study. The purpose of the 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 uranium (U). The AK Summary Report (AKSR) 

CCP-AK-INL-500, Revision 0 provides detailed information regarding several aspects of the 

actinide partitioning. From a radiological perspective, 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 was composed almost entirely of 238U by weight. In contrast, 

over 87% of the activity is attributable to 241Pu, with lesser quantities of 238U and cesium-137 

(

137Cs). Several source documents (e.g., P019, P020, U001) were examined to verify that the 

radiological composition of the solidified material in the two drums is consistent with the AKSR. 

INL-CCP stated that the debris within this stream contained extraneous vials and other debris 

that may have come from general cell activities unrelated to the E-14 dissolution. This analysis 

affected how INL-CCP chose to obtain additional 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 debris. 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 waste. The AKSR and related references provided 

information to adequately define the waste stream, 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 addressed in Item (3), below. 

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

adequate. 

INL-CCP assumes that Waste Stream ID-INTEC-RH obtained its radiological signature from a 

single H.B. Robinson Fuel Rod, number E-14. The AKSR states that dissolution of this fuel rod 

was associated with an actinide partitioning study that was conducted in the RAF, wherein halfinch pieces of the sectioned Fuel Rod E-14 (assembly B-05) underwent dissolution. After 

dissolution, the solution was extracted to remove U and Pu using the PUREX4

 process, and the 

resulting organic phase from this extraction was solidified in the RAF and placed in the two 

containers of this waste stream. INL-CCP used information presented in AK source documents 

(e.g., P019, P020, P022) to determine container-specific radiological information and to assign 

the distributions presented in Table 4 of the AKSR. As shown in this table, the predominant 

radionuclides by weight are 238U (98.75%) and 235U (0.49%), while the predominant 

radionuclides by activity are 241Pu (87.64%) and 137Cs (8.61%) (P019). 

AKE analyzed available AK data, including historical inventory data, measured E-14 fuel pin 

concentration data, historic isotopic distribution information, ORIGEN calculations, mass 

balance data, burn-up data, and other information, to develop a recommended 2008 radionuclide 

list (by mass and activity), as well as proposed scaling factors (U001). INL-CCP stated that the 

calculations, assumptions, and uncertainties associated 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 information presented and concluded that the data 

presented were sufficient, because the waste stream 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 stream 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 Waste 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 examination of the waste was conducted and the drum 

contents appear consistent with the actinide partitioning study.” Several AK source documents 

state only that the contents of the containers are sludges, SNF, 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, including historic repackaging information (U035), 

showed that the stream contains significant 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 miscellaneous 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 two 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 markings on the bottle (Containing solid white 

residue). The bottle was brittle and broke during repackaging. 

(19) 40-ml empty glass bottles (brown in color) with septum lids. NOTE: Markings 

were present on several of the bottles, such as 0620 WC114, 06150410 WC114. 
8 

(4) 1/4-inch lead disks (two on the top and two on the bottom of the drum). Note: 

Operator assumes there are two disks on the bottom; was not verified by the Operator to 

have two disks on the bottom. Operator could 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 the 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 material in Drum IDIC000000460. 

INL-CCP used the above information, among other data, and concluded that the waste stream is 

composed of greater than 50 percent heterogeneous organic and inorganic debris, thus 

warranting the assignment of waste matrix code S5400, Heterogeneous Debris. INL-CCP also 

states in the AKSR that “[although the waste stream] is comprised of more than 50 percent 

heterogeneous debris, any drum may include nearly any percentage of the waste material 

parameters [WMPs] listed in Section 5.4.1.2, except that no individual 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 percent of material, the mass percent calculations 

presented in the AKSR associated with WMP analyses show that the waste stream is composed 

of over 95% inorganic waste by mass, the vast majority 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 physical attributes of the waste can be ascertained through the AK 

record, and specifically those records obtained during recent repackaging. These data, together 
9 

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 the AKSR pertaining to the identification of SNF 

and HLW. The discussion addressed the presence/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 address 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 addresses SNF and HLW, but does not clearly 

distinguish between the two different components that are addressed using different arguments. 

EPA expects that this discussion will be expanded in revisions of the AKSR to better delineate 

these aspects. INL-CCP stated that LLW is not expected, which was verified during dose-tocurie (DTC) measurement 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 the content of the AKSR and the sufficiency of AK 

implementation were assessed. 

The AKSR includes the required data, and the AK process used to obtain and evaluate the data 

was comparable to the CH process. Since the 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 establish the historical AK record for each drum. 
10 

Select references were examined to obtain drum history, starting with older 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 Waste 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 ILTSF 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 drum Nos. 460 and 427, respectively, included in 

the site’s “Integrated Waste Tracking System.” These forms show general container 

information, including drum data and historic radiological information. INL-CCP indicated that 

both these drums underwent “fast scan” after the retrieval event 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 results 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 during the process. The drum also contained empty glass bottles and 

lead disks. 

Lastly, drums underwent VE and DTC processes 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 the waste material parameter calculations), and 

includes various waste materials such as plastic 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% organic 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 waste 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 AKSR reference listing and Attachment 4 of 

CCP-TP-005. INL-CCP representatives 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 reference list, but this is 
11 

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 and technical adequacy of the CTP and was found to be 

adequate. 

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

how RH waste characterization will take place at each site, as well as a CTP when this plan is 

required as part of AK Qualification. EPA’s intent was that the sites present, somewhere, 

exactly how characterization is to take place on a waste stream basis, followed by a detailed plan 

explaining implementation of confirmatory testing when this is to take place. 

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 subject to confirmatory testing 

• An explicit description of the waste characterization DQOs and quality assurance 

objectives (QAOs) that will be satisfied with the data being qualified 

• A description of the DQOs and QAOs that will 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 representative of the waste stream 

or waste stream lot 

INL-CCP elected to combine the 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 the exception of the payload container based 

parameters, have been met ...This Plan will identify 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 combinations of strategies to 

qualify AK and indicates that the following DQOs were addressed using the listed qualification 

methodologies: 

 

• Defense Determination (which can be determined only through AK and does not require 

qualification as per the WCPIP) 

• TRU Waste Determination which is to be qualified by DTC which uses characterization 

data obtained through solid sampling and swipe sampling for scaling factor determination 
12 

• 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 evaluation that the sampling and analysis performed to obtain scaling 

factors were conducted by INL-CCP using characterization processes described in the WCPIP 

that had not been approved by EPA. EPA concluded 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-CCP had been evaluated. INL-CCP informed EPA 

that the processes used for RH waste sampling 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 performed 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 adequacy of the CRR were evaluated and found to be adequate. 

The content of the CRR was examined to see whether 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 that 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, corroborative data, proceedings of a peer review, 

etc. 

• Radiography and/or visual examination summary 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 measurement data used to meet the DQOs and to 

confirm AK 

• A complete AK summary 
13 

• A complete listing of all container identification numbers used to generate the WSPF, 

cross-referenced to each 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 that included the above information, but did not 

include the signature of the SPM. INL-CCP provided a full copy of the CRR (pdf version) 

following the inspection that met the requirements of the WCPIP. Although not anticipated 

because of the limited waste stream size, notification 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 representative indicated that CH data were not 

used in this manner, so a CSSF was not prepared for this waste stream. 

(11) Personnel training was evaluated 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 examined to determine whether both individuals’ 

training was up to date. Neither document indicated that the AKEs 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-mail verification method is used to ensure each individual receives 

and completes site-specific reading. 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 respect to radiological characterization aspects, both of which are 

required in the WCPIP. Since the WCPIP is currently under revision, EPA will examine future 

training against the modified WCPIP. 

(12) The WSPF was examined and was found to be adequate. 

INL-CCP representatives provided a draft of the WSPF, without required signatures or 

attachments. The WSPF included a section, which stated that “testing” was not applicable, but 

the stream underwent sampling and analysis 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 waste 
14 

stream as non-hazardous, and INL-CCP’s determination that the stream should be RCRAhazardous (D008-lead, and D018-benzene). The form 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 required contents as presented in the WCPIP. The 

WCPIP requires AK accuracy to be assessed in three areas: reassignment 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 placed in a different waste stream, and some of 

the general radiological parameters (i.e., TRU and RH determination) were met through 

implementation of the WCPIP and comparison to the AK Record. Notification of availability of 

a final AK Accuracy Report for this 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 tests performed on this pin would serve a broad purpose, including 

those related to defense. INL-CCP also argued that the waste was contaminated with other 

radiological materials from the cell that were defense related, but little support 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 contaminated with material from other defense-related 

activities. However, the AK Summary does not reference documents that sufficiently 

describe the other defense-related 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 paragraph states that the subject waste stream 

is commingled with other defense waste (References C012, C016, and U035). INL-CCP 

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

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

fuels occurred since decontamination of the 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 assumes that the cell(s) in which 

the HB Robinson Fuel Rod E-14 studies took place are also contaminated with material 
15 

from other defense-related activities due to incidental contamination and commingling 

with defense materials. The argument based on incidental contamination and 

commingling is possible based on data in the AK Record, so CCP adequately addressed 

EPA’s concern. The concern is closed. 

(16) Load management was assessed and 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 Attachment 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 concern and no AK finding relative to the two 

containers in the ID-INTEC-RH waste stream, which were the subject of this T1 change 

evaluation. The AK concern was 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 technically 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 respect to obtaining meaningful 

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

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

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

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

radionuclide scaling factors for 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 evaluation, EPA examined the following elements of 

the INL-CCP radiological characterization program: 

• Development of a DTC correlation as a function of waste density using MCNP5 based on 

each drum’s measured external exposure (dose) rate, assuming the main contributors to 

the external exposure was 137Cs 

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

radionuclides as supported by calculation packages and the destructive assay of swipe 

and waste samples 

The radiological characterization process is summarized in Figure 1, below. 
17 

The development of the 137Cs scaling factors was supported primarily by the application of 

Inductively Coupled Plasma – Mass Spectrometry (ICP-MS) and radiometric (alpha and gamma 

spectrometry) results from the collection and analysis of one smear and two grab samples from 

each of the two drums of INTEC waste. These activities are summarized in CCP-AK-INL-551 

and presented in detail in calculation packages INL-RH-91, INL-RH-92 and INL-RH-93. 

Evaluations of the sample collection and analyses can be found in Attachments C and D of this 

report. 

Documents Reviewed

The list provided in Attachment B includes all documents related to the INL-CCP RH TRU 

radiological characterization program 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 Characterization Process for INTEC RH-TRU Drums 

Locate and retrieve records 

relevant to the waste stream

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 respect 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 curie-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 interest

Determine the Scaling Factors: Determine the DTC Conversion Factor:
18 

EPA evaluated the following: 

• Activity values derived from modeling and statistical metrics, namely mean and standard 

deviation values for each measured radionuclide 

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

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

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

attribute 

• Isotopic activity values are correlated to the radionuclides whose physical half-lives are 

such that they could be responsible for the measured external dose rate, i.e., 137Cs, 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 the 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 

[

233U, 234U, 238U, 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 137Cs and strontium-90 (90Sr)] 

• The determination of the contribution of all radionuclides to the radiological hazard5

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

to derive the appropriate DTC relationships as a function of waste density for the 

geometry appropriate to the two 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 238Pu scaling factors; 

ICP-MS data were used to support the scaling factors for 239Pu, 240Pu and the U isotopes, since 

they cannot be adequately separated by alpha spectrometry; and the scaling factor for 90Sr was 

based on chemical separation and counting by gas 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 related to the technical adequacy or documentation of radionuclide scaling 

factors for the two drums of INTEC wastes. 

 

5

 Although the determination of a waste container’s radiological hazard is not an EPA requirement, this 

information may be useful in understanding other aspects of a container’s radiological characterization. 
19 

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

found to be unchanged from what EPA had inspected and approved previously, and both 

aspects were acceptable. 

 

The DTC correlation was based on the following assumptions: 

• The waste drum is 100 percent full with waste 

• The radionuclides of interest are dispersed uniformly throughout the waste 

• The waste matrix’s density is assumed to be unity (one), because photon attenuation is 

more influenced by material density, as opposed to specific composition or atomic 

number 

• Waste densities range from 0.1 grams per cubic centimeter (g/cm3

) to 2.1 g/cm3, but an 

assumed value of 1.2 g/cm3 was assumed for DTC calculations (corresponding to a net 

sample mass of 4.8 kilograms) 

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

INTEC waste. Most notable of these were the effects of two layers of quarter-inch lead shielding 

(see CCP-AK-INL-551, Figure 5.1), detailed in calculation package INL-RH-97. There are no 

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

two drums of INTEC wastes. 

(3) Technical aspects and documentation of the radiological characterization process were 

evaluated and found to be acceptable. 

CCP-AK-INL-551 is the main document that describes the radiological characterization 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 Jene Vance, Jim Holderness, Dave Moody, Jesse 

Klingensmith and Larry Porter to support the INTEC wastes, as well as several RH baselines that 

had been previously evaluated by EPA. These packages documented the following: 

• Application and verification of Microshield®

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

of short-lived radionuclides 

• Potential sources of uncertainty 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 spreadsheet 
20 

The EPA evaluation team reviewed 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, the EPA evaluation team had the opportunity to discuss technical 

concerns and apparent discrepancies 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 modifications. The EPA evaluation team found that 

CCP-AK-INL-551 adequately documented the radiological characterization process for INTEC 

wastes, and the calculation packages described above and listed in Attachment B adequately 

supported the activities upon which the radiological characterization 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 characterization 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 swipe and two bulk material samples from each of the two INTEC 

containers and their analyses were evaluated as separate 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 Total 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 determination of the radiological constituents of RH 

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

quadrature. The TMU determination included contributions of the following: 

• Drum weight measurement 

• Dose rate measurement uncertainty 

• Scaling factor uncertainty, which includes the contribution of sample 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/cm3

) 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 90Sr have 

individual contributions that exceed 50%, based 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 documentation of TMU for the INL-CCP INTEC RH 

wastes. 
21 

(6) RH and TRU determinations were assessed and were found to be adequate. 

The determination that the RH containers meet the definition of TRU wastes and RH waste were 

examined during the baseline inspection. 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 documentation-related concerns 

regarding the TRU and RH determinations for INL INTEC wastes. 

Summary of Radiological Characterization Findings and Concerns

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

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

from this T1 evaluation. 

Tiering Changes

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

assigned to radiological characterization during the baseline approval. 

5.0 FINDINGS AND CONCERNS 

Summary of Concerns and Findings 

The EPA inspection team identified one AK concern which is closed. No findings were made 

related to AK or radiological characterization. There are no open concerns resulting from this T1 

evaluation. 

6.0 CONCLUSIONS 

EPA concluded that the waste characterization processes of AK and radiological characterization 

proposed for use to characterize RH TRU (ID- INTEC-RH) wastes from INL-CCP are adequate. 

There are no open issues relative 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, there 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-A4-126 
 

 B-1 

ATTACHMENT B 

LISTING OF DOCUMENTS REVIEWED 

 

• CCP Waste Stream Characterization Checklist, 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 Transuranic 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 Engineering 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 Confirmation Test Plan for INL Waste Stream: 

ID-INTEC-RH, Revision 0, April 2, 2009 

• CCP-TP-005 Attachment 1, Acceptable Knowledge Documentation Checklist, 

ID-INTEC-RH, provided December 8, 2009 

• CCP-TP-005 Attachment 4, Acceptable Knowledge 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 memorandum, INTEC, provided December 8, 2009 

• CCP-TP-504, CCP Dose-to-Curie Survey Procedure for Remote-Handled Transuranic Waste, 

Revision 7, Effective Date: August 20, 2008 

• Characterization Reconciliation Report Waste Stream ID-INTEC-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 Stream 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, 2009 
 

 B-2 

• Memorandum to Irene Quintana, CCP Project Manager 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 Mixed 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. Hendricks, 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. Robinson 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 Container Profile, IDIC000000460 Solidified Fuel 

Sludge, Matthew Allen, Paul R. Smith, Joel R. Hitz, July 9, 2007 

• P007, Integrated Waste Tracking System Container 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-Handled/Special-Case Stored Transuranic 

Waste, WM-PD-85-014, Dennis A. Peterson, November 1985 

• P020, Engineering Design File, Radiological Properties 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 Development, LA-9647-PR, E.D. Arthur, et al., 

April 1983 
 

 B-3 

• P025, Engineering Design File, Crosswalk for the Remote-Handled Transuranic Waste 

Inventory, EDF-4699, Revision 1, Cecilia Hoffman, December 13, 2004 

• P039, Characteristics of Commercial 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 Compounds for Separation of Actinides 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 Decontamination and Decommissioning 

of Building CPP-627, the Remote Analytical 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 Environmental Laboratory, 

INEEL/EXT-99-00400, E.P. Wagner, June 1999 

• P048, Characteristics of Nuclear Materials Stored in the MTR Canal, Volume I, 

INEEL/INT-98-00768, 3rd Draft, R.K. McCardell, October 1998 

• P049, Characteristics of Nuclear Materials Stored in the MTR Canal, Volume II, 

INEEL/INT-98-00768, 3rd Draft, R.K. McCardell, October 1998 

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

Waste Stored at the Radioactive Waste Management Complex (RWMC) – (Part 4, page 38), 

3460-94-084, H.D. Killian and S.K. McDermott, September 1994 

• P056, AK Summary Documentation AK TRU Packaging, RPT-456, DRAFT, Revision 0, 

Idaho Cleanup Project, October and November 2007 

• P057, Engineering Design File, CPP-1617 Fire Area Evaluation, EDF-4684, Nancy Makey, 

April 26, 2004 

• P058, Technical Procedure, CPP-1617 Waste Handling and Operations, TPR-7318, 

Radioactive Waste Management Complex at INTEC, February 1, 2007 

• P059, Estimated Radiological Inventory Sent from the Idaho Nuclear Technology and 

Engineering Center to the Subsurface 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 (includes Nochar, Fiberset, Primafloc C-3, and 

diatomaceous earth), Various dates 
 

 B-4 

• P063, Engineering Design File, Baseline Estimate of the Volume of Remote-Handled 

Transuranic Waste Stored at the Radioactive Waste Management Complex, EDF-4379, 

Revision 0, Cecilia R. Hoffman, March 29, 2004 

• P068, A Survey of NRTS Waste Management 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 Facility, 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 Operating Manual, PTR-729, B.R. Hunter, G.A. 

Huff, Editors, November 1964 

• P111, WIR Citation Determination Checklist for INTEC CPP-627, File Numbers 

IDIC000000427 and IDIC000000460, INL, October 31, 2008 

• P112, INEL Transuranic Waste Acceptance Criteria Fuel Processing 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, Preliminary Radiological Assessment on INTEC RH TRU 

Drums, Yale D. Harker, EDF-8050, Revision 0, November 17, 2008 

• P114, WIR Citation Determination Checklist, WIR Citation Documentation for 

Contaminated Job Waste, Doug Hendricks, Joe McKaig, Jason Orme, File Number 4181Q, 

November 18, 2008 

• U001, Engineering Design File, Radiological 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 Repackaging/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, 2008 
 

 B-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 Characterization, Radiochemistry & Gamma Spectroscopy, David 

W. Moody, INL-RH-91, Revision 0, October 1, 2009 

• U041, INTEC RH TRU Characterization, Mass Spectrometry Data Analysis Input Check, 

David W. Moody, INL-RH-92, Revision 0, October 1, 2009 

• U042, INTEC RH TRU Characterization, INTEC Cs-137 Scaling Factor Development, 

David W. Moody, INL-RH-93, Revision 0, October 1, 2009 

• U044, INTEC RH TRU Characterization, 95% Hazard Calculation for INTEC Debris, Jesse 

J. Klingensmith, INL-RH-95, Revision 1, December 5, 2009 

• U045, INTEC RH TRU Characterization, INTEC Debris Waste Uncertainty Analysis, Jesse 

J. Klingensmith, INL-RH-96, Revision 1, December 5, 2009 

• U047, INTEC RH TRU Characterization, ID-INTEC-RH Dose-to-Curie (DTC) Calculations, 

Jesse J. Klingensmith, INL-RH-98, Revision 1, December 6, 2009 

• U613, MCNP5 Analysis for DTC Uncertainty, 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 Holderness, 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, 2006 
 

C-1 

ATTACHMENT C 

APPROVAL SUMMARY FOR IDAHO NATIONAL LABORATORY 

REMOTE-HANDLED WASTE SAMPLING 

AT ARGONNE NATIONAL LABORATORY 

1.0 SUMMARY AND SCOPE 

On February 16-17, 2010, the U.S. Environmental Protection Agency (EPA) conducted a followup Tier 1 (T1) change evaluation of the collection of remote-handled (RH) transuranic (TRU) 

debris waste samples at Argonne National Laboratory (ANL). 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 implemented by the Central 

Characterization Project (CCP) at ANL (ANL-CCP). EPA’s evaluation included a review of: 

sampling technique(s) to obtain representative waste samples, personnel qualifications/training 

(by review of records and conducting interviews), laboratory chain of custody, quality 

assurance/quality control records and non conformance procedures. The scope of this T1 followup evaluation included the collection of samples from Idaho National Laboratory (INL)-CCP 

waste stream ID-INTEC-RH that were analyzed 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 sampling. By observing sample collection of RH TRU 

debris waste at ANL, EPA was able to evaluate and approve this technique for generating 

radiometric data to support the development of radionuclide-specific scaling factors. The 

sampling and analysis of the two containers at INTEC provided analytical data that were used in 

large part to generate radionuclide-specific scaling factors that were then part of the Dose-toCurie (DTC) process whereby INL-CCP certified these containers for shipment to the Waste 

Isolation Pilot Plant (WIPP). 

As discussed earlier in the report, EPA found it necessary to evaluate the sampling and 

radiometric analyses of an RH waste stream similar 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 the collection and analysis of RH TRU debris waste samples for 

the purpose of generating analytical data to support the development 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 swipe (smear) samples. While the sampling that was observed 

occurred at ANL, EPA considers this activity to be representative 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 support the packaging of RH TRU wastes 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 was performed by two operators using manipulators: 

John Falkenberg and Ken Wesolowshi. Both individuals were listed on the current List of 

Qualified Individuals (LOQI) and training for both operators was appropriately documented. All 

sample collection-related activities were recorded in Operational Logbook RH-ANLE-WS.001, 

2010, K Wing Hot Cells Building 205, ANL. Prior to beginning sample collection, 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 Project Sampling and Analysis Plan for 

Argonne Remote-Handled Waste, 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 sample bottles. The collection was not volumetric, 
 

C-3 

meaning there was no attempt to transfer a predetermined 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 the external radiation from each sample 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 large container holding the fluid to be sampled was connected to a 

pump and tygon-type tubing to transfer 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 operators initiated an Attachment 1 form from CCP-TP-512 for each 

sampling event. EPA also observed that the operators initiated a Chain-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 transferred 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 approves the collection of RH TRU debris samples 

for the purpose of supporting radionuclide-specific scaling factors. 
 

D-1 

ATTACHMENT D 

APPROVAL SUMMARY FOR IDAHO NATIONAL LABORATORY 

REMOTE-HANDLED WASTE SAMPLING ANALYSIS 

AT IDAHO NATIONAL LABORATORY 

1.0 SUMMARY AND SCOPE 

This report supports the U.S. Environmental Protection Agency’s (EPA’s) approval of 

retrievably-stored, remote-handled (RH) transuranic (TRU) debris (S5000) from a new waste 

stream from the Idaho National Laboratory (INL). Specifically, this approval supports the 

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

As discussed earlier in the report, EPA found it necessary to evaluate the sampling and 

radiometric analyses of RH waste stream similar to the INTEC waste. This led to EPA’s 

evaluation and approval of the sample analyses conducted at the INTEC laboratory at INL as 

described in this attachment, and the sample collection activities 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 waste 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 implemented 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), laboratory 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 collection of samples and analysis of samples from 

INL-CCP waste stream ID-INTEC-RH. Since the sampling event at INL was limited and EPA 

was not able to observe it directly, EPA evaluated the records that documented the sampling. 

Additionally, EPA evaluated the collection of RH TRU debris samples from ANL as a surrogate 

for the INTEC RH debris waste sampling, as described in Attachment C to this report. The 

sampling and analysis of the two containers at INTEC provided analytical data that were used in 

large part to generate radionuclide-specific scaling factors that were then part of the Dose-toCurie (DTC) process whereby INL-CCP certified these containers for shipment to the Waste 

Isolation Pilot Plant (WIPP). 

With this report, EPA approves the two containers of RH TRU waste from waste stream IDINTEC-RH. In addition, EPA approves the INTEC Laboratory for the analysis of RH TRU 

debris waste samples for the purpose of generating analytical data to support the development of 

radionuclide-specific scaling factors to characterize 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 samples 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 occurred on March 11 and 12, 2009, and EPA did not 

observe this event. EPA did evaluate the records 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 Waste Sampling, Revisions 1 and 2 

• Sampling personnel training records 

• CCP RH Program - INL List of Qualified Individuals (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. ALD09008I 
 

D-3 

On March 11 and 12, 2009, containers IDIC000000427 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-Handled Waste Sampling. The individuals 

collecting the samples were all listed on the current LOQI, as indicated above. A total of 5 solid 

and 4 smear samples were taken, including a co-located (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 sample. These samples were delivered, and custody 

transferred, to the laboratory on March 16, 2009. The COC forms requested gamma 

spectrometry, alpha spectrometry, and Inductively 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 checklist used in this evaluation is included as 

Addendum 1 to this attachment. 

3.2 Analysis 

EPA evaluated the INTEC Laboratory by examining personnel qualifications/training (by review 

of records and conducting interviews), quality assurance/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 Separation by Phase Extraction, Revision 15 

• ACMM-2803, Determination of Elements and Isotopes by Inductively Coupled Plasma Mass 

Spectrometry, Revision 2 

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

Revision 2 

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

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

• ACMM-3993, Gamma Spectroscopy, Revision 9 

• ACLP-3.15, Germanium and LEPS Detector Calibration and Performance 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_SDP, and ALD09008I_SPD, ALD09003R, 

ALD09004R, ALD09003R_SDP, ALD09004R_SDP

• Various logbooks for sample preparation and analysis by ICP-MS
 

D-4 

During the January 14, 2010 on-site visit, EPA performed the following: 

• Verified the completeness and adequacy of preparative 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 were the current revisions 

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

• Reviewed BDRs to verify sample preparation, 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 and analysis of RH TRU debris 

waste samples from INL-CCP waste stream ID-INTEC-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-specific scaling factors. 
D-5 

ADDENDUM 1 - SAMPLING CHECKLIST 

CCP-INL-AK-555, REVISION 0, CCP SAMPLING AND ANALYSIS PLAN FOR RH TRU CHECKLIST 

EPA Inspection No.: INL T1 Sampling Checklist Inspect

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Objective Evide

Establishment of DQOs Section 

1.1.1.1 

DQOs from WCPIP Precision – duplicate RPD Accuracy – sampling cross contamination Representativeness – use of sampling plan Completeness - # valid samples Comparability – compliance with WCPIP 

The sampling plan (CCP-AK-DQOs stated in the WCPIP to reviews if accuracy, precisioncompleteness and comparabilsampling batch. The DQOs a• Equipment blanks are fre

(accuracy) 

• RPD criteria are met (pre• Use of an approved samp

(representativeness) 

• Completeness is ≥90% (c

• Use of an approved samp

(comparability) 

The sampling procedure used stream was CCP-TP-512, RevHandled Waste Sampling. At Revision 2 of this procedure wapproved for use on April 16, Objective evidence:

1. CCP-AK-INL-555, Revis

Analysis Plan for TRU D

2. CCP-TP-512, Revisions 

Handled Waste Sampling 

Sampling Sections 

2.0 and 3.0 

• Smear sampling (in plastic container) 

• Scoop sample of solid (2-5 g, plastic 

container) 

• Each container sampled 3 times each 

Waste Stream ID-INTEC-RH drums with 30-gallon inner coIDIC000000427 was sampled container IDIC000000460 wa2009. The sampling batch nuwere IDRH0901 and IDRH09
D-6 

CCP-INL-AK-555, REVISION 0, CCP SAMPLING AND ANALYSIS PLAN FOR RH TRU CHECKLIST 

EPA Inspection No.: INL T1 Sampling Checklist Inspect

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Objective Evide

Samples were taken as requireincluded field blanks, smears samples and 1 smear were tak

a solid collocated sample was IDIC000000427. Objective evidence:

1. CCP-AK-INL-555, Revis

Analysis Plan for TRU D

2. CCP-TP-512, Revisions 

Handled Waste Sampling 

3. Sampling BDR IDRH090

Quality control Section 4.2 

Attachment 1 

• Duplicates (collocated), 1 per batch 

• Smear samples of equipment 

• Sampling sequence: 

FB (smear) FB (smear) 1st drum: 3 samples either smear or solid, FD 2nd drum: 3 samples either smear or solid 

The two samples in waste streIDIC000000427 were sampleincluded in 1 sampling BDR Iof-Custody (COC) forms wersampling event. The COC numCOCIDRH09031 and COCIDThe sampling sequence for cowas: FB smear, manipulator FB smear, scoop Smear (from drum – bottom) Solid (from 4-liter plastic conSolid (from 4-liter plastic conSolid (from 4-liter plastic conIn accordance with the samplisample (duplicate) should havsuffix on the identification nuand CCP initiated NCR-RHINissue. The NCR was correctly disposition was “use as is.” NCR-RHINL-0507-09 was insample ID03110903 was misi
D-7 

CCP-INL-AK-555, REVISION 0, CCP SAMPLING AND ANALYSIS PLAN FOR RH TRU CHECKLIST 

EPA Inspection No.: INL T1 Sampling Checklist Inspect

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Objective Evide

NCR was properly documentecorrected on the applicable reContainer IDIC000000460 waMarch 12, 2009, with the folloSmear (from drum bottom, gSolid (from 4-liter plastic conSolid (from 4-liter plastic conSample Tracking Forms, Attawere used to record sampling included in the sampling BDRusing TIDs and the TID numtracking forms and COC. All completed as required. Objective evidence:

1. CCP-AK-INL-555, Revis

Analysis Plan for TRU D

2. CCP-TP-512, Revisions 

Handled Waste Sampling 

3. Sampling BDR IDRH0904. NCR-RHINL-0201-09 5. NCR-RHINL-0507-09 

COC and sample handling Section 4.3 • COC form from CCP-TP-512 for sampling 

• Laboratory COC procedure after transfer to 

lab 

Chain-of-Custody (COC) formsamples, COC numbers COCCOCIDRH09032. Samples wlaboratory on March 16, 2009COC forms were gamma, alphUpon receipt in the laboratoryand assigned laboratory trackiformal COC procedures were analysts were required to sign samples. Sample managemenaccordance with the laboratorQAP-103. 
D-8 

CCP-INL-AK-555, REVISION 0, CCP SAMPLING AND ANALYSIS PLAN FOR RH TRU CHECKLIST 

EPA Inspection No.: INL T1 Sampling Checklist Inspect

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Objective Evide

Objective evidence:

1. CCP-AK-INL-555, Revis

Analysis Plan for TRU D

2. CCP-TP-512, Revisions 

Handled Waste Sampling 

3. Sampling BDR IDRH0904. QAP-103, Analytical Lab

Plan for Environmental T

Batch Data Reporting Section 4.4 • Sample #s – IDMMDDYY followed by 

consecutive # beginning “01” 

• Data reporting requirements from WCPIP, 

Section 3.5.3 

• CCP-TP-512 – review, verification and 

validation of data 

Samples were labeled as requexcept that a “D” suffix was nsample. NCR-RHINL-0201-0this issue. The NCR was corrfinal disposition was “use as iprovided to EPA for review, Ball the required attachments fr(CCP-TP-512, Attachments 1at data generation and project completed checklists were incObjective evidence:

1. Sampling BDR IDRH0902. NCR-RHINL-0201-09 3. CCP-TP-512, Revisions 

Handled Waste Sampling 

Non-conformances BDR IDRH0903 has 2 NCRs

NCR-RHINL-0201-09 was innumbering of the collocated sIDIC000000427. The NCR wand its final disposition was “NCR-RHINL-0507-09 was insample ID03110903 was misiNCR was properly documentecorrected on the applicable reObjective evidence:
D-9 

CCP-INL-AK-555, REVISION 0, CCP SAMPLING AND ANALYSIS PLAN FOR RH TRU CHECKLIST 

EPA Inspection No.: INL T1 Sampling Checklist Inspect

Establishment of Required 

Technical Elements in Procedures 

Y/N 

Location Execution of Procedures Objective Evide

1. CCP-AK-INL-555, Revis

Analysis Plan for TRU D

2. CCP-TP-512, Revisions 

Handled Waste Sampling 

3. Sampling BDR IDRH0904. NCR-RHINL-0201-09 5. NCR-RHINL-0507-09 

Sampling procedure Section 4.5 • CCP-TP-512 This procedure provides instru

transfer and sampling BDR prEPA’s review of this proceduadequate instructions and infowas performed in a technicallObjective evidence:

1. CCP-TP-512, Revisions 

Handled Waste Sampling 

Training Section 4.5 • Trained personnel (CCP-TP-512 & CCP-INLAK-555) CCP’s current List of Qualifie

reviewed on March 11 and 12trained and qualified personnesampling. EPA determined frrecords that personnel responsIDRH0903 were appropriately EPA also reviewed the LOQI individuals remained as on thaddition of another OJT/SME Objective evidence:

1. LOQI, dated 3/12/09, 3/3