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 Aven ue, NW Washington, DC 20460

January 201 3i TABLE OF CONTENTS Section Page Abbreviations and Acronyms

................................ ................................ ................................ ......... ii 1.0 I ntroduction

................................ ................................ ................................ .......................... 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 Kno wledge 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 Impl emented 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 Evaluationii ABBREVIATIONS AND AC RONYMS
ACL Analytical Chemistry Laboratory AK acceptable knowledge AL /CL Analytical Laboratory /Casting Laboratory AKSR AK summary repo rt 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 Fl ux 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 IF R Integral Fast Reactor IWTS Integrated Waste Tracking System ITG Idaho Treatment Group, LLC LMFBR Liquid Metal Fast Breeder Reactoriii MFC Materials and Fuels Complex nCi/g nanocuries per gram NDA nondestructive assay NDE nondestructive examination NWPA Nucl ear 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 s ummary c ategory g roup 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 w aste s tream p rofile f orm1 1.0 I NTRODUCTION This report supports the U.S. Environmental Protection Agency ’s (EPA ’s ) approval of the proposed Tier 1 (T1) changes to the EPA

- a pproved 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

- ha ndled (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 basel ine 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 a n AK T1 change that req uired 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

- g enerated 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 pr ocesses are not affected by inclusion of ANLE

- and MFC

- generated waste and are not included in the scope of this evaluation. T his review also did not address AK procedural adequacy , AMWTP procedural compliance , or drum or data traceability , as these elemen ts 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 AM WTP later this winter

.

1 ANLE was initially designated ANL

- E (ANL

- East) to distinguish it from ANL

- West (ANLW). In 2009, ANLW wa s 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 through out the report to clearly differentiate ANLE information from historical ANLW information.2 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

- approve d program

. EPA ’s evaluation required certain changes to several relevant AK documents , and AMWTP provided Document Change Requests (DCRs) for the se revised documents to EPA before the conclusion of this T1 evaluation. EPA expects formal revisions of the fo llowing documents to be completed by March 31, 2013 , and submitted as part of AMWTP’s fiscal year 2013 s econd q uarter 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, Re vision 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 designation s: 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 subst antive 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 manag ed 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 reserv ed 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 equipmen t, processes and procedures that EPA approved during October 2006 baseline approval (see EPA Docket No A

98

- 49: II

- A4

- 66, October 3, 2006). AMWTP

- ITG needs to confi r m the AK using NDA and NDE by generat ing batch data reports (BDR) for these waste types for EPA review before the subject waste is disposed of at the WIPP

. This report serv es 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).3 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 201 3 ) 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 st ream Notification to EPA upon completion of or substantive modification** to:

• S ite procedures requiring CBFO approval

• Load management status of approved waste streams

• All final WSPF s with related attachments (e.g., CIS), including updates or additions to waste streams within approved SCG s and summaries of radiological data for those containers included on the CIS drum list

• AK a ccuracy r eports ( annually , at a minimum )

• All n ew 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 Non d estructive 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:
• S ite procedures requiring CBFO a pproval
• S oftware for approved equipment
• O perating ranges upon CBFO approval Real

- Time Radiography None Notification to EPA upon substantive modification** to:
• S ite procedures requiring CBFO approval
• New equipment or physical modifications to approved e quipment *** Visual Examination and Visual Examination Technique Changes in vendor performing VE and/or VET Notification to EPA upon : • Substantive modification** to s ite procedures requiring CBFO approval
• Addition of new waste category
• Addition of new proc edure or site equipment identifier WIPP Waste Data System Changes to WDS algorithms specific to load management Notification to EPA upon substantive modification** to:
• S ite procedures requiring CBFO approval
• Load management status of approved waste strea ms 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 t o a change with the potential to impact AMWTP’ s CH waste characterization processes or documentation thereof, excluding changes that are solely related to e nvironment, s afety and h ealth; nuclear safety; or the Resource Conservation and Recovery Act , or tha t are editorial in na ture 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 affec t data relative to waste isolation and exclude minor changes, such as the addition of safety

- related equipment.4 2.0 PURPOSE OF TIER 1 EV ALUATION S 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 s ite’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 fo r 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 usi ng 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 PU RPOSE 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 wa ste to AMWTP’s baseline approval as a T1 change. Although they ini tially 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 i tem 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 cit ed 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 8822 1

- 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 PE RSONNEL 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 func tion. 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. EP A 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, I TG

- 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 por tions 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).6 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 activit ies, 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 progr ams 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 De velopment 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 Laborato ry 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 trea tment, repackag ing operations and storage. During repackaging by WMO, wastes from the primary generation locations mentioned above were routi nely 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 test ing 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 cu rrent 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 initiativ es. The p rocessing and characterizati on 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 and7 decontamination of gloveboxes a nd 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 glov eboxes, hot cells and laboratory hoods ( References C852A, C1054S, P312A, P675A, P678 S , P679A, P683S, P688S, P695A, P696S, P697S, P698S, P708A, P716A, P727A and P862S ):

• Building 752

– Laboratory and office building containing the Analytical Laboratory/Cast ing 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 an d 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 f acilities [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, U236 S 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 documen tation 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 C H waste characterization:

• Waste identification and de scrip tion , including radiological and physic al 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 sh ipment to the WIPP facility.8 • Verification that the subject waste is of defense ori gin and is not high

- level waste (HLW) or spent nuclear fuel (SNF).

• Load m anagement

. 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 cha racterizati on 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 f or 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, segre gation 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 weapons

grade, fuel

- grade, reactor

- grade and higher enrichments of plutoni um (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 activ ity are expected to be 241 Pu and 239 Pu for S5000 waste and 239 Pu and 241 Pu for S3000 waste (Reference P1379A). ANLE labeled each container 3 with a content code before shipping the containers to INL RWMC. INL later applied item description codes (IDCs) to each container based on the ANLE

assigned 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 his torical 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 La boratory ( 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 i nformation, 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, AE

111 and AE

- 121 were historically managed by ANLE as the same content code (102) and drums of all three types primarily contain v ermiculite or Oil

- Dri® and absorbed liquids ; and (3) IDC AE

- 105 also primarily c ontains vermiculite and the same absorbed liquids that were combined and poured into the AE

- 1 02, 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 characteri ze 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 a re T2 changes (see Table 1). Heterogeneous Debris ( S 5 000 ) 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 d ebris 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 requir ements 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 b e performed in the future if direct shipment of ANLE S5000 waste is deemed necessa ry. Notifications of the availability of all AKSRs and WSPFs , including for any direct

- shipped waste10 streams are T2 changes (see Table 1). See Item (4) for additional requirements related to payload management of direct

- shipped waste. B. Idaho National Labor atory Materials and Fuels Complex
- Generated Waste MFC

- generated waste was and is produced by a host of experimental an d support activities. Waste is bagged out of each area on a campaign basis, and MFC then generates its own Integrated Waste Tracking Syst em (IWTS) profiles that group waste based on its physical and chemical cha racteristics , waste generator local e , or other waste descriptors ( References P7 34A, P751A, P848A, P710A, P718A and P850A). Although the IWTS profiles do not directly correspond to ID Cs, 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. T he waste was not co m mingled between generator locations, so determination of drum radiological composition requires review of IWTS m aterial and w aste c haracterization profiles, as well as review of individual IWTS container

- specific data. AMWTP did not inc lude 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 a nticipated concentration range of radionuclides in waste from B u ildings 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 239 Pu or other isotopes, even though weapons - grade materi al was managed in all buildings

. AMWTP concluded that the table and information in the MFC summary AK report w ere 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 h eterogeneous d ebris and WIPP c andidate c haracterization d ebris 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 americiu m - 241 and 241 Pu for all SCG S5000 MFC

generated waste (References C1056S, P842A and U337A). T he 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

- TRUW

05 , Revision 30

. As with ANLE

- generated waste, MFC

- generated waste containe rs 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

- T RUW

- 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 suggests11 that AMWTP is consi dering 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 s econd debris waste stream. AMWTP has not yet developed an adequate case for waste stream determination s . However, waste stream determinations are not required to integrate MFC waste into supercompacted Waste Stream BN510.1; only IDC determination is requir ed. 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 s upercompact 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 shipm ent of MFC

- generated S5000 waste. Notifications of the availability of all AKSRs and WSPFs , includin g for any direct

shipped 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 ANL E

- 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 d evelopment 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 r eport), and RPT

TRUW

- 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 ot her 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).

• “ D etermination 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,” MP

TRUW

- 8.13, Revision 24 , Idaho Falls, Idaho , December 12, 2011.12 • “Acceptable Knowledge Summary for Supercompacted Debris Waste (BN510.1)” (RPT

TRUW

- 83, Revision 3).
T hese reports plus their supporting source documents contain the information required by the WIPP w aste a cceptance c riteria (WAC) 5 and WIPP Waste Analysis Plan. 6 Except for RPT

TRUW

- 83, AMWTP revised each document to address ANLE

- and M FC

- 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 lo w - 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 (R PT

- TRUW

- 79, Revision 1) does not include this information. EPA reviewed RPT

- TRUW

- 05, Revision 30, and found that the report reference d several source documents for the physical waste descriptions ; in some cases, it also reference d inappropriate source docu ments. For example, the description for IDC AE

- 111 references “Waste Characterization for INEL [Idaho National Engineering Laboratory] Remote

- Handled/Special

Case 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 RPT

TRUW

- 05 that co vers these changes. As revised, RPT

- TRUW

- 05 adequately present s the physical characteristics of each IDC in the ANL E

- 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 re vision 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 W AC. Draft RPT

- TRUW

- 07, Revision 18a, adequately presents summary radiological data for ANLE

and 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 , Rev ision 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 descript ions of AMWTP

- approved waste streams that originated from EPA

- approved waste sites but are shipped to WIPP as AMWTP waste streams. RPT

TRUW

- 12 is typically used to identify the waste’s hazardous constituents by IDC. RPT

- TRUW

12, Revision 18 , did not addres s ANLE

- or MFC

- generated waste. AMWTP provided draft RPT

TRUW

- 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 w ill look for the S3000 information in future revisions of RPT

TRUW

- 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 1 9 , to incorporate the DCR and to be com pleted 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 ref erred 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 n eeds 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 reque sts. 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 t o 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

- generat ed 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 i nformation 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

- TRUW

12 adequately addresses ANLE

- and MFC

- generated S5000 CH waste.14 radiolo gical 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 rep ort (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 c omposition 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 w astes 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 energ y defense activities listed in section 10101(3) of the “ Nuclear Waste Policy Act of 1982 ” (NWPA)

. 8 The WIPP Land Withdrawal Act 9 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 withd rawn 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 a nd 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. Ar gonne National Laboratory East
- Generated Waste ANLE laboratories supported many defense

- related activities through fuel examinations, including m aterials from the Liquid Metal Fast Breeder Reactor (LMFBR) Program, fuels irradiated in EBR

- II and the Fast F lux Test Facility (FFTF), samples for the Reduced Enrichment for Research and Test Reactors (RERTR) Program, specimens of Integral Fast Reactor (IFR) Pu

uranium

- zirconium metallic alloy s , and specimens from the Knolls Atomic Power Laboratory (hereafter ref erred 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 variet y 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 parti cipated in many non

defense

- 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 . T herefore, 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 swarf 10 and fines, were stored separately as accountable materials 11 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 t he 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 th e AL/CL, FMF, and HRA/WCA are classified as defense

- related waste .” The MFC rep ort c ite s source documents C555 S and P679 A in support of this statement. However, Reference P679 A 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 C555 S addresses the F M F (Building 704) only and was developed to support remote

- handled waste defense determination

. Because M FC waste was not com m ingled between buildings , overall waste co m mingling 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

- re lated activities, better references for defense activities associated with the HRA and WCA, and additional support for waste co m mingling at the generator source. EPA expects AMWTP to evaluate the contents of each IDC accepted for supercompaction , as well a s 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 contai n material “ incidental to reprocessing .” The report state s 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 SN F is reprocessed, HLW may be generated

. T he MFC summary AK report also states that SNF was reprocessed to extract P u . EPA pointed out that the explanation offered

10 “ Swarf ” is material produced by a cutting or gri nding 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 M FC 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 ID C 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 managemen t 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 “ t he outermost container [( e.g., drum, Standard Large B ox 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, TRUPACT

III, HalfPACT, RH

- TRU 72

- B, or 10

- 160B) for transport. ” The AKSR for e ach waste stream select ed 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. E ach container selected for payload management must also contain at least one TRU isotope whose activity excee ds 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 t he payload container. Waste that is direct shipped from AMWTP may be payload mana ged 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 RPT

TRUW

- 07, Revision 18a, and the a ccompanying DCR, which adequately address WIPP WAC payload management requirements for ANLE

- and MFC

- generated waste (Reference U127A). 7.0 FINDINGS AND CONCERN S The EPA inspection team did not identify any findings or concerns during th ese T1 evaluation s a nd there are no open issues relative to th ese T1 evaluation s . 8.0 CONCLUSION S 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 th e substanti ve T1 and T217 cha nges 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 Th is T1 change consisted of the use of AK to characterize ANLE

- gene rated 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 equipmen t, processes and procedures that EPA approved during October 2006 baseline approval (see EPA Docket No A

98

- 49: II

- A4

- 66, October 3, 2006). AMWTP

- ITG needs to confi r m the AK using NDA and NDE by generat ing BDR s 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 Date s EPA Docket Number

AMWTP C H Baseline Ap proval 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

- 143B

- 1 ATTACHMENT B LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION C1054S, Email from Roy P. Grant to Randall C. Morris, R e: Summary of Our Conversation Yesterday, March 28, 2012 C1056S, Email from Roy P. Grant to Randall C. Mor ris, 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 , R e: Radioactive Waste, i.e., non

- recoverable material, being transferred from ANL to ORNL for s torage 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 Idah o 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 W aste Management, to Mr. Dennis Wilkinson, RWMC/SWEP, R e: 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

- 119 50, 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 Wast e 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, 2012B

- 2 Document Change Request for RPT

- TRUW

- 79, Revi sion 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, WM

F1

- 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 Re port for Argonne Contact

- Handled TRU Waste f rom 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 f or 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 f or 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, R evision 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, EDF

RWMC

- 1043, April 7, 1999 P310A, EPA Hazardous Waste Codes Found i n INEL Stored TRU Waste Content Codes, EG&G Idaho, Inc., EDF

- RWMC

- 421, Rev ision 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 1981B

- 3 P365A, Waste Description Information for Transurani cally

- 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 E ngineering and Environmental Laboratory, EDF

- 2550, Rev ision 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 Energ y, 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, Analyt ical 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, Dissol ution 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 S pectrometer, 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. Sta ndfield, 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, 2 010 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 Wast e 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, 2010B

- 4 P718A, Integrated Waste Tracking System Material a nd 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

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