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

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT: 

ADDITION OF CONTACT-HANDLED TRANSURANIC WASTE TO THE ADVANCED 

MIXED WASTE TREATMENT PROJECT 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 2014
 ii 

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 Advanced Mixed Waste Treatment Project 

Contact-Handled Waste Characterization Program 

Attachment B: List of Documents Cited by EPA during the T1 Evaluation 
 iii 

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 (formerly 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 Engineering and Environmental Laboratory 

INTEC Idaho Nuclear Technology and Engineering 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 

m3

 cubic meter 

MFC Materials and Fuels Complex 
 iv 

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 transuranic (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 characterization processes discussed in this report, AMWTP can 

characterize INL-generated CH legacy waste [stored at the INL Radioactive Waste Management 

Complex (RWMC) Transuranic Storage Area (TSA)] and newly-generated waste for disposal 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. EPA’s October 2006 baseline approval 

applied to (1) CH retrievably-stored SCG S3000 and SCG S5000 waste and (2) newly-generated 

SCG S5000 CH waste. The AMWTP baseline final inspection report (see EPA Docket No. A98-49; 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 SCG 

S3000 and SCG S5000 waste and newly generated SCG S5000 waste. The baseline report 

defined inclusion of wastes from sources other 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 inspection. Attachment A provides a table listing EPA’s 

approvals of the AMWTP CH TRU waste characterization program. 

On August 15, 2013, the Carlsbad Field Office (CBFO) 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, EPA limited the scope of this T1 

evaluation to the AK process for generating RPT-TRUW-92, Revision 0, “Acceptable 

Knowledge Document for Select Idaho National Laboratory 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 generation and disposal records to support 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 the 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 subsequent T1 approvals remain in effect. The 

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

including load-managed and direct-shipped waste streams. 
 2 

Based on this evaluation, EPA approves the addition of INL-generated SCG S3000 and SCG 

S5000 CH waste to AMWTP’s EPA-approved program. This approval allows AMWTP to 

characterize the physical and radiological 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 characterization equipment, processes and 

procedures EPA approved as part of the AMWTP 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 review a sample of these NDA and NDE batch 

data reports during the next continued 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 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 AMWT

(Based on March 28–30 and April 11–13, 2006, Baseline Inspection and Subsequent T1 Evaluations, Upda

Process Elements AMWTP CH Waste Characterization Processes – T1 Changes AMWTP CH Waste Characterizatio

Acceptable Knowledge, 

including Load Management 

Any new waste category Any waste from sources other than the Mound Site; Rocky Flats 

Environmental Technology Site; Battelle Columbus Laboratories; Bettis Atomic Power Laboratory; Argonne National Laboratory-East; and Idaho National Laboratory, including the 

Materials and Fuel Complex and pre-1980 INL-exhumed Subsurface Disposal Area waste 

Load management of any new or unapproved waste stream 

Notification to EPA upon completion of or 

 Implementation of procedures and relat

NDA-AK communication requirements

 AK accuracy reports (annually, at a min All final WSPFs with related attachmen

additions to waste streams within approradiological data for those containers in

 New and revised AKSRs and generator

RPT-TRUW-79, RPT-TRUW-89, RPT

 Item description code inclusion memora The load management status of approve Site procedures requiring CBFO approv Any waste identified outside of the was

Transuranic Waste Baseline Inventory R

 RPT-TRUW-05, RPT-TRUW-07 and R

Nondestructive Assay New equipment or substantive physical modifications to approved 

equipment** Extension of or changes to the approved calibration range for 

approved equipment 

Notification to EPA upon substantive modi

 Site procedures requiring CBFO approv Software for approved equipment  Operating ranges upon CBFO approval 

Real-Time Radiography None Notification to EPA upon: 

 Substantive modification** to site proc New equipment or substantive physical 

equipment 

Visual Examination and Visual Examination Technique 

Changes in the vendor performing visual examination or visual examination technique 

Notification to EPA upon: 

 Substantive modification** to site proc Addition of a new waste category  Addition of a new procedure or site equ

WIPP Waste Data System Changes to Waste Data System algorithms specific to load 

management 

Notification to EPA upon substantive modi

 Site procedures requiring CBFO approv The load management status of approve

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 * 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 documentatio

are solely related to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act; or that are editoriaddress 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 activities from the date of the site’s baseline 

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

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

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

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

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

TRU waste generator site’s waste characterization program. The purpose of EPA’s baseline 

inspection is to approve the site’s waste characterization program, based on the demonstration 

that the program’s components, with applicable conditions and limitations, can adequately 

characterize TRU wastes and comply with the regulatory requirements imposed on TRU wastes 

destined for disposal at the WIPP. 

Following EPA’s baseline approval, EPA is authorized to evaluate and approve changes, if 

necessary, to the site’s approved waste characterization program by conducting additional 

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

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

are identified in the site-specific baseline inspection reports and subsequent T1 evaluation 

reports. When evaluating proposed T1 changes for 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 and EPA and EPA contractor staff discussed 

DOE’s TRU site cleanup goals through 2016 and ways to improve EPA’s evaluation and 

decision process to support DOE sites’ state-mandated cleanup needs. As a result of this 

discussion, EPA finalized a streamlined evaluation 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 characterization processes that are 

not expected to significantly vary on a waste stream or T1 basis. Examples of the common 

characterization elements are personnel training, procedures and equipment capabilities. EPA 

will evaluate these elements during T1 change evaluations or in conjunction with the quarterly 

T2 change reports as necessary to ensure that EPA’s waste characterization approvals reflect any 

significant changes made to DOE’s waste characterization program. 

This streamlined approach allows EPA to consider the results of continued compliance 

inspections when setting the scope and evaluating site-specific T1 changes. EPA conducted a 

continued compliance inspection of AMWTP 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 characterization processes, procedures and equipment 

at AMWTP that EPA approved in the October 2006 baseline approval 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-generated CH TRU waste to AMWTP’s baseline approval as a 

T1 change. EPA’s approval of INL-generated 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 evaluation are cited in different sections throughout 

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

following address: 

Manager, National TRU Program 

Carlsbad Field Office 

U.S. Department of Energy 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

4.0 SCOPE OF THIS TIER 1 EVALUATION 

The scope of this T1 evaluation was the addition 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 determine 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 address AK, NDA or NDE procedural adequacy; 

AMWTP procedural compliance; or NDA and NDE equipment because EPA evaluated these 

elements during its continued compliance evaluation of AMWTP on October 30–November 1, 

2012, and February 26, 2013 (EPA Docket 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 AMWTP 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 Evaluator – Acceptable Knowledge, SC&A 

Eric Schweinsberg Site Project Manager, AMWTP-ITG 

George Byram TRU Programs Manager, AMWTP-ITG 
 6 

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 development, and testing and operation of nuclear reactors. Various 

INL facilities have supported programs involved with energy development, aircraft propulsion, 

naval propulsion, fast breeder reactor development, light-water safety 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 Area (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 Naval Reactors Facility (NRF), the Test Area 

North (TAN), the Test Reactor Area [(TRA), currently known as the Advanced Test Reactor 

Complex], the Power Burst Facility (PBF), the RWMC (excluding waste previously disposed of 

within the INL SDA) and the Idaho Chemical Processing Plant [(ICPP), currently known as the 

Idaho Nuclear Technology and Engineering Center (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 evaluation (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 the 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 description, including radiological and physical characteristics. 

 Verification that the subject waste 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 reports and related documentation and found 

them to be adequate. 

AMWTP prepares multiple documents that together summarize the available information for 

INL-generated CH TRU waste. AMWTP’s AK characterization procedure MP-TRUW-8.13, 

Revision 24,1

 states that the characterization process begins with development of generator-sitespecific AKDs. For this T1 request, AMWTP prepared the INL AKD. This document is very 

general and includes data from the entire INL, not just the facilities that are known to have 

contributed TRU CH waste to the TSA. 

According to procedure MP-TRUW-8.13, information from the generator-site-specific AKD is 

then used to update other AMWTP 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 Knowledge 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 Knowledge Summary for Supercompacted 

Debris Waste,” November 27, 2013. 

These reports and their supporting source documents 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 the INL-generated waste because the AK procedure 

(MP-TRUW-8.13) does not allow for such revision until after EPA approves the INL AKD. EPA 

evaluated AMWTP’s process for updating these 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 evaluation, EPA reviewed only the versions of these 

reports listed above (i.e., the current 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 Department, “Waste Isolation Pilot Plant Hazardous Waste Facility Permit, 

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

3

 DOE CBFO, “Transuranic Waste Acceptance 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 periodically review the current 

versions of these reports to ensure adequate document preparation and revision. 

The waste matrix code (WMC) reference manual, RPT-TRUW-05, contains detailed information 

about the physical characteristics of all wastes 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 IDCs 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 one 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 continues to be a T2 change (see Table 1). 

RPT-TRUW-07 presents radiological information for EPA-approved offsite waste generators 

(e.g., RFP, Mound Site, Battelle Columbus Laboratories, Bettis, the 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 waste and other revisions. These are the revisions EPA expected to 

see based on previous T1 evaluations. RPT-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. Notification to EPA upon the availability 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 waste number assignments for TRU IDCs that 

AMWTP characterizes and certifies. Revision 22 of RPT-TRUW-12 includes some of the INL 

IDCs listed in the INL AKD; AMWTP will revise RPT-TRUW-12 again after EPA approves 

INL-generated waste for inclusion in the AMWTP waste characterization program. Notification 

to EPA upon the availability of a revised RPT-TRUW-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 Waste Stream BN510.3. RPT-TRUW-83 (the supercompacted waste 

stream AKSR) includes information about all feed material inputs to the 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 will 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 definition of the supercompacted waste 

stream. Notification to EPA upon the availability 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 determined that the waste is appropriately 

identified for future development of specific waste streams or for inclusion of SCG 

S5000 waste in the supercompacted waste stream. 

As described in section 6.1, the INL-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 RWMC 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% soil, 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 hold 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 debris 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 (m3

) of INL-generated SCG S3000 containers. 

The INL AKD and references (e.g., References P891A and P1424S) indicate that the SCG S5000 

(heterogeneous debris) containers hold any variety of combustible and noncombustible 

heterogeneous debris and may also hold absorbents and/or solidification agents. The container 

contents may also include lesser volumes of excess sample material, such as homogeneous solids 

or soil/gravel. AMWTP expects to identify more than 300 m3 of debris containers described by 

the IDCs listed below. Some containers are marked with generator-location-specific IDCs,4

 but 

most containers are marked with the generic INL IDC. Containers marked with the generic INL 

IDC (ID) cannot be traced to any specific INL generating facility or facilities. 

 ID-021 (IC): Radioactive 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 specific waste generator and are identified here in 

parentheses. The codes indicate location 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, Wash, 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 radionuclides in all of the INL-generated waste 

containers (both SCG S3000 and S5000) to be americium-241 and plutonium-241 (241Pu), with 

239Pu, 238Pu, 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 representative 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 containers into new waste streams according to 

AMWTP’s procedures after receiving EPA’s approval to add INL-generated waste to the 

AMWTP TRU waste characterization program. 

The WIPP WAP defines a waste stream as waste material that has common physical form, 

contains similar hazardous constituents, and is generated 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 properties apply to the individual waste streams. The INL AKD 

and referenced source documents contain sufficient information to indicate that AMWTP will be 

able to develop the detailed WMP percentages and generating process information for each 

identified waste stream. EPA, therefore, expects 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 availability of new AKSRs and/or a revised INL AKD (RPTTRUW-92) continues to be a T2 change (see Table 1). 

EPA compared the information presented in the INL AKD to the description of the current 

supercompacted waste stream, Waste Stream BN510.3 (RPT-TRUW-83, Revision 7) and 

determined that the physical composition, generating processes and radiological properties of the 

INL debris were consistent with the current Waste Stream BN510.3. Notification to EPA upon 

the availability of a revised RPT-TRUW-83 continues to be a T2 change (see Table 1). 

 5

 Ret. RF TRU is defined as “returned Rocky Flats transuranic 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 Laboratory 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 whole or part by one of the atomic energy defense 

activities listed in section 10101(3) of the Nuclear Waste Policy Act of 1982 (NWPA).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 activities 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 may contain both defense and nondefense waste. Source documents 

indicate that no pure nondefense waste was shipped 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, P1865S, P1847S, P1909S and P1910S). 

The INL AKD indicates that several of the INL 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 storage. Additionally, DOE policies prohibited storage 

of SNF at the TSA, and INL is currently banned from shipping HLW to AMWTP. Some INLgenerated waste containers include test specimens of fissionable material that were irradiated for 

research and development only. The NWPA specifically excludes such test specimens from the 

definition of SNF. The ICPP’s mission was to reprocess SNF and, therefore, the ICPP produced 

and handled HLW. However, DOE has determined that all of the waste that the ICPP sent to the 

RWMC is considered waste incidental to reprocessing and not HLW. If any SNF or HLW is 

identified during characterization, AMWTP will manage it separately from waste destined for 

the WIPP (References C1283A, C1298S, P1424S, 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 identified during the 2012–2013 AMWTP continued compliance 

inspection (EPA Docket No. A-98-49; II-A4-173), 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 with 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 Plant 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 findings or concerns during this T1 evaluation. 

There are no open issues related to this T1 evaluation. 

8.0 CONCLUSIONS 

Changes to Tiering

Notification to EPA upon revision to AMWTP reports RPT-TRUW-05, RPT-TRUW-06, RPTTRUW-07, RPT-TRUW-12 and RPT-TRUW-83 and the INL AKD (RPT-TRUW-92) remains a 

T2 change. Table 1 was modified to update the list 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 baseline approval and during subsequent T1 evaluations and approvals 

remain in effect; these are listed as applicable in section 6.0. The 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-generated legacy and newlygenerated SCG S3000 and SCG S5000 waste stored at the TSA. With this approval of the AK 

aspect of the characterization process, AMWTP may characterize physical and radiological 

contents of these two waste types using the equipment, processes and procedures that EPA 

approved during the October 2006 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 review a sample of these NDA and NDE batch data reports 

during the next continued compliance inspection. 
 A-1 

ATTACHMENT A 

APPROVAL SUMMARY FOR ADVANCED MIXED WASTE TREATMENT PROJECT 

CONTACT-HANDLED WASTE CHARACTERIZATION PROGRAM 

Approved Activity EPA Inspection Number, 

Approval Dates EPA Docket Number 

AMWTP CH Baseline Approval EPA-AMWTP-03.06-8 

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

T1 Change – Addition of Four Hanford Legacy Debris 

Waste Streams to the BN510 Super-Compacted Debris 

Waste Stream 

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

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

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-A4-178 
 B-1 

ATTACHMENT B 

LIST OF DOCUMENTS CITED BY EPA DURING THE T1 EVALUATION 

C1283A, Evaluation of Records for Waste Generated at the Idaho Chemical Processing Plant 

(ICPP) and Disposed at the Radioactive Waste Management Complex (RWMC) during the 

Period of 1960–1983, D. W. Rhodes, DWR-01-93, January 8, 1993 

C1298S, Section 3116 Determination for the Idaho Nuclear Technology and Engineering Center 

Tank Farm Facility at the Idaho National Engineering Laboratory, Samuel W. Bodman, DOEWD-2006-001, November 19, 2006 

P024A, Content Code Assessments for INEL Contact-Handled Stored Transuranic Wastes, 

T.L. Clements, Jr., WM-F1-82-021, October 1982 

P1390A, A Comprehensive Inventory of Radiological and Nonradiological 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 INTEC Area Cleanup Project, PLN-2084, June 1, 2008 

P1424S, INL Integrated Waste Tracking System (IWTS) Container Profiles, variable dates 

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

P1426A, Idaho National Laboratory and Argonne National Laboratory-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 Engineering Center, Sodium-Bearing Waste – WasteIncidental-to- Reprocessing Determination Report, Bechtel BWXT Idaho, LLC (BBWI), 

DOE/ID-10780, August 2002 

P1845S, INEL Reusable Property, Recyclable Materials, 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 for Legacy Transuranic Waste at the Idaho 

National Laboratory Test Reactor Area Warm and Hot Waste Systems, ICP/EXT-04-00729, 

April 1, 2005 
 B-2 

P1866S, Historical American Engineering Record Idaho National Engineering Laboratory Test 

Reactor Area: Materials Testing and Engineering Test Reactors 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/Cost Analysis for Decommissioning of the TRA-632 Hot Cells, 

DOE/ID-11397, September 2009 

P1889S, Basis for Section 3116 Determination 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 DOE 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 Acceptable Knowledge Summary Report for Idaho 

National Laboratory Remote-Handled Transuranic 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 Acceptable Knowledge Summary Report for Idaho 

National Laboratory Remote-Handled Transuranic 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/Cost Analysis for Power Burst Facility (PER-620), Final End 

State and PBF Vessel Disposal, DOE/ID-11309, May 1, 2007 

P1933S, Idaho Nuclear Technology and Engineering Center Summary, 

http://www.globalsecurity.org/intell/library/imint/doe_inel_icpp_1.htm, screenshot July 27, 2011 

P1942S, INEL Environmental Characterization Report, 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 Laboratory, Critical Infrastructure Test Range Complex Summary, 

http://www.globalsecurity.org/wmd/facility/idaho_inel-facility-citr.htm, screenshot July 24, 2011 
 B-3 

P365A, Waste Description Information for Transuranically 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 Operating History for the CPP-601/-640/-627 Fuel 

Reprocessing Complex at the Idaho National Engineering and Environmental Laboratory, 

INEEL/EXT-99-0040, July 1999 

P682S, Laboratory-wide Procedure, Transuranic Waste Handling, Idaho National Laboratory 

LWP-8300, undated draft document 

P755A, Ancillary Basis for Risk Analysis of the 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 Radioactive Waste Management Complex 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 Summary Report for CH TRU Waste and Mixed 

Low-Level Waste Generated at INTEC and RWMC ICP Analytical Laboratories 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 Designations, 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 Report 1970 through 1971, INL, March 11, 2009 
 B-4 

U329S, AMWTP Waste Tracking System (WTS) Database 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 information from WTS, RWMIS, and IWTS, not dated