DOCKET NO: A-98-49, II-A4-160

WASTE CHARACTERIZATION REPORT

EPA TIER 1 EVALUATION
OF THE CENTRAL CHARA CTERIZATION PROJECT
REMOTE-HANDLED TRANSURANIC WAS TE CHARACTERIZATION PROGRAM:
ADDITION OF CONTAINERS GENERATED FROM WASTE GROUPS PKE00027/54
AND PKE00047 TO THE REMOTE-HAND LED DEBRIS WASTE STREAM
SNL-HCF-S5400-RH AT THE S ANDIA NATIONAL LABORATORY

December 2011 – January 2012

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

March 2012i CONTENTS

Section Page

1.0 Executive Summary ............................................................................................................ 4

2.0 Purpose of Tier 1 Evaluations ............................................................................................. 6

3.0 Purpose of This Report ....................................................................................................... 6

4.0 Scope of the Tier 1 Evaluation............................................................................................ 7

5.0 Evaluation Personnel .......................................................................................................... 7

6.0 Technical Evaluation .......................................................................................................... 8

6.1 Acceptable Knowledge ......................................................................................... 10

6.2 Radiological Characterization ............................................................................... 19

6.3 Visual Examination ............................................................................................... 32

7.0 Summary of Results .......................................................................................................... 3 4

Attachment A: List of Documents Revi ewed by EPA During T1 Evaluation....................A-1

TABLES

Table 1. Tier 1 Evaluation Personnel .......................................................................................... .... 8 Table 2. Summary of PKE Reports ............................................................................................... .. 9
Table 3. PKE00047 Radionuclide Ac tivity Ratio Comparison .................................................... 15
Table 4. Radionuclide Activit y Ratios for PKE00027/54 ............................................................ 16 Table 5. Container Traceability ............................................................................................... ..... 18 Table 6. Sample Disposition Summary ........................................................................................ 23
Table 7. 137 Cs Scaling Factors for PKE00027/54 and PKE00047, Ci Radionuclide/Ci 137 Cs ...... 29
Table 8. Overall Uncertainties for PKE00027/54 and PKE00047 ............................................... 30ii ACRONYMS AND ABBREVIATIONS

AK acceptable knowledge

AKSR acceptable knowledge summary report

Am americium

Ba barium

BDR batch data report

CBFO Carlsbad Field Office

CCP Central Characterization Project

CFR Code of Federal Regulations

CH contact-handled

Ci curie

CIS characterization information summary

Cm curium

Co cobalt

CRR characterization reconciliation report

Cs cesium

CSSF Correlation and Surrogate Summary Form

DOE U.S. Department of Energy

DQO data quality objective

DR discrepancy resolution

DTC dose-to-curie

EPA U.S. Environmental Protection Agency

Eu europium

GBL Glovebox Laboratory

GFPC gas-flow proportional counting

g/cm 3 grams per cubic centimeter

HCF Hot Cell Facility

HLW high-level waste

ID identification

LCS laboratory control standard

LCSD laboratory control sample duplicate

LOQI List of Qualified Individualsiii mR/hr/Ci milliroentgen per hour per curie

nCi/g nanocurie per gram

NCR nonconformance report

ORIA Office of Radiation and Indoor Air

PKE process knowledge evaluation

Pm promethium

Pu plutonium

QA quality assurance

QC quality control

RH remote-handled

RWNMDD Regulated Waste/Nuclear Ma terial Disposition Department

SCB steel containment box

SNF spent nuclear fuel

SNL Sandia National Laboratory

SPM Site Project Manager

Sr strontium

ST source term

T1 Tier 1

T2 Tier 2

TMU total measurement uncertainty

TRU transuranic

U uranium

VE visual examination

WCPIP Waste Characterization Program Implementation Plan

WIPP Waste Isolation Pilot Plant

WSPF Waste Stream Profile Form

WTS Washington TRU Solutions

Y yttrium4 1.0 EXECUTIVE SUMMARY

This report supports the U.S. E nvironmental Protection Agency’s (EPA’s) decision to approve a Tier 1 (T1) change to add cont ainers generated from the PKE00027/54 1 and PKE00047 waste groups to the previously approved remote-handled (RH) transuranic (TRU) debris Waste Stream SNL-HCF-S5400-RH at the U.S. Department of Energy’s (DOE’s) Sandia National Laboratory (SNL) in Albuquerque, New Mexico. 2 In November 2011, EPA approved the Central Characterization Project (CCP) to characterize RH waste at SNL. 3 The November 2011 baseline approval applied to 19 parcels 4 of retrievably stored RH TR U waste from the PKE00044 waste group (see EPA Docket No. A-98-49: II-A 4-155). Using the EPA-approved waste characterization processes discussed in this re port, SNL-CCP can charac terize waste containers generated from the PKE00027/54 and PKE00047 wa ste groups, which were generated during decontamination operations of the Glovebox Labor atory (GBL) at the SN L Hot Cell Facility (HCF). This HCF GBL waste is packaged in 55-gallon containers 5 and characterized and
therefore can be added to SNL Waste Stream SNL-HCF-S5400-RH for emplacement in the Waste Isolation Pilot Plant (WIPP).

The November 2011 SNL baseline fi nal inspection report (discussing 19 parcels) documents the following components. The November 2011 baseline approval includes (1) acceptable knowledge (AK); (2) radiological characterization using dose-to-c urie (DTC), in conjunction with radionuclide-specific scaling factors s upported by radiochemical analyses of smear 6 samples from the parcels; and (3) visual ex amination (VE). These components are used to confirm the physical and radiologica l contents of waste containers. Table 1 of that report cited the inclusion of the two remaining waste groups (PKE00027/54 and PKE00047) in the approved waste stream as a Tier 1 (T1) change that requires EPA approval prior to implementation. The EPA SNL baseline final inspecti on report also stated that SNL- CCP needs to provide additional information showing more commonality of experi ments and radiological materials between the steel containment box (SCB)/Zone 2A ar ea (PKE00044) and the GBL (PKE00027/54 and

1 PKE00027 was originally developed assuming that th e parcels were low-level waste, but SNL determined that some were TRU and created PKE00054 for wastes originally designated as PKE00027. Different SNL-CCP
documents refer to PKE00027 and PKE00027/54. For consis tency, this report uses PKE00027/54 to indicate the population of TRU debris waste generated from Glovebox 3.

2 SNL also has a site in California. All references to SNL in this report are exclusively to SNL’s New Mexico site, unless otherwise stated.

3 In this report, “SNL” refers to the host site and its past and present waste generation, management and storage activities. “SNL-CCP” means the party responsibl e for the TRU waste characterization activities that are within the scope of EPA’s baseline inspection.

4 SNL is the only site within the DOE TRU complex that uses “parcel” as a term for a waste package instead of the term “container,” commonly used to describe a waste package. More than one parcel may be put into a 30-gallon drum, which in turn goes into a 55-gallon container for WIPP disposal. This report uses the term “parcel” to be consistent with the site usage.

5 “Containers” is a generic term that applies to cans, canisters, drums and any other types of waste packaging units that may be charact erized individually for their radi ological and physical contents.

6 A “smear,” “wipe” or “swipe” is a nonquantitativ e test for the presence of removable radioactive
materials in which a surface or area is wi ped with a filter paper or other substan ce, which is then assayed for specific radionuclides using destructive or nondestructive techniqu es. For these samples, the “smear” was a cotton swab.5 PKE00047). The baseline also states that more justification for why th e distinct radiological populations do not warrant design ation as separate waste streams as implied by the Waste Characterization Program Implementa tion Plan (WCPIP), Revision 2.

On December 15, 2011, the Carlsbad Field Offi ce (CBFO) requested EPA approval of a T1 change to add containers generated from Waste Groups PK E00027/54 and PKE00047 to Waste
Stream SNL-HCF-S5400-RH. SNL-CCP collected and analyzed samples from both new waste groups to develop scaling factors for charac terization by DTC, as described in CCP-AKSNL-501, Revision 2, Appendices A and B, fo r PKE00027/54 and PKE00047, respectively. CCP-AK-SNL-500, Revision 4, and related source documents provided additional information and justification that supports (a) why the waste containers in these two waste groups are similar
to those waste containers in the waste group PKE00044 which EPA approved in November 2011, (b) why new scaling factors were developed, and (c) why the waste containers in these two waste groups do not warrant designation as separa te waste streams as required by the WCPIP,
Revision 2.

Because the T1 request did not include any new e quipment or additional new processes on site at SNL, EPA conducted a desktop review of this ch ange, concluding that SNL-CCP’s plan to use the EPA-approved system of controls to char acterize the debris wa ste from the PKE00027/54 and PKE00047 waste groups was acceptable. EP A did not identify any findings or concerns during this evaluation. As a result, EPA approves th e T1 change request to add containers from the PKE00027/54 and PKE00047 waste groups to th e previously approv ed RH TRU Waste
Stream SNL-HCF-S5400-RH.

In the case of PKE00027 waste grouping, SNL-CCP collected five waste samples for radioassay. The analytical results for four out of five waste samples, however, were not RH or TRU. The documentation we reviewed, namely, the post-sampling memorandum, did not adequately describe the impact of these results on the deve lopment of scaling factor s and the disposition of
waste containers in this wast e group. EPA discussed this i ssue with CBFO and SNL-CCP and stated that SNL-CCP should revise the post- sampling memorandum discussing explicitly how waste sample data were used. At CBFO’s s uggestion, SNL-CCP added a footnote “data are
valid” to one of the tables wher e the data were presented. EPA informed CBFO that this change was inadequate objective evidence and asked CBFO to provide a bett er rationale. CBFO’s response letter dated March 28, 2012, explained whic h waste sample data were used. This CBFO response is satisfactory.

To better support EPA’s approval, EPA recommends that changes be made to the WCPIP the next time it is revised. These changes would sp ecify the importance of agreement between the objective evidence that documents a waste charac terization process and th e process itself, and would prevent recurrence of the situation EPA encountered with the documentation for
PKE00027/54.

This approval is limited to parcels fro m the PKE00027/54 and PKE00047 waste groups; however, it does not necessarily limit the number of containers that can be characterized using the radiological process de scribed in CCP-AK-SNL-501, Revi sion 2. CBFO has informed EPA that SNL-CCP does not expect to characterize ad ditional RH debris waste or add additional RH6 debris containers to these two PKEs or the pr eviously approved PKE00044 in the foreseeable future. However, if SNL-CCP resumes RH waste characterization activities, the tiering requirements included as Table 1 in the final baseline inspection report remain applicable, as does the process for adding containers to the a pproved waste stream described in EPA’s final approval. As a result, no specific mention of T1 and T2 changes is made in the remaining sections of this report.

This report serves as EPA’s public notification of the results of the proposed T1 change and its evaluation. EPA will provide this information through the EPA website and by sending emails to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3).

2.0 PURPOSE 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, as amen ded, and incorporated into the November 2011 SNL-CCP RH baseline final report (Docket No.: A-98-49; II-A4-155).

EPA must perform a single ba seline inspection of a TRU waste-generator site’s waste characterization program, in order to approve the site’s waste characterization program. 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 t hose requiring post-implementation notification [Tier 2 (T2)] are identified in the site-specific baseline inspection reports. When evaluating proposed T1 changes for approval, EPA may conduc t a site inspection to observe firsthand the implementation of the change or can opt to c onduct a desktop review of information provided specific to a change. DOE may choose to characte rize and dispose of any previously approved TRU waste using processes, procedures and equi pment implemented as T2 changes at risk of subsequent EPA disapproval. EPA reviews T2 changes on a quarterly basis and may conduct continued compliance inspections to evaluate imp lemented T2 changes to verify adequacy.

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluation of a T1 change to add containers generated from the PKE00027/54 and PKE00047 waste groups to Waste Stream SNL-HCF-S5400-RH, as described in CCP-AK-SNL-500, Revision 4, and CCP-AK-SNL-501, Revision 2, Appendices A and B. This report presents the technical basi s and results of EPA’s approval decision. EPA’s approval has been conveyed to DOE separately by letter. EPA will also announce the decision on its website at www.epa.gov/radiation/wipp in accordance with 40 CFR 194.8(b)(3).

The DOE documents that EPA reviewed for this evaluation are cited in different sections throughout the report and are listed in Attachment A. Any of these documents can be requested from the following address:7 Manager, National TRU Program
Carlsbad Field Office U. S. Department of Energy
P.O. Box 3090 Carlsbad, NM 88221-3090

4.0 SCOPE OF THE TIER 1 EVALUATION

The scope of this evaluation is the addition of containers generated from the PKE00027/54 and PKE00047 waste groups to Waste Stream SNL-HC F-S5400-RH. Based on criteria set forth by EPA during the SNL-CCP baseline inspection, a T1 request is re quired for characterization of
containers from the PKE00027/54 an d PKE00047 waste groups. Theref ore, the scope of the T1 request is to evaluate the a ddition of containers generate d from the PKE00027/54 and PKE00047 waste groups to Waste Stream SNL-HCF-S 5400-RH, as specified in CCP-AK-SNL-501, Revision 2, Appendices A and B, and CCP-AK-SNL-500, Revision 4.

Sections 6.1 through 6.3 of this report detail the three techni cal areas assessed during this
evaluation:

• AK.

• Radiological characterization.

• VE.

This evaluation involved expanding an existing waste stream to incorporate new containers and not the addition of a new summary category group or waste stream; therefore, EPA did not use inspection checklists.

5.0 EVALUATION PERSONNEL

EPA and its support personnel c onducted interviews with SN L-CCP personnel in several disciplines by telephone. The EPA evaluation team members and the personnel contacted are
listed in Table 1 with their affiliations and tech nical areas of expertise. This list includes personnel present at meetings conduct ed as part of this evaluation.8 Table 1. Tier 1 Evaluation Personnel

Personnel Name Affiliation Area of Expertise, Function
Rajani Joglekar EPA ORIA Tier 1 Evaluation Lead
Ed Feltcorn EPA ORIA Tier 1 Evaluation Team Connie Walker SC&A Acceptable Knowledge, Technical Inspector Kira Darlow SC&A Acceptable Knowledge, Technical Inspector Amir Mobasheran SC&A Radiological Characterization, Technical Inspector Patrick Kelly SC&A Radiological Ch aracterization, Technical Inspector Rose Gogliotti SC&A Radiological Characterization, Technical Inspector Kevin Peters CCP-TechSpecs Acceptable Knowledge Expert Dorothy Gill SC&A Visual Exam ination, Technical Inspector John Kleckner CCP-TechSpecs Acceptable Knowledge Expert Steve Schafer CCP-TechSpecs Acceptable Knowledge Expert Jene Vance WTS-CCP Radiological Ch aracterization, Technical Expert Irene Quintana WTS-CCP Remote Handled Site Project Manager

6.0 TECHNICAL EVALUATION

Waste-Generating Activities

CCP-AK-SNL-500 [the AK summary report (AKSR) ], Revision 4, describes Waste Stream SNL-HCF-S5400-RH as consisting of 32 waste parc els packaged in 29 containers, 27 of which are shielded and two unshielded. The 32 waste pa rcels were generated during decontamination operations in the SNL HCF from 1995 to 1997 (References I1030 and M1016). The waste originated from pre- and post-test processes associated with reactor fuel studies conducted in the HCF SCBs, Zone 2A, and Gloveboxes 1, 2 and 3 between the late 1970s and the mid-1990s. Different experiments were conducted in the SC B/Zone 2A area and Gloveboxes 1, 2 and 3, but source term (ST) experiments were common to all of these areas (References C1004, M1016, M1019, P1015, P1102 and P1104).

The PKE00027/54 portion of the waste stream (two single-parcel drums and one drum containing one PKE00027/54 parcel commingled with two PKE00047 parcels) resulted primarily from ion chromatography studies of fission products, mainly from light-water reactor fuels, in Glovebox 3. The PKE00047 portion of the waste stream (seven single-parcel drums and one drum containing one PKE00027/54 parcel commi ngled with two PKE00047 parcels) resulted primarily from experiments involving breeder mixed-oxide reactor fuels, including fuel disruption studies, transient axial relocation studies, and effective equation of state experiments,
in Gloveboxes 1 and 2.

PKE00027 was originally developed assuming that the parcels were low-level waste, but SNL
determined that some were TRU and created PKE00054 for wastes originally designated as
PKE00027. Different SNL-CCP documents refer to PKE00027 and PKE00027/54. For consistency, this report uses PKE00027/54 to indicate the population of TRU debris waste generated from Glovebox 3.9 Process Knowledge Evaluation and Waste Stream Delineation

SNL-CCP determined that Waste Stream SNL- HCF-S5400-RH should be divided into three separate portions because the radi onuclide distributions in waste from the SCB/Zone 2A area and from the gloveboxes were different. Wastes ge nerated during experiments were typically retained in the cells or areas of generation. Duri ng decontamination of the HCF, there was little or no commingling between the waste-generating sources (i.e., the SCB/Zone 2A area and the gloveboxes). Regulated Waste/Nucl ear Material Disposition De partment (RWNMDD) personnel developed and used process knowledge evaluation (PKE) reports to establish the radiological characterization of each parcel based on info rmation provided in the disposal request documentation (Reference M1016). SN L-CCP followed this pattern a nd developed a separate set of scaling factors for each of the three groups described in Table 2 to account for the three distinct, area-specific radiological signatures.

Table 2. Summary of PKE Reports

Document

Number Waste-Generation
Source Number of
Parcels Number of
Drums

PKE00044 SCBs and Zone 2A 19 19
PKE00047 Gloveboxes 1 and 2 7 7
PKE00027/54 Glovebox 3 5 3

Despite the differences discussed above, the AKS R combined waste generated in the gloveboxes, SCBs, and Zone 2A into a single waste stream based on (1) the similarity of waste generation processes and summary category groups, (2) co mmon sample storage areas, and (3) equipment sharing and overall cross-contaminati on between gloveboxes (References C1004, M1016, M1019, P1015, P1102 and P1104). The portion generate d in the SCB/Zone 2A area of the HCF in Building 6800 and designated as PKE00044 was evaluated and approved for characterization during Baseline Inspection No. EPA-SNL-CCP -RH-06.11-8 (EPA Docket No. A-98-49; II-A4- 155). Therefore, this current evaluation and appr oval are limited to the ad dition of parcels in PKE00027/54 and PKE00047. [See Section 6.1, Item (1) for discussion and acceptance of the waste stream definition.] The total number of containers in both PKEs initially proposed by SNL-CCP is based on the AKSR, Revision 4, an d CCP-AK-SNL-501, Revision 1, both prepared
in November 2011. The numbers do not coincide with current estimat es, which are lower
because containers were removed from the RH waste stream, as discussed below.

SNL-CCP initially identified PKE00047 as includi ng nine parcels in eigh t containers, but one container containing two PKE 00047 parcels was found to be co mmingled with waste from PKE00027/54, and it was reassigned to PKE00027/ 54 for sampling purposes. EPA found that
Gloveboxes 1 and 2 were interconnected and shared experiments and the waste from these two gloveboxes is considered togeth er in this T1 review.

SNL-CCP originally included four parcels in PKE00027/54 but moved a parcel from PKE00047 to PKE00027/54 for radiological sampling purposes b ecause it was in a 30-gallon drum with two other PKE00027/54 parcels. This drum contained three waste parcels, which is why there are more parcels than drums.10 Documents, Waste Containers and Batch Da ta Reports/Calculation Packages Provided

EPA evaluated the documentation that SNL-CCP prep ared to support the incl usion of containers generated from PKE00027/54 and PKE00047 in Waste Stream SNL-HCF-S5400-RH. EPA’s
review identified several technical issues th at necessitated revision of the AKSR, CCP-AK-SNL502, some of the associated AK documentation and CCP-AK-SNL-501. SNL-CPP provided the revised documents to EPA prior to the conclusion of this T1 ev aluation. Attachment A lists all documentation and BDRs reviewed by EPA for this evaluation.

6.1 Acceptable Knowledge

EPA examined the AK process and associated information to determine whether SNL-CCP demonstrated compliance with 40 CFR 194.8 requirements and can include the containers generated from PKE00027/54 and PKE00047 in Waste Stream SNL-HCF-S5400-RH.

Waste Characterization Element Description

As part of the inspection, EPA reviewed the following with respect to programmatic requirements and the use of AK fo r RH waste characterization:

• Inspection scope and waste stream identification.

• Identification and adequacy of the WC PIP waste characterization process.

• Adequacy of the Certification Pl an and other WCPIP documentation.

• Adequacy of training.

• Adequacy of the Waste Stream Profile Form (WSPF) and related attachments.

• Adequacy of nonconformance reports (NCRs) a nd discrepancy resolu tion (DR) reports.

• Waste stream definition, 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).

• Role of AK in the characterization methodology, including scaling factors.

• Adequacy of the AK procedure and procedur e implementation, including attachments, AK accuracy reports, characterization rec onciliation reports (CRRs), and CSSFs.

• Adequacy of the AKSR and associated source documents.

• AK data traceability.

• Attainment of data quality objectives (DQOs).

Technical Evaluation

EPA evaluated the adequacy of AK information for the PKE00047 and PKE00027/54 parcels to determine whether including these parcel s in Waste Stream SNL-HCF-S5400-RH was11 adequately supported, as described in the ASKR, Revision 4, and CCP-AK-SNL-501, Revision
2. EPA also evaluated the records relative to the programmatic requirements in the WCPIP.

(1) Several items reviewed by EPA as part of th e baseline approval were not affected by the
inclusion of PKE00047 and PKE00027/54 in Waste Stream SNL-NCF-S5400-RH. Therefore, this T1 review did not examine the following elements (see the baseline report (EPA Docket A-98-49; II-A4-155) for a fu ll discussion of each of these items):

• Defense origin was assessed and found to be adequate.

• Identification of HLW and SNF was assessed and found to be adequate.

• Interpretation of WCPIP with respect to contents of the Certification Plan and
Confirmation Test Plan was evalua ted and found to be satisfactory.

• Personnel training was evaluated and was found to be adequate.

• Attainment of DQOs was evalua ted and found to be adequate.

(2) The scope of the T1 request and waste stream determination were examined for Waste
Stream SNL-HCF-S5400-RH and found to be adequate (WCPIP, Section 3.0, p. 13). 7

The scope of the T1 request was adequately defined. The purpose of EPA’s T1 evaluation was to determine if it is technically defensible and a ppropriate to include parcels (repackaged in SNL waste drums) originating from PKE00047 and PKE00027/54 in Waste Stream SNL-HCF-S5400- RH. EPA also evaluated the adequacy, implementa tion and effectiveness of technical processes
that SNL-CCP used to characterize de bris waste from PKE00047 and PKE00027/54.
The WCPIP defines a waste stream as waste materi al that is (1) genera ted from a single process or activity and (2) is similar in material, physical form a nd radiological properties. EPA examined AK information presented in the revised AKSR, Revision 4, and related source documents to determine whether the waste stream was adequately defined.

ST experiments were common to the SCB/ Zone 2A area (PKE00044), Gloveboxes 1 and 2 (PKE00047), and Glovebox 3 (PKE00027/54). EPA evalua ted the nature of the ST experiments performed, the movement of material between areas, and commonality of activities to determine whether these justify placing all three PKEs in a single waste stream. The ST program investigated fission product releas e from irradiated and nonirradiated fuel under severe accident
conditions. Irradiated fuels were obtained fr om Belgian Reactor 3 (Mol, Belgium), and
nonirradiated fuels were fabricated at Battelle Pacific Northwest Laboratories. Source documents indicate that ST experiments and tests involving irradiated fuel were performed in the SCB/Zone 2A area (PKE00044), Gloveboxes 1 and 2 (PKE00047) and Glovebox 3 (PKE00027/54). Reference P1102 suggests that test material was originally receiv ed in the SCB/Zone 2A area. Fuels were then transferred to “shielded glove boxes” (i.e., Gloveboxes 1 and 2) for sectioning and test assembly packaging. The test assembly was transferred to the Annular Core Research Reactor and neutronically heated to 2,400 kelv in. Source documents do not state where post-

7 The WCPIP references are examples and are not meant to be an exhaustive list. Many of these requirements are discussed in se veral places within the WCPIP.12 heating experiments were perfor med, but Reference P1102 states that fission product release observation took place in the SCBs, so EPA assume s that the experiments were conducted in the
SCBs. Filters or other material from these tests were sent to Glovebox 3 for ion chromatography, and the heated, irradiated material was sent to Gloveboxes 1 and 2 for further metallurgical analyses (References M1015, M1020b, M1021 and P1105). Source documents suggest that irradiated ST experiments were moved throughout the hot cell f acility during the course of experimentation and subsequent analyses, with the SCB/Zone 2A area, Gloveboxes 1 and 2, and Glovebox 3 all used in the ST experimental process. Commona lity of experiments between the SCB/Zone 2A area, Gloveboxes 1 and 2, and Glovebox 3 was ad equately demonstrated (References P1102 and P1015).

Historical records indicate that the p hysical compositions of PKE00027/54 and PKE00047 are adequately understood and support the waste st ream determination. PKE00027/54 is composed of five parcels, the contents of which are desc ribed in accompanying disposal requests generated by SNL-CCP. For example, DR204139, associated with Parcel P2000988 and SNL Drum No. SNLNM007020, says that the parcel is composed of a one-gallon can that contains “GB3” sweepings ( References M1016, M1019, M1020 and M1020b) . SNL-CCP’s VE of the final 30- gallon container (later overpacked into a 55-gallon drum) in which material from the one-gallon container was placed verifies that the waste is composed of various debris, bags, sweepings and shavings. PKE00047 is composed of seven parcels, and t he PKE00047 report states that the
waste includes decontamination material such as rags and wipes, as well as tools and pieces of metal (e.g., steel, aluminum), trash and debris from the empty gloveboxes, and associated box components (Reference M1020b).

SNL-CCP prepared PKE00044, PKE00027/54 and PKE00047 reports that assign unique radiological signatures to each PKE wast e grouping (References M1016, M1020b, M1021 and CCP-AK-SNL-501, Revision 2). However, these repor ts and other information also show that the PKEs exhibit some radiological similari ties. Radiological inform ation in other source documents and obtained through samp ling indicates that uranium-235 ( 235 U) and 238 U are the predominant isotopes by mass in all three PKEs. Al so, PKE reports indicate that the predominant TRU isotope in the three PKEs is plutonium-239/240 ( 239/240 Pu). Based on a review of the radiological distributions assi gned to the waste in the thr ee PKEs and excluding cesium-137 ( 137 Cs) and strontium-90 ( 90 Sr), the distribution of the remaining isotopes [americium-241 ( 241 Am), 238 Pu, 239/240 Pu, promethium-147 ( 147 Pm) and 241 Pu] in each PKE are relatively similar. Specifically, the three PKEs exhibit similar mass percent 239/240 Pu, 241 Am and 241 Pu (References C1038, M1016, P1015, P1102 and P1104). The three PKEs appear to have a similar general radiological composition that s upports including all three PKEs in a si ngle waste stream, although sampling of parcels from each PKE is required to obtain PKE-specific radiological
distributions. See Section 6.2 for additional info rmation about the radiological composition of
PKE00027/54 and PKE00047.

(3) Example nonconformance documentation and discrepancy resolution reports were examined and found to be adequate (WCPIP, Section 3.4.2.3, p. 24).

SNL-CCP provided an example NCR rela ted to PKE00027/54. NCR No. NCR-RHSNL-2345- 11, Revision 0, applied to Drum No. SNLNM007 020 and addressed discrepant drum number identification on CCP-TP-005, Attachment 8. SN L-CCP Discrepancy Report DR1004 addressed13 the identification of paperwork showing that PKE00047 and PKE00027/54 parcels were combined during repacking and genera tion of SNL Container No. C080216.

(4) The acceptable knowledge procedure was examined and found to be adequate and appropriately implemented (WCPIP, Section 4.1, pp. 32–33).

Since the approval of Revision 22 during th e baseline inspection, CCP revised CCP-TP-005 twice more, as part of the resolution of CBFO CAR11-043 (Revision 23) and again to incorporate additional WCPIP requirements on November 28, 2011 (Revision 24). EPA found that CCP-TP-005, Revision 24, reflected all applicab le WCPIP requirements and expects that all document revisions and procedure implementations will follow the requirements in the revision of CCP-TP-005 that is in place at the time of th e activity. AK documents submitted with this T1 request were created under Revisions 22, 23 or 24 depending on when the document was generated, and this is adequate.

CCP-TP-005, Revision 24, includes 15 attachments and requires development and maintenance of an AK Tracking Spreadsheet that presents a running compilation of containers within each waste stream at a site. Many of these attachment s were provided with the original baseline inspection, so only those attachments with new in formation pertinent to this T1 request were provided to and reviewed by EPA. SNL-CCP pr ovided updated versions of Attachments 1, 4, 6, 8, 13 and 14 that included changes incorporating PKE00027/54 and PKE00047.

• Attachments 1 and 4 were adequate, because Attachment 4 had been updated to include recent radiological references.

• Attachment 6 is addressed in Item (5).

• Attachment 8 is also adequate because it includes containers from PKE00027/54 and PKE00047. SNL-CCP also provided the AK Tr acking Spreadsheet that identified container and parcel numbers, associated PKE, associated disposal records, and container status. Note that Attachment 8 was prep ared in June 2011, while the AK Tracking Spreadsheet was printed in September 2011. Th e AK Tracking Spreadsheet indicates that
several containers are “no l onger in the RH population,” but these containers are still presented on Attachment 8. This discrepancy is acceptable but emphasizes that all data sources (Attachment 8, AK Tracking Spreadsh eet, and Add Container Memoranda) must
be examined to understand the containers in the waste stream at any given time.

• Attachment 13, the waste characterization checkli st, was prepared in draft and adequately demonstrates SNL-CCP’s ongoing ability to prepare this attachment.

• Attachment 14, the AK accuracy report , is addressed in Item (8).

Relevant CCP-TP-005 attachments were adequately prepared.14 (5) The acceptable knowledge summary report was ex amined, along with associated source documents, and found to be adequate (WCPIP, Section 4.1, p. 31).

Since the baseline inspection, SNL-CCP revised th e AKSR twice: to modify the hazardous waste numbers assigned to the waste stream (Revisio n 3), and to change the TRU Content Code assignments (Revision 4). In this T1 review , EPA examined Revision 4, which addressed EPA concerns about whether PKE00044, PKE00027/54 a nd PKE00047 belonged in the same waste

stream.

SNL-CCP created Revision 4 of the AKSR to bette r identify process areas; include complete radiological information; explai n the flow between process ar eas; identify common processes with respect to the SCB/Zone 2A area, Gl oveboxes 1 and 2, and Glovebox 3; and justify the waste stream determination. The AKSR, Revision 4, adequately justifies th at waste belonging to PKE00044, PKE00047 and PKE00027/54 constitutes RH Waste Stream SNL-HCF-S5400-RH [see Item (1)]. The AKSR, Revision 4, includes Table 10 that addresses the characterization process. EPA recommends that SNL-CCP revise this table during the next revision cycle to
remove mention of the term “qualification.”

(6) The radiological and physical properties of the waste stream were examined and found to be adequately described for PKE00027/ 54 and PKE00047 wastes based on acceptable knowledge (WCPIP, Section 3.0, p. 13).

The AKSR, Revision 4, describes wastes from Waste Steam SNL-HCF- S5400-RH as organic and inorganic debris generated during the de structive and nondestru ctive examinations conducted in the HCF, including items from the va rious cells and gloveboxes. The waste stream includes paper and cloth items, bottles, jars, tubi ng, glovebox gloves and wast e, gaskets, stainless steel hardware, buckets, plates , machinery, tubing and various aluminum items (References C1039, M1016, M1019, M1020 and M1021).

The physical composition of the waste stream is adequately defined. SNL-CCP presented estimated waste material parameter weight-percent calculations and distribu tions by parcel from
each PKE in a memorandum to Attachment 6 of CCP-TP-005, Revision 22. This memorandum indicates that the waste stream is compose d, on average, of 84.5% inorganic waste and 15.5% organic waste, with the predominant average waste material parameters being iron-based metals (62.1%), aluminum-based metals (10.1%), plasti c (8.3%) and other inorganic materials (7.8%). Parcel data show that PKE00047 is composed primar ily of metal, consistent with the distribution expected for the waste stream as a whole. PKE00027/54 includes only three containers, and waste material parameter information was missing from the AK record for one parcel used to generate Attachment 6. SNL-CCP representative s verified that the missing container underwent
VE and contains waste constituents consiste nt with the waste stream; the remaining
PKE00027/54 AK container data are also consistent with the overall waste stream description.

AK data indicate that the predominant radi onuclides in both PKEs include cobalt-60 ( 60 Co), 90 Sr,

235 U, 238 U, 137 Cs and small amounts of TRU radionuclides, primarily 238 Pu, 239 Pu and 241 Am (References M1016, M1019, M1020 and M1021). In the late 1990s, SNL RWNMDD waste15 handlers initially characterized RH containers with high dose 8 rates using only a portable gamma system. SNL-CCP confirmed the list of radi onuclides in PKE00027/54 and PKE00047 in the early 2000s, based on limited swipe samples collected from the parcels that were analyzed by
destructive and nondestructive radiometric an alyses. The measurements indicated that PKE00044, PKE00027/54 and PKE00047, while contai ning many common radionuclides, also showed different quantities and distributions that differentiated the three PKEs. SNL-CCP found that the measurements were sufficiently accura te to differentiate TR U and non-TRU waste based on the 100-nanocuries-per-gram (nCi/g) criterion. Table 3 presents a comparison of the SNL sampling results and the original PKE00047 ra dionuclide activities (R eferences M1016, M1020 and M1021).

Table 3. PKE00047 Radionuclide Ac tivity Ratio Comparison

Radionuclide Measured Activity
Ratio to 137 Cs PKE00047 Activity Ratio to

137 Cs Measured Activity Ratio to

241 Am PKE00047 Activity Ratio to

241 Am

241 Am 4.09E-02 1.00E+00 1.00E+00 1.00E+00

238 Pu 2.56E-02 3.50E-03 6.27E-01 3.50E-02

239/240 Pu 4.01E-02 1.30E-02 9.80E-01 1.30E-01

90 Sr 6.85E-01 1.00E+00 NA NA

147 Pm 2.13E-02 --- NA NA

241 Pu 3.97E-01 --- 9.71E+00 ---
TRU alpha 1.07E-01 1.17E-01 2.61E+00 1.17E+00 NA: Not applicable because this is not a transuranic radionuclide.
Source: AKSR.

SNL-CCP determined that calc ulation errors compromised th e original PKE00027/54 activity ratios. SNL-CCP performed additional sampling and analysis in 2008 to determine representative radionuclide activity ratios (Refer ences M1020 and M1021). Table 4 presents a summary of the 2008 revised ratios used by SNL-CCP to ch aracterize waste ge nerated from Glovebox 3 (Reference M1016).

8 “Rem” or “millirem” is a unit of dose equivalent, which is often commonly called “dose” or, when it is expressed per unit time, a “dose rate.” The criterion for RH determination is expressed in terms of a dose rate in rem, which, while technically incorrect, is commonly used. In this report, the terms “dose” and “dose rate” are used in place of the technically correct term s “dose equivalent” or “dose equivale nt rate.” The actual differences among these values for the purpose of this report are negligible.16 Table 4. Radionuclide Activi ty Ratios for PKE00027/54

Radionuclide Measured Activity
Ratio to 137 Cs Measured Activity
Ratio to 241 Am

241 Am 8.99E-05 1.00E+00

243 Am 3.05E-06 3.39E-02

238 Pu 1.41E-05 1.56E-01

239 Pu 4.91E-05 5.46E-01

242 Pu 1.41E-06 1.57E-02

90 Sr 3.05E-02 NA

137 Cs 1.00E+00 NA

147 Pm 5.63E-05 NA

241 Pu 2.67E-04 NA
TRU Alpha 1.58E-04 1.75E+00 NA: Not applicable because the radionuclide is not transuranic.
Source: AKSR.

The radiological composition of the each PKE and related parcels is adequately described in AK
source documents. EPA understands th at the information in these tables is based on AK source documents and may not correspond to SNL-CCP pa rcel sampling results presented in CCP-AKSNL-501. However, AK radiological information ade quately demonstrates the availability and use of AK information to describe the general radiological composition of the waste stream.

SNL-CCP used radionuclide information from the DR documents and other AK to develop a summary of the radionuclides in all 32 waste parc els at the time the evaluation was performed; a few parcels have since been removed from the RH population. The evaluation included data for PKE00044, PKE00027/54 and PKE00047. (See the base line report for further details.) The radiological compositions of each parcel, the groups of parcels in each PKE, and all parcels as a whole are adequately described.

(7) The Waste Stream Profile Form and attached characterization reconciliation reports were examined and found to be adequate (WCPIP, Section 3.4.2.1, p. 22).

SNL-CCP provided EPA with a draft WSPF and the PKE00047 and PKE00027/54 CRRs; the draft WSPF was dated and signed December 6, 2011. The WSPF states that the waste stream
includes 28 containers in 10 RH casks. This container number does not coincide with the number stated in the AKSR or the number presented in the AK Tracking Spreadsheet, which indicates that only 20 containers remain in this RH waste stream. The draft WSPF presents an accurate representation of the waste stream at the time the form is prepared, and additional
characterization has caused several containers to be removed from the RH waste stream. See Item (4) above for a description of how the actua l number of containers in a waste stream is determined at any given point in time.

The draft WSPF did not specify the batch data report (BDR) numbers supporting waste stream
characterization and instead referenced the ch aracterization information summary (CIS). The CIS is not required or mentione d in WCPIP or CCP-TP-005, Revisi on 24, but preparing a CIS is17 necessary to meet WCPIP requirements. On December 20, 2010, SNL-CCP prepared a draft PKE00027/54 CIS for inspection purposes only that will be updated to include additional
characterization information as the containers are characterized. Togeth er, the draft WSPF and draft CIS are complete and adequate.

SNL-CCP prepared a draft PKE00027/54 CRR on December 20, 2010. The CRR is a draft
document and therefore does not include the Site Project Manager (SPM) signature and date. The revised draft CRR is adequate.

(8) The acceptable knowledge accuracy report was examined and found to be adequate; a Correlation and Surrogate Summary Form was not required (WCPIP, Sections 4.1, p. 30; and 3.2.2, pp. 17–19).

SNL-CCP prepared a draft AK accuracy report for Lot 2 on May 31, 2011, which included four
containers that were associated with PKE00027/54 at that time. The report states that Container Nos. SNLNM007023 and SNLNM007021 were rejected because their TRU activity was below 100 nCi/g. Also, Parcel 9800776 in SNL Contai ner No. C980313 was rejected because the summary category group is S3000, and external dose r eadings indicate that this container is not TRU waste. As a result, the AK accuracy of Waste Stream SNL-HC F-S5400-RH PKE00027/54 containers was 25% when the AK accuracy re port was prepared, and 3 of the 4 PKE00027/54 containers failed to meet the DQOs of CCP-AK-SNL-502. The WCPIP requires EPA notification if the AK accuracy falls below 90%. An SNL-CCP representative stated that EPA will be notified following certification of PKE00 027/54. EPA expects to receive this notification when the T1 request is approved.

Waste Stream SNL-HCF-S5400-RH has a compani on CH waste stream, but the CH information
was not used to characterize this RH waste stream. If CH informati on is used to characterize RH waste, a CSSF is required.

(9) Container data are adequately traceable a nd are in the AK record (WCPIP, Sections 3.4.4.1, p. 20; 3.4.2.2, p. 23; and 4.1, pp. 29–34).

SNL-CCP provided traceability informa tion for CCP Container Nos. SNLNM7020 (PKE00027/54) and SNLNM7024 (PKE00047). A prim ary source of container traceability information are the Disposal Request Forms in Reference M1016, which include the location and date of parcel packaging, a list of the parcel contents (in some cases this includes information about the contributing experiment), and the date the parcel was tr ansferred to the Manzano Base. The AK Tracking Spreadsheet provided by SNL-CCP also correlated the CCP container number, SNL 30-gallon container numbers, SNL container number and old/new parcel numbers. From packaging to disposal, each parcel was assigned or associated w ith several different identifiers, including:

• Disposal Request Form.

• Original packaging parcel number.

• New parcel number assi gned at a future date.18 • SNL-assigned container into which the parcel was placed for storage.

• Number of the 30-gallon drum into which th e parcel was or will be repackaged during
VE.

• Number of the 55-gallon drum into which the 30-gallon drum was packed (SNL-CCP drum number).

Table 5 presents traceability information fo r the two containers provided by SNL-CCP.
Container data are in the AK record and ar e traceable to packaging records from the decontamination operations in the HCF.

Table 5. Container Traceability

CCP 55-
Gallon Drum
Number 30-
Gallon
Drum
Number Container
No. Original
Parcel
Number Parcel
No. Disposal Request

Form Packaging
Date and
Location Contributing Experiment (if known) Transfer
Date to
Manzano Storage

SNLNM007020 P1110158 C200357 204139 P2000988 204139 Prior to
12/05/97
Glovebox 3 ST 3/01/00

SNLNM007024 P1110156 C980391 TRUHCF-97-
06 P9800962 005940 01/23/83
Gloveboxes

1 and 3 Unknown 6/8/98

Summary of Acceptable Knowledge Findings and Concerns

During this T1 change evaluation, the EPA eval uation team did not identify any AK-related findings or concerns relative to the inclusion of c ontainers generated from PKE00027/54 and
PKE00047 in Waste Stre am SNL-HCF-S5400-RH.

Changes to Acceptable Knowledge Tiering

There are no changes to the AK tiering based on the results of this T1 evaluation. As stated in the Executive Summary, if SNL-CCP were to ch aracterize additional RH wastes from PKE00027/54, PKE000457 or PKE00044 in the future , the tiering conditions and limitations
included in Table 1 of the baseline approval report are applicable.

Acceptable Knowledge Approval

Based on the results of this evaluation, EPA a pproves inclusion of containers generated from
PKE00027/54 and PKE00047 in Waste Stream SNL-HCF-S5400-RH and finds that all procedural requirement s have been met.19 6.2 Radiological Characterization

Radiological Characterization Overview

The radiological characteri zation of parcels PKE00027/54 an d PKE00047 of SNL-CCP Waste Stream SNL-HCF-S5400-RH relies on DTC in conj unction with radionuclid e-specific scaling factors. The scaling factors were developed i ndependently for these two waste parcels, based primarily on two sources of information:

• AK for Waste Stream SNL-HC F-S5400-RH, as summarized in the AKSR and associated
source documents.

• Radionuclide-specific laboratory results from the analysis of smear samples collected for
all three containers of waste from PK E00027/54 and, separately, for five randomly selected drums from PKE00047, as summar ized in CCP-AK-SNL-501, Revision 2, and its supporting calculation packages.

Overviews of the radiological characterization processes us ed for PKE00027/54 and PKE00047 are depicted separately in CCP-AK-SNL-501, Revision 2, Figures A2-1 and B2-1. EPA combined these in a single flow diagram provided in Figure 1 below.

EPA evaluated the radiological characterization methods us ed for PKE00027/54 and PKE00047 in terms of the technical adequacy of the a pproach, as supported by the program’s documents, procedures and controls, and th e knowledge and understanding of the personnel involved in the RH waste characterization program.

Documents Reviewed

Attachment A includes all documents that were examined to support this T1 evaluation.20 Figure 1. Flow Diagram of the Charac terization Process for PKE00027/54 and
PKE00047 Locate and retrieve relevant
records.

Develop and execute a sampling plan to obtain representative samples from
PKE00027/54 and
PKE00047.

Use laboratory results to develop container-specific

137 Cs-based scaling factors
for PKE00027/54 and one set
of 137 Cs-based scaling factors
for PKE00047. Use MicroShield ® to model the external gamma dose rate at 1 meter as a function of waste density to develop a 137 Cs DTC correlation based on a 1-Ci
source of 137 Cs

Develop DTC conversion factor (density correlation equation in mR/hr/Ci) for 137 Cs for 30-gallon drum overpacked in a 55-gallon drum.

Find mean gamma dose rate at 1 meter based on four measurements; determine the waste density based on the actual weight of drum contents and fill factor.

Divide the mean measured dose rate by the DTC
conversion factor to find the 137 Cs activity in curies.

Multiply 137 Cs activity by the scaling factors to
determine activities of radionuclides of interest.

Determine uncertainties
for radionuclides of interest. Submit samples to laboratory
to determine concentrations
of radionuclides of interest. Determine Scaling Factor: Determine DTC Conversion Factor:

Execute DTC to Determine 137 Cs Activity:21 Technical Evaluation

(1) EPA evaluated the methodology and the tec hnical approaches us ed to characterize
PKE00027/54 and PKE00047 and determined that they were technically adequate.

EPA reviewed the information that formed the ba sis of the radiological ch aracterization process, documented in Appendices A and B of CC P-AK-SNL-501, Revision 2, two post-sampling memoranda, and supporting calculation packages . The following aspects were evaluated:

• The methodology and the technical approach.

• The principal sources of the tw o PKEs and their distinction.

• The sampling procedures implemented by SNL-CCP.

• Collection of smear samples for PKE 00027/54: Container No. P1110155 (containing commingled PKE00027 Parcel P200 0836 and PKE00047 Parcels P9900533 and P9900534); Container No. P1110158 (containing Parcel P2000998); and Container No. P1110159 (containing Parcel P9800935).

• Collection of smear samples for PKE00047: randomly selected Container Nos. P1110156, P1110157, P1110198, P1110199 and P1110201, containing, respectively, Parcels P9800962, P9900529, P9800958, P9900532 and P9801007.

• Representativeness of laboratory samples, co mposites of at least three samples taken from each container/parcel sampled.

• The technical adequacy and documentation of th e analytical data used to develop scaling
factors.

• Use of small sample sizes to characterize the two portions of the waste stream and the impact on the scaling factor uncertainties.

• Derivation of three sets of container-specific, 137 Cs-based scaling factors using radiometric and spectrometric analyses of the smear samples from PKE00027/54.

• Derivation of a single set of 137 Cs-based scaling factors, using radiometric and spectrometric analyses of smear samples fr om five, randomly selected single-parcel
containers from PKE00047.

• Development of DTC correlation for 30-ga llon drums overpacked in 55-gallon drums using waste densities ranging from 0.2 grams per cubic centimeter (g/cm 3 ) to 1.8 g/cm 3

based on MicroShield ® modeling of the container’s exte rnal dose rate using a one-curie (Ci) source of 137 Cs.

• External gamma measurements (DTC) made at SNL, as evidenced by the DTC BDRs.

• Determination of reportable radionuclid es and the bounding analyses performed.

• Activity in Ci and mass in grams and the a ssociated uncertainties that were determined for the 10 WIPP-tracked radionuclides ( 233 U, 234 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 242 Pu, 241 Am,

137 Cs and 90 Sr), 235 U, 241 Pu, curium-244 ( 244 Cm), 245 Cm, yttrium-90 ( 90 Y) and barium137 m ( 137m Ba).22 • The appropriateness of the physical consta nts and radionuclide-specific attributes (specific activity, physical half-life, decay he at, neutron cross-sec tions, photon transition probabilities, etc.) and the technical correctne ss of the values assigne d to each attribute.

The constants and other values in the calculation packages were taken from the appropriate sources and were spot-checked for accurac y. Calculations were performed using Excel spreadsheets, as shown in CCP-AK-SNL-501, Revision 2, Figures A5-3 and B5-3, for PKE00027/54 and PKE00047, respectively. The i nput for these calculations includes:

• Date of characterization.

• Waste stream designation.

• Container number.

• Container gross weight.

• Container net weight.

• Measured contai ner dose rates.

There were no concerns regard ing the methodology and the technical approaches used for the radiological characterizati on of PKE00027/54 and PKE00047.

(2) Technical aspects and documentation of the radiological characteriz ation process were evaluated and found to be acceptable.

CCP-AK-SNL-501, Revision 2, is the main doc ument that describes the radiological characterization process, supported by a series of calculation packages, which were prepared or reviewed by SNL-CCP radiological characteriza tion personnel J. Holderness and J. Vance. EPA determined that CCP-AK-SNL-501 adequately do cumented the radiological characterization process for PKE00027/54 and PKE00047 and that the calculation packages in conjunction with the post-sampling memoranda dated August 10, 2011, for PKE00027/54 and August 26, 2011, for PKE00047 adequately supported the activities upon which the radiological characterization is
based.

(3) Technical aspects and documentation of the sample collection were evaluated and were found to be acceptable.

SNL-CCP developed a sampling plan for the co ntainers from both PKEs assuming that all containers were RH TRU, based on availa ble AK. Upon completion of the radiological characterization, some of the containers fell out of the waste stream because they were non-TRU (three from PKE00027/54) or CH TRU (one container from PKE00047). Additionally, in the
case of PKE00027/54 one container was not from the same waste matrix. Summaries of the samples collected for both PKEs are provided in Table 6 below, along with their parcel numbers, sample and laboratory identification numbers, 30-gallon and 55-gallon dr um numbers and final dispositions.23Table 6. Sample Disposition SummaryPKESample ID Nos.Parcel /30-Gallon/55-Gallon Nos.Lab. ID No.Sample DescriptionDrumDisposition27/54 SN03081101 SN03081102 SN03081103P2000998/P1110158/SNLNM70201DG50 &1DG50DPrimary & laboratoryduplicateRH TRU, Used forSF Development27/54 SN003241101 SN003241102 SN003241103P9800935/P1110159/SNLNM70211DG51 Primary sampleNon-TRU, Not Usedfor SF Development27/54 SN03301101 SN03311101 SN03311102P9800776/P1110154/1DG52 Primary sampleWrong Matrix, NotUsed for SFDevelopment27/54 SN04141101 SN04151101 SN04151102P2000836/P1110155/SNLNM70231DG53Primary sample, (firstsample from ContainerNo. P1110155)Non-TRU, Not Usedfor SF Development27/54 SN04151103 SN04151104 SN04151105P9900534/P1110155/SNLNM70231DG54Primary sample, (noncollocated, secondsample from ContainerNo. P1110155)Non-TRU, Not Usedfor SF Development47 P9800962-1 P9800962-2 P9800962-3P9800962/P1110156SNLNM70241DG61 &1DG61DPrimary & laboratoryduplicateCH TRU, Used forSF Development47 P9900529-1 P9900529-2 P9900529-3P9900529/P1110157/SNLNM70251DG62 Primary sampleRH TRU, Used forSF Development47 P9800958-1 P9800958-2 P9800958-3P9800958/P1110198SNLNM7012IDG63 Primary sampleRH TRU, Used forSF Development47 P9900532-1 P9900532-2 P9900532-3P9900532/P1110199/SNLNM70171DG64 Primary sampleRH TRU, Used forSF Development47 P9801007-1 P9801007-2 P9801007-3P9801007/P1110201/SNLNM70181DG65 Primary sampleRH TRU, Used forSF Development24 The post-sampling memoranda for both PKEs were developed prior to the determination of the
containers’ final status as RH or TRU, which presents two issues.

1. The scaling factors for PKE00047 were based on the analytical results of five samples, but one of the samples is CH TRU, not RH TRU. Since four out of five samples were RH, the impact of one sample being a CH sample is minimal and no revisions were

necessary.

2. The scaling factors, for PKE00027/54, howev er, were based on only a single RH TRU container (No. P1110158) out of five that we re sampled. The remaining four samples were either non-TRU or belonged to anothe r waste matrix. As a result only one RH container from this waste group was eligible for WIPP disposal. Accordingly, the postsampling memorandum for PKE 00027/54 should have been re vised to document the effects of this change on the quality assuran ce (QA) objectives, as st ated in Section 3.0, and present an accurate description of the data analyses using the actual number of valid samples, i.e., one.

Several sections of the post- sampling memorandum for PKE00027/54 required revision to reflect the actual number of valid RH TRU samples th at were used to suppor t the development of scaling factors and their statis tical evaluation. EPA communicated these concerns to CBFO via a written memorandum on February 29, 2012, a nd CBFO provided a written response. EPA commented on the revised post-sampling memora ndum stating they were unsatisfactory. EPA arranged for a conference call to convey what revisions would be acceptable as appropriate objective evidence. Instead of fully explaining th e impact of non-RH waste samples on the drumspecific radiological content of RH contai ners in PKE00027/54, the revised post-sampling memorandum contained only two footnotes to Tabl e 2.1, simply stating that the data are valid. This response was not acceptable. The derivation of scaling factors must be based on samples that are representative of the RH TRU wastes in tended for disposal at WIPP. The changes made did not reflect this. Subsequently on Marc h 28, 2012, CBFO sent a response which is satisfactory.

EPA approvals are based on documented objective ev idence that reflects the actual events and conditions that form the characterization process, and not solely on subjective judgment, namely,
that the drums came from the same waste stre am, as asserted by CBFO. Documentation of a waste characterization process th at CBFO presents for EPA’s appr oval must represent the actual conditions for which the approval is sought. For PKE00027/54, all of the samples except one were ultimately classified as non-TRU wastes , yet the document of record (post-sampling memorandum) presented information to the contrar y. This mistake was even tually clarified but until it was, it created confusion and delayed the approval of the request.

To better support EPA’s approval, EPA recommends that changes be made to the WCPIP the next time it is revised. These changes would sp ecify the importance of agreement between the objective evidence that documents a waste charac terization process and the process itself, and would prevent recurrence of the situation EPA encountered with the documentation for
PKE00027/54.25 (4) Technical aspects and documentation of th e sample analysis were evaluated and were found to be acceptable.

The same radiometric and spectrometric techni ques were used for samples from PKE00027/54
and PKE00047. The results were documented in technique-specific BDRs, which EPA evaluated
for technical content. These ar e discussed separately below.

PKE00047

General Comments The tamper-indicating ratchet-t ype caps on 11 of the 15 swab samples were ineffective in demonstrating sample integrity, and the laboratory initiated NCR No. 63602 to address this issue. The disposition of the NCR was “Use As Is” be cause the shipping container tamper-indicating
device was intact when the cont ainer was received by the labora tory. The laboratory composited each set of three swabs into a single sample for analysis, one of which was designated as a laboratory duplicate in the post-sampling me morandum. However, the laboratory analyzed duplicate laboratory control standa rds (LCSs) as allowed by its own QA program for all analyses except gamma spectrometry, for which a duplicate sample was processed and identified as such in the post-sampling memorandum. Section 4.3.4.3 of the WCPIP allows a laboratory to defer to its own QA requirements if the laboratory ha s an established QA program, so this was acceptable.

The sample swabs were composited and leached in acid with a laboratory blank, LCS, and duplicate LSC (LSCD), unless noted below. The fo llowing sections discuss the pertinent details of each analytical technique.

Alpha Spectrometry, BDR No. ALD11021A – 241 Am and Isotopic Cm, Pu and U The BDR narrative stated that all quality cont rol (QC) requirements were met. The analyses performed on the sample leachates also included Am/Cm, 245 Cm, isotopic Pu, and isotopic U fractions. The report narrative did not identify any problems with these analyses. The BDR contained a completed “Sample Receiving a nd Custody Review Checklist – Analytical Laboratory,” in which initiation of NCR No. 63602 was recorded. The BDR also contained a completed “Independent Technical Review Ch ecklist – Actinides by Alpha Spectrometry.” “Attachment 7 – Site Project Manager Radiochemi stry or ICP-MS Analytical Batch Data Report
Checklist” was attached a nd completed as required.

Gas Flow Proportional Counting, BDR No. ALD11021B – 90 Sr The BDR narrative stated that all QC requireme nts were met. The BDR contained a completed “Sample Receiving and Custody Revi ew Checklist – Analytical Laboratory” form, in which
initiation of NCR No. 63602 was recorded. The BD R also contained a completed “Independent Technical Review Checklist, Radiostrontiu m by Gas-Flow Proportional Counting (GFPC).” “Attachment 7 – Site Project Manager Radiochemi stry or ICP-MS Analytical Batch Data Report
Checklist” was attached a nd completed as required.26 Gamma Spectrometry, BDR No. ALD11021G – 137 Cs and Gamma-Emitting Radionuclides The sample swabs were composited and leached in acid with a laboratory blank. The postsampling memorandum for PKE00047 identified Sample No. 1DG61 as the laboratory duplicate, but the laboratory analyzed Sa mple No. 1DG65 as a duplicate to assess precision. The BDR narrative stated that all QC requirements were met except for the detection limits for 134 Cs in one sample. Gamma spectrometry was performed for 60 Co, 134 Cs, 137 Cs, europium-154 ( 154 Eu) and other gamma-emitting radionuclides. The BDR c ontained a completed “Sample Receiving and Custody Review Checklist – Anal ytical Laboratory” form, in which initiation of NCR No. 63602 was recorded. The BDR also contained a comple ted “Independent Technical Review Checklist, Gamma Spectroscopy” and an “Attachment 7 – Site Project Manager Radiochemistry or ICP-MS Analytical Batch Data Report Checklist,” which was completed as required.

Inductively Coupled Plasma-Mass Spectrome try, BDR No. ALD11021I – Isotopic U and Pu

239 Pu was detected in the laboratory blank and in one instrument verification blank but the level was below required acceptance levels. LCS/LCSD duplicate analyses demonstrated acceptance precision. A post-digestion spike wa s prepared, one for Pu and one for U, and analyzed with acceptable recoveries. The BDR contained a comp leted “Sample Receiving and Custody Review Checklist – Analytical Laboratory” form, in wh ich initiation of NCR No. 63602 was recorded. The BDR also contained a completed “ITR Checklis t, Pu and U Isotopes by Inductively Coupled Plasma Mass Spectrometry.” “Attachment 7 – Site Project Manager Radiochemistry or ICP-MS Analytical Batch Data Report Checklist” wa s attached and completed as required.

Liquid Scintillation Counting, BDR No. ALD11021L – 241 Pu The Pu fraction of the leachate was separated us ing an approved laboratory method and was also used for the alpha spectrometry analyses discus sed above. The BDR narrative stated that all QC requirements were met, although a spiking error re quired that a blank and an LCS be leached in
acid a second time. The BDR contained a co mpleted “Sample Receiving and Custody Review Checklist – Analytical Laboratory” form, in wh ich initiation of NCR No. 63602 was recorded. The BDR also contained a completed “ITR Ch ecklist, Determination of Pu-241 by Liquid Scintillation Counting (LSC).” “Attachment 7 – S ite Project Manager Radiochemistry or ICPMS Analytical Batch Data Report Checklist ” was attached and completed as required.

EPA did not identify any issues with the analytical data for PKE00047.

PKE00027/54

General Comments The laboratory received sample containers with tamper-indicating caps; however, the laboratory determined that the containers could be ope ned without breaking th e seal. The laboratory
initiated NCR No. 63436 to addres s the ineffective sample seals that could not demonstrate sample integrity. The NCR was dispositioned as “Use As Is” because the shipping container tamper-indicating device was intact when th e container was receive d by the laboratory. The laboratory composited each set of three swabs into a single sample for analysis. A sample consisting of three swabs was designated as a laboratory duplicate in the post-sampling memorandum, but the laboratory analyzed duplic ate LCSs as allowed by its own QA program except for gamma analysis, for which Sample No. 1DG50 was processed in duplicate as required27 by the post-sampling memorandum. Section 4.3.4.3 of the WCPIP allows a laboratory to defer to its own QA requirements if the laboratory ha s an established QA program, so this was acceptable.

The sample swabs were composited and leached in acid with a laboratory blank and duplicate LCSs, unless noted below. The following sections di scuss the pertinent deta ils of each analytical technique.

Alpha Spectrometry, BDR No. ALD11019A – 241 Am and isotopic Cm, Pu and U The BDR narrative stated that all QC requirements were met. The analyses performed on the sample leachates also included Am/Cm, 245 Cm, isotopic Pu and isotop ic U fractions. The report narrative identified a possi ble positive bias for 233 U/ 234 U for Sample Nos. 1DG51 and 1SG52 and a possible high bias for 239 Pu/Pu 240 for Sample No. 1DG51. The BDR contained a completed “Sample Receiving and Custody Revi ew Checklist – Analytical Laboratory,” in which initiation
of NCR No. 63436 was recorded. The BDR also c ontained a completed “Independent Technical Review Checklist – Actinides by Alpha Spectrome try.” “Attachment 7 – Site Project Manager Radiochemistry or ICP-MS Analytical Batc h Data Report Checklist” was attached and completed as required.

Gas Flow Proportional Counting, BDR No. ALD11019B – 90 Sr The BDR narrative stated that all QC requireme nts were met. The BDR contained a completed “Sample Receiving and Custody Revi ew Checklist – Analytical Laboratory,” in which initiation
of NCR No. 63436 was recorded. The BDR also contained a completed “ITR Checklist, Radiostrontium by Gas-Flow Proportional Count ing (GFPC).” “Attachment 7 – Site Project Manager Radiochemistry or ICP-MS Analytical Batch Data Report Checklist” was attached and completed as required.

Gamma Spectrometry – BDR No. ALD11019G, 137 Cs and Gamma-Emitting Radionuclides The sample swabs were composited and leached in acid with a laboratory blank, sample duplicate and LCS/LSCD. The post-sampling memo randum for PKE00027/54 identified Sample No. 1DG50 as the laboratory duplicate, and this was used to assess prec ision. The BDR narrative stated that all QC requirements were met except for the detection limit for 134 Cs in Sample Nos. 1DG50, 1DG50D and 1DG52. Gamma spectrometry was performed for 60 Co, 134 Cs, 137 Cs, 154 Eu and other gamma-emitting radionuclides. The BDR contained a completed “Sample Receiving and Custody Review Checklist – Analytical Labo ratory,” in which initiation of NCR No. 63436 was recorded. The BDR also contained a comple ted “ITR Checklist, Gamma Spectroscopy” and “Attachment 7 – Site Project Manager Radiochemi stry or ICP-MS Analytical Batch Data Report Checklist,” which was completed as required.

Inductively Coupled Plasma-Mass Spectrometry – BDR No. ALD11019I, 239 Pu, 240 Pu, 242 Pu,

233 U, 234 U, 235 U and 238 U

239 Pu and 240 Pu were detected in a laboratory blank a nd in one instrument verification blank, but

239 Pu was at a level below required acceptance levels. The level of 240 Pu detected in the laboratory blank was such that a positive bias in the reported result for Sample Nos. 1DG50, 1DG51 and 1DG52 may be presen t. LCS/LCSD duplicate analyses demonstrated acceptance precision. A post-digestion spike wa s prepared, one for Pu and one for U, and analyzed with28 acceptable recoveries. 239 Pu was not detected in Sample Nos. 1DG51 and 1DG52. The BDR contained a completed “Sample Receiving a nd Custody Review Checklist – Analytical Laboratory,” in which initiation of NCR No. 63436 was recorded. The BDR also contained a completed “ITR Checklist, Pu and U Isot opes by Inductively Coupled Plasma Mass Spectrometry.” “Attachment 7 – Site Project Ma nager Radiochemistry or ICP-MS Analytical Batch Data Report Checklist” was at tached and completed as required.

Liquid Scintillation Counting, BDR No. ALD11019L – 241 Pu The Pu fraction of the leachate was separated us ing an approved laboratory method and was also used for the alpha spectrometry discussed above. The BDR narrative stated that all QC requirements were met, although a spiking error re quired that one blank and an LCS be leached
in acid a second time. The BDR contained a co mpleted “Sample Receiving and Custody Review Checklist – Analytical Laboratory,” in which initiation of NCR No. 63436 was recorded. The BDR also contained a completed “ITR Ch ecklist, Determination of Pu-241 by Liquid Scintillation Counting (LSC).” “Attachment 7 – S ite Project Manager Radiochemistry or ICPMS Analytical Batch Data Report Checklist ” was attached and completed as required.

EPA did not identify any issues with the analytical data for PKE00027/54.

(5) Technical aspects and documentation of the development of scaling factors were evaluated and were found to be acceptable.

The scaling factors for Container No. SN LNM007023 from PKE00027/54 (containing three commingled parcels) were different from t hose developed for the two single-parcel waste containers, resulting in three sets of scal ing factors for PKE00027/54. However, the only container to be promoted as RH TRU waste from PKE00027/54 is Container No. SNLNM007020, as discussed above, and this co ntainer had its own scaling factor. For PKE00047, a single set of scaling factors was developed for all seven containers based on the five samples collected. As discussed above, C ontainer No. SNLNM007012 was determined to be CH TRU. Scaling factors for both parcels are provided in Table 7 below. The PKE00027/54 values are listed according to their 30-gallon drum number.29 Table 7. 137 Cs Scaling Factors for PKE00027/54 and PKE00047,
Ci Radionuclide/Ci 137 Cs

Radionuclide Scaling Factors PKE00027/54 Scaling Factors
PKE00047 P1110158 P1110159 P1110155

241 Am 6.99E-04 4.38E-03 2.38E-03 8.79E-02

242 Cm 4.96E-06 5.59E-05 1.92E-05 7.49E-04

244 Cm 2.35E-05 4.43E-05 1.16E-04 6.08E-04

245 Cm 1.29E2.5 2.35E-04 1.30E-04 3.84E-03

238 Pu 1.11E-03 9.93E-04 7.58E-03 2.28E-02

239 Pu 6.02E-05 1.41E-04 3.20E-04 6.74E-02

240 Pu 8.43E-05 1.98E-04 4.49E-04 4.05E-02

241 Pu 4.32E-03 1.05E-02 1.95E-02 4.66E-01

242 Pu 5.64E-06 3.29E-04 4.64E-04 5.23E-06

233 U 3.57E-07 2.09E-05 2.94E-05 2.08E-05

234 U 3.56E-05 3.22E-05 3.89E-04 1.56E-04

235 U 1.10E-06 6.68E-07 1.09E-05 4.73E-06

236 U - - - 4.80E-06

238 U 2.01E-07 2.05E-07 1.18E-06 3.98E-06

137 Cs 1.00E+00 1.00E+00 1.00E+00 1.00E+00

90 Sr 2.84E-01 2.55E+00 4.73E-01 4.36E-01

(6) The technical basis and derivation of tota l measurement uncertainty were evaluated and were found to be adequate.

The development of total measurement uncerta inty (TMU) for both PKEs is based on the propagation of uncertainties presen t in all aspects of the radiol ogical characterization process. These aspects are assumed to be independent, wh ich allows them to be added in quadrature. 9 The
TMU determination included contributions of the following sources of uncertainties:

• 137 Cs DTC correlation – MicroShield ® code, MicroShield ® modeling, and waste density
uncertainties.

• 137 Cs activity measurement – dose rate measur ement uncertainty and uncertainty due to the contribution of other gamma-emitting radionuclides.

• Scaling factor uncertainty – uncertainties in the mean scaling factors from the sample
data.

Because the measurement of 137 Cs is common to the activity determinations for all radionuclides, a statistical dependency exists for derived parameters (e.g., TRU determination) that are summations over multiple radionuclides. The use of effective scaling factors (i.e., the sum of the individual scaling factors multiplied by appropr iate weighting factors) addresses this.

A general treatment of TMU for PKE00027/54 and PKE00047 is presented in Sections A.6.0 and B.6.0 of CCP-AK-SNL-501, Revision 2, respective ly, and the detailed tr eatment of TMU is

9 Adding in quadrature is a standard statistical techni que that allows one to combine the square root of the sum of each contributor to uncertainty squared, resulting in a lower value than what would be obtained if the values were simply added.30 provided in Calculation Package SNL-RH-10, Re vision 0 (Reference U1038) , and in Calculation Package SNL-RH-15, Revision 0 (R eference U1043). The overall uncertainties are consistent
with what EPA has observed for RH determina tions at other RH TRU generator sites. The
overall uncertainties for PKE00027/54 and PKE00047 c ontainers are provided below in Table 8. There were no concerns regarding the techni cal derivation and documentation of TMU for
PKE00027/54 and PKE00047.

Table 8. Overall Uncertainties for PKE00027/54 and PKE00047

Radionuclide Total 137 Cs Uncertainty Total Scaling Factor Uncertainty Total Uncertainty
PKE00027/54 PKE00047 PKE00027/54 PKE00047 PKE00027/54 PKE00047

233 U 28.0% 28.0% 100.0% 100.0% 103.8% 103.8%

234 U 28.0% 28.0% 37.7% 57.8% 46.9% 64.2%

235 U 28.0% 28.0% 45.9% 52.3% 53.7% 59.3%

238 U 28.0% 28.0% 51.4% 16.8% 58.5% 32.6%

238 Pu 28.0% 28.0% 18.4% 10.1% 33.5% 29.7%

239 Pu 28.0% 28.0% 39.6% 32.7% 48.5% 43.1%

240 Pu 28.0% 28.0% 38.8% 32.4% 47.9% 42.8%

241 Pu 28.0% 28.0% 26.7% 20.0% 38.7% 34.4%

242 Pu 28.0% 28.0% 100% 100% 103.8% 103.8%

241 Am 28.0% 28.0% 36.2% 26.3% 45.7% 38.4%

245 Cm 28.0% 28.0% 52.7% 29.1% 59.7% 40.4%

90 Sr 28.0% 28.0% 31.8% 20.8% 42.3% 34.8%

137 Cs 28.0% 28.0% 0.0% 0.0% 28.0% 28.0%

90 Y 28.0% 28.0% 31.8% 20.8% 42.3% 34.8%

137 m Ba 28.0% 28.0% 0.0% 0.0% 28.0% 28.0%

(7) Remote-handled and transuranic determina tions were assessed and were found to be adequate.

The determinations that the containers were RH were based on radiological survey reports provided by SNL-CCP. These reports s howed the external dose rates.

(8) The technical basis of the dos e-to-curie correlation and its documentation were evaluated, and both aspects were acceptable.

The DTC correlation was evaluated ba sed on DTC BDR Nos. SNLRHDTC11001 and SNLRHDTC11002, which addresse d containers from PKE0 0027/54, PKE00047 and PKE00044.
The EPA evaluation team verified that both DTC BDRs contained the following:

• “Attachment 2 – Container Data Sheets” for all containers.

• “Attachment 8 – SPM Checklist.”

• “Attachment 4 – Batch Data Report Cover Sheet.”

• “Attachment 5 – Batch Data Report Table of Contents.”

• “Attachment 6 – Batch Data Report Narrative Summary.”

• “Attachment 7 – ITR Checklist.”31 • “Attachment 10 – Duplicate Container Data Sheet” and “Attachment 11 – Relative
Percent Difference” for Container Nos. SNLNM007121 (SNLRHDTC11001) and SNLNM007021 (SNLRHDTC11002).

• “Attachment 1 – Measurement Control Repor t,” with all parameters acceptable.

• Container data sheets for al l containers (Attachment 2).

• Waste container DTC conversion records with all required parameters for all containers, including TRU determinations.

• “Attachment 1 – CCP Nonconformance Report (NCR).”

• Evidence that the correct revision of CCP-TP-504 was used: Revision 11.

• All forms had the correct signatures, i.e., ITR, SPM, DTC Operators and NCR Originators.

• The DTC conversion records for all containers indicated that the correct PKE-specific version of the DTC spreadsheet was used.

Additionally, the EPA evaluation team verified th at all DTC operators and ITRs were listed on the list of Qualified Indivi duals (LOQI) for the time periods they conducted measurements.

Four of the containers fro m BDR No. SNLRHDTC11001 were determined to be non-TRU by virtue of having TRU alpha concentrations le ss than 100 nCi/g, as documented in NCR Nos.
NCR-RHSNL-2352-11 and NCR-RHSNL-2353-11. Th e BDR also contained NCR No. NCRRHSNL-2347-11, which addressed the use of the incorrect DTC spread sheet. The BDR was technically adequate.

Four of the containers fro m BDR No. SNLRHDTC11001 were determined to be non-TRU by virtue of having TRU alpha concentrations less that 100 nCi/g, as documented in NCR No.
NCR-RHSNL-2354-11. The BDR wa s technically adequate.

There were no issues related to the DTC correla tion and its documentation for containers from
PKE00027/54 and PKE00047.

Summary of Radiological Characterization Findings and Concerns

The EPA evaluation team did not identify any ra diological characterization-related findings or
concerns relative to the addition of the PKE 00047 and PKE00027/54 containers to Waste Stream SNL-HCF-S5400-RH during this T1 evaluation. However, EPA rais ed an issue concerning how RH waste sample data for PKE00027 group (see Item #3 in Section 6.2) were used. CBFO provided a response letter, which is satisfactory.

To better support EPA’s approval, EPA recommends that changes be made to the WCPIP the next time it is revised. These changes would sp ecify the importance of agreement between the objective evidence that documents a waste charac terization process and the process itself, and would prevent recurrence of the situation EPA encountered with the documentation for
PKE00027/54.32 Changes to Radiological Characterization Tiering

There are no changes to the radiological characte rization tiering based on the results of this T1
evaluation. As stated in the Ex ecutive Summary, if SNL-CCP were to characterize additional RH wastes from PKE00027/54, PKE000457 or PKE00044 in the future, the tiering conditions and
limitations included in Table 1 of the ba seline approval report are applicable.

Radiological Characterization Approval

Based on the results of this evaluation, EPA appr oves the process of determining the radiological content of the PKE00027/54 and PKE00047 portions of Waste Stream SN L-HCF-S5400-RH, as described in this report.

6.3 Visual Examination

EPA examined three VE BDRs to determine whether SNL-CCP demonstrated continued compliance with the approved process during charac terization of the containers generated from
PKE00027/54 and PKE00047. These are discussed separately below

PKE00047

The VE data for PKE00047 were repo rted in VE BDR Nos. SNLRHVE110006, SNLRHVE11007, and RHSNLVE110101. SN L-CCP stated that the reason for the inconsistent numbering format between BDR Nos. SN LRHVE11007 and SNLRHVE11010 (year designator followed by 3 numbers) and RHSNLVE110006 (year designator followed by four numbers) was a process change. EPA used an Excel spreadshee t, “SNL HCF RH Container Info Matrix 9-19- 11,” supplied by SNL-CCP to verify that the container data reviewed belonged to PKE00047. VE data for the following containers were reported in the following BDRs:

• BDR No. SNLRHVE110006 contained VE data for one container, SNLNM007023. This
container was determined not to be TRU waste and was removed from the waste stream.

• BDR No. SNLRHVE11007 contained VE da ta for four containers, SNLNM007024, SNLNM007025, SNLNM007017 and SNLNM007018.

• BDR No. SNLRHVE11010 contained VE da ta for two containers, SNLNM007098 and
SNLNM007099.

The VE data were generated using CCP-TP -500, “CCP Remote-Handled Waste Visual Examination”; Revision 10 (December 29, 2010) of this document was used for BDR No. SNLRHVE110006, and Revision 11 (April 21, 2011) was used for BDR Nos. SNLRHVE11007 and SNLRHVE11010. EPA had previously reviewed Procedure CCP-TP-500 and determined it to be adequate for the generation of VE data for RH TRU waste containers. A change was made to the data sheets in Revision 11, so that opera tors are no longer required to determine the “Primary Contents” of containers. This change did not affect EPA’s determination about the adequacy of the procedure for the generation of VE data for RH TRU waste containers.33 The waste in the 30-gallon containers, loaded into 55-gallon drums, consisted of general debris items, and SNL-CCP verified that the wast e was consistent with the waste stream description/waste matrix code. Both BDRs had been reviewed at both the data generation and project level as required by CCP-TP-500. No nonc onformance reports were generated for BDR
Nos. SNLRHVE11007 and SNLRHVE11010. The SN L-CCP LOQI that EPA reviewed demonstrated that VE data were generated by qualified personnel. EP A reviewed selected training records for the VE operato rs generating the data containe d in the BDRs listed above and determined that they were trained in accordance with SNL-CCP requirements.

PKE00027/54

The VE data for PKE00027/54 were provi ded in VE BDR No . RHSNLVE110003, which contained data for one container, SNLNM07020. EPA used an Excel spreadsheet, “SNL HCF RH Container Info Matrix 9-19-11,” supplied by SNL-CCP to verify that the container data reviewed belonged to PKE00027/54.

The VE data were generated using CCP-TP- 500, Revision 10. EPA had previously reviewed
Procedure CCP-TP-500 and determined it to be ad equate and effective for the generation of VE data for RH waste. The 30-gallon Contai ner No. P1110158 was packaged into 55-gallon Container No. SNLNM007020 and included general de bris items; the primary contents were designated as “Steel.” NCR N o. NCR-RHSNL-2345-11 was generated for this container on April 4, 2011, and revised on April 12, 2011

. The NCR was initiated because the parent container was
not listed in the comments section of the data sh eet. The data sheet was corrected and the revised
data sheet was included in the BDR. The SNL-CCP LOQI reviewed by EPA demonstrated that VE data were generated by qualified personnel. EP A reviewed selected training records for the VE operators who generated the data contained in the BDR above and determined that the operators were trained in accordance with SNL-CCP requirements.

EPA did not identify any concerns or findi ngs relative to the VE data for PKE00047 and
PKE00027/54.

Summary of Visual Examination Findings and Concerns

The EPA evaluation team did not identify any VE-re lated findings or concerns relative to the
addition of PKE00027/54 and PKE00047 to Waste Stream SNL-HCF-S5400-RH.

Changes to Visual Examination Tiering

There are no changes to the VE tiering based on the results of this T1 evaluation. As stated in the Executive Summary, if SNL-CCP were to ch aracterize additional RH wastes from PKE00027/54, PKE000457 or PKE00044 in the future , the tiering conditions and limitations
included in Table 1 of the final base line approval report are applicable.34 Visual Examination Approval

Based on the results of this evaluation, EPA a pproves the process of VE for determining the physical contents of the PKE00027/54 and PK E00047 portions of Waste Stream SNL-HCFS5400-RH, as described in this report.

7.0 SUMMARY OF RESULTS

EPA concluded that the waste ch aracterization processes of AK, radiological characterization,
and VE used to characterize RH TRU contai ners generated from PKE00027/54 and PKE00047 as part of SNL-CCP Waste Stream SNL-HCF- S5400-RH are adequate, as evidenced by the records evaluated. There are no open issues relative to this T1 evaluation.

Findings and Concerns

The EPA evaluation team did not identify any findi ngs or concerns related to AK, radiological characterization or VE. EPA personnel worked inte ractively with their SN L-CCP counterparts to answer questions, identify information needs a nd acquire necessary data and references; all potential issues were resolved in a timely fash ion. There are no open issues related to AK, or VE resulting from this T1 evaluation.

To address EPA’s issue concerning the post- sampling memorandum for PKE00027/54 [see Item (3) in Section 6.2] to support the development of scaling factors, CBFO provided a response letter which is satisfactory. To better support EPA’s approval, EPA recommends that changes be
made to the WCPIP the next time it is revise d. These changes would specify the importance of agreement between the objective evidence that documents a waste characterization process and the process itself, and would prevent recurren ce of the situation EPA encountered with the
documentation for PKE00027/54.

Tiering Changes

Based on the results of this evaluation, there are no significant change s to the SNL-CCP tiering
table included in the November 2011 EPA final baseline approval report. As stated in the Executive Summary, if SNL-CCP were to ch aracterize additional RH wastes from PKE00027/54, PKE000457 or PKE00044 in the future , the tiering conditions and limitations
included in Table 1 of the final base line approval report are applicable.

Approval

EPA determined that the procedures and pr ocesses used by SNL-CCP for the addition of
PKE00047 and PKE00027/54 to RH Waste Stre am SNL-HCF-S5400-RH were adequate. Therefore, EPA approves the addition of PK E00047 and PKE00027/54 to RH Waste Stream SNL-HCF-S5400-RH as a T1 change.A-1 ATTACHMENT A

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION

Acceptable Knowledge Accuracy Report, Sand ia National Laboratory/New Mexico Waste Stream Number SNL-HCF-S5400-RH, Lot 2, for Audit Purposes Only, May 31, 2011

AK Container Tracking Spread sheet SNL RH AK Containe r Matrix, September 19, 2011

Analytical Laboratory Batch Data Reports ALD11021A, ALD11021B, ALD11021G, ALD11021I, ALD11021L, ALD11019A, ALD11019B, ALD11019G, ALD11019I and ALD11019L

Batch Data Reports SNLRHDTC 11001, SNLRHDTC11002, SNLRHVE110006,
SNLRHVE11007 and SNLRHVE11010

CCP-AK-SNL-500, Central Characterization Proj ect Acceptable Knowledge Summary Report
for Sandia National Laboratories/New Mexico Re mote-Handled Hot-Cell Facility Transuranic Waste (Debris), Waste Stream: SNL-HC F-S5400-RH, Revision 4, November 30, 2011

CCP-AK-SNL-501, Central Characteri zation Project Remote-Handled Transuranic Radiological Characterization Technical Report for Sandia National Laboratories/New Mexico Hot-Cell Facility Remote-Handled Transuranic Debr is Waste, Waste Str eam: SNL-HCF-S5400-RH, Revision 2, November 4, 2011

CCP-AK-SNL-502, Central Characterization Project RH TRU Waste Certification Plan for 40 CFR Part 194 Compliance for Sandia Natio nal Laboratories/New Mexico Laboratory Remote-Handled Transuranic Debris Waste, Waste Stream: SNL-HCF-S5400-RH, Revision 1, August 10, 2011

CCP-AK-SNL-505, Central Characterization Project Sampling and Analysis Plan for Sandia National Laboratory Remote-Handled Transura nic Debris Waste, Waste Stream: SNL-HCFS5400-RH, Revision 0, November 29, 2010

CCP-TP-005, Attachment 1, Acceptable Knowle dge Documentation Checklist, August 15, 2011

CCP-TP-002, Attachment 2, CCP Waste Stream Profile Form, Waste St ream SNL-HCF-S5400- RH, Draft for Audit Purposes, November 10, 2011

CCP-TP-005, Attachment 4, Acceptable Know ledge Source Document Reference List, December 6, 2011

CCP-TP-005, Attachment 6, Waste Form, Waste Ma terial Parameters, Prohibited Items, and Packaging, April 21, 2011

CCP-TP-005, Attachment 8, Wast e Containers, July 1, 2011A-2 CCP-TP-005, Attachment 13, CCP Waste Stream Characterization Checklists, PKEs 00047 and 00027/54, Example Forms, provided January 12, 2012

CCP-TP-512, CCP Remote-Handled Wast e Sampling, Revision 4, December 29, 2010

Characterization Reconciliation Reports for Waste Stream SNL- HCF-S5400-RH, Draft for Audit Purposes, PKEs 00047 and 00027/54, files dated December 20, 2011, and January 12, 2012, respectively

Characterization Information Summary, Waste St ream SNL-HCF-S5400-RH, Draft, file dated December 20, 2011

C1004, Reactor Accident Experiments and Fund ing, Sandia National Laboratories, Summer
1978

C1038, Ken Reil Interview; J. Kleckner, February 3, 2010

C1039, Memorandum, Waste Material Parameter for Waste Stream SNL-HCF-S5400, SNL Hot Cell Facility, Mixed Heterogeneous Debris Waste, J. Kleckner, February 2, 1010

DR1004, Discrepancy Resolution re: The SA P for Waste Stream SNL-HCF-S5400-RH Segregates the Three Principal Sources of Waste Generation into Three Ra diological Categories, J. Kleckner, June 29, 2011

I1020, Hot Cell Facility (HCF) Dec ontamination Plan, December 1994

M1015, Miscellaneous Articles and Public Extracts, 1976 through 2008

M1016, TRU Waste Disposal Requests from the 2007/2008 Repackaged Containers, 2007 through 2008

M1019, Collection of Spreadsheets Pertaining to TRU Waste Generated at the AHCF and Other Locations on TA-V, 2007 through 2009

M1020 and M1020b, Process Knowledge Evalua tions (PKE) for Radiological Ratios, PKE00044, PKE00047, and PKE00027/54, March 1980 through March 2004

M1021, Memo to Record, re: Evaluation of Radi onuclide Activity Ratios for Hot Cell Facility Wastes (PKE00044 and PKE00047); Memo to Record, re: PKE000047 Radionuclide Activity Ratios, M. Enghauser, June 24, 2004

P1015, Sampling and Analysis Plan for Characteriza tion of Waste Arising from Hot Cell Facility Glovebox, Revision 1, PLA 95-28, October 12, 1995A-3 P1102, Building 6580 Hot Cell Facility, Steel Containment Boxes and Zone 2A Process Knowledge Documentation: Is otope Production Program, Hot Ce ll Facility Decontamination Project, L. Fugelso, S. Longley, L. Bourcier, June 28, 1996

P1104, Hot Cell Facility (HCF) Safety Analys is Report, Main Report and Appendices, L.F. Restrepo, SAND94-2650, October 21, 1994

P1105, Series of Procedures Titled AHCF Ca mpaign Operating Procedure for TRU Waste, C. Barch, M. Wasiolek, AHCF-AP-003.02 and AHCF-OP-008.00, Revisions 2 and 00, respectively, August 30, 2010, and December 22, 2010

Post-Sampling Analysis Memorandum “Analy sis of Sample Data for Sandia National Laboratory/New Mexico (SNL/NM) Waste St ream SNL-HCF-S5400-RH , PKE00027/54,” from J. Holderness to I. Quintana, Augus t 10, 2011 and Revision 1, February 29, 2012

Post-Sampling Analysis Memorandum “Analy sis of Sample Data for Sandia National Laboratory/New Mexico (SNL/NM) Waste St ream SNL-HCF-S5400-RH, PKE00047,” from J. Holderness to I. Quintana, August 26, 2011

Radiological Characteriza tion Concern for SNL-CCP: PKE00027/54 and PKE00047 with CBFO’s Response and EPA’s Assessment of CB FO’s Response, February 29, 2012 and March 6, 2012

RH Program – SNL List of Qua lified Individuals, April 27, 2011

RH Program – SNL List of Qu alified Individuals, May 19, 2011

RH Program – SNL List of Qua lified Individuals, June 8, 2011

RH Program – SNL List of Qua lified Individuals, July 22, 2011

RH Program – SNL List of Qua lified Individuals, October 22, 2011

SNL Radiological Survey Report: Survey M-20110526-4; Survey M-20110526-13 through Survey M-20110526-21

SNL Radiological Survey Report: Survey M-20110711-22; Survey M-20110711-25; Survey M20110711-27; Survey M-20110711-28

SNL Radiological Survey Report: Survey M-20111004-4; Survey M-20111004-7 through Survey M-20111004-9; Survey M-20111004-11; Survey M-20111004-13

SNL Radiological Survey Report: Surv ey M-20111005-8 through Survey M-20111005-10

U1032, Drum Dose-to-Curie Derivation for Cs- 137, J. Vance, SNL-RH-04, Revision 1, May 31,
2011A-4 U1035, Radiochemistry and Mass Spectrometry Data Input Check, J. Vance, SNL-RH-07, Revision 0, September 30, 2011

U1036, Scaling Factor Development Debris – PKE00027, J. Vance, SNL-RH-08, Revision 0, September 30, 2011

U1037, Determination of Reportable Radionuc lides, J. Vance, SNL-RH-09, Revision 0, September 30, 2011

U1038, Uncertainty Analysis for Drums – PKE0 0027, J. Holderness, SNL-RH-10, Revision 0, September 30, 2011

U1039, DTC and Related Calculations for Dr ums – PKE00027, J. Holderness, SNL-RH-11, Revision 0, September 30, 2011

U1040, Radiochemistry and Mass Spectrometry Data Input Check, J. Vance, SNL-RH-12, Revision 0, November 9, 2011

U1041, Scaling Factor Development Debris – PKE00047, J. Vance, SNL-RH-13, Revision 0, September 30, 2011

U1042, Determination of Reportable Radionuc lides, J. Vance, SNL-RH-14, Revision 0, September 30, 2011

U1043, Uncertainty Analysis for Drums – PKE0 0047, J. Holderness, SNL-RH-15, Revision 0, September 30, 2011

U1044, DTC and Related Calculations for Dr ums – PKE00047, J. Holderness, SNL-RH-16, Revision 0, September 30, 2011