DOCKET NO: A-98-49; II-A4-169

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT:

ADDITION OF CONTACT-HANDLED TRANSURANIC WASTE TO THE ADVANCED 

MIXED WASTE TREATMENT PROJECT APPROVED PROGRAM:

S3000 AND S5000 WASTE FROM ARGONNE NATIONAL 

LABORATORY-EAST AND S5000 WASTE FROM IDAHO NATIONAL 

LABORATORY MATERIALS AND FUELS COMPLEX

October – December 2012

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air

Center for Waste Management and Regulations

1200 Pennsylvania Avenue, NW

Washington, DC 20460

January 2013
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TABLE OF CONTENTS

Section Page

Abbreviations and Acronyms ......................................................................................................... ii

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

2.0 Purpose of Tier 1 Evaluations..............................................................................................4

3.0 Purpose of This Report ........................................................................................................4

4.0 Scope of the Tier 1 Evaluation.............................................................................................5

5.0 Tier 1 Evaluation Personnel.................................................................................................5

6.0 Technical Evaluation of Acceptable Knowledge and Load Management...........................6

6.1 Waste-Generating Activities....................................................................................6

6.2 Documents Provided................................................................................................7

6.3 Waste Characterization Element Description ..........................................................7

6.4 Technical Evaluation ...............................................................................................8

7.0 Findings and Concerns.......................................................................................................16

8.0 Conclusions........................................................................................................................16

LIST OF TABLES

Table 1. Tiering of CH TRU Waste Characterization Processes Implemented by AMWTP........ 3

Table 2. T1 Evaluation Personnel.................................................................................................. 5

ATTACHMENTS

Attachment A: Approval Summary for Advanced Mixed Waste Treatment Project 

Contact-Handled Waste Characterization Program

Attachment B: List of Documents Reviewed by EPA during T1 Evaluation
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ABBREVIATIONS AND ACRONYMS

ACL Analytical Chemistry Laboratory

AK acceptable knowledge

AL/CL Analytical Laboratory/Casting Laboratory

AKSR AK summary report

AMWTP Advanced Mixed Waste Treatment Project

ANL-E or ANLE Argonne National Laboratory-East

ANLW Argonne National Laboratory-West

CBFO Carlsbad Area Field Office

CCP Central Characterization Project

CFR Code of Federal Regulations

CH contact-handled

CIS characterization information summary

CMT Chemical Technology Division

D&D decontamination and decommissioning

DCR document change request

DOE U.S. Department of Energy

EBR Experimental Breeder Reactor

EPA U.S. Environmental Protection Agency

FFTF Fast Flux Test Facility

FMF Fuel Manufacturing Facility

GGE gas generation experiment

HFEF Hot Fuel Examination Facility

HLW high-level waste

HRA Hot Repair Area

IDC item description code

INL Idaho National Laboratory

INEL Idaho National Engineering Laboratory

IFR Integral Fast Reactor

IWTS Integrated Waste Tracking System

ITG Idaho Treatment Group, LLC

LMFBR Liquid Metal Fast Breeder Reactor
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MFC Materials and Fuels Complex

nCi/g nanocuries per gram

NDA nondestructive assay

NDE nondestructive examination

NWPA Nuclear Waste Policy Act

PK process knowledge

Pu plutonium

RERTR Reduced Enrichment for Research and Test Reactors

RFETS Rocky Flats Environmental Technology Site

RWMC Radioactive Waste Management Complex

SCG summary category group

SNF spent nuclear fuel

SWEPP Stored Waste Examination Pilot Plant

T1 Tier 1

T2 Tier 2

TRU transuranic

TWBIR Transuranic Waste Baseline Inventory Report

VE visual examination

VET visual examination technique

WAC waste acceptance criteria

WCA Waste Characterization Area

WDS Waste Data System

WIPP Waste Isolation Pilot Plant

WMO Waste Management Operations Division

WSPF waste stream profile form
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1.0 INTRODUCTION

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

proposed Tier 1 (T1) changes to the EPA-approved transuranic (TRU) waste characterization 

program at the U.S. Department of Energy’s (DOE’s) Advanced Mixed Waste Treatment Project 

(AMWTP). This approval allows AMWTP to characterize (1) Argonne National Laboratory-East 

(ANLE)1-generated contact-handled (CH) TRU homogeneous solids [Summary Category Group 

(SCG) S3000], (2) ANLE-generated heterogeneous debris (SCG S5000), and (3) Idaho National 

Laboratory (INL) Materials and Fuels Complex (MFC)-generated CH TRU S5000 waste for 

emplacement at the Waste Isolation Pilot Plant (WIPP). 

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

conducted Baseline Inspection No. EPA-AMWTP-03.06-8 of the waste characterization program 

at AMWTP on March 28–30 and April 11–13, 2006. The October 2006 baseline approval 

applied to CH retrievably stored S3000 and S5000 waste and newly generated S5000 CH waste. 

The AMWTP baseline final inspection report (see EPA Docket No. A-98-49; II-A4-66, dated 

October 2006) documents EPA’s approval of the acceptable knowledge (AK) and load 

management processes and several nondestructive assay (NDA) and nondestructive examination 

(NDE) systems for use in characterizing CH retrievably stored S3000 and S5000 waste and 

newly generated S5000 waste. The baseline report defined inclusion of wastes from sources 

other than Mound Site, Rocky Flats Environmental Technology Site (RFETS), Battelle 

Columbus Laboratories, and Bettis Atomic Power Laboratory (hereafter referred to as “Bettis”) 

as an AK T1 change that required EPA approval before implementation. A table listing EPA’s 

approvals of the AMWTP CH TRU waste characterization program is included as Attachment A.

On August 13, 2012, the Carlsbad Field Office (CBFO) requested EPA approval of the addition 

of ANLE-generated CH waste from SCGs S3000 and S5000 to the AMWTP baseline approval 

as a T1 change. On October 1, 2012, CBFO submitted a second request for EPA approval of the 

addition of MFC-generated CH S5000 waste to the AMWTP baseline approval as an additional 

T1 change. EPA limited the scope of these reviews to the AK and load management processes to 

determine whether AMWTP’s AK documents and records are sufficient to support inclusion of 

ANLE- and MFC-generated waste in the approved program. The NDA and NDE processes are 

not affected by inclusion of ANLE- and MFC-generated waste and are not included in the scope 

of this evaluation. This review also did not address AK procedural adequacy, AMWTP 

procedural compliance, or drum or data traceability, as these elements were addressed along with 

NDE processes and equipment during an EPA continued compliance evaluation of AMWTP on 

October 30–November 1, 2012 (report forthcoming). EPA will conduct a continued compliance 

evaluation of the NDA processes and equipment at AMWTP later this winter.

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

ANLW was renamed the Idaho National Laboratory Materials and Fuel Complex, and ANLE has since been 

referred to as ANL (Argonne National Laboratory). Both designations are found in the documents that EPA 

reviewed for this evaluation; however, EPA uses ANLE throughout the report to clearly differentiate ANLE 

information from historical ANLW information.
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During the evaluation, EPA did not identify any findings or concerns and, based on this 

evaluation, EPA approves the addition of the ANLE-generated S3000 and S5000 CH waste and 

the MFC-generated S5000 CH waste to AMWTP’s EPA-approved program. EPA’s evaluation 

required certain changes to several relevant AK documents, and AMWTP provided Document 

Change Requests (DCRs) for these revised documents to EPA before the conclusion of this T1 

evaluation. EPA expects formal revisions of the following documents to be completed by 

March 31, 2013, and submitted as part of AMWTP’s fiscal year 2013 second quarter 

submission of Tier 2 (T2) changes to EPA for review and concurrence:

• RPT-TRUW-05, Revision 30.

• RPT-TRUW-06, Revision 14.

• RPT-TRUW-07, Revision 17.

• RPT-TRUW-12, Revision 19.

• RPT-TRUW-79, Revision 1.

• RPT-TRUW-89, Revision 0.

Attachment B is a list of all documentation that EPA reviewed for this evaluation.

Based on this evaluation, there is one substantive change to the AK T1 designations: ANLE 

and MFC have been added to the list of approved waste sources. There are also two 

substantive changes to the AK T2 designations: notification to EPA upon revisions to 

AMWTP reports RPT-TRUW-05, RPT-TRUW-07 and RPT-TRUW-12, and upon 

completion of or revisions to all acceptable knowledge summary reports (AKSRs) and 

generator-site-specific summary AK reports (e.g., RPT-TRUW-79 and RPT-TRUW-89). 

EPA also revised the tiering table to ensure completeness and consistency with recent EPA 

T1 approval reports. Table 1 shows the substantive T1 and T2 changes in bold text. T1 and 

T2 changes that were initiated during the baseline approval remain in effect. The language 

in Table 1 regarding AK documentation applies to all AMWTP waste streams, including 

load managed and direct-shipped waste streams.

During the evaluation, EPA noticed that many of the AMWTP document titles include the phrase,

“Baseline Report.” In the WIPP regulations, the term “baseline” has specific regulatory 

significance, such that it is reserved for EPA actions and, therefore to prevent confusion, no 

DOE WIPP-related documents should use the term “baseline.” 

With this approval of the AK aspect of the characterization process, AMWTP-ITG (responsible 

since late 2011 for AMWTP’s CH TRU waste characterization program), may characterize 

physical and radiological contents of these two waste types using the equipment, processes and 

procedures that EPA approved during October 2006 baseline approval (see EPA Docket No A98-49: II-A4-66, October 3, 2006). AMWTP-ITG needs to confirm the AK using NDA and NDE

by generating batch data reports (BDR) for these waste types for EPA review before the subject 

waste is disposed of at the WIPP.

This report serves as EPA’s public notification of the approval of this T1 change. This 

information will be provided through the EPA website and by sending emails to the WIPPNEWS 

list, in accordance with 40 CFR 194.8(b)(3).
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Table 1. Tiering of CH TRU Waste Characterization Processes Implemented by AMWTP

(Based on March 28-30 and April 11-13, 2006 Baseline Inspection and Subsequent T1 Evaluations, Updated January 2013)

Process Elements AMWTP CH Waste Characterization Processes – T1 Changes AMWTP CH Waste Characterization Processes – T2 Changes*

Acceptable Knowledge,

including Load 

Management

Any new waste category

Any waste from sources other than Mound, RFETS, Battelle 

Columbus, Bettis, ANLE and MFC

Load management of any new or unapproved waste stream

Notification to EPA upon completion of or substantive modification** to: 

• Site procedures requiring CBFO approval

• Load management status of approved waste streams

• All final WSPFs with related attachments (e.g., CIS), including updates or 

additions to waste streams within approved SCGs and summaries of 

radiological data for those containers included on the CIS drum list

• AK accuracy reports (annually, at a minimum)

• All new and revised AKSRs and generator-site-specific summary AK 

reports (e.g., RPT-TRUW-79 and RPT-TRUW-89)

• Any waste identified outside of the waste profiles included in the 2002 

TWBIR, when applicable

• Implementation of procedures and related documentation that formalize 

NDA-AK communication requirements

• RPT-TRUW-05, RPT-TRUW-07 and RPT-TRUW-12

Nondestructive Assay New equipment or physical modifications to approved equipment***

Extension or changes to approved calibration range for approved 

equipment 

Notification to EPA upon substantive modification** to: 

• Site procedures requiring CBFO approval

• Software for approved equipment

• Operating ranges upon CBFO approval

Real-Time Radiography None Notification to EPA upon substantive modification** to:

• Site procedures requiring CBFO approval

• New equipment or physical modifications to approved equipment***

Visual Examination and 

Visual Examination 

Technique

Changes in vendor performing VE and/or VET Notification to EPA upon:

• Substantive modification** to site procedures requiring CBFO approval

• Addition of new waste category

• Addition of new procedure or site equipment identifier

WIPP Waste Data System Changes to WDS algorithms specific to load management Notification to EPA upon substantive modification** to:

• Site procedures requiring CBFO approval

• Load management status of approved waste streams

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.

* AMWTP will report all T2 changes to EPA every three months. 

** “Substantive modification” refers to a change with the potential to impact AMWTP’s CH waste characterization processes or documentation thereof, excluding changes that 

are solely related to 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. New references that are included as part of the document revision may be requested by EPA.

*** Modifications to approved equipment include all changes with the potential to affect data relative to waste isolation and exclude minor changes, such as the addition of 

safety-related equipment.
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2.0 PURPOSE OF TIER 1 EVALUATIONS

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

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

requirements set forth in 40 CFR 194.8 and incorporated into the AMWTP CH baseline final 

report (see EPA Docket No. A-98-49; II-A4-66).

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 

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 notification (T2) 

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

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

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

specific to a change. DOE may choose to characterize and dispose of 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 will conduct 

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

3.0 PURPOSE OF THIS REPORT

This report presents the technical basis for and results of EPA’s evaluation of the addition of 

SCG S3000 and S5000 ANLE-generated and SCG S5000 MFC-generated CH TRU waste to 

AMWTP’s baseline approval as a T1 change. Although they initially were separate T1 requests, 

EPA determined that it would be appropriate to present the technical evaluations in a single 

report. Throughout the report, the ANLE-generated CH TRU waste and MFC-generated CH 

TRU waste are discussed together under each item when issues, conditions or processes are 

similar, and separately when they differ. EPA’s approval of ANLE-generated CH TRU S3000 

and S5000 waste and MFC-generated CH TRU S5000 waste for characterization for 

emplacement at WIPP 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:
5

Manager, National TRU Program

Carlsbad Field Office

U.S. Department of Energy

P O Box 3090

Carlsbad, NM 88221-3090

4.0 SCOPE OF THE TIER 1 EVALUATION

The scope of the T1 evaluation was the addition of SCG S3000 and S5000 ANLE-generated CH 

waste and SCG S5000 MFC-generated CH waste to the AMWTP baseline approval as a T1 

change. EPA limited the scope of this review to the AK and load management processes to 

determine whether AMWTP’s AK documents and records are sufficient to support inclusion of 

ANLE- and MFC-generated waste in the approved program. This review did not address AK, 

NDA or NDE procedural adequacy, or AMWTP procedural compliance, or NDA and NDE 

equipment, as these elements were either evaluated during an EPA continued compliance 

evaluation of AMWTP on October 30–November 1, 2012 (report forthcoming) or will be 

evaluated during a follow-up site visit in the first half of 2013.

5.0 TIER 1 EVALUATION PERSONNEL 

EPA and its support personnel conducted interviews with AMWTP personnel by telephone. The 

EPA evaluation team members and the personnel contacted are listed in Table 2 with their 

affiliations and function. This list includes personnel present at meetings conducted as part of 

this evaluation.

Table 2. T1 Evaluation Personnel

Name Affiliation & Function 

Rajani Joglekar Lead Inspector, U.S. EPA 

Ed Feltcorn Inspector, U.S. EPA 

Kira Darlow Technical Evaluator – Acceptable Knowledge, SC&A, ANLE review

Connie Walker Technical Evaluator – Acceptable Knowledge, SC&A, MFC review

Tim Venneman Acceptable Knowledge Expert, ITG-AMWTP

Steve Carpenter Acceptable Knowledge Expert, ITG-AMWTP

Sue Peterman TRU Programs Manager, ITG-AMWTP

EPA conducted a continued compliance investigation concurrently with the T1 evaluation. While 

on site at AMWTP, Connie Walker (AK Technical Evaluator for SC&A, working on behalf of 

EPA) discussed portions of the T1 AK documents with AMWTP AK personnel to facilitate 

information transfers between EPA and AMWTP. The full list of personnel contacted during the 

continued compliance inspection will be included in EPA’s continued compliance inspection 

report (forthcoming).
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6.0 TECHNICAL EVALUATION OF ACCEPTABLE KNOWLEDGE AND LOAD 

MANAGEMENT

6.1 Waste-Generating Activities

A. Argonne National Laboratory East-Generated Waste

ANLE generated SCG S3000 and S5000 CH TRU waste from various laboratory buildings and 

activities, including laboratory support operations such as maintenance and decontamination and 

decommissioning (D&D). The Analytical Chemistry Laboratory (ACL) generated CH TRU 

waste during operations in Buildings 200 and 205. The ACL supported most of the programs at 

ANLE, including the Chemical Technology Division (CMT). Operations included separation of 

irradiated and nonirradiated actinides, chemical purification, isotope identification by mass 

spectrometry, and other radiometric determination. Building 212 (Energy Technology Division) 

housed the Materials Science Division Glovebox Complex and the Alpha-Gamma Hot Cell 

Facility and performed research operations to advance reactor technology using plutonium as 

fuel. Buildings 315 and 316 (Reactor Research and Development Group) produced a minimal 

amount of CH TRU waste through design, mock-up and construction of bench scale models of 

various reactor systems. Building 350 housed the Plutonium Fuel Fabrication Facility and later 

the relocated New Brunswick Laboratory operations. Small amounts of CH TRU waste were 

generated in other buildings, including Buildings 40, 202, 206, 211, 222, 223, 330, 331, 333, 

362, 369, 378, 391, 398 and 815. The Waste Management Operations Division (WMO) used 

Building 306 for waste treatment, repackaging operations and storage. During repackaging by 

WMO, wastes from the primary generation locations mentioned above were routinely 

commingled with the repackaging operations wastes. Debris waste was also generated during 

D&D operations from Buildings 205 and 350 (References P319A, P1155A, P1379A, P1380A 

and P1381A).

The waste that is the subject of this T1 evaluation generated at ANL was shipped to the 

Radioactive Waste Management Complex (RWMC) at INL prior to 1990 (Reference U325S). 

Waste generated at ANL was shipped to INL after 1990 and was diverted to the Central 

Characterization Project (CCP) program at INL for characterization and shipment to the WIPP 

facility as Waste Streams ID-AECHDM (S5000) and ID-AECHHM (S3000) (Reference C574S). 

B. Idaho National Laboratory Materials and Fuels Complex-Generated Waste

ANLW was established in 1949 and was renamed the MFC in 2005. ANLW’s historic mission 

was the development of advanced reactor concepts (including the liquid metal reactor program)

and fuel cycle processes, fabrication of fuel and fuel rods, examination and testing of fuel and 

fuel materials, research related to homeland security, D&D technologies, reactor and fuel cycle 

safety, and WIPP-related waste characterization activities. The current MFC mission includes 

development of nuclear power systems in the United States under programs such as the 

Advanced Fuel Cycle Initiative, Generation IV Nuclear Reactor Programs, and space nuclear 

program initiatives. The processing and characterization of radionuclide-containing materials 

such as spent fuel and weapons-grade plutonium generated TRU waste. Activities included 

actinide recovery, experimental fabrication of fuels, transmutation experiments, maintenance and 
7

decontamination of gloveboxes and related equipment, and processing and handling of nuclear 

materials. Debris waste was also generated during WIPP-related characterization activities 

(i.e., coring and headspace gas sampling and analyses). MFC facilities include buildings that 

house gloveboxes, hot cells and laboratory hoods (References C852A, C1054S, P312A, P675A, 

P678S, P679A, P683S, P688S, P695A, P696S, P697S, P698S, P708A, P716A, P727A and 

P862S):

• Building 752 – Laboratory and office building containing the Analytical 

Laboratory/Casting Laboratory (AL/CL).

• Building 704 – Fuel Manufacturing Facility (FMF).

• Building 785 – Hot Repair Area (HRA) and Waste Characterization Area (WCA) inside 

the Hot Fuel Examination Facility (HFEF), including gas generation experiment (GGE)-

related waste and ash stabilization experiment cleanup waste.

Activities in these buildings supported commercial and offsite DOE facilities, including, but not 

limited to, Los Alamos National Laboratory, RFETS, and Lawrence Livermore National 

Laboratory, as well as INL facilities [e.g., the Experimental Breeder Reactor (EBR)-II]. Other 

INL facilities handled fuel actinide materials that were transferred to Buildings 752 and 704 for 

processing, including the Fuel Conditioning Facility, HFEF-North and HFEF-South, Zero Power

Physics Reactor, and the Space and Security Systems Facility (References P237A, P679A, 

P842A and U005A). Consequently, although debris waste was generated in Buildings 752, 504 

and 785, the waste may be associated with support activities originating from onsite and offsite 

sources. Waste includes both legacy waste (including waste managed by CCP under Waste 

Stream ID-MFC-S5490) and waste that will be generated in the future from MFC (References 

C557A, C852A, P237A, P816A, P842A, U005A, U236S and U237S). 

6.2 Documents Provided

EPA evaluated the AMWTP documentation that supported inclusion of the SCGs S3000 and 

S5000 ANLE-generated CH waste and SCG S5000 MFC-generated CH waste in AMWTP’s 

approved characterization program. Attachment B is a list of all documentation reviewed.

6.3 Waste Characterization Element Description 

EPA limited the scope of the T1 review to the following elements related to the use of AK for 

CH waste characterization:

• Waste identification and description, including radiological and physical characteristics 

and verification that the subject S5000 waste is suitable for inclusion in supercompacted

Waste Stream BN510.1.2

• Sufficiency of AK reports, including integration of source documents. 

 2 AMWTP intends to incorporate the ANLE-generated S5000 waste and the MFC-generated S5000 waste 

into supercompacted debris Waste Stream BN510.1 [see Item (1)] for shipment to the WIPP facility.
8

• Verification that the subject waste is of defense origin and is not high-level waste (HLW) 

or spent nuclear fuel (SNF).

• Load management.

6.4 Technical Evaluation 

In late 2011, the Idaho Treatment Group (ITG) took responsibility for characterization CH TRU 

waste at INL using AMWTP’s CH TRU waste characterization program approved by EPA in 

October 2006. Upon verification and with proper referencing, ITG uses ANLE generated AK 

information to generate their own documentation. Similarly, ITG uses the Central 

Characterization Project (CCP) generated AK information for MFC waste. EPA concurs with 

this approach with a caveat that ITG must substantiate the use of any information provided by 

non-ITG sources when questioned by EPA. 

(1) The wastes were evaluated based on process, radiological and physical information for 

inclusion in supercompacted Waste Stream BN510.1 for direct shipment and found to be 

adequate.

A. Argonne National Laboratory East-Generated Waste

As described in section 6.1.A, all of the ANLE-generated waste subject to this T1 was generated 

prior to 1990 from laboratory operations throughout the ANLE complex. The waste from various 

locations was routinely commingled by WMO in Building 306 for more efficient packaging and 

to ensure compliance with all applicable procedures and regulations. Therefore, segregation by 

generation location or process is not possible (Reference P1155A). 

A single ratio of radionuclides will not represent all drums in the ANLE-generated CH TRU 

waste because the waste was generated from various research and development activities and 

then commingled by WMO. The waste generation forms only indicated if the waste was TRU or 

not TRU. Measured isotopic ratios will vary significantly and are expected to represent weaponsgrade, fuel-grade, reactor-grade and higher enrichments of plutonium (Pu). AMWTP analyzed 

radionuclide information compiled by INL-CCP for the ID-AECHDM and ID-AECHHM waste 

streams and determined that the two most common radionuclides by activity are expected to be 

241Pu and 239Pu for S5000 waste and 239Pu and 241Pu for S3000 waste (Reference P1379A).

ANLE labeled each container3 with a content code before shipping the containers to INL 

RWMC. INL later applied item description codes (IDCs) to each container based on the ANLEassigned content code and additional research conducted by the Stored Waste Examination Pilot 

Plant (SWEPP) at the RWMC. The physical contents associated with most of the content codes 

and IDCs are well known (References D094A, P024A, P365A and P888A). However, in some 

cases (e.g., IDC AE-106) the historical records concerning the physical contents are incomplete. 

In these situations, AMWTP assumes that all ANLE-generated S5000 waste would be similar in 

 3 “Container” is a generic term that applies to cans, canisters, drums, boxes and any other types of waste 

packaging units that may have been used to transfer waste from the generator site to AMWTP or storage at INL.
9

content to IDC AE-100 waste and to historical waste that was sent from ANLE to Oak Ridge 

National Laboratory (Reference C1090S).

Homogeneous Solids (S3000) Waste 

AMWTP stated that it intends to combine all four IDCs into a single waste stream for direct 

shipment to the WIPP facility, but that it will make the final decision on waste stream definition 

after receiving EPA’s approval and beginning to characterize the waste. Combining all four IDCs 

into a single waste stream is the broadest application of the waste stream definition; therefore, 

this is what EPA evaluated. According to currently available information, a single S3000 waste 

stream would be appropriate for the following reasons: (1) individual drums cannot be 

differentiated based on waste-generating processes or radionuclide content because liquid wastes 

were routinely mixed and consolidated by the WMO as detailed above; (2) IDCs AE-102, AE111 and AE-121 were historically managed by ANLE as the same content code (102) and drums 

of all three types primarily contain vermiculite or Oil-Dri® and absorbed liquids; and (3) IDC 

AE-105 also primarily contains vermiculite and the same absorbed liquids that were combined 

and poured into the AE-102, AE-111 and AE-121 drums (References RPT-TRUW-89, 

Revision 0; D094A; P024A; P365A and P888A).

After receiving EPA’s approval for this T1, AMWTP will characterize the S3000 waste and 

develop waste-stream-specific AKSRs and waste stream profile forms (WSPFs). Depending on 

the results of characterization, multiple S3000 waste streams may need to be created. 

Notifications of the availability of all AKSRs and WSPFs are T2 changes (see Table 1).

Heterogeneous Debris (S5000) Waste 

AMWTP intends to incorporate the ANLE-generated S5000 waste into supercompacted debris 

Waste Stream BN510.1. Waste Stream BN510.1 currently includes various combustible and 

noncombustible debris waste from the Hanford Site, Mound Site, RFETS, Battelle Columbus 

Laboratories, and AMWTP-generated waste. Waste-producing activities at each site included 

plutonium production and research activities, including laboratory operations and maintenance.

The ANLE-generated debris waste is physically similar to the BN510.1 waste and fits within the 

general BN510.1 radiological composition envelope (References P1030A; RPT-TRUW-05, 

Revision 30; and RPT-TRUW-83, Revision 3). See Item (4) for additional requirements related 

to payload management of the BN510.1 waste stream.

AMWTP may not be able to supercompact all of the ANLE-generated S5000 waste or may 

decide in the future to direct ship the ANLE-generated S5000 waste to the WIPP facility. In the 

event that some of the debris waste needs to be direct shipped to the WIPP facility, AMWTP will 

create one or more S5000 waste streams. As mentioned above, the waste was regularly 

commingled during packaging at ANLE; it is likely that each drum contains some general plant 

waste (IDC AE-100) and a mixture of radionuclide ratios. However, AMWTP has not yet 

defined specific ANLE-generated S5000 waste streams. AMWTP stated that this would be 

performed in the future if direct shipment of ANLE S5000 waste is deemed necessary. 

Notifications of the availability of all AKSRs and WSPFs, including for any direct-shipped waste 
10

streams are T2 changes (see Table 1). See Item (4) for additional requirements related to payload 

management of direct-shipped waste.

B. Idaho National Laboratory Materials and Fuels Complex-Generated Waste

MFC-generated waste was and is produced by a host of experimental and support activities. 

Waste is bagged out of each area on a campaign basis, and MFC then generates its own 

Integrated Waste Tracking System (IWTS) profiles that group waste based on its physical and 

chemical characteristics, waste generator locale, or other waste descriptors (References P734A, 

P751A, P848A, P710A, P718A and P850A). Although the IWTS profiles do not directly 

correspond to IDCs, AMWTP used the profiles to understand the processes associated with 

waste generation. The IWTS profiles, together with IDC descriptions in RPT-TRUW-05, 

Revision 30, and RPT-TRUW-79, Revision 1 (MFC summary AK report), provide adequate 

information about MFC waste generation processes.

As with ANLE-generated waste, a single ratio of radionuclides cannot be used to represent all 

drums in the MFC-generated CH TRU waste because the waste was generated from a variety of 

research and development activities. The waste was not commingled between generator 

locations, so determination of drum radiological composition requires review of IWTS material 

and waste characterization profiles, as well as review of individual IWTS container-specific data. 

AMWTP did not include detailed information about the radiological composition of MFC wastes 

in the MFC summary AK report, but instead combined the information from these sources into 

one table presenting the anticipated concentration range of radionuclides in waste from Buildings 

704 and 752, and a second table presenting generalized radiological data for waste originating 

from Building 785 and related experiments. However, EPA pointed out that neither table 

included 239Pu or other isotopes, even though weapons-grade material was managed in all 

buildings. AMWTP concluded that the table and information in the MFC summary AK report

were inaccurate and revised the summary AK report to include updated data derived from IWTS 

profiles and AMWTP NDA of IDCs representative of those in both the TRU heterogeneous 

debris and WIPP candidate characterization debris populations (revised Tables 5, 6 and 10 in 

RPT-TRUW-79, Revision 2A). These revised data indicate that the two most common 

radionuclides by activity are expected to be americium-241 and 241Pu for all SCG S5000 MFCgenerated waste (References C1056S, P842A and U337A). The revised MFC summary AK 

report data also fit within the general radiological envelope expected for Waste Stream BN510.1 

waste as a whole, but AMWTP will evaluate MFC wastes on an IDC basis to ensure that 

individual IDCs still match the BN510.1 envelope. 

AMWTP assembled IDC-specific physical information and included these data in RPT-TRUW05, Revision 30. As with ANLE-generated waste, MFC-generated waste containers are 

individually assigned an IDC.

MFC waste has been generated since the early 1950s at several different glovebox, laboratory 

hood, and hot cell facilities. Waste from each location was bagged out on a campaign basis. The 

MFC summary AK report (RPT-TRUW-79, Revision 1) and related source documents do not 

state that waste from different process lines are commingled and do not indicate that waste 

between building locations was or is ever commingled. The MFC summary AK report suggests 
11

that AMWTP is considering combining waste from Buildings 752 and 704 into a single waste 

stream if waste is eventually direct shipped from AMWTP. The MFC report also indicates that 

waste from the Building 785 HRA/WCA and ash stabilization/GGE cleanup may be combined 

into a second debris waste stream. AMWTP has not yet developed an adequate case for waste 

stream determinations. However, waste stream determinations are not required to integrate MFC 

waste into supercompacted Waste Stream BN510.1; only IDC determination is required. Based 

on the above information, the process, physical composition, and radiological composition of 

each IDC are or can be sufficiently defined to indicate that the candidate IDCs fit within the 

Waste Stream BN510.1 envelope.

AMWTP may not be able to supercompact all of the MFC-generated S5000 waste or may decide 

in the future to direct ship the MFC-generated S5000 waste. In the event that some of the debris 

waste needs to be direct shipped to the WIPP facility, AMWTP will create one or more S5000 

waste streams. As mentioned in the previous paragraph, AMWTP has not yet defined specific 

MFC-generated S5000 waste streams but would do so prior to direct shipment of MFC-generated

S5000 waste. Notifications of the availability of all AKSRs and WSPFs, including for any directshipped waste streams are T2 changes (see Table 1). See Item (4) for additional requirements 

related to payload management of direct-shipped waste. 

(2) The acceptable knowledge reports and related documentation were assessed and found to 

be adequate. 

AMWTP prepares multiple documents that together fully summarize the available information 

for ANLE- and MFC-generated CH TRU waste. AMWTP’s AK characterization process, 

procedure MP-TRUW-8.13, Revision 24,

4 states that the process begins with development of 

generator-site-specific summary AK reports. In the case of these T1 requests, AMWTP prepared 

two summary AK reports: RPT-TRUW-89, Revision 0, “Acceptable Knowledge Baseline 

Document for Argonne National Laboratory-East” (the ANLE summary AK report), and RPTTRUW-79, Revision 1, “Acceptable Knowledge Document for Materials and Fuels Complex” 

(the MFC summary AK report). According to procedure MP-TRUW-8.13, information from the 

generator-site-specific summary AK reports is then used to update other AMWTP summary 

reports. AMWTP provided the following reports to EPA as evidence of this process:

• “Waste Matrix Code Reference Manual” (RPT-TRUW-05, Revision 30). 

• “Acceptable Knowledge Baseline Document for AMWTP Waste” (RPT-TRUW-06, 

Revision 14).

• “Determination of Radioisotopic Content in TRU Waste Based on Acceptable 

Knowledge” (RPT-TRUW-07, Revision 17).

• “AMWTP Waste Stream Designations” (RPT-TRUW-12, Revision 18).

 4 AMWTP, “Collection, Review, and Management of Acceptable Knowledge Documentation,” MPTRUW-8.13, Revision 24, Idaho Falls, Idaho, December 12, 2011.
12

• “Acceptable Knowledge Summary for Supercompacted Debris Waste (BN510.1)” (RPTTRUW-83, Revision 3).

These reports plus their supporting source documents contain the information required by the 

WIPP waste acceptance criteria (WAC)5 and WIPP Waste Analysis Plan.6 Except for RPTTRUW-83, AMWTP revised each document to address ANLE- and MFC-generated waste, as 

discussed below.

RPT-TRUW-05, the waste matrix code reference manual, contains detailed information, by 

generator site IDC and waste matrix code, about the physical characteristics of all waste that is 

handled by AMWTP, including low-level waste. RPT-TRUW-05 includes information for all the 

IDCs identified in the ANLE and MFC summary AK reports. RPT-TRUW-05 is also the primary 

source of information about the prohibited-item content of each MFC IDC because the MFC 

summary AK report (RPT-TRUW-79, Revision 1) does not include this information. EPA 

reviewed RPT-TRUW-05, Revision 30, and found that the report referenced several source 

documents for the physical waste descriptions; in some cases, it also referenced inappropriate 

source documents. For example, the description for IDC AE-111 references “Waste 

Characterization for INEL [Idaho National Engineering Laboratory] Remote-Handled/SpecialCase Stored Transuranic Wastes” (WM-PD-85-014), which does not discuss IDC AE-111 

(Reference P888A). AMWTP revised the report to correct the references to include additional 

documents that support descriptions for all IDCs for ANLE-generated waste (References 

C1090S, C1091S, P310A, P365A and P567A). AMWTP provided EPA with a DCR for RPTTRUW-05 that covers these changes. As revised, RPT-TRUW-05 adequately presents the 

physical characteristics of each IDC in the ANLE- and MFC-generated waste. Notification of the 

availability of a revised RPT-TRUW-05 is a new T2 change (see Table 1). EPA expects formal 

revision of RPT-TRUW-05, Revision 30, to incorporate the DCR and to be completed before 

AMWTP’s 2013 second quarter submission of T2 changes to EPA for review and concurrence.

RPT-TRUW-07 presents radiological information for EPA-approved waste sites, i.e. RFETS, 

Mound Site, Battelle Columbus Laboratories, Bettis, the Hanford Site, and AMWTP 

supercompacted and newly generated (not supercompacted) wastes. RPT-TRUW-07, Revision 

17, did not thoroughly address ANLE- or MFC-generated waste, including radiological

information about each site and payload-management-related data [see Item (4)]. AMWTP 

provided draft RPT-TRUW-07, Revision 18a, and the accompanying DCR, which add ANLE 

and MFC radiological information and present payload management data required by the WAC. 

Draft RPT-TRUW-07, Revision 18a, adequately presents summary radiological data for ANLEand MFC-generated waste. Notification of the availability of a revised RPT-TRUW-07 is a new 

T2 change (see Table 1). See Item (4) for additional information about payload management. 

EPA expects formal revision of RPT-TRUW-07, Revision 17, to incorporate the DCR and to be 

completed prior to the AMWTP’s 2013 second quarter submission of T2 changes to EPA for 

review and concurrence.

 5 U.S. DOE CBFO, “Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant,” 

DOE/WIPP-02-3122, Revision 7.2, Carlsbad, New Mexico, June 13, 2011.

6 Waste Isolation Pilot Plant Hazardous Waste Facility Permit, New Mexico Environment Department, 

Waste Analysis Plan, Santa Fe, New Mexico, June 29, 2010.
13

RPT-TRUW-12 is limited to descriptions of AMWTP-approved waste streams that originated 

from EPA-approved waste sites but are shipped to WIPP as AMWTP waste streams. RPTTRUW-12 is typically used to identify the waste’s hazardous constituents by IDC. RPT-TRUW12, Revision 18, did not address ANLE- or MFC-generated waste. AMWTP provided draft RPTTRUW-12, Revision 20,

7 and the accompanying DCR, which add information about the IDCs 

associated with the ANLE- and MFC-generated S5000 waste. AMWTP representatives 

explained that the ANLE-generated S3000 waste information will be added to RPT-TRUW-12 as 

a future revision when the S3000 waste has been characterized and AMWTP is ready to profile 

the waste to WIPP. RPT-TRUW-12, Revision 20, adequately addresses S5000 ANLE- and 

MFC-generated waste. EPA will look for the S3000 information in future revisions of RPTTRUW-12. Notification of the availability of a revised RPT-TRUW-12 is a new T2 change (see 

Table 1). EPA expects formal revision of RPT-TRUW-12, Revision 19, to incorporate the DCR 

and to be completed prior to the AMWTP’s 2013 second quarter submission of T2 changes to 

EPA for review and concurrence.

Information about all AMWTP-generated waste, including supercompacted Waste Stream 

BN510.1, is presented in RPT-TRUW-06, Revision 14 (hereafter referred to as the “AMWTP 

summary AK report”). AMWTP provided draft RPT-TRUW-06, Revision 15, and the 

accompanying DCR, which add necessary information about the ANLE- and MFC-generated 

feedstock material for supercompacted Waste Stream BN510.1. AMWTP still needs to update 

RPT-TRUW-83, Revision 3 (hereafter referred to as “the BN510.1 AKSR”), to incorporate 

ANLE- and MFC-generated waste prior to shipping waste to the WIPP facility. However, EPA 

does not require an updated BN510.1 AKSR to approve these T1 requests. Notification of the 

availability of revised generator-site-specific summary AK reports (including RPT-TRUW-06) 

and AKSRs (including the BN510.1 documentation) is a new T2 change. Notification of the 

availability of revised WSPFs (including revisions to the Waste Stream BN510.1 WSPF to 

incorporate ANLE- and MFC-generated waste) remains a T2 change.

A. Argonne National Laboratory East-Generated Waste

The ANLE summary AK report (RPT-TRUW-89, Revision 0) covers all general information 

about the ANLE-generated waste, including specific physical descriptions and general 

radionuclide content for both S3000 and S5000 waste. AMWTP’s primary sources for the 

information in the summary AK report were AK and process knowledge (PK) reports written by 

INL-CCP and ANLE-CCP for CH waste generated in ANLE laboratories after 1990. During the 

review process, AMWTP updated the ANLE summary AK report to include additional source 

documents that support applying CCP’s defense determination, process information and 

radiological information to the older AMWTP waste (References C1090S, C1091S and U342S).

Additionally, AMWTP revised the statement about the waste not being SNF or HLW to better 

support the assertion. The waste stream definition and documentation of physical and 

 7 EPA did not review RPT-TRUW-12, Revision 19, which was approved on November 13, 2012. EPA 

reviewed the draft version of RPT-TRUW-12, Revision 20, dated November 14, 2012, to confirm that RPT-TRUW12 adequately addresses ANLE- and MFC-generated S5000 CH waste.
14

radiological components are discussed further in Item (1) above. The defense origin of the waste 

and the absence of SNF and HLW are discussed further in Item (3) below.

B. Idaho National Laboratory Materials and Fuels Complex-Generated Waste

The MFC summary AK report (RPT-TRUW-79, Revision 1) presents general information about 

MFC-generated waste, including waste origin, physical composition, and general radionuclide 

information for S5000 waste only. EPA questioned the defense determination, HLW, and 

radiological composition information presented in the MFC summary AK report. AMWTP 

adequately revised the MFC summary AK report to address EPA’s concerns. The waste stream 

definition and documentation of physical and radiological components are discussed further in 

Item (1) above. The defense origin of the waste and the absence of SNF and HLW are discussed 

further in Item (3) below.

(3) The generator-site-specific summary acceptable knowledge reports were examined and 

indicate that data are available to determine that the wastes are defense in origin and are 

not high-level waste or spent nuclear fuel.

TRU waste to be emplaced in the WIPP must be defense in origin. DOE guidance defines waste 

as defense in origin if it was generated in whole or part by one of the atomic energy defense 

activities listed in section 10101(3) of the “Nuclear Waste Policy Act of 1982” (NWPA).

8 The 

WIPP Land Withdrawal Act9 prohibits the disposal of SNF and HLW as defined by the NWPA 

at the WIPP. The NWPA states that SNF is “fuel that has been withdrawn from a nuclear reactor 

following irradiation, the constituent elements of which have not been separated by reprocessing. 

SNF may not include test specimens irradiated for research and development only (i.e., these 

may be classified as waste when it is technically infeasible, cost prohibitive, or would increase 

worker exposure).” HLW is defined by the NWPA as “the highly radioactive material resulting 

from the reprocessing of spent nuclear fuel, including liquid waste produced directly in 

reprocessing and any solid material derived from such liquid waste that contains fission products 

in sufficient concentrations, and other highly radioactive material that the Commission, 

consistent with existing law, determines by rule requires permanent isolation.”

A. Argonne National Laboratory East-Generated Waste

ANLE laboratories supported many defense-related activities through fuel examinations, 

including materials from the Liquid Metal Fast Breeder Reactor (LMFBR) Program, fuels 

irradiated in EBR-II and the Fast Flux Test Facility (FFTF), samples for the Reduced Enrichment 

for Research and Test Reactors (RERTR) Program, specimens of Integral Fast Reactor (IFR) Puuranium-zirconium metallic alloys, and specimens from the Knolls Atomic Power Laboratory 

(hereafter referred to as “Knolls”) and Bettis. The Knolls and Bettis specimens were part of 

research conducted by the Naval Research Laboratory. The RERTR and IFR experiments 

 8 U.S. Code, Title 42, “The Public Health and Welfare,” Chapter 108, “Nuclear Waste Policy Act of 1982.” 

9 Public Law 102-579, The Waste Isolation Pilot Plant Land Withdrawal Act, October 30, 1992 as amended 

by Public Law 104-201, September 23, 1996.
15

supported weapons nonproliferation efforts. Both EBR-II and FFTF irradiated fuels for a variety 

of defense programs, including the LMFBR Program and large-scale tritium production projects. 

The LMFBR Program was critical to efforts to develop a safe, reliable and economical method of 

energy production (References P1379A and P1380A). ANLE also participated in many nondefense-related activities. However, in addition to WMO commingling wastes from the various 

laboratory locations at ANLE [see Item (2)], the laboratory cleaning practices resulted in wastes 

that contain radionuclides from both defense- and non-defense-related activities, which cannot be 

separated. Therefore, all ANLE TRU CH waste, including the wastes that were shipped to INL 

RWMC, is considered to be defense in origin.

The ANLE waste is not HLW or SNF, as defined above. ANLE laboratory operations conducted 

research on irradiated and nonirradiated test specimens that by definition are not SNF. Also, any 

measurable quantities of fuel test specimens, including swarf10 and fines, were stored separately 

as accountable materials11 and would be characterized separately from the CH TRU wastes. 

ANLE laboratory operations did not include reprocessing of SNF.

B. Idaho National Laboratory Materials and Fuels Complex-Generated Waste

The MFC summary AK report (RPT-TRUW-79, Revision 1) states, “based on the AK review of 

MFC PK [process knowledge] documentation and communication with MFC personnel relating 

to waste-generating processes, the CH-TRU waste generated at the MFC in the AL/CL, FMF, 

and HRA/WCA are classified as defense-related waste.” The MFC report cites source documents 

C555S and P679A in support of this statement. However, Reference P679A clearly states, “This 

report, lacking in detail, is not intended to substitute for AK documentation that is prepared prior 

to shipment of ANL-West TRU waste. Detailed documents, including AK Reports are prepared 

to certify that the waste acceptance requirements have been met.” Reference C555S addresses 

the FMF (Building 704) only and was developed to support remote-handled waste defense 

determination. Because MFC waste was not commingled between buildings, overall waste 

commingling cannot be used as a defense argument. EPA pointed out these weaknesses in the 

referenced supporting documents. AMWTP revised the MFC summary AK report to include 

additional defense-related activities, better references for defense activities associated with the 

HRA and WCA, and additional support for waste commingling at the generator source. EPA 

expects AMWTP to evaluate the contents of each IDC accepted for supercompaction, as well as 

wastes assigned to forthcoming direct ship waste streams, to ensure that the defense 

determination is adequately supported.

The MFC summary AK report states that processing of intact fuels was not performed at any 

MFC facility, but that waste may contain material “incidental to reprocessing.” The report states

that, because waste does not contain intact fuel elements, it does not contain SNF or HLW.

However, the condition of fuel elements prior to reprocessing does not affect the HLW

determination; if SNF is reprocessed, HLW may be generated. The MFC summary AK report 

also states that SNF was reprocessed to extract Pu. EPA pointed out that the explanation offered 

 10 “Swarf” is material produced by a cutting or grinding process.

11 “Accountable materials” are items that are tracked and controlled in accordance with DOE M 435.1-1, 

“Radioactive Waste Management Manual,” because of their special nuclear material content.
16

in the MFC summary AK report does not take this information into account. AMWTP revised 

the MFC summary AK report and provided additional source documents supporting the idea that 

HLW and SNF were managed at the facility but were segregated from this waste stream

(References P1395A and P1396S). EPA expects AMWTP to evaluate the contents of each IDC 

accepted for supercompaction, as well as wastes assigned to forthcoming direct-ship waste 

streams to ensure that the SNF and HLW determinations are adequately supported.

(4) Load management was found to be acceptable. 

The WIPP WAC allows payload management wherein a payload container may include drums 

that measure less than 100 nanocuries per gram (nCi/g) so long as the payload in total is greater 

than 100 nCi/g. The WAC defines a payload container as “the outermost container [(e.g., drum, 

Standard Large Box 2, standard waste box, 10-drum overpack, or canister)] for TRU waste 

material that is placed in a reusable Type B shipping container (e.g., TRUPACT-II, TRUPACTIII, HalfPACT, RH-TRU 72-B, or 10-160B) for transport.” The AKSR for each waste stream 

selected for payload management must include an estimate of the total waste volume and 

percentage of the waste volume that is above and below100 nCi/g. Each container selected for 

payload management must also contain at least one TRU isotope whose activity exceeds the 

lower limit of detection of the radioassay system used to characterize the waste, and each 

container may only be overpacked into a payload container with other containers from the same 

TRU waste stream.

AMWTP includes WAC payload documentation in RPT-TRUW-07 instead of in individual 

AKSRs. Supercompacted waste is payload managed because the 100-gallon drum in which 

supercompacted silver drums are placed is considered the payload container. Waste that is direct 

shipped from AMWTP may be payload managed so long as the appropriate WAC requirements 

are met. However, AMWTP had not updated RPT-TRUW-07, Revision 17, to include ANLE- or 

MFC-generated waste. EPA brought this to the attention of AMWTP, which provided draft RPTTRUW-07, Revision 18a, and the accompanying DCR, which adequately address WIPP WAC 

payload management requirements for ANLE- and MFC-generated waste (Reference U127A).

7.0 FINDINGS AND CONCERNS

The EPA inspection team did not identify any findings or concerns during these T1 evaluations

and there are no open issues relative to these T1 evaluations.

8.0 CONCLUSIONS

Changes to Tiering

Table 1 was modified to update the list of approved waste sources to include ANLE and MFC. 

Notification to EPA upon revisions to AMWTP reports RPT-TRUW-05, RPT-TRUW-07 and 

RPT-TRUW-12 and upon revisions to AKSRs and generator-site-specific summary AK reports 

were added as new T2 changes. EPA also revised the tiering table to ensure completeness and 

consistency with recent EPA T1 approval reports. Table 1 shows the substantive T1 and T2 
17

changes in bold text. T1 and T2 changes that were initiated during the baseline approval remain 

in effect; these are listed as applicable in section 6.0.

Approval

This T1 change consisted of the use of AK to characterize ANLE-generated S3000 and S5000 

and MFC-generated S5000 CH TRU waste at AMWTP for emplacement in the WIPP facility. 

With this approval of the AK aspect of the characterization process, AMWTP-ITG (responsible 

since late 2011 for AMWTP’s CH TRU waste characterization program), may characterize 

physical and radiological contents of these two waste types using the equipment, processes and 

procedures that EPA approved during October 2006 baseline approval (see EPA Docket No A98-49: II-A4-66, October 3, 2006). AMWTP-ITG needs to confirm the AK using NDA and NDE

by generating BDRs for these waste types for EPA review before the subject waste is disposed of 

at the WIPP.
A-1

ATTACHMENT A

APPROVAL SUMMARY FOR ADVANCED MIXED WASTE TREATMENT PROJECT 

CONTACT-HANDLED WASTE CHARACTERIZATION PROGRAM

Approved Activity EPA Inspection Number, 

Approval Dates

EPA Docket Number

AMWTP CH Baseline Approval EPA-AMWTP-03.06-8

October 2006 A-98-49; II-A4-66

T1 Change – Addition of Four Hanford Legacy Debris 

Waste Streams to the BN510 Super-Compacted Debris 

Waste Stream

June 2010 A-98-49; II-A4-127

Unannounced Continued Compliance Inspection March 2011 A-98-49; II-A4-143
B-1

ATTACHMENT B

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION 

C1054S, Email from Roy P. Grant to Randall C. Morris, Re: Summary of Our Conversation 

Yesterday, March 28, 2012

C1056S, Email from Roy P. Grant to Randall C. Morris, Re: Another problem with the MFC 

Rad data, April 11, 2012

C1090S, CCP source document C013, Correspondence to Mr. E.M. King, Oak Ridge National 

Laboratory, Re: Radioactive Waste, i.e., non-recoverable material, being transferred from ANL 

to ORNL for storage and/or processing, L.A. Neimark, Materials Science Division, April 10, 

1974

C1091S, CCP source document AE-I-015, Sequence of events for camphor coating of UN 

powder, DL-208, May 22, 1987

C555S, Correspondence to Craig R. Tyler, Lockheed Martin Idaho Technologies Co., from D.S. 

Kirschner, Manager, Radiation Fire and Safety, Argonne National Laboratory-West, Re: ANL 

Transuranic Waste – Definition as Defense Waste, April 16, 1997

C557A, Correspondence to Monte V. Davis, INEEL Site Treatment Plan, BBWI Coordinator 

from R.P. Grant, NTD Environmental Programs, ANL-W, Re: Evaluation of ANL-W 

Transuranic (TRU) Waste Stream, Identification Number ANL-WCA-553, Listed in the Site 

Treatment Plan, May 22, 2001

C574S, Correspondence from R. Thuot, Manager, ANL-E Waste Management, to Mr. Dennis 

Wilkinson, RWMC/SWEP, Re: TRU Waste at Argonne National Laboratory-East, May 17, 

1990, February 18, 2012

C852A, Email to Roy Grant in response to an Email from Carolyn Abbott regarding HRA and 

CWA waste generation processes, March 12, 2010

D094A, AMWTP Discrepancy Report regarding ANL-E waste identified under content codes 

AE-110 and AE-120; AE-111 and AE-121, January 30, 2012

Document Change Request for RPT-TRUW-05, Revision 30, Advanced Mixed Waste Treatment 

Project, DCR-11950, provided to EPA on December 10, 2012

Document Change Request for RPT-TRUW-06, Revision 14, Advanced Mixed Waste Treatment 

Project, DCR-11919, provided to EPA on November 14, 2012

Document Change Request for RPT-TRUW-07, Revision 17, Advanced Mixed Waste Treatment 

Project, DCR-10866, provided to EPA on November 14, 2012

Document Change Request for RPT-TRUW-12, Revision 19, Advanced Mixed Waste Treatment 

Project, DCR-11951, provided to EPA on November 14, 2012
B-2

Document Change Request for RPT-TRUW-79, Revision 1, Advanced Mixed Waste Treatment 

Project, DCR-11897, provided to EPA on November 14, 2012

Document Change Request for RPT-TRUW-89, Revision 0, Advanced Mixed Waste Treatment 

Project, DCR-11917, provided to EPA on December 4, 2012

P024A, Content Code Assessments for INEL Contact-Handled Stored Transuranic Wastes, WMF1-82-021, October 1982

P1030A, BN510.1 Supercompacted Debris Waste Stream Profile Package, Revision 4, 

October 2, 2012

P1155A, Central Characterization Project Process Knowledge Summary Report for Argonne 

Contact-Handled TRU Waste from Facility Maintenance and Laboratory Operations, Waste 

Streams: AECHDM-PK and AECHHM-PK, CCP-PK-ANLE-001, August 10, 2010

P1379A, Central Characterization Project Acceptable Knowledge Summary Report for Idaho 

National Laboratory, Argonne Contact-Handled Transuranic Waste from Facility Maintenance 

and Laboratory Operations, Waste Streams: ID-AECHDM, ID-AECHHM, CCP-AK-INL-025, 

Revision 1, December 2011

P1380A, Central Characterization Project Acceptable Knowledge Summary Report for Argonne 

National Laboratory-East Contact-Handled TRU Waste, Facility Maintenance and Laboratory 

Operations, CCP-AK-ANLE-001, Revision 11, December 31, 2011

P1381A, Central Characterization Project Acceptable Knowledge Summary Report for Argonne 

Remote-Handled Debris Waste, Waste Stream: AERHDM, CCP-AK-ANLE-500, Revision 9, 

December 2011

P1395A, Facility Waste Descriptions: Argonne-West, draft, December 14, 1973

P1396S, Radioactive Waste Management at the EBR-II Site, Donald C. Hampson, Revision 0, 

April 17, 1969

P237A, Characterization of Wastes Used in the 1991 through 1993 SWEPP Certified Waste 

Sampling Program, Lockheed Idaho Technologies Company, INEEL/INT-98-01210, EDFRWMC-1043, April 7, 1999

P310A, EPA Hazardous Waste Codes Found in INEL Stored TRU Waste Content Codes, EG&G 

Idaho, Inc., EDF-RWMC-421, Revision 4, April 1, 1994

P312A, Characterization of Wastes Generated at Argonne National Laboratory-West with IDCs 

of 161, 162, and 163, C.B. Ransom, INEEL/INT-99-00081, EDF-RWMC-1048, Revision 0, 

April 7, 1999

P319A, Idaho National Engineering Laboratory Stored Transuranic Waste Characterization: 

Non-radiological Hazards Identification, T.L. Clements, Jr., WM-F1-81-015, September 1981
B-3

P365A, Waste Description Information for Transuranically-Contaminated Wastes Stored at the 

Idaho National Engineering Laboratory, B.D. Raivo, G.K. Becker, T.H. Smith and G.L. 

Anderson, INEL-95/0412, Revision 0, December 1, 1995

P567A, INEEL Stored Contact-Handled Transuranic Waste Volumes, Idaho National 

Engineering and Environmental Laboratory, EDF-2550, Revision 0, September 30, 2002

P675A, MFC TRU Waste Certification Program Plan, PLN-8300, Revision 0, October 27, 2008

P678S, Advanced Fuel Cycle Initiative (AFCI) Program Plan, DOE Office of Nuclear Energy, 

Science and Technology, May 1, 2005

P679A, The Defense Programs Origin of Transuranic Waste at Argonne National Laboratory 

West, H.F. McFarlane, ANL-NT-192, November 2001

P683S, Analytical Laboratory Procedure, Dissolution of Pu Metal, Argonne National 

Laboratory-West, W0630-0026-KP, May 22, 2001

P688S, Analytical Laboratory Procedure, Dissolution of SRM-B Eutectic Salt Reference 

Material, J. Berg and D.D. Standfield, Argonne National Laboratory-West, W0630-0102-KP, 

Revision 1, May 7, 2001 

P695A, Analytical Laboratory Administrative Procedure, Dissolution of Plutonium Metal 

Samples for Silicon Analysis, J. Berg and D.D. Standfield, Argonne National Laboratory-West, 

W0650-0062-KP, Revision 0, November 5, 2002

P696S, Analytical Laboratory Procedure, Dissolution of Plutonium Oxide Samples for Trace 

Metal Analysis, Argonne National Laboratory-West, W0650-0063-KP, Revision 1, March 31, 

2004 

P697S, Analytical Laboratory Procedure, Determination of Gallium in Plutonium Oxide by 

Inductively-Coupled-Plasma Mass Spectrometer, Argonne National Laboratory-West, W0650-

0064-KP, Revision 0, March 26, 2003 

P698S, Analytical Laboratory Procedure, Determination of Boron in Plutonium Oxide by 

Inductively-Coupled-Plasma Atomic Emission Spectrometry, D. Cummings and D.D. Standfield, 

Argonne National Laboratory-West, W0650-0065-KP, Revision 0, March 26, 2003 

P708A, Integrated Waste Tracking System Material and Waste Characterization Profile No. 

3527: Analytical Lab TRU Waste, profile date April 1, 1999, print date March 11, 2010

P710A, Integrated Waste Tracking System Material and Waste Characterization Profile No. 

3657P: Glovebox Debris from: Testing, Alpha, & Special Projects, Casting Labs, etc., profile 

date December 3, 2002, print date March 11, 2010

P716A, Integrated Waste Tracking System Material and Waste Characterization Profile No. 

5274N: Misc. Waste from Waste Form Testing, Alpha, & Special Projects Glovebox, etc., 

profile date March 9, 2007, print date March 31, 2010
B-4

P718A, Integrated Waste Tracking System Material and Waste Characterization Profile No. 

5185N: Casting Lab Pb Lined Gloves, profile date January 10, 2007, print date March 31, 2010

P727A, ANL-W Waste Handling Manual, Chapter 7.8, Hazardous Waste Accumulation Areas, 

WHM-96-01, October 19, 2004

P734A, Integrated Waste Tracking System Material and Waste Characterization Profile No. 

ANL503T: HEPA Filters Contaminated with Characteristic Waste and TRU, profile date 

February 18, 1998, print date March 31, 2010

P751A, Integrated Waste Tracking System Material and Waste Characterization Profile No. 

ANL505T.R1: Debris Contaminated with Characteristic Waste and MTRU, profile date 

February 18, 1998, print date April 5, 2010

P816A, Characterization of Mixed CH-TRU Waste for the WIPP Experimental Test Program 

Conducted at ANL-W, C.C. Dwight, G.C. McClellan, K.P. Guay, J.C. Courtney, and M.J. Duff, 

ANL-CP-74106, DE92 007399, 1992

P842A, Process Knowledge Summary Report for Materials and Fuels Complex Contact Handled 

Transuranic Debris Waste, INL/EXT-10-17600, April 2010

P848A, Integrated Waste Tracking System Material and Waste Characterization Profile No. 

3527.R1: Analytical Lab CH-TRU Waste, profile date September 29, 2009, print date 

March 31, 2010

P850A, Integrated Waste Tracking System Material Profile No. 5274N.R1: Misc. Waste from 

Waste Form Testing, Alpha, & Special Projects Glovebox, etc., profile date September 29, 2009, 

print date March 31, 2010

P862S, Weapons of Mass Destruction (WMD) website: Idaho National Laboratory, Materials & 

Fuels Complex, www.globalsecurity.org/wmd/facility/idaho_inel-facility-mfc.htm, 5-602010

P888A, Waste Characterization for INEL Remote-Handled/Special-Case Stored Transuranic 

Wastes, WM-PD-85-014, November 1, 1985

RPT-TRUW-05, Waste Matrix Code Reference Manual, Advanced Mixed Waste Treatment 

Project, Revision 30, September 26, 2012

RPT-TRUW-06, Acceptable Knowledge Baseline Document for AMWTP Waste, Revision 14, 

July 5, 2012, Revision 15, draft

RPT-TRUW-07, Determination of Radioisotopic Content in TRU Waste Based on Acceptable 

Knowledge, Advanced Mixed Waste Treatment Project, Revision 17, June 23, 2011, Revision

18a, draft

RPT-TRUW-12, AMWTP Waste Stream Designations, Advanced Mixed Waste Treatment 

Project, Revision 18, August 31, 2011, Revision 20, draft
B-5

RPT-TRUW-79, Acceptable Knowledge Document for Materials and Fuels Complex, Advanced 

Mixed Waste Treatment Project, Revision 1, September 20, 2012, Revision 2A, draft

RPT-TRUW-83, Acceptable Knowledge Summary for Supercompacted Debris Waste 

(BN510.1), Advanced Mixed Waste Treatment Project, Revision 3, September 17, 2012

RPT-TRUW-89, Acceptable Knowledge Baseline Document for Argonne National LaboratoryEast, Advanced Mixed Waste Treatment Project, Revision 0, May 8, 2012, Revision 1, draft

U005A, EDF-RWMC-563, Results of the SWEPP Certified Waste Sampling Program for 

FY-1991, August 1992

U127A, BBWI-Generated Drum Data, including Data from the Transuranic Waste Management 

Information System (TWMIS), date unknown

U236S, Integrated Waste Tracking System Material Profile No. 3521T: Laboratory Waste 

IDC-150, April 14, 2010

U237S, Integrated Waste Tracking System Material Profile No. 3531T: Laboratory Mixed Lead 

Waste IDC 150

U325S, AMWTP, ANL-E TWMIS, December 2011

U337A, MFC Rad Measurements, Randall C. Morris, Revision 0, November 20, 2012

U342S, CCP source document U3006, Radionuclide Data for Waste Streams ID-AECHDM and 

ID-AECHHM, Central Characterization Project, September 26, 2011