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 2014i T ABLE 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 Cha racterization 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. Pack aging 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 Evaluationii ACRONYMS A ND 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 Ce ntral 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 i nduct ively 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 De pletion 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 factoriii

Sr strontium SRS Savannah River Site T1 Tier 1 T2 Tier 2 TSFU t otal scaling factor u ncertainty TSRs technical safety requirements TRU transuranic U uranium UREX Uranium Extraction VE visual examination WDS waste data system WIPP Waste Isolation Pilot Plant1

1.0 INTRODUCTION This report supports the U.S. Environmental Protection Agency’s (EPA’s) approv al 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 w aste s tream AERHDM at the U.S. Department of Energy ’s (DOE’s) Arg onne National Laboratory (ANL)
. 1 In June 2012, EPA approved the Central Characterization Pro gram (CCP) 2 to 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 Ca rlsbad Field Office (CBFO) requested EPA approval of a T1 change to add the second batch of solidified liquid debris to w aste s tream AERHDM . Using the EPA

- approved waste characterization processes discussed in this report, ANL

- CCP has demonstrated its ca pability to characterize the second batch of solidified liquid debris waste as part of w aste s tream AERHDM for disposal at the Waste Isolation Pilot Plant (WIPP). As discussed below, EPA approves the T1 change request to add solidified liq u ids to the AERHD M 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 baseli ne 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
- cur ie (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 approv al 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 w aste s tream AE RHDM 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 A nalytical C hemistry L aboratory (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 repor t.

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

T h is restriction regarding use of the ANL Analytical Chemistry Laboratory is detailed in EPA’s T1 report from June 2012 and re mains 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 cont rols to characteri ze the 55

- gallon containers of w as te s tream AERHDM i s 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 modif

ications 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 provi ded 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 I nspection and Sub sequent T1 Evaluations, Updated February 201 4 ) 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 wa ste streams not approved under this baseline Modification of w aste s tream 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 Gam ma 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 crucib les and melts FEW Notification to EPA upon availability or nonsubstantive modification** of AKSRs and certification confirmation test plans (e.g., CCP

- AK

- ANLE

500 , CCP

- AK

- ANLE

- 502 ) Notification to EPA upon availability or modification of:
 T he final DTC det ermination 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 da ta 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 w aste s tream AERHDM, including the approximate number of contain ers 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 ap provals† 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 pro cedure 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 baselin e or addition of containers to w aste s tream AERHDM that require changing the established radionuclide scaling factors Application of new (i.e., not EPA

- approved scaling factors for isot opic determination other than those documented in CCP

- AK

ANLE

- 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 radiol ogical characterization technical reports (e.g., CCP

- TP

- 504, CCP

AK

- 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 th ose 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 ANL

CCP†

Visual Examination (VE) VE by reviewing existing a udio/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 ap proval 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” re fers 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 EV ALUATION Ce rtain 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

- CC P 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 was te 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 appro ved 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 iden tified 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 b asis 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 REPO RT This report presents the results of EPA’s evaluation of a T1 change to add the second batch of solidified liquid debris to w aste s tream AERHDM in ANL

- CCP’s approved waste characterization program . This report presents the technical basis for and results of EPA’s approval decis ion. EPA’s approval decision regarding the modification to w aste s tream 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: Mana ger, National TRU Program Carlsbad Field Office U.S. Department of Energy P O Box 3090 Carlsbad, NM 88221

- 30906

4.0 SCOPE OF T HE TIER 1 EVALUATION The scope of EPA’s T1 evaluation is the radiological characterization approach used to characterize the second bat ch 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 t he radiological characterization process as detailed in section 6. 0 of this report. 5.0 EPA EVALUATION PERSO NNEL 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, 3 the CCP RH Project Manager, who served as the point of contact for this T1 evaluation. Members of the EPA Eva luation Team had discussions with several ANL

CCP 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 CHARACT ERIZATION TECHNICAL EVALUATION Waste Overview The solidified liquid and soli d 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 w aste s tream AERHDM. The K

- Wing wastes were left over from experiments to im prove 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). The se were consolidated into a bulking tank, sampled, and solidif ied 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 (S Fs) 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

– Radiol ogical Characterization, SC&A Amir Mobasheran Technical Evaluator

– Radiological Characterization, SC&A Kira Darlow Technical Document Coordinator, SC&A7

of K

- Wing solidified liquid waste have been generated for the second batch of solidified liquid and debris; these drums are the subj ect 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 w aste s tream AERHDM
. ANL

- CCP provided CCP

AK

- 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 BDR s and calculation packages. Radiological Characterization Element Description EPA evaluated t he 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 pr ogram. During this RH evaluation, the EPA evalua tion 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 resul ts 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 ( 137 Cs). Each of these is discussed in the sections that follow.8

Technical Eval uation 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 AN L K Wing 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 137 Cs in a carboy in a drum Collect relevant AK Develop Certification Plan While mixing, sample the liquid at three tank locations

S ubmit sample s to ACL for radiometric and ICP

- MS analyses

Calculate th e a ctivity 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 137 Cs for each drum geometry
Find the mean gamma dose rate f or each drum based on four 1

- meter measurements Calculate the 137 Cs content of drums

Develop a composite set of scaling factors for each drum D evelop the 137 Cs inventory contributions from debris and solidified liquids U se analytical results to quant ify 137 Cs and develop 137 Cs scaling factors for all measured radionuclides Solidify liquid in 20

- L carboys, repackage into 55

- gallon drums, overpack with debris waste

Source: F igure G2

- 1 of Appendix G to CCP

- AK

- ANLE

- 501, Revision 109

(1) EPA evaluated the technical adequacy and documentation supporting the col lection of samples to develop scaling factors and found them to be adequate. The waste

- producing activities in the K

- Wing separated fission products ( 137 Cs) and prevented the development of SFs based solely on ORIGEN 2.2 4 . ANL

- CCP prepared a sampling and a nalysis 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 t he 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 radiolog ical characterization process hinges on the ability to establish a technically sound relationship between 137 Cs and the radionuclides of interest which are then scaled to the measured 137 Cs. ACL performed several radiometric and spectrometric analyses to q uantify these radionuclides to support SF development, i.e., uranium

- 233 ( 233 U ) , 234 U, 238 U, plutonium

- 238 ( 238 Pu ) , 239 Pu, 240 Pu, 242 Pu, americium

- 241 ( 241 Am), and strontium

- 90 ( 90 Sr ). The laboratory’s technical adequacy was discussed at length during the ANL

- CCP RH T1 for the first batch of K

Wing solidified liquids and is detailed in EPA D ocket N o. 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 de velop 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 th e 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 f or this batch of K

- Wing RH TRU solidified liquid and debris wastes is 137 Cs. The measured dose rate, waste density and the DTC correlation enable the determination of 137 Cs and other reportable radionuclides. These drums contained both debris and solidifie d liquids and the relative contributions of each were assessed, as described below.

 Sampling: ANL

- CCP collected r epresentati ve 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 137 Cs was modeled inside a carboy inside a 55

- gallon drum at a distance of 1 meter at different configura tions 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 137 Cs concentration from sampling and the carboy’s volume, the 137 Cs content of each carboy was determ ined, 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 t o the debris.
 Determining the Debris 137 Cs content: The debris’ contribution to dose rate and historical MicroShield modeling was used to calculate the 137 Cs 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 137 Cs 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 Drums11

 The effective scaling factors ( SF e ) for the drum were obtaine d from the contributions of the 137 Cs in the debris and so lidified liquid, as follows : SF e = f x SF

e Debris + (1

-

f ) x SF e, 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 a pplication 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 met rics, appropriate mean and standard deviation values
.  The physical constants and radionuclide

- specific attributes (specific activity, physical half

- life, de cay heat , photon transition probabilities, etc.) and the technical correctness of the values assigne d to the attribute
.  Appropriate correction for radioactive ingrowth and decay of all radionuclide s.
 The calculated results used to d eve lop SFs a nd convert measured dose rates to radionuclide activities.
 Determination of the activities an d un cer tainties f or the 10 WIPP

- t racked radionuclides ( 233 U, 234 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 242 Pu, 241 Am, 137 Cs and 90 Sr)
.  The contribution of all radionuclides to the radiological hazard
. 5
 Shielding and other calculations performed with Microshield to derive the appropri ate 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

- W ing 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 d escribes 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 report able radionuclides ( ANLE

- RH

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

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 propagatin g uncertainties in specific aspects of t he 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 fo llowing :

 137 Cs activity measurement.

- Measurement uncertainty.

- Dose contribution of other gamma

- emitting radionuclides.
 137 Cs 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 t he determi nations 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 i ndicated 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 regar ding 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 AN L

- 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, wh ich 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.”
 “At tachment 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
. ”
 At tachment 2

– CCP Records Transmittal/Receiving Form” CCP

- QP

- 008 , Rev ision 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 f orms 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 CONCERN S EPA did not identify any findings or concerns related to radiological characterizati on 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 res ult 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 th e T1 and T214

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 c haracterization processes to characterize the second batch of solidified liquids and debris added to ANL w aste s tream AERHDM using DTC and SFs based on sample analysis . Based on the results of this evaluation, EPA approves this T1 change , consistent with th e limita tions specified in this report. While these five drums of TRU waste are the subject of this T1 report , EPA’s approval also includes any addi tional drums that are added to w aste s tream 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 th e 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 REMOTE HANDLED WASTE CHARACTERIZATION PROGRAM Approved Activity EPA Inspection Number, Approval Date s EPA Docket Number ANL R H 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 Examina tion 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 w aste s tream AERHDM October 2008 A

- 98

- 49; II

- A4

- 136 Tier 1 Change

– Addition of K

- Wing debris waste to w aste

s tream AE RHDM S eptember 2010 A

- 98

- 49; II

- A4

- 132 Tier 1 Change

– Addition of 120 containers of AGHCF debris

waste to w aste s tream AERHDM S eptember 2010 A

- 98

- 49; II

- A4

- 134 Tier 1 Change

– Add ition of AGHCF fuel pin FEW to w aste

s tream AERHDM November 2010 A

- 98

- 4 9; II

- A4

- 140 Tier 1 Change

– Addition of K

- Wing FEW to w aste s tream

AERHDM F ebruary 2012 A

- 98

- 49; II

- A4

- 158 Tier 1 Change

– Addition of K

- Wing Solidified Liquid Waste

to w aste s tream AERHDM J une 2012 A

- 98

- 49; II

- A4

- 162 Tier 1 Change

– Addition of AGHC F RERTR FEW and

Second Batch of Fuel Pin FEW October 2012 A

- 98

- 49; II

- A4

- 16 7B

- 1 ATTACHMENT B LIST OF DOCUMENTS REVIEWED BY EPA DURING THE T1 EVALUATION Analysis of Sample Data for ANL

- E K

- Wing 2 nd 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 2 nd Batch of Solidified Liquids, Revision 0, February 26, 2013, and Calculations Spr eadsheet, 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 2 nd Batch of Liquids and Debris, Revision 0, February 26, 2013, and Revision 1, October 28, 2013 ANLE

- RH

- 72, DTC Spreadsheet 2 nd 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 Char acterization 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 i n Bldg. 205 Senior Cave and K

- 116 Facilities, R.D. Wolson, CMT50

- 0 US

- Draft, Revision 0, March 7, 2009B

- 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 Demo lition 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. Mil ler, 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, A nalysis 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 t o 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