DOCKET NO: A-98-49; II-A4-180

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT:

ADDITION OF CONTACT-HANDLED TRANS URANIC WASTE TO THE ADVANCED MIXED WASTE TREATMENT PR OJECT APPROVED PROGRAM: IDAHO NATIONAL LABORATORY SUMMARY CATEGORY GROUPS S3000 AND S5000 WASTE

U.S. Environmental Protection Agency Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

February 2014ii TABLE OF CONTENTS

Section Page Abbreviations and Acronyms .................................................................................................... .... iii

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

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

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

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

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

6.0 Technical Evaluation of Acceptable Knowledge .................................................................6

6.1 Waste-Generating Activities ....................................................................................6 6.2 Waste Characterization Element Description ..........................................................6 6.3 Technical Evaluation ...............................................................................................7

7.0 Findings and Concerns .......................................................................................................12

8.0 Conclusions ................................................................................................................... .....12

LIST OF TABLES

Table 1. Tiering of CH TRU Waste Characterization Processes Implemented by AMWTP ........ 3
Table 2. Tier 1 Evaluation Personnel ......................................................................................... .... 5

ATTACHMENTS

Attachment A: Approval Summary for A dvanced Mixed Waste Treatment Project Contact-Handled Waste Ch aracterization Program Attachment B: List of Documents C ited by EPA during the T1 Evaluationiii ABBREVIATIONS AND ACRONYMS

AK acceptable knowledge

AKD AK document AKSR AK summary report AMWTP Advanced Mixed Waste Treatment Project ANLE Argonne National Laboratory-East ARA Auxiliary Reactor Area (f ormerly Army Reactor Area)

CBFO Carlsbad Field Office

CFA Central Facilities Area CFR Code of Federal Regulations

CH contact-handled CIS characterization information summary DOE U.S. Department of Energy EPA U.S. Environmental Protection Agency HLW high-level waste IA ARA generator code IC INTEC or ICPP generator code ICPP Idaho Chemical Processing Plant (now INTEC) IDC item description code IF CFA generator code INL Idaho National Laboratory INEL Idaho National Engineering Laboratory INEEL Idaho National Engineeri ng and Environmental Laboratory INTEC Idaho Nuclear Technology and E ngineering Center (formerly ICPP) IR TRA generator code IT TAN generator code ITG Idaho Treatment Group, LLC IW RWMC generator code IWTS Integrated Waste Tracking System LWA Waste Isolation Pilot Plant Land Withdrawal Act, as amended

m 3 cubic meter MFC Materials and Fuels Complexiv NDA nondestructive assay

NDE nondestructive examination NRF Naval Reactors Facility NWPA Nuclear Waste Policy Act of 1982 PBF Power Burst Facility PCB polychlorinated biphenyl Pu plutonium PVC polyvinyl chloride RFP Rocky Flats Plant RWMC Radioactive Waste Management Complex RWMIS Radioactive Waste Management Information System SCG summary category group SDA Subsurface Disposal Area SNF spent nuclear fuel

T1 Tier 1

T2 Tier 2

TAN Test Area North

TRA Test Reactor Area

TRU transuranic TSA Transuranic Storage Area WAP waste analysis plan

WIPP Waste Isolation Pilot Plant

WMC waste matrix code WMP waste material parameter WSPF waste stream profile form WTS Waste Tracking System (AMWTP)1 1.0 INTRODUCTION

This report supports the U.S. Environmental Protection Agency ’s (EPA’s) approval of the proposed Tier 1 (T1) change to the EPA-approved transurani c (TRU) waste characterization program at the U.S. Department of Energy’s ( DOE’s) Advanced Mixed Waste Treatment Project (AMWTP) at the Idaho National Laboratory (INL). This approval is for contact-handled (CH) debris [Summary Category Group (SCG) S5000 ] and homogenous solid waste (SCG S3000). Using the EPA-approved waste char acterization processes discusse d in this report, AMWTP can characterize INL-generated CH legacy waste [sto red at the INL Radioactive Waste Management Complex (RWMC) Transuranic Storage Area (TSA)] and newly-generated wa ste for disposal at the Waste Isolation Pilot Plant (WIPP).

In accordance with Title 40 of th e 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, 20 06. EPA’s October 2006 baseline approval applied to (1) CH retrievabl y-stored SCG S3000 and SCG S5000 waste and (2) newly-generated SCG S5000 CH waste. The AMWTP baseline fina l inspection report (see EPA Docket No. A98-49; II-A4-66, dated October 2006) documents EP A’s approval of the a cceptable knowledge (AK) and load management processes a nd several nondestructive assay (NDA) and nondestructive examination (NDE) systems for use in characterizing CH retrievably stored SCG S3000 and SCG S5000 waste and newly generate d SCG S5000 waste. The baseline report defined inclusion of wastes from sources ot her than Mound Site, Rocky Flats Environmental Technology Site [or the Rocky Flats Plant (RFP)], Battelle Columbus Laboratories, and Bettis Atomic Power Laboratory (hereafter referred to as “Bettis”) as an AK T1 change that required EPA approval before implementation. Wastes from the DOE sites listed above were specifically evaluated as part of the baseline inspecti on. Attachment A provide s a table listing EPA’s approvals of the AMWTP CH TRU waste characterization program.

On August 15, 2013, the Carlsbad Field Office (CBF O) requested EPA approval of a T1 change to include INL-generated waste. Consistent with the streamlined approach to EPA’s evaluation and decision process described in section 2 of this report, EP A limited the scope of this T1 evaluation to the AK process for genera ting RPT-TRUW-92, Revision 0, “Acceptable Knowledge Document for Select Idaho National La boratory Facilities” [hereafter referred to as the “INL AK document (AKD)” or “INL AKD”)]. The review was necessary to determine whether AMWTP’s AK documentation and records adequately include and cross-reference available historical waste genera tion and disposal records to s upport inclusion of INL-generated CH waste.

EPA did not identify any findings or concerns during this review . Based on this evaluation, there is one substantive change to th e AK T1 designations: INL-generated waste has been added to the list of approved waste sources. There are no substantive changes to the AK Tier 2 (T2) designations. Table 1 shows the substantive T1 change in bold text. T1 and T2 changes that were initiated during the baseline approval and subs equent T1 approvals remain in effect. The language in Table 1 regarding AK documentati on applies to all AMWTP waste streams, including load-managed and di rect-shipped waste streams.2 Based on this evaluation, EPA approves the addition of INL-generated SCG S3000 and SCG S5000 CH waste to AMWTP’s EPA-approved pr ogram. This approval allows AMWTP to characterize the physical and radiol ogical contents of containers of the legacy INL-generated SCG S3000 and SCG S5000 CH waste stored at the RWMC TSA and newly-generated INL SCG S3000 and SCG S5000 CH waste using the ch aracterization equipment, processes and procedures EPA approved as part of the AMWT P baseline approval (see EPA Docket No A-98- 49; II-A4-66, October 3, 2006). AMWTP must confirm the AK using the EPA-approved NDA and NDE processes and procedures. EPA may re view a sample of these NDA and NDE batch data reports during the next c ontinued compliance inspection.

This report serves as EPA’s public notification of the approval of this T1 change. This information will be provided through the EPA we bsite and by sending emails to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3).3Table 1. Tiering of CH TRU Waste Characterization Processes Implemented by AMWTP(Based on March 28–30 and April 11–13, 2006, Baseline Inspectionand Subsequent T1 Evaluations, Updated February 2014)Process ElementsAMWTP CH Waste Characterization Processes – T1 ChangesAMWTP CH Waste Characterization Processes – T2 Changes*Acceptable Knowledge,including LoadManagementAny new waste categoryAny waste from sources other than the Mound Site; Rocky FlatsEnvironmental Technology Site; Battelle Columbus Laboratories;Bettis Atomic Power Laboratory; Argonne NationalLaboratory-East;and Idaho National Laboratory, including theMaterials and Fuel Complex and pre-1980 INL-exhumed SubsurfaceDisposal Area wasteLoad management of any new or unapproved waste streamNotification to EPA upon completion of or substantive modification** to:Implementation of procedures and related documentation that formalizeNDA-AK communication requirementsAK accuracy reports (annually, at a minimum)All final WSPFs with related attachments (e.g., CIS), including updates oradditions to waste streams within approved SCGs and summaries ofradiological data for those containers included on the CIS drum listNew and revised AKSRs and generator-site-specific AK documents (e.g.,RPT-TRUW-79, RPT-TRUW-89, RPT-TRUW-06, RPT-TRUW-83)Item description code inclusion memorandaThe load management statusof approved waste streamsSite procedures requiring CBFO approvalAny waste identified outside of the waste profiles included in the 2002Transuranic Waste Baseline Inventory Report, when applicableRPT-TRUW-05, RPT-TRUW-07 and RPT-TRUW-12Nondestructive Assay New equipment or substantive physical modifications to approvedequipment**Extension of or changes to the approved calibration range forapproved equipmentNotification to EPA upon substantive modification** to:Site procedures requiring CBFO approvalSoftware for approved equipmentOperating ranges upon CBFO approvalReal-Time Radiography None Notification to EPA upon:Substantive modification** to site procedures requiring CBFO approvalNew equipment or substantive physical modifications** to approvedequipmentVisual Examination andVisual ExaminationTechniqueChanges in the vendor performing visual examination or visualexamination techniqueNotification to EPA upon:Substantive modification** to site procedures requiring CBFO approvalAddition of a new waste categoryAddition of a new procedure or site equipment identifierWIPP Waste Data System Changes to WasteData System algorithms specific to loadmanagementNotification to EPA upon substantive modification** to:Site procedures requiring CBFO approvalThe load management statusof approved waste streamsNew T1s, T2s and significant modifications to existing T1s or T2s are inboldtext; 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 affect AMWTP’s CH waste characterization processes or documentation of them, excluding changes thatare solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act; or that are editorial in nature or are required toaddress administrative concerns. EPA may request copies of new references that DOE adds during a document revision.4 2.0 PURPOSE AND SCOPE OF TIER 1 EVALUATIONS

Certain changes to the waste characterization act ivities from the date of the site’s baseline inspection must be reported to and, if a pplicable, approved by EPA according to the tiering requirements set forth in 40 CFR 194.8 and inco rporated 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 perf orm a single baseline inspection of a TRU waste generator site’s waste characteri zation program. The purpose of EPA’s baseline inspection is to approve the site’s waste char acterization program, based on the demonstration that the program’s components, with applicable conditions and limitations, can adequately characterize TRU wastes and comply with the re gulatory requirements imposed on TRU wastes destined for disposal at the WIPP.

Following EPA’s baseline approval, EPA is author ized to evaluate and approve changes, if necessary, to the site’s approved waste char acterization program by conducting additional inspections under the authorit y 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 in spection reports and subsequent T1 evaluation reports. When evaluating proposed T1 changes fo r approval, EPA may conduct a site inspection to observe 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.

In November 2012, DOE, DOE contractor staff a nd EPA and EPA contractor staff discussed DOE’s TRU site cleanup goals through 2016 and ways to im prove EPA’s evaluation and decision process to support DOE sites’ state-ma ndated cleanup needs. As a result of this discussion, EPA finalized a streamlined evaluati on and decision process that includes an EPA annual continued compliance inspection at each active, EPA-approved TRU waste site. The annual inspections will cover the common elements of waste charac terization processes that are not expected to significantly vary on a waste stream or T1 basis. Examples of the common characterization elements are pe rsonnel training, procedures an d equipment capabilities. EPA will evaluate these elements during T1 change ev aluations or in conjunction with the quarterly T2 change reports as necessary to ensure that EPA’s waste characterizati on approvals reflect any significant changes made to DOE’s waste characterization program.

This streamlined approach allows EPA to c onsider the results of continued compliance inspections when setting the scope and evalua ting site-specific T1 changes. EPA conducted a continued compliance inspection of AMWT P in October 2012 and February 2013, and concluded in April 2013 (see EPA Docket No. A-98-49; II-A4-173) that AMWTP continues to adequately implement the CH TRU waste characte rization processes, pro cedures and equipment at AMWTP that EPA approved in the October 2006 baseline approva l and in subsequent tiering changes listed in Attachment A.5 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 SCG S5000 INL-gene rated CH TRU waste to AMWTP’s baseline approval as a T1 change. EPA’s approval of INL-gene rated SCG S3000 and SCG S5000 waste for characterization for emplacement at the 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).

DOE documents that EPA reviewed for this eval uation are cited in diffe rent sections throughout the report and are listed in Attachment B. A ny of these documents can be requested from the following address:

Manager, National TRU Program Carlsbad Field Office U.S. Department of Energy P.O. Box 3090 Carlsbad, NM 88221-3090

4.0 SCOPE OF THIS TIER 1 EVALUATION

The scope of this T1 evaluation was the addi tion of SCG S3000 and SCG S5000 INL-generated CH waste to the AMWTP baseline approval as a T1 change. EPA limited the scope of this review to the AKD generation process to dete rmine whether AMWTP’s INL AKD and records are sufficient to support inclusion of the INL- generated SCG S3000 and SCG S5000 waste in the approved program. This review did not addr ess AK, NDA or NDE procedural adequacy; AMWTP procedural compliance; or NDA and ND E equipment because EPA evaluated these elements during its continued compliance ev aluation of AMWTP on October 30–November 1, 2012, and February 26, 2013 (EPA Dock et No. A-98-49; II-A4-173).

5.0 TIER 1 EVALUATION PERSONNEL

EPA and its support personnel communicated with AMWTP personnel by email. Table 2 lists the EPA evaluation team members and the AMWT P personnel contacted, with their affiliations and functions.

Table 2. Tier 1 Evaluation Personnel

Name Affiliation & Function Rajani Joglekar Lead Inspector, EPA Ed Feltcorn Inspector, EPA Kira Darlow Technical Evaluato r – Acceptable Knowledge, SC&A Eric Schweinsberg Site Project Manager, AMWTP-ITG George Byram TRU Programs Manager, AMWTP-ITG6 6.0 TECHNICAL EVALUATION OF ACCEPTABLE KNOWLEDGE

6.1 Waste-Generating Activities

INL has had several missions over the years, including, but not limited to, waste operations, nuclear reactor research and deve lopment, and testing and operation of nuclear reactors. Various INL facilities have supported programs involved with energy development, aircraft propulsion, naval propulsion, fast breeder reac tor development, light-water sa fety tests, organic moderator and coolant development, materials testing, space reactor development and environmental waste treatment and disposal (Reference P1942S).

The RWMC includes the Subsurface Disposal Ar ea (SDA), the TSA and the Administrative and Operational Facilities Area. In 1952–1970, TRU wastes were buried at the SDA. Waste from the SDA is not included in the INL AKD and is not included in this EPA approval.

The INL-generated legacy waste discussed in this report was generated at various INL facilities and sent to the RWMC TSA for storage on asphalt pads from 1970 to 2008. The RWMC TSA later became the AMWTP TSA and is referred to in this report as “the TSA” (References C1283A, P755A, P1425A, P1426A, P1847S and P1942S). INL facilities that are known to have contributed waste to the TSA are the Central Facilities Area (CFA ), the Auxiliary Reactor Area [(ARA), formerly the Army Reactor Area], the Na val Reactors Facility (NRF), the Test Area North (TAN), the Test Reactor Area [(TRA), cu rrently known as the Advanced Test Reactor Complex], the Power Burst Facility (PBF), the RWMC (excluding waste pr eviously disposed of within the INL SDA) and the Idaho Chemical Pr ocessing Plant [(ICPP), currently known as the Idaho Nuclear Technology and Engineering Ce nter (INTEC)] (References P1426A, P1847S, P1942S, P1955S, P1956S and U329S).

INL CH waste generated at some of the same INL facilities from 2008 to 2011 is also discussed in the INL AKD and included in this T1 eval uation (References P891A and U426S). AMWTP’s procedures require AMWTP to manage receipt of the legacy and newly-generated INL wastes separately. EPA does not distinguish between th e two populations, and this approval applies to both legacy and newly-generated INL CH waste.

6.2 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:

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

 Waste identification and descri ption, including radi ological and physical characteristics.

 Verification that the subject wa ste is of defense origin and is not high-level waste (HLW) or spent nuclear fuel (SNF).7 6.3 Technical Evaluation

(1) EPA assessed the acceptable knowledge repor ts and related documentation and found them to be adequate.

AMWTP prepares multiple documents that togeth er summarize the available information for INL-generated CH TRU wast e. AMWTP’s AK characterization procedure MP-TRUW-8.13, Revision 24, 1 states that the characterization process begins with developm ent of generator-sitespecific AKDs. For this T1 request, AMWTP prep ared the INL AKD. This document is very general and includes data from th e entire INL, not just the faci lities that are known to have contributed TRU CH waste to the TSA.

According to procedure MP-TRUW-8.13, informati on from the generator-site-specific AKD is then used to update other AM WTP summary reports. AMWTP provided the following reports to EPA as evidence of this process:

 RPT-TRUW-05, Revision 33, “Waste Matrix Code Reference Manual,” October 29, 2013.

 RPT-TRUW-06, Revision 15, “Acceptable Kn owledge Document for AMWTP Waste,” October 23, 2013.

 RPT-TRUW-07, Revision 19, “Determination of Radioisotopic Content in TRU Waste Based on Acceptable Knowledge,” November 5, 2013.

 RPT-TRUW-12, Revision 22, “AMWTP Waste Stream Designations,” November 21, 2013.

 RPT-TRUW-83, Revision 7, “Acceptable K nowledge Summary for Supercompacted Debris Waste,” November 27, 2013.

These reports and their supporting source documen ts contain the information required by the WIPP waste analysis plan (WAP) 2 and WIPP waste acceptance criteria. 3 They are living documents that are revised regularly to keep up with production needs. AMWTP has not fully revised all of these documents to address th e INL-generated waste because the AK procedure (MP-TRUW-8.13) does not allow for such revi sion until after EPA appr oves the INL AKD. EPA evaluated AMWTP’s process for updating th ese documents during the 2012–2013 continued compliance inspection and during subsequent T1 evaluations and found the process to be acceptable. Therefore, as part of this T1 eval uation, EPA reviewed only the versions of these reports listed above (i.e., the cu rrent approved revisions), not any new revisions that might be in

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

2 New Mexico Environment Departme nt, “Waste Isolation Pilot Plan t Hazardous Waste Facility Permit, Waste Analysis Plan,” Santa Fe , New Mexico, June 29, 2010.

3 DOE CBFO, “Transuranic Waste A cceptance Criteria for the Waste Isolation Pilot Plant,” DOE/WIPP02-3122, Revision 7.2, Carlsbad, New Mexico, June 13, 2011.8 draft pending approval of the INL AKD. EPA will continue to periodica lly review the current versions of these reports to ensure ad equate document preparation and revision.

The waste matrix code (WMC) reference manual, RPT-TRUW-05, contains detailed information about the physical characteristics of all wast es handled by AMWTP, including low-level waste, listed by generator site item description code (IDC) and WMC. Revision 33 of RPT-TRUW-05 includes information for all of the INL-wide ID Cs identified in the INL AKD and also includes revisions that AMWTP committed to making during previous T1 evaluations. EPA found that RPT-TRUW-05, Revision 33, does not identify all of the generator-specific IDC alternatives that are included in the INL AKD and does include on e INL IDC that is not addressed in the INL AKD. AMWTP stated that these differences occurred because additional information was determined after publication of the INL AKD in July 2013 and before publication of RPTTRUW-05, Revision 33 in October 2013. This is an example of AMWTP’s efforts to continually improve and expand upon the AK available. EPA will evaluate revisions of both the INL AKD and RPT-TRUW-05 during a future inspection to verify that the information available for specific IDCs is updated in both documents prior to waste characterization. Notification to EPA upon the availability of a revised RPT-TRUW-05 c ontinues to be a T2 change (see Table 1).

RPT-TRUW-07 presents radiological informati on for EPA-approved offsite waste generators (e.g., RFP, Mound Site, Battelle Columbus Labor atories, Bettis, th e Hanford Site) and AMWTP’s supercompacted and newly generated ( not supercompacted) wastes. Chapters 10 and 11 and appendices H and I of Revision 19 of RPT-TRUW-07 address pre-1980 INL-exhumed SDA waste and LANL debris wast e and other revisions. These are the revisions EPA expected to see based on previous T1 evaluations. RP T-TRUW-07, Revision 19, does not include any information specific to the INL-generated waste. This is acceptable at this stage in the characterization process. Notifi cation to EPA upon the availabili ty of a revised RPT-TRUW-07 remains a T2 change (see Table 1).

RPT-TRUW-12 (1) documents all TRU IDCs that AMWTP handles, (2) identifies chemical constituents and (3) documents hazardous wast e number assignments for TRU IDCs that AMWTP characterizes and certifi es. Revision 22 of RPT-TRUW- 12 includes some of the INL IDCs listed in the INL AKD; AMWTP will revi se RPT-TRUW-12 again after EPA approves INL-generated waste for inclusion in the AMWT P waste characterizati on program. Notification to EPA upon the availability of a revised RPT-TR UW-12 continues to be a T2 change (see Table 1).

RPT-TRUW-06 (the AMWTP AKD) presents information about all AMWTP-generated waste, including supercompacted Wast e Stream BN510.3. RPT-TRUW-83 (the supercompacted waste stream AKSR) includes information about all feed material inputs to th e supercompacted waste stream. AMWTP has substantially revised RPT- TRUW-06 and RPT-TRUW-83 since EPA’s last continued compliance inspection of AMWTP. A full review of the adequacy of these two reports is outside the scope of this T1 evaluation and wi ll be included in the next continued compliance inspection. EPA examined Revision 15 of RPT- TRUW-06 and Revision 7 of RPT-TRUW-83 to ensure that the proposed T1 INL waste fits within the definitio n of the supercompacted waste stream. Notification to EPA upon the availabil ity of a revised RPT-TRUW-06 or RPT-TRUW83 remains a T2 change (see Table 1).9 The waste stream definition and documentation of physical and radiological components are discussed further in Item (2) below. The defense origin of the waste and the absence of SNF and HLW are discussed further in Item (3) below.

(2) EPA evaluated information about the waste- generating processes and radiological and physical characteristics of the waste and de termined that the waste is appropriately identified for future development of speci fic waste streams or for inclusion of SCG S5000 waste in the supercompacted waste stream.

As described in section 6.1, the IN L-generated waste originated in several INL facilities and was shipped to the TSA for storage from 1970 to 2011. Wastes were not sorted according to SCG prior to packaging, so each container may hold more than one SCG. AMWTP expects to identify containers of waste from the INTEC and RW MC laboratories that hold more than 50% homogeneous solids (SCG S3000), and containers of waste from various INL facilities that are more than 50% debris (SCG S5000). AMWTP does not expect to identify any TRU containers generated by INL that hold more than 50% so il, gravel or sand, so EPA did not include SCG S4000 in this review.

The INL AKD and references (e .g., References P891A and P1424S) indicate that the SCG S3000 (homogeneous solids) containers primarily hol d sludge, including solidified sludge and/or solidified liquids, and may also hold absorbents and/or solidification agents. The container contents may also include lesser volumes of debr is such as vials and other laboratory sample containers. The INTEC laboratory generated such waste from 1970 to 2009, and the RWMC laboratory generated this waste from 2010 to 2011. AMWTP expects to identify eight cubic meters (m 3 ) of INL-generated SCG S3000 containers.

The INL AKD and references (e .g., References P891A and P1424S) indicate that the SCG S5000 (heterogeneous debris) containe rs hold any variety of combustible and noncombustible heterogeneous debris and may also hold absorben ts and/or solidificati on agents. The container contents may also include lesser volumes of ex cess sample material, such as homogeneous solids or soil/gravel. AMWTP expect s to identify more than 300 m 3 of debris containers described by the IDCs listed below. Some containers are ma rked with generator-location-specific IDCs, 4 but most containers are marked with the generic IN L IDC. Containers marked with the generic INL IDC (ID) cannot be traced to any specific INL generating facility or facilities.

 ID-021 (IC): Radioactiv e Mixed Lead Waste.

 ID-150 (IC): Laboratory Waste.

 ID-153: Combustible Lab Waste.

 ID-154 (IR): Sample Fuel.

 ID-155 (IW): TRU Scrap.

 IC-156: Chem Cell Rip Out.

4 Generator-location-specific IDCs indicate the speci fic waste generator and are identified here in parentheses. The codes indicate locatio n as follows: IA = ARA; IC = INTEC or ICPP; IF = CFA; IR = TRA; IT = TAN; and IW = RWMC. For example, all containers marked as ID-021 and IC-021 will hold radioactive mixed lead waste; the IC-021 containers were generated by INTEC or ICPP, while the ID-021 containers were generated by any of the INL facilities.10  ID-157 (IA, IC, IF, IR, IT, IW): Miscellaneous Radionuclide Sources.

 ID-175 (IT): DRCT Scrap Metal Waste – TAN.

 ID-337: Plastic, Teflon, Wa sh, PVC, Ret. RF TRU. 5

 IC-526: INTEC Laboratory PCB Debris Waste.

 IW-526: RWMC Laboratory PCB Debris Waste.

 IC-527: INTEC Laboratory Non-PCB Debris Waste.

 IW-572: RWMC Laboratory Non-PCB Debris Waste.

 IC-601: Alpha Low Level Lab. WIPP Analytical Waste.

AMWTP expects the two most predominate radi onuclides in all of the INL-generated waste containers (both SCG S3000 and S5000) to be americium-241 and plutonium-241 ( 241 Pu), with
239 Pu, 238 Pu, neptunium-237 and cesium-137 contributing 95% of the radioactivity. This estimate is based on Integrated Waste Tracking System (IWTS) profiles for 142 INL-generated containers stored at the TSA and confirmed by data from 97 INL-generated containers assayed at AMWTP. The IWTS profiles include waste only from INTEC, NRF, TRA, TAN and RWMC; however, AMWTP considers these data to be representati ve of waste from ARA, CFA and PBF as well (References P891A, P1390A, P1424S, P1457A , P1458A, P1886S, P1901S, U235S and U423A).

AMWTP will identify specific waste containers to add to the supercompacted waste stream and will sort the remaining INL-generated waste c ontainers into new waste streams according to AMWTP’s procedures after receiving EPA’s a pproval to add INL-generated waste to the AMWTP TRU waste characterization program.

The WIPP WAP defines a waste stream as wast e material that has common physical form, contains similar hazardous constituents, and is ge nerated from a single process or activity. When defining specific INL-generated waste streams, AMWTP will need to (1) develop detailed waste material parameter (WMP) percentages identifying the cellulose, plastic and rubber contents of waste containers, (2) identify the specific process that produced the waste and (3) verify that the population-specific radiological pr operties apply to the indivi dual waste streams. The INL AKD and referenced source documents contain sufficient information to indicate that AMWTP will be able to develop the detailed WMP percentage s and generating process information for each identified waste stream. EPA, therefore, expect s that future AKSRs for each direct-shipped INLgenerated waste stream will include sufficient detail to justify the waste stream determination. Notification to EPA upon the av ailability of new AKSRs a nd/or a revised INL AKD (RPTTRUW-92) continues to be a T2 change (see Table 1).

EPA compared the information presented in th e INL AKD to the descri ption of the current supercompacted waste stream, Waste St ream BN510.3 (RPT-TRUW-83, Revision 7) and determined that the physical composition, generati ng processes and radiological properties of the INL debris were consistent with the curre nt Waste Stream BN510.3. Notification to EPA upon the availability of a revised RPT-TRUW-83 c ontinues to be a T2 change (see Table 1).

5 Ret. RF TRU is defined as “returned Rocky Flats tr ansuranic waste” and consists of “containers of IDC RF-337 waste retrieved from TSA-1, Cell 5 during 1983. Containers were sent to the RFP, opened, and the contents were reviewed, sorted, and repackaged.” AMWTP assumes that the returned waste is similar to the original RF-337
waste.11 (3) EPA examined the Idaho National Laborator y acceptable knowledge document and found that data are available to verify 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 w hole or part by one of the atomic energy defense activities listed in section 10101(3) of th e Nuclear Waste Policy Act of 1982 (NWPA). 6 The WIPP Land Withdrawal Act (LWA), as amended, 7 prohibits the disposal of SNF and HLW as defined by the NWPA at the WIPP.

The INL AKD indicates that several nondefense ac tivities conducted at INL contributed waste to the TSA; however, waste generated prior to 1992 was not required to be sorted by defense status and individual containers ma y contain both defense and nondefense waste. Source documents indicate that no pure nondefense waste was sh ipped to the TSA (References P365A, P024A, P1424S, P1824S, P1865S and P1901S). Additionally, waste containers retrieved from the TSA may only be traceable to the INL level, and not to the INL facility level (References P365A, P465A, P768A, P891A, P1424S, P1425A, P 1865S, P1847S, P1909S and P1910S).

The INL AKD indicates that several of the IN L facilities handled SNF and HLW; however, shipping documents from the INL facilities to the TSA do not provide any evidence that SNF or HLW were ever shipped to the TSA for storag e. Additionally, DOE polic ies prohibited storage of SNF at the TSA, and INL is currently ba nned from shipping HLW to AMWTP. Some INLgenerated waste containers include test specimens of fissionable mate rial that were irradiated for research and development only. The NWPA specifi cally excludes such test specimens from the definition of SNF. The ICPP’s mission was to re process SNF and, therefore, the ICPP produced and handled HLW. However, DOE has determined th at all of the waste that the ICPP sent to the RWMC is considered waste incidental to repr ocessing and not HLW. If any SNF or HLW is identified during characterization, AMWTP will ma nage it separately from waste destined for the WIPP (References C1283A, C1298S, P 1424S, P465A, P605A, P682S, P788S, P891A, P1420S, P1824S, P1845S, P1847S, P1866S, P1868S, P1889S, P1892S, P1909S, P1910S, P1918S, P1920S and P1933S).

As a result of an EPA concern identifie d during the 2012–2013 AMWTP continued compliance inspection (EPA Docket No. A-98-49; II-A 4-173), AMWTP will prepare IDC inclusion memoranda documenting the evaluations performed on each new IDC to be included in the supercompacted waste stream (currently Waste Stream BN510.3). These memoranda will document that the IDCs meet the requirements of the LWA restrictions wi th respect to defense waste, SNF and HLW. Notification to EPA upon completion of or revision to IDC inclusion memoranda remains a T2 change (see Table 1).

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

7 Public Law 102-579, The Waste Isolation Pilot Pl ant Land Withdrawal Act, October 30, 1992, as amended by Public Law 104-201, September 23, 1996.12 7.0 FINDINGS AND CONCERNS

The EPA inspection team did not identify any fi ndings or concerns during this T1 evaluation. There are no open issues rela ted to this T1 evaluation.

8.0 CONCLUSIONS

Changes to Tiering

Notification to EPA upon revision to AMWT P reports RPT-TRUW-05, RPT-TRUW-06, RPTTRUW-07, RPT-TRUW-12 and RPT-TRUW-83 a nd the INL AKD (RPT-TRUW-92) remains a T2 change. Table 1 was modified to update the li st of approved waste sources to include INLgenerated waste. Table 1 shows the substantive T1 change in bold text. T1 and T2 changes that were initiated during the baseli ne approval and during subsequent T1 evaluations and approvals remain in effect; these are liste d as applicable in section 6.0. Th e language in Table 1 regarding AK documentation applies to all AMWTP waste streams, including load-managed and directshipped waste streams.

Approval

This T1 change consisted of the use of AK to characterize INL-genera ted legacy and newlygenerated SCG S3000 and SCG S5000 waste stored at the TSA. With this approval of the AK aspect of the characterizati on process, AMWTP may characte rize physical and radiological contents of these two waste types using the e quipment, processes and procedures that EPA approved during the October 2006 baseline appr oval (see EPA Docket No A-98-49: II-A4-66, October 3, 2006). AMWTP must confirm th e AK using the EPA-approved NDA and NDE processes and procedures. EPA ma y review a sample of these NDA and NDE batch data reports during the next continue d compliance inspection.A-1 ATTACHMENT A

APPROVAL SUMMARY FOR ADVANCED MIXED WASTE TREATMENT PROJECT CONTACT-HANDLED WASTE CH ARACTERIZATION 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 BN51 0 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

T1 Change – Addition of ANLE-generated SCG S3000 and S5000 CH Waste and MFC-generated SCG S5000 CH Waste January 2013 A-98-49; II-A4-169

Continued Compliance Inspection April 2013 A-98-49; II-A4-173

T1 Change – Addition of Pre-1980 INL-Exhumed SDA SCG S3000 and S5000 CH Waste July 2013 A-98-49; II-A4-174

T1 Change – Addition of Los Alamos National Laboratory Debris CH Waste September 2013 A-98-49; II-A4-178B-1 ATTACHMENT B

LIST OF DOCUMENTS CITED BY EP A DURING THE T1 EVALUATION

C1283A, Evaluation of Records for Waste Genera ted at the Idaho Chemical Processing Plant (ICPP) and Disposed at the Radioactive Wa ste Management Complex (RWMC) during the Period of 1960–1983, D. W. Rhodes, DWR-01-93, January 8, 1993

C1298S, Section 3116 Determination for the Ida ho Nuclear Technology and Engineering Center Tank Farm Facility at the Idaho National Engi neering Laboratory, Samuel W. Bodman, DOEWD-2006-001, November 19, 2006

P024A, Content Code Assessments for INEL C ontact-Handled Stored Transuranic Wastes, T.L. Clements, Jr., WM-F1-82-021, October 1982

P1390A, A Comprehensive Inventor y of Radiological and Nonrad iological Contaminants in Waste Buried in the Subsurface Disposal Area of the INEL RWMC During the Years 1952–1983 (Volume 2), INEL-95/0310 (formerly EGG-WM-10903), August 1, 1995

P1420S, Project Execution Plan for the IN TEC Area Cleanup Project, PLN-2084, June 1, 2008

P1424S, INL Integrated Waste Tr acking System (IWTS) Containe r Profiles, variable dates

P1425A, Guidelines for the Interim Storage of AEC-Generated Solid Transuranic Wastes, LA5645, June 1971

P1426A, Idaho National Laborator y and Argonne National Laborator y-West – Site Description, Oak Ridge Associated Universities, Dade Moeller, ORAUT-TKBS-0007-2, August 2, 2010

P1457A, Form-1900 INTEC lab, AMWTP, IW-LAB-S5490-221F, January 12, 2010

P1458A, Form-1900 INTEC lab, AMWTP, IW-LAB-S3900-221F, not dated

P1824S, Idaho Nuclear Technology and Engineer ing Center, Sodium-Bearing Waste – WasteIncidental-to- Reprocessing Determination Report, Bechtel BWXT Idaho, LLC (BBWI), DOE/ID-10780, August 2002

P1845S, INEL Reusable Property, Recyclable Ma terials, and Waste Acceptance Criteria, DOE/ID-10381, October 10, 1995

P1847S, A Survey of NRTS Waste Management Practices, Volume II, ICP-1042-II, September 1971

P1865S, Defense-Related Waste Determination fo r Legacy Transuranic Waste at the Idaho National Laboratory Test Reactor Area Warm and Hot Waste Systems, ICP/EXT-04-00729, April 1, 2005B-2 P1866S, Historical American Engineering Record Idaho National Engineering Laboratory Test Reactor Area: Materials Testi ng and Engineering Test Reactor s HAER No. ID-33-G, INL/EXT06-01185, March 1, 2006

P1868S, Historical American Engineering Record – Idaho National Engineering and Environmental Laboratory – Test Area North, HAER No. ID- 33-E, INEEL/EXT-04-02536, February 2005

P1886S, Engineering Evaluation/Co st Analysis for Decommissioning of the TRA-632 Hot Cells, DOE/ID-11397, September 2009

P1889S, Basis for Section 3116 Determinati on for the Idaho Nuclear Technology and Engineering Center Tank Farm Facility, DOE/NE-ID-11226, November 2006

P1892S, National Spent Nuclear Fuel Fact Sheets – Storage of DO E Spent Nuclear Fuel at the Idaho National Laboratory, not dated

P1901S, Evaluation of Closure Options for the Transuranic-Contaminated Components Associated with the TRA-630 Catch Tank System , Voluntary Consent Order Action Plan VCO5.8.d, RPT-351, March 1, 2007

P1909S, Central Characterization Project Acce ptable Knowledge Summary Report for Idaho National Laboratory Remote-Handled Transurani c Debris Waste from the Naval Reactors Facility Waste Stream Waste Stream IN-ID-NRF-153, CCP-AK-INL-560, September 30, 2009

P1910S, Central Characterization Project Acce ptable Knowledge Summary Report for Idaho National Laboratory Remote-Handled Transurani c Debris Waste from the Naval Reactors Facility Waste Stream IN-ID-NRF -SPC, CCP-AK-INL-570, December 5, 2011

P1918S, The Decontamination, Decommissioning, and Demolition of the Engineering Test Reactor at the Idaho Cleanup Project, Daniel Coyne and Kelly Rhodes, Waste Management Conference, Phoenix, AZ, Abstract # 8297, February 24

− 28, 2008

P1920S, Engineering Evaluation/Co st Analysis for Power Burst Facility (PER-620), Final End State and PBF Vessel Disposal, DOE/ID-11309, May 1, 2007

P1933S, Idaho Nuclear Technology a nd Engineering Ce nter Summary, http://www.globalsecurity.org/inte ll/library/imint/doe_inel_icpp_1.htm, screenshot July 27, 2011

P1942S, INEL Environmental Characterization Re port, Volumes I-III, A. L. Bowman, W.F. Downs, K.S. Moor, and B.F. Russell, EG&G Inc., EGG-NPR-6688, September 1984

P1955S, Critical Infrastructure Test Range User's Manual, Idaho National Laboratory, INEEL/EXT-04-02348, Revision 2, January 2006

P1956S, Idaho National Laborator y, Critical Infrastructure Te st Range Complex Summary, http://www.globalsecurity.org/wmd/ facility/idaho_inel-f acility-citr.htm, screenshot July 24, 2011B-3 P365A, Waste Description Information for Transura nically Contaminated Wastes Stored at the Idaho National Engineering Laboratory, INEL-95/0412, December 1, 1995

P465A, Criteria for Packaging Transuranic Waste for Receipt at the Idaho National Engineering Laboratory Radioactive Waste Management Complex Manual, DOE/ID-10074, August 1981

P605A, Process Description and Operati ng History for the CPP-601/-640/-627 Fuel Reprocessing Complex at the Idaho National Engineering and Envir onmental Laboratory, INEEL/EXT-99-0040, July 1999

P682S, Laboratory-wide Procedure, Transura nic Waste Handling, Ida ho National Laboratory LWP-8300, undated draft document

P755A, Ancillary Basis for Risk Analysis of th e Subsurface Disposal Area, K. Jean Holdren, Bruce H. Becker, Nancy L. Hampton, L. Don Koeppen, Swen O. Magnuson, T.J. Meyer, Gail L. Olson, A. Jeffrey Sondrup, INEEL/EXT-02-01125, September 27, 2002

P768A, A History of the Radi oactive Waste Management Co mplex at the Idaho National Engineering Laboratory, WM-F1-81-003, July 1985

P788S, Proving the Principle, Susan M. Stacy, 2000

P891A, CH2M-WG Idaho Process Knowledge Su mmary Report for CH TRU Waste and Mixed Low-Level Waste Generated at INTEC and RWMC ICP Analytical Labora tories in Support of AMWTP Sampling Activities, Waste Matrix Codes: S5490 and S3900, RPT-670, November 2010

RPT-TRUW-05, Waste Matrix Code Reference Manual, Advanced Mixed Waste Treatment Project, Revision 33, October 29, 2013

RPT-TRUW-06, Acceptable Knowledge Baseline Document for AMWTP Waste, Revision 15, October 23, 2013

RPT-TRUW-07, Determination of Radioisotopic Content in TRU Waste Based on Acceptable Knowledge, Advanced Mixed Waste Treatment Project, Revision 19, November 5, 2013

RPT-TRUW-12, AMWTP Waste Stream Designa tions, Advanced Mixed Waste Treatment Project, Revision 22, November 21, 2013

RPT-TRUW-83, Acceptable Knowledge Summary for Supercompacted Debris Waste, Advanced Mixed Waste Treatment Project, Revision 7, November 27, 2013

RPT-TRUW-92, Acceptable Knowledge Document for Select Idaho National Laboratory (INL) Facilities, Revision 0, July 18, 2013

U235S, RWMIS Waste Disposal Re port 1970 through 1971, INL, March 11, 2009B-4 U329S, AMWTP Waste Tracking System (WTS) Da tabase information for INL Generators, Randall Morris, February 7, 2012

U423A, Radiation Data for INL Generators from IWTS. Randall C. Morris, March 14, 2013

U426S, Spreadsheet of INL historical informa tion from WTS, RWMIS, and IWTS, not dated