DOCKET NO: A-98-49; II-A4-181

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT

EPA TIER 1 EVALUATION

OF THE CENTRAL CHARACTERIZATION PROGRAM

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM

FOR THE ARGONNE NATIONAL LABORATORY:

ADDITION OF THE SECOND BATCH OF SOLIDIFIED LIQUID WASTE TO 

WASTE STREAM AERHDM

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air

Center for Federal Regulations

1200 Pennsylvania Avenue, NW

Washington, DC 20460

February 2014
i

TABLE OF CONTENTS

Section Page

Acronyms and Initializations.......................................................................................................... ii

1.0 Introduction..........................................................................................................................1

2.0 Purpose of Tier 1 Evaluation ...............................................................................................5

3.0 Purpose of This Report ........................................................................................................5

4.0 Scope of the Tier 1 Evaluation.............................................................................................6

5.0 EPA Evaluation Personnel...................................................................................................6

6.0 Radiological Characterization Technical Evaluation...........................................................6

7.0 Findings and Concerns.......................................................................................................13

8.0 Conclusions........................................................................................................................13

TABLES

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by ANL-CCP....... 3

Table 2. EPA Tier 1 Evaluation Team Members............................................................................ 6

FIGURES

Figure 1. Flow Diagram of the Characterization Process for the Second Batch of ANL K-Wing 

Solidified Liquids and Debris Waste................................................................................ 8

Figure 2. Packaging of Drums...................................................................................................... 10

ATTACHMENTS

Attachment A: Approval Summary for Argonne National Laboratory Remote-Handled Waste 

Characterization Program

Attachment B: List of Documents Reviewed by EPA during T1 Evaluation
ii

ACRONYMS AND INITIALIZATIONS

ACL Analytical Chemistry Laboratory

AGHCF Alpha Gamma Hot Cell Facility

AK acceptable knowledge

AKSR acceptable knowledge summary report

Am americium

ANL Argonne National Laboratory

BDR batch data report

CBFO Carlsbad Field Office

CCP Central Characterization Program

CFR Code of Federal Regulations

Ci curie

CRR Characterization Reconciliation Report

Cs cesium

DOE U.S. Department of Energy

DTC dose-to-curie

EPA U.S. Environmental Protection Agency

FEWs fuel examination wastes

ICP-MS inductively coupled plasma mass spectrometry

ITR Independent Technical Reviewer

L liter

MCNP5 Monte Carlo N-Particle Transport Code RSICC Computer Code 

Collection, Oak Ridge National Laboratory

NCR nonconformance report

ORIGEN Oak Ridge Isotope Generation and Depletion Code

Pu plutonium

RERTR Reduced Enrichment Research and Test Reactor Program

RH remote-handled

RTR real-time radiography

SAR Safety Analysis Report

SC&A S. Cohen and Associates (SC&A, Inc.)

SF scaling factor
iii

Sr strontium

SRS Savannah River Site

T1 Tier 1

T2 Tier 2

TSFU total scaling factor uncertainty

TSRs technical safety requirements

TRU transuranic

U uranium

UREX Uranium Extraction

VE visual examination

WDS waste data system

WIPP Waste Isolation Pilot Plant
1

1.0 INTRODUCTION

This report supports the U.S. Environmental Protection Agency’s (EPA’s) approval of a Tier 1 

(T1) change to add the second batch of solidified liquid debris to the previously-approved 

remote-handled (RH) transuranic (TRU) debris waste stream AERHDM at the U.S. Department 

of Energy’s (DOE’s) Argonne National Laboratory (ANL).

1

In June 2012, EPA approved the 

Central Characterization Program (CCP)2to characterize the first batch of solidified liquid debris 

waste at ANL (see EPA Docket No. A-98-49; II-A4-162). On July 12, 2013, the Carlsbad Field 

Office (CBFO) requested EPA approval of a T1 change to add the second batch of solidified 

liquid debris to waste stream AERHDM. Using the EPA-approved waste characterization 

processes discussed in this report, ANL-CCP has demonstrated its capability to characterize the 

second batch of solidified liquid debris waste as part of waste stream AERHDM for disposal at 

the Waste Isolation Pilot Plant (WIPP). As discussed below, EPA approves the T1 change 

request to add solidified liquids to the AERHDM waste stream.

In accordance with Title 40 of the Code of Federal Regulations (40 CFR) 194.8(b), EPA 

conducted Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8 of the CCP waste 

characterization program at ANL on September 12–14, 2006. The January 2007 baseline 

approval applied to 45 containers of legacy RH debris waste. The ANL baseline final inspection 

report (see EPA Docket No. A-98-49; II-A4-73) documents EPA’s approval of the acceptable 

knowledge (AK), radiological characterization using dose-to-curie (DTC) and visual 

examination (VE) processes specific to ANL-CCP’s RH waste characterization program. Table 1 

of that report defined the inclusion of any additional containers of debris to the approved waste 

stream as a T1 change that requires EPA approval before implementation. Hence, the request for 

approval with the focus on radiological characterization (RC). The acceptable knowledge (AK) 

documentation and non-destructive examination (NDE) processes and documentation submitted 

to support this request had been the same as the AK and NDE that supported inclusion of the first 

batch of solidified liquids which EPA approved in June 2012 (see A-98-49; II-A4-162). This 

eliminated the need for AK and NDE evaluation for this T1 change request. Since the baseline 

approval, ANL-CCP added containers to the approved AERHDM waste stream as shown in 

Attachment A. 

The evaluation presented below supports EPA’s approval of the proposed T1 change request and 

also allows addition of debris drums to waste stream AERHDM in the future, provided they are 

characterized using the same sampling data and scaling factor (SF) development process with the 

following restriction. ANL-CCP may not use any additional analytical data generated by the 

ANL’s Analytical Chemistry Laboratory (ACL) to support the characterization of TRU waste for 

WIPP until the EPA formally inspects and approves the ACL’s radiological analysis program.

 

1 ANL was initially designated ANL-E (ANL-East) to distinguish it from ANL-West (ANL-W). In 2009, 

ANL-W was renamed the Materials and Fuel Complex, and ANL-E has since been referred to as ANL. Both 

designations are found in the documents that EPA reviewed for this evaluation, and these terms are interchangeable 

in this report.

2 The Central Characterization Program was formerly known as the Central Characterization Project, and 

both names are used in the documentation reviewed for this evaluation.
2

This restriction regarding use of the ANL Analytical Chemistry Laboratory is detailed in EPA’s 

T1 report from June 2012 and remains applicable (see EPA Docket No. A-98-49; II-A4-162). 

Because there were no new equipment or additional new processes on site at ANL as part of the 

T1 request, EPA conducted a desktop review of this change, concluding that the ANL-CCP plan 

to use the EPA-approved system of controls to characterize the 55-gallon containers of waste 

stream AERHDM is acceptable. EPA did not identify any findings or concerns during this 

evaluation. 

As a result of this evaluation, there are no new T1 or Tier 2 (T2) requirements. However, EPA 

has made minor modifications to the tiering table as part of EPA’s ongoing efforts to harmonize 

the format and language of the tiering tables for all RH waste characterization programs. All the 

T1 and T2 changes that were established during the baseline approval and modified in 

subsequent T1 approvals (as listed in Attachment A) remain in effect and are listed as applicable 

in section 6.0.

This report serves as EPA’s public notification of the results of the proposed T1 change and its 

evaluation. This information will be provided through the EPA website and by emails to the 

WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3). 
3

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by ANL-CCP

(Based on September 12–14, 2006, Baseline Inspection and Subsequent T1 Evaluations, Updated February 2014)

RH Waste Characterization 

Process Elements ANL-CCP RH Waste Characterization Process - T1 Changes ANL-CCP RH Waste Characterization Process - T2 Changes*

Acceptable Knowledge (AK) Any new waste streams not approved under this baseline

Modification of waste stream AERHDM to include additional 

containers if the pedigree of the additional containers has not been 

approved by the baseline or a subsequent T1 approval 

Substantive modification** to EPA-approved AKSRs and 

certification confirmation test plans (e.g., CCP-AK-ANLE-500, 

CCP-AK-ANLE-502) that have the potential to affect the 

characterization process

Implementation of load management for any RH waste stream

Characterization of any Alpha Gamma Hot Cell Facility (AGHCF) 

or K-Wing fuel examination wastes (FEWs) other than the AGHCF 

and K-Wing fuel pin FEW, AGHCF Reduced Enrichment Research 

and Test Reactor FEW and AGHCF second batch of fuel pin 

FEW—specifically, characterization of AGHCF crucibles and melts 

FEW

Notification to EPA upon availability or nonsubstantive modification** of 

AKSRs and certification confirmation test plans (e.g., CCP-AK-ANLE500, CCP-AK-ANLE-502)

Notification to EPA upon availability or modification of:

 The final DTC determination for RH containers in the approved 

waste stream

 AK documentation as a result of Waste Characterization Program 

Implementation Plan revisions (e.g., CRR)

 The list of references that document the assembly of fuel pin data and 

review process 

 The data package for this debris waste stream and any modifications

or change notifications to the waste stream profile form, including 

the CRR, characterization information summary and AKSR

 AK accuracy reports (annually at a minimum)

 Attachment 4 of CCP-TP-005 that reflect the updated AKSR Source 

Document Reference List

 Attachment 8 of CCP-TP-005 or Add Container Memoranda that

have been added to Source Document C2029

 ANL-CCP’s decision regarding the disposition path for vitrified 

high-level waste from Savannah River Site and vitrified sludge from 

West Valley

 The source document containing compiled information supporting 

Source Document U344

Notification to EPA of the intention to add containers to waste stream 

AERHDM, including the approximate number of containers and volume(s) 

of waste, the timeframe for waste generation, characterization, and disposal

and submission of an updated AKSR documenting that the pedigree of the 

additional containers is the same as those covered by the baseline and/or 

subsequent T1 approvals†

Submission of a list of fully characterized containers from a population of 

additional containers proposed as a T2 change, above†
4

RH Waste Characterization 

Process Elements ANL-CCP RH Waste Characterization Process - T1 Changes ANL-CCP RH Waste Characterization Process - T2 Changes*

Radiological Characterization, 

including Dose-To-Curie (DTC) 

Use of any alternate radiological characterization procedure other 

than DTC with sampling-derived scaling factors as documented in 

CCP-TP-504 and CCP-AK-ANLE-501, Revision 0, respectively

Substantive modification** to EPA-approved procedures or 

radiological characterization technical reports (e.g., CCP-TP-504, 

CCP-AK-ANLE-501)

Any new waste stream not approved under this baseline or addition 

of containers to waste stream AERHDM that require changing the 

established radionuclide scaling factors

Application of new (i.e., not EPA-approved scaling factors for 

isotopic determination other than those documented in CCP-AKANLE-501

Implementation of gravimetric analysis for waste other than debris 

will require EPA approval as a T1 change

Notification to EPA upon nonsubstantive modification** of the procedures 

or radiological characterization technical reports (e.g., CCP-TP-504, CCPAK-ANLE-501) requiring CBFO approval

Submission of an updated CCP-AK-ANLE-501 documenting that the 

radiological characterization processes used for the additional containers is 

the same as those covered by the baseline and/or subsequent T1 approvals†

Submission of DTC BDRs or calculation packages for containers selected 

by EPA from a list of fully characterized containers provided by ANLCCP†

Visual Examination (VE) VE by reviewing existing audio/visual recordings for any waste 

summary category group not covered by this approval

VE by any new process

Submission of VE BDRs for containers selected by EPA from a list of fully 

characterized containers provided by ANL-CCP†

Substantive modification** to site procedures requiring CBFO approval

Addition of new S5000 debris waste streams

Real Time Radiography (RTR) Any use of RTR requires EPA approval N/A

WIPP Waste Data System (WDS) None Substantive modification** to site procedures requiring CBFO approval

New T1s, T2s and significant modifications to existing T1s or T2s are in bold text; T1s or T2s that were only revised for style are not shown in bold.

* ANL-CCP will report all unmarked T2 changes to EPA quarterly. 

** “Substantive modification” refers to a change with the potential to affect ANL-CCP’s RH waste characterization processes or documentation of them, excluding changes 

that are solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act, or that are editorial in nature or are required to 

address administrative concerns. EPA may request copies of new references that DOE adds during a document revision.

† ANL-CCP will report this T2 change immediately.
5

2.0 PURPOSE OF TIER 1 EVALUATION

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

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

requirements set forth in 40 CFR 194.8 and incorporated into the ANL-CCP RH baseline final 

report (see EPA Docket No. A-98-49; II-A4-73).

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

(Vol. 69, No. 136, pages 42571–42583), EPA must perform a single baseline inspection of a 

TRU waste generator site’s waste characterization program. 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 

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

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

are identified in the site-specific baseline inspection reports. When evaluating proposed T1 

changes for approval, EPA may conduct a site evaluation to observe at first hand the 

implementation of the change or can decide to conduct a desktop review of information provided 

specific to a change. DOE may choose to characterize and dispose of any previously approved 

TRU waste using processes, procedures or equipment implemented as T2 changes at risk of 

subsequent EPA disapproval. EPA reviews T2 changes on a quarterly basis and may conduct 

continued compliance inspections to evaluate implemented T2 changes to verify adequacy.

Attachment A lists all of EPA’s non-T2 approvals of the ANL-CCP RH TRU waste 

characterization program.

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluation of a T1 change to add the second batch of 

solidified liquid debris to waste stream AERHDM in ANL-CCP’s approved waste 

characterization program. This report presents the technical basis for and results of EPA’s 

approval decision. EPA’s approval decision regarding the modification to waste stream 

AERHDM has been conveyed to DOE separately by letter. EPA will also announce the decision 

on its website at www.epa.gov/radiation/wipp, in accordance with 40 CFR 194.8(b)(3). 

The DOE documents that EPA reviewed for this evaluation are cited in different sections 

throughout the report and are listed in Attachment B. Any of these documents can be requested 

from the following address:

Manager, National TRU Program

Carlsbad Field Office

U.S. Department of Energy

P O Box 3090

Carlsbad, NM 88221-3090
6

4.0 SCOPE OF THE TIER 1 EVALUATION

The scope of EPA’s T1 evaluation is the radiological characterization approach used to 

characterize the second batch of solidified liquid debris. EPA confirmed that the AK supporting 

the second batch of solidified liquids is the same as the AK that supported inclusion of the first 

batch of solidified liquids. Therefore, EPA limited the scope of this T1 evaluation to the 

radiological characterization process as detailed in section 6.0 of this report.

5.0 EPA EVALUATION PERSONNEL

The EPA evaluation team members consisted of the personnel listed in Table 2 with their 

affiliations and functions. EPA relied primarily on reviews of documents and information 

provided by ANL-CCP. When additional information or clarifications were needed, EPA had 

discussions with Irene Joo,3the CCP RH Project Manager, who served as the point of contact for 

this T1 evaluation. Members of the EPA Evaluation Team had discussions with several ANLCCP technical staff, predominantly Mr. Derek Ott, who answered technical questions and 

clarified specific aspects of ANL-CCP’s documentation relative to radiological characterization.

Table 2. EPA Tier 1 Evaluation Team Members

6.0 RADIOLOGICAL CHARACTERIZATION TECHNICAL EVALUATION

Waste Overview

The solidified liquid and solid debris wastes generated from activities involving Uranium 

Extraction (UREX) processing and other material processing in the ANL K-Wing hot cells 

comprise a portion of the RH TRU waste stream AERHDM. The K-Wing wastes were left over 

from experiments to improve the process for chemically separating fission products, plutonium 

(Pu) and uranium (U) in the UREX process (References C2002, C2004, C2005, C2006, C2033, 

P344, P2011, P2023 and P2024). These were consolidated into a bulking tank, sampled, and 

solidified in nine 20-liter carboys, which were loaded into five 55-gallon drums with additional 

K-Wing debris wastes. Accordingly, each drum contains one or more solidification containers 

and other K-Wing debris. ANL-CCP developed bulking-tank scaling factors (SFs) and used them 

in conjunction with the previously-determined K-Wing debris SFs (see EPA Docket No. A-98-

49; II-A4-132) to develop drum-specific SFs for the five drums that are the subject of this T1 

evaluation. Solid debris from the K-Wing hot cells was packed around the solidification 

containers [see VE batch data report (BDR) ANLRHVE12008]. A total of five 55-gallon drums 

 

3

Irene Joo was formerly called Irene Quintana, and both names are used in the documentation reviewed for 

this evaluation.

Name Affiliation & Function 

Rajani Joglekar Lead Inspector, EPA 

Ed Feltcorn Inspector, EPA

Rose Gogliotti Technical Evaluator – Radiological Characterization, SC&A

Patrick Kelly Technical Evaluator – Radiological Characterization, SC&A 

Amir Mobasheran Technical Evaluator – Radiological Characterization, SC&A 

Kira Darlow Technical Document Coordinator, SC&A
7

of K-Wing solidified liquid waste have been generated for the second batch of solidified liquid 

and debris; these drums are the subject of this T1 evaluation.

Documents, Batch Data Reports and Calculation Packages

EPA evaluated the ANL-CCP documentation that supported radiological characterization of the 

second batch of solidified liquid debris in waste stream AERHDM. ANL-CCP provided CCPAK-ANLE-500, Revision 12, CCP-AK-ANLE-501, Revisions 9 and 10, CCP-AK-ANLE-502, 

Revision 7, and CCP-AK-ANLE-505D, Revision 1, to EPA as the main documents for review. 

Attachment B lists all documentation reviewed by EPA, including BDRs and calculation

packages.

Radiological Characterization Element Description

EPA evaluated the radiological characterization of the second batch of ANL-CCP RH solidified 

liquid debris in terms of its technical adequacy, 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 RH evaluation, the EPA evaluation team 

evaluated the following elements of the ANL-CCP radiological characterization program:

 Sampling and analysis plan CCP-AK-ANL-505D, Revision 1, developed for collecting 

representative samples of liquid waste before solidification to determine concentrations 

of the radionuclides of interest.

 Radiometric and spectrophotometric laboratory results of the representative samples 

analyzed by the ACL.

 CCP-AK-ANLE-501, Revisions 9 and 10, and supporting calculation packages, several 

of which required revision.

 Post-sampling memorandum, which performed a data evaluation as required by the 

sampling and analysis plan and ACL laboratory procedures.

 DTC and ACL analytical BDRs.

 Derivation of radionuclide SFs for quantification of the 10 WIPP-tracked radionuclides 

and their uncertainties, as supported by the sampling and the calculation packages.

 Development of DTC relationships as a function of waste density based on each drum’s 

measured external exposure (dose) rate, assuming that the main contributor to the dose 

was cesium-137 (137Cs).

Each of these is discussed in the sections that follow.
8

Technical Evaluation

Figure 1 (based on CCP-AK-ANLE-501, Revision 10) depicts the radiological characterization 

process for the second batch of K-Wing RH TRU solidified liquids and debris waste. 

Figure 1. Flow Diagram of the Characterization Process for the Second Batch of ANL KWing Solidified Liquids and Debris Waste

Use MicroShield to model 

the 1-meter dose rate as a 

function of density based on 

a 1-Ci source of 137Cs in a 

carboy in a drum

Collect relevant AK

Develop Certification Plan While mixing, sample the 

liquid at three tank 

locations 

Submit samples to ACL for 

radiometric and ICP-MS 

analyses

Calculate the activity and 

mass content of drums for 

all reportable radionuclides Determine uncertainties in 

the reported activities and 

masses of the radionuclides

Average the DTC density

correlation for 137Cs for each 

drum geometry

Find the mean gamma dose 

rate for each drum based 

on four 1-meter 

measurements

Calculate the 137Cs content 

of drums

Develop a composite set of 

scaling factors for each 

drum

Develop the 137Cs 

inventory contributions 

from debris and solidified 

liquids

Use analytical results to 

quantify 137 Cs and develop 

137Cs scaling factors for all 

measured radionuclides

Solidify liquid in 20-L 

carboys, repackage into 

55-gallon drums, overpack 

with debris waste

Source: Figure G2-1 of Appendix G to CCP-AK-ANLE-501, Revision 10
9

(1) EPA evaluated the technical adequacy and documentation supporting the collection of 

samples to develop scaling factors and found them to be adequate.

The waste-producing activities in the K-Wing separated fission products (137Cs) and prevented 

the development of SFs based solely on ORIGEN 2.24. ANL-CCP prepared a sampling and 

analysis plan for collecting and analyzing samples of the K-Wing liquids. EPA reviewed the plan 

and the results of its implementation and determined that they resulted in representative (i.e., 

statistically unbiased) samples, and that these activities were technically adequate and 

appropriately documented.

(2) EPA evaluated the radiometric and spectrophotometric analyses that ANL-CCP used to 

support the development of radionuclide scaling factors and found them to be adequate 

for their intended use.

The radiological characterization process hinges on the ability to establish a technically sound 

relationship between 137Cs and the radionuclides of interest which are then scaled to the 

measured 137Cs. ACL performed several radiometric and spectrometric analyses to quantify these 

radionuclides to support SF development, i.e., uranium-233 (233U), 

234U, 238U, plutonium-238 

(

238Pu), 239Pu, 240Pu, 242Pu, americium-241 (241Am), and strontium-90 (90Sr). The laboratory’s 

technical adequacy was discussed at length during the ANL-CCP RH T1 for the first batch of KWing solidified liquids and is detailed in EPA Docket No. A-98-49, II-A4-162. EPA determined 

that the ACL’s analytical approach was acceptable in that it generated data that were adequate 

for their intended use, to develop radionuclide SFs. 

EPA evaluated the ACL analytical BDRs generated as a result of analyzing these five containers 

and concluded that the laboratory results were acceptable for use in supporting the generation of 

radionuclide SFs. EPA did not identify any concerns regarding the application of the ACL data 

to support the development of radionuclide-specific SFs for these five containers. This analysis 

was done in conjunction with the previous T1 change approval of June 2012 when the Agency 

restricted the use of analytical data generated by the ACL post June 2012.

(3) EPA evaluated the conceptual model to develop radionuclide scaling factors and found it 

to be technically adequate and appropriately documented.

The dominant contributor to the gamma dose rate for this batch of K-Wing RH TRU solidified 

liquid and debris wastes is 137Cs. The measured dose rate, waste density and the DTC correlation 

enable the determination of 137Cs and other reportable radionuclides. These drums contained 

both debris and solidified liquids and the relative contributions of each were assessed, as 

described below.

 Sampling: ANL-CCP collected representative liquid samples from three locations in the 

bulking tank while the samples were mixing. The samples were analyzed to determine the

SF for the solidified liquids and Cs content per unit volume.

 

4 ORIGEN is the Oak Ridge Isotope Generation and Depletion Code.
10

 Repackaging: The approximately 48 liters of liquid were transferred to nine 20-liter 

carboy containers and solidified. The carboys were then packed into five 55-gallon drums 

containing hot cell solid debris waste, a 90-mil fiberboard liner and two 3⁄4 in plywood 

disks debris, as shown in Figure 2.

 MicroShield Modeling: A 1-Curie (Ci) source of 137Cs was modeled inside a carboy 

inside a 55-gallon drum at a distance of 1 meter at different configurations to account for 

variations in shielding caused by debris at each orientation. The results of the 

configurations were averaged to find the DTC correlation factor for a carboy.

 1-Meter Dose Measurements: The 1-meter dose rate was measured for each drum at 0 ̊, 

90 ̊, 180 ̊ and 270 ̊ and the arithmetic mean of the four measurements was calculated for 

each drum.

 Determining Carboy Dose Contribution: Using the 137Cs concentration from sampling 

and the carboy’s volume, the 137Cs content of each carboy was determined, and this was 

multiplied by the carboy’s DTC factor to determine the carboy’s dose contribution.

 Determining Debris Dose Contribution: The carboy 1-meter dose rate was subtracted 

from the average DTC measurement and the remaining dose was attributed to the debris.

 Determining the Debris 137Cs content: The debris’ contribution to dose rate and historical 

MicroShield modeling was used to calculate the 137Cs content in the debris of each drum. 

Scaling factors for the debris were previously approved by EPA.

 The Cs content in the debris and carboys were compared to determine the fractional 

contribution (f) of 137Cs attributed to the debris.

3⁄4 inch plywood disk

3⁄4 inch plywood disk

55-gallon drum

90-mil fiberboard liner

1 or 2 carboys stacked on side

Debris

Figure 2. Packaging of Drums
11

 The effective scaling factors (SFe) for the drum were obtained from the contributions of 

the 137Cs in the debris and solidified liquid, as follows:

SFe = f x SFe Debris + (1-f) x SFe, Solidified Liquid

EPA evaluated the details of the effective SF development for each drum and determined that 

they were technically adequate and appropriately documented.

(4) EPA evaluated the application and documentation to support the development of 

radionuclide scaling factors and found them to be technically adequate.

EPA evaluated the following more general aspects of SF development:

 Activity values derived from modeling and statistical metrics, appropriate mean and 

standard deviation values.

 The physical constants and radionuclide-specific attributes (specific activity, physical 

half-life, decay heat, photon transition probabilities, etc.) and the technical correctness of 

the values assigned to the attribute.

 Appropriate correction for radioactive ingrowth and decay of all radionuclides.

 The calculated results used to develop SFs and convert measured dose rates to 

radionuclide activities.

 Determination of the activities and uncertainties for the 10 WIPP-tracked radionuclides 

(

233U, 234U, 238U, 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 137Cs and 90Sr).

 The contribution of all radionuclides to the radiological hazard.

5

 Shielding and other calculations performed with Microshield to derive the appropriate 

DTC relationships as a function of waste density following repackaging.

 The application of SFs previously developed for K-Wing debris waste

There are no issues related to the application and documentation of radionuclide SFs for the 

second batch of K-Wing RH TRU solidified liquids and debris waste at ANL.

(5) EPA evaluated technical aspects and documentation of the radiological characterization 

process and found them to be acceptable.

Attachment G to CCP-AK-ANLE-501, Revision 10, is the main document that describes the 

radiological characterization process and was supported by a series of calculation packages. 

These packages documented the following aspects of the radiological characterization process:

 Development of SFs (ANLE-RH-70).

 Determination of reportable radionuclides (ANLE-RH-69).

 Technical basis and calculations supporting the DTC correlations for 137Cs. 

 

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.
12

 Determination of uncertainty.

 Technical basis for the DTC spreadsheet.

Several of the calculation packages required minor revisions as a result of initial discussions with 

ANL-CCP personnel. ANL-CCP provided the revised documents to EPA and there are no 

additional issues related to the documentation of technical aspects of the radiological 

characterization approach for the second batch of K-Wing RH TRU solidified liquids and debris 

wastes.

(6) EPA evaluated the technical basis and derivation of total scaling factor uncertainty and 

found them to be adequate.

The development of total scaling factor uncertainty (TSFU) for these wastes is based on 

propagating uncertainties in specific aspects of the determination of the radiological constituents 

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

in quadrature. The TSFU determination included the contributions of the following:



137Cs activity measurement.

- Measurement uncertainty.

- Dose contribution of other gamma-emitting radionuclides.



137Cs DTC correlation.

- MCNP5 modeling uncertainties based on sensitivity studies. 

- MCNP5 code uncertainties.

 Scaling factor uncertainty.

- Uncertainty in the mean SF.

- Uncertainty in the contribution of each consolidation carboy to the drum inventory 

(only for drums containing solidified liquid waste from more than one consolidation 

liquid carboy).

- Uncertainty in composite SFs.

- Uncertainty in the contribution from solidified liquids and debris.

EPA did not identify any concerns regarding the technical derivation and documentation of 

TSFU for the second batch of K-Wing RH TRU solidified liquids and debris waste at ANL.

(7) EPA evaluated the determinations of the waste status as remote-handled and transuranic 

and found them to be acceptable. EPA also found the training of all personnel executing 

the dose-to-curie techniques to be current.

EPA reviewed Remote Handled Dose-to-Curie Survey sheets that indicated all five containers 

had external dose rates in excess of 200 millirem per hour. ANL DTC BDR No. 

ANLRHDTC13005 documented that all containers had TRU alpha concentrations in excess of 

100 nanocuries per gram. EPA did not identify any concerns regarding the RH and TRU 

determinations for these five containers.
13

Additionally, EPA reviewed the training of all DTC personnel as documented in the List of 

Qualified Individuals that ANL-CCP provided. Training was current for all personnel involved 

with the ANL-CCP DTC process.

(8) EPA evaluated the application of the dose-to-curie procedure and its documentation and 

found both aspects to be acceptable.

EPA evaluated the DTC process based on BDR No. ANLRHDTC13005, which documents the 

results of the DTC process for these five drums. EPA verified that the DTC BDR contained the 

following:

 “Attachment 1 – Measurement Control Report,” with all parameters acceptable.

 “Attachment 2 – Container Data Sheets” for all drums.

 “Attachment 4 – Batch Data Report Cover Sheet.” 

 “Attachment 5 – Batch Data Report Table of Contents.” 

 “Attachment 6 – Batch Data Report Narrative Summary.” 

 “Attachment 7 – ITR Checklist.” 

 “Attachment 8 – SPM Checklist.” 

 “Attachment 10– Duplicate Container Data Sheet.”

 “Relative Percent Difference.” 

 Attachment 2 – CCP Records Transmittal/Receiving Form” CCP-QP-008, Revision 21.

 Waste container DTC conversion records with all required parameters for all drums, 

including TRU determinations.

 Evidence that the correct revision of CCP-TP-504 was used.

 All forms had the correct signatures, i.e., Independent Technical Reviewer (ITR), Site 

Project Manager (SPM), DTC Operators and NCR Originators.

EPA did not identify any concerns regarding the adequacy of the DTC BDR.

7.0 FINDINGS AND CONCERNS

EPA did not identify any findings or concerns related to radiological characterization of the 

second batch of K-Wing solidified liquids and debris during this T1 change evaluation. There are 

no open issues relative to this T1 evaluation.

8.0 CONCLUSIONS

Changes to Tiering

As a result of this evaluation, there are no new T1 or T2 requirements. EPA made minor 

modifications to the tiering table as part of EPA’s ongoing efforts to harmonize the format and 

language of the tiering tables for all RH waste characterization programs. All the T1 and T2 
14

changes that were established during the baseline approval and modified in subsequent T1 

approvals (as listed in Attachment A) remain in effect and are listed as applicable in section 6.0.

Approval

This T1 change consisted of the radiological characterization processes to characterize the 

second batch of solidified liquids and debris added to ANL waste stream AERHDM using DTC 

and SFs based on sample analysis. Based on the results of this evaluation, EPA approves this T1 

change, consistent with the limitations specified in this report.

While these five drums of TRU waste are the subject of this T1 report, EPA’s approval also 

includes any additional drums that are added to waste stream AERHDM in the future, provided 

they are characterized using the same sampling data and SF development process. However, the 

restriction regarding use of the ANL Analytical Chemistry Laboratory (ACL) detailed in EPA’s 

T1 report from June 2012 remains. Specifically, ANL-CCP may not use any analytical data 

generated by the ANL ACL to support the characterization of TRU waste for WIPP until EPA 

formally inspects and approves the ACL.
A-1

ATTACHMENT A

APPROVAL SUMMARY FOR ARGONNE NATIONAL LABORATORY REMOTEHANDLED WASTE CHARACTERIZATION PROGRAM

Approved Activity EPA Inspection Number, 

Approval Dates

EPA Docket Number

ANL RH Baseline Approval EPA-ANL-CCP-RH-9.06-8,

January 2007 A-98-49; II-A4-73

Tier 1 Change – Approval of WIPP Waste Information System January 2007 A-98-49; II-A4-74

Tier 1 Change – Approval of Visual Examination for Newly 

Generated Waste June 2008 A-98-49; II-A4-102

Tier 1 Change – Approval of 100 additional drums of AGHCF 

debris waste to waste stream AERHDM October 2008 A-98-49; II-A4-136

Tier 1 Change – Addition of K-Wing debris waste to waste 

stream AERHDM September 2010 A-98-49; II-A4-132

Tier 1 Change – Addition of 120 containers of AGHCF debris 

waste to waste stream AERHDM September 2010 A-98-49; II-A4-134

Tier 1 Change – Addition of AGHCF fuel pin FEW to waste 

stream AERHDM November 2010 A-98-49; II-A4-140

Tier 1 Change – Addition of K-Wing FEW to waste stream 

AERHDM February 2012 A-98-49; II-A4-158

Tier 1 Change – Addition of K-Wing Solidified Liquid Waste 

to waste stream AERHDM June 2012 A-98-49; II-A4-162

Tier 1 Change – Addition of AGHCF RERTR FEW and 

Second Batch of Fuel Pin FEW October 2012 A-98-49; II-A4-167
B-1

ATTACHMENT B

LIST OF DOCUMENTS REVIEWED BY EPA DURING THE T1 EVALUATION

Analysis of Sample Data for ANL-E K-Wing 2nd Batch of Liquids, J. Vance, September 3, 2012

Analytical Chemistry Laboratory Report of Analytical Results for ANL Nuclear Operations 

Division, 205 K-Wing, SDG:TIC-1, ACL:11-0197, February 28, 2012

ANLE-RH-68, Scaling Factors of 2nd Batch of Solidified Liquids, Revision 0, February 26, 2013, 

and Calculations Spreadsheet, provided July 29, 2013

ANLE-RH-69, Determination of Reportable Radionuclides, Revision 0, February 26, 2013

ANLE-RH-70, Scaling Factors for Solidified Liquids and Debris-2

nd Batch, Revision 0, February 

26, 2013, Revision 1, October 28, 2013, and Calculations Spreadsheet, provided July 29, 2013 

ANLE-RH-71, Uncertainty for 2nd Batch of Liquids and Debris, Revision 0, February 26, 2013, 

and Revision 1, October 28, 2013

ANLE-RH-72, DTC Spreadsheet 2nd Batch K-Wing Liquids, Revision 0, March 14, 2013,

Revision 1, October 30, 2013, and Calculations Spreadsheet, provided July 29, 2013.

CCP-AK-ANLE-500, Central Characterization Project Acceptable Knowledge Summary Report 

for Argonne Remote-Handled Debris Waste, Waste Stream: AERHDM, Revision 12, September

18, 2013

CCP-AK-ANLE-501, Central Characterization Project Remote-Handled Transuranic 

Radiological Characterization Technical Report for Remote-Handled Transuranic Debris Waste 

from Argonne National Laboratory-East, Revision 9, March 8, 2013, and Revision 10, December 

4, 2013

CCP-AK-ANLE-502, Central Characterization Project RH TRU Waste Certification Plan for 40 

CFR Part 194 Compliance and Confirmation Test Plan for ANL RH Waste Stream: AERHDM, 

Revision 7, September 25, 2013

CCP-AK-ANLE-505D, Central Characterization Project Sampling and Analysis Plan for 

Argonne Remote-Handled Debris Waste, Waste Stream: AERHDM, Revision 1, February 6, 

2013

C2002, Memorandum from Timothy S. Crawford to Dr. F.Y. Fradin regarding the Safety 

Analysis Report (SAR) Revision 02 and Technical Safety Requirements (TSRs) Revision 01 for 

the Argonne National Laboratory-East (ANL-E) Building 205 G & K Wing Laboratories, T.S. 

Crawford, 0898-016, August 07, 1998

C2004, Safety Review for Unsaturated Testing of Uranium Metal Spent Fuel in Bldg. 205 Senior 

Cave and K-116 Facilities, R.D. Wolson, CMT50-0 US-Draft, Revision 0, March 7, 2009
B-2

C2005, Safety Review of Tests with Samples of Spent Fuel in Bldg. 205, K-104 (Senior Cave) 

and, in K-116, Sampling of Leachate Solutions from the Tests, P.A. Finn, CMTS0-0058-EP, 

Revision 1, March 13, 2000

C2006, Work Plan for the Preparation of Unirradiated AI-clad Specimens for GMT, T.S. Bray, 

IPS-329-00-00, December 02, 1999

C2033, Communication with Dan Pancake and Laura Maggos regarding Clarification on the 

Management of Corrosion Study Liquids and West Valley and SRS Vitrified High-Level Waste 

Samples in the K-Wing, K.J. Peters, March 6, 2012

DTC BDR No. ANLRHDTC13005, November 18, 2013

P2011, Nuclear Operations Deactivation, Decommissioning, and Demolition Program: 

Appendix B: Building 205 K-Wing Hot Cell Deactivation Project Plan, D. Hodge, NOD-162-00-

01, Revision 1, March 5, 2009

P2023, Results of the UREX+2 Spent Fuel Demonstration, C. Pereira, G.F. Vandegrift, 

M.C. Regalbuto, A. Bakel, S. Aase, D. Bowers, J.P. Byrnes, M.A. Clark, J.W. Emery, 

J.A. Falkenberg, A.V. Gelis, A. Leyva, L. Hafenrichter, Y. Tsai, K.J. Quigley, M.H. Vander Pol, 

and K. Wardle, February 28, 2005

P2024, Results of the 2005 UREX+1a Spent Fuel Demonstration, C. Pereira, L.E. Miller, 

G.F. Vandegrift, M.C. Regalbuto, A. Bakel, J. Basco, D. Bowers, J. Bruso, J.P. Byrnes, 

M.A. Clark, J.W. Emery, J.A. Falkenberg, A.V. Gelis, L. Hafenrichter, A.A. Leonard, A. Leyva, 

H. Mayes, T. Robinson, Y. Tsai, and K. Quigley, March 31, 2006

P344, Analysis of Spent Nuclear Fuel Sample A/G 574B2 (Limerick Reactor) to Determine 

Selected Isotopes and Estimate Fuel Burnup, D.G. Graczyk, April 2003

P730, Calculation Package for MCNP5 Uncertainty Analysis, J. Vance, SRS-RH-04, Revision 0, 

May 16, 2007, and Revision 1, November 7, 2007

RH Program- ANLE List of Qualified Individuals, July 14, 2011, July 18, 2011, July 22, 2011, 

July 26, 2011, August 11, 2011, September 30, 2011, March 12, 2012, September 28, 2012, 

March 1, 2013, and May 31, 2013

RH-TRU Dose to Curie Survey Log for 331 Shell, Drum Nos. RW48259, RW48260, RW48264, 

RW48265, RW48266, October 11, 2012

Sampling BDR No. AERH1101, December 20, 2011

VE BDR ANLRHVE12008, April 2, 2012