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

WASTE CHARACTERIZATION REPORT 

EPA TIER 1 EVALUATION 

OF THE CENTRAL CHARACTERIZATION PROJECT 

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM: 

ADDITION OF CONTAINERS GENERATED FROM WASTE GROUPS PKE00027/54 

AND PKE00047 TO THE REMOTE-HANDLED DEBRIS WASTE STREAM 

SNL-HCF-S5400-RH AT THE SANDIA 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 2012
 i 

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 .......................................................................................................... 34

Attachment A: List of Documents Reviewed 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 Activity Ratio Comparison .................................................... 15

Table 4. Radionuclide Activity Ratios for PKE00027/54 ............................................................ 16

Table 5. Container Traceability .................................................................................................... 18

Table 6. Sample Disposition Summary ........................................................................................ 23

Table 7. 137Cs Scaling Factors for PKE00027/54 and PKE00047, Ci Radionuclide/Ci 137Cs ...... 29

Table 8. Overall Uncertainties for PKE00027/54 and PKE00047 ............................................... 30
 ii 

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/cm3

 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 Individuals 
 iii 

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 Material 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 yttrium 
4 

1.0 EXECUTIVE SUMMARY 

This report supports the U.S. Environmental Protection Agency’s (EPA’s) decision to approve a 

Tier 1 (T1) change to add containers generated from the PKE00027/541

 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 parcels4

 of retrievably stored RH TRU waste from the PKE00044 waste 

group (see EPA Docket No. A-98-49: II-A4-155). Using the EPA-approved waste 

characterization processes discussed in this report, SNL-CCP can characterize waste containers 

generated from the PKE00027/54 and PKE00047 waste groups, which were generated during 

decontamination operations of the Glovebox Laboratory (GBL) at the SNL Hot Cell Facility 

(HCF). This HCF GBL waste is packaged in 55-gallon containers5 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 final 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-curie (DTC), in conjunction 

with radionuclide-specific scaling factors supported by radiochemical analyses of smear6

samples from the parcels; and (3) visual examination (VE). These components are used to 

confirm the physical and radiological 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 inspection report also stated that SNL-CCP needs to provide additional 

information showing more commonality of experiments and radiological materials between the 

steel containment box (SCB)/Zone 2A area (PKE00044) and the GBL (PKE00027/54 and 

 1

 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. 

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 responsible 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 characterized individually for their radiological and physical contents. 

6

 A “smear,” “wipe” or “swipe” is a nonquantitative test for the presence of removable radioactive 

materials in which a surface or area is wiped with a filter paper or other substance, which is then assayed for specific 

radionuclides using destructive or nondestructive techniques. For these samples, the “smear” was a cotton swab. 
5 

PKE00047). The baseline also states that more justification for why the distinct radiological 

populations do not warrant designation as separate waste streams as implied by the Waste 

Characterization Program Implementation Plan (WCPIP), Revision 2. 

On December 15, 2011, the Carlsbad Field Office (CBFO) requested EPA approval of a T1 

change to add containers generated from Waste Groups PKE00027/54 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 characterization by DTC, as described in CCP-AKSNL-501, Revision 2, Appendices A and B, for 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 separate waste streams as required by the WCPIP, 

Revision 2. 

Because the T1 request did not include any new equipment or additional new processes on site at 

SNL, EPA conducted a desktop review of this change, concluding that SNL-CCP’s plan to use 

the EPA-approved system of controls to characterize the debris waste from the PKE00027/54 

and PKE00047 waste groups was acceptable. EPA did not identify any findings or concerns 

during this evaluation. As a result, EPA approves the T1 change request to add containers from 

the PKE00027/54 and PKE00047 waste groups to the previously approved 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 development of scaling factors and the disposition of 

waste containers in this waste group. EPA discussed this issue 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 suggestion, SNL-CCP added a footnote “data are 

valid” to one of the tables where the data were presented. EPA informed CBFO that this change 

was inadequate objective evidence and asked CBFO to provide a better rationale. CBFO’s 

response letter dated March 28, 2012, explained which 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 specify the importance of agreement between the 

objective evidence that documents a waste characterization process and the process itself, and 

would prevent recurrence of the situation EPA encountered with the documentation for 

PKE00027/54. 

This approval is limited to parcels from 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 described in CCP-AK-SNL-501, Revision 2. CBFO has informed EPA 

that SNL-CCP does not expect to characterize additional RH debris waste or add additional RH 
6 

debris containers to these two PKEs or the previously 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 approved 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 activities from the date of the site’s baseline 

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

requirements set forth in 40 CFR 194.8, as amended, 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 baseline 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 authorized to evaluate and approve changes, if 

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

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

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

[Tier 2 (T2)] are identified in the site-specific baseline inspection reports. When evaluating 

proposed T1 changes for approval, EPA may conduct a site inspection to observe firsthand the 

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

specific to a change. DOE may choose to characterize and dispose of any previously approved 

TRU waste using processes, procedures and equipment 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 implemented 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 basis 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-HCF-S5400-RH. Based on criteria set forth by 

EPA during the SNL-CCP baseline inspection, a T1 request is required for characterization of 

containers from the PKE00027/54 and PKE00047 waste groups. Therefore, the scope of the T1 

request is to evaluate the addition of containers generated from the PKE00027/54 and PKE00047 

waste groups to Waste Stream SNL-HCF-S5400-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 technical 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 conducted interviews with SNL-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 technical areas of expertise. This list includes 

personnel present at meetings conducted 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 Characterization, Technical Inspector 

Rose Gogliotti SC&A Radiological Characterization, Technical Inspector 

Kevin Peters CCP-TechSpecs Acceptable Knowledge Expert 

Dorothy Gill SC&A Visual Examination, Technical Inspector 

John Kleckner CCP-TechSpecs Acceptable Knowledge Expert 

Steve Schafer CCP-TechSpecs Acceptable Knowledge Expert 

Jene Vance WTS-CCP Radiological Characterization, 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 parcels packaged in 29 containers, 27 of which 

are shielded and two unshielded. The 32 waste parcels 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 SCB/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 commingled 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 radionuclide distributions in waste from the SCB/Zone 2A area and 

from the gloveboxes were different. Wastes generated during experiments were typically 

retained in the cells or areas of generation. During 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/Nuclear Material Disposition Department (RWNMDD) personnel 

developed and used process knowledge evaluation (PKE) reports to establish the radiological 

characterization of each parcel based on information provided in the disposal request 

documentation (Reference M1016). SNL-CCP followed this pattern and 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 AKSR 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) common sample storage areas, and (3) equipment 

sharing and overall cross-contamination between gloveboxes (References C1004, M1016, 

M1019, P1015, P1102 and P1104). The portion generated 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 approval are limited to the addition 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, and CCP-AK-SNL-501, Revision 1, both prepared 

in November 2011. The numbers do not coincide with current estimates, which are lower 

because containers were removed from the RH waste stream, as discussed below. 

SNL-CCP initially identified PKE00047 as including nine parcels in eight containers, but one 

container containing two PKE00047 parcels was found to be commingled 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 together 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 because 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 Data Reports/Calculation Packages Provided

EPA evaluated the documentation that SNL-CCP prepared to support the inclusion of containers 

generated from PKE00027/54 and PKE00047 in Waste Stream SNL-HCF-S5400-RH. EPA’s 

review identified several technical issues that 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 evaluation. 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 for RH waste characterization: 

• Inspection scope and waste stream identification. 

• Identification and adequacy of the WCPIP waste characterization process. 

• Adequacy of the Certification Plan and other WCPIP documentation. 

• Adequacy of training. 

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

• Adequacy of nonconformance reports (NCRs) and discrepancy resolution (DR) reports. 

• Waste stream definition, including radiological and physical characteristics. 

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

or spent nuclear fuel (SNF). 

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

• Adequacy of the AK procedure and procedure implementation, including attachments, 

AK accuracy reports, characterization reconciliation 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 parcels in Waste Stream SNL-HCF-S5400-RH was 
11 

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 the 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 full 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 evaluated and found to be satisfactory. 

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

• Attainment of DQOs was evaluated 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 appropriate 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, implementation and effectiveness of technical processes 

that SNL-CCP used to characterize debris waste from PKE00047 and PKE00027/54. 

The WCPIP defines a waste stream as waste material that is (1) generated from a single process 

or activity and (2) is similar in material, physical form and 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 evaluated 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 release from irradiated and nonirradiated fuel under severe accident 

conditions. Irradiated fuels were obtained from 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 received 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 kelvin. 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 several places within the WCPIP. 
12 

heating experiments were performed, but Reference P1102 states that fission product release 

observation took place in the SCBs, so EPA assumes 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 facility 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. Commonality of experiments between the SCB/Zone 2A 

area, Gloveboxes 1 and 2, and Glovebox 3 was adequately demonstrated (References P1102 and 

P1015). 

Historical records indicate that the physical compositions of PKE00027/54 and PKE00047 are 

adequately understood and support the waste stream determination. PKE00027/54 is composed 

of five parcels, the contents of which are described 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 the 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 waste grouping (References M1016, M1020b, M1021 and 

CCP-AK-SNL-501, Revision 2). However, these reports and other information also show that 

the PKEs exhibit some radiological similarities. Radiological information in other source 

documents and obtained through sampling indicates that uranium-235 (235U) and 238U are the 

predominant isotopes by mass in all three PKEs. Also, PKE reports indicate that the predominant 

TRU isotope in the three PKEs is plutonium-239/240 (239/240Pu). Based on a review of the 

radiological distributions assigned to the waste in the three PKEs and excluding cesium-137 

(

137Cs) and strontium-90 (90Sr), the distribution of the remaining isotopes [americium-241 

(

241Am), 238Pu, 239/240Pu, promethium-147 (147Pm) and 241Pu] in each PKE are relatively similar. 

Specifically, the three PKEs exhibit similar mass percent 239/240Pu, 241Am and 241Pu (References 

C1038, M1016, P1015, P1102 and P1104). The three PKEs appear to have a similar general 

radiological composition that supports including all three PKEs in a single waste stream, 

although sampling of parcels from each PKE is required to obtain PKE-specific radiological 

distributions. See Section 6.2 for additional information 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 related to PKE00027/54. NCR No. NCR-RHSNL-2345-

11, Revision 0, applied to Drum No. SNLNM007020 and addressed discrepant drum number 

identification on CCP-TP-005, Attachment 8. SNL-CCP Discrepancy Report DR1004 addressed 
13 

the identification of paperwork showing that PKE00047 and PKE00027/54 parcels were 

combined during repacking and generation 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 the 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 applicable 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 the 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 attachments were provided with the original baseline 

inspection, so only those attachments with new information pertinent to this T1 request were 

provided to and reviewed by EPA. SNL-CCP provided 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 Tracking Spreadsheet that identified 

container and parcel numbers, associated PKE, associated disposal records, and container 

status. Note that Attachment 8 was prepared in June 2011, while the AK Tracking 

Spreadsheet was printed in September 2011. The AK Tracking Spreadsheet indicates that 

several containers are “no longer 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 Spreadsheet, and Add Container Memoranda) must 

be examined to understand the containers in the waste stream at any given time. 

• Attachment 13, the waste characterization checklist, 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 examined, along with associated source 

documents, and found to be adequate (WCPIP, Section 4.1, p. 31). 

Since the baseline inspection, SNL-CCP revised the AKSR twice: to modify the hazardous waste 

numbers assigned to the waste stream (Revision 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 and PKE00047 belonged in the same waste 

stream. 

SNL-CCP created Revision 4 of the AKSR to better identify process areas; include complete 

radiological information; explain the flow between process areas; identify common processes 

with respect to the SCB/Zone 2A area, Gloveboxes 1 and 2, and Glovebox 3; and justify the 

waste stream determination. The AKSR, Revision 4, adequately justifies that 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 destructive and nondestructive examinations 

conducted in the HCF, including items from the various cells and gloveboxes. The waste stream 

includes paper and cloth items, bottles, jars, tubing, glovebox gloves and waste, 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 distributions 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 composed, 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%), plastic (8.3%) and other inorganic materials (7.8%). 

Parcel data show that PKE00047 is composed primarily 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 representatives verified that the missing container underwent 

VE and contains waste constituents consistent 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 radionuclides in both PKEs include cobalt-60 (60Co), 90Sr, 

235U, 238U, 137Cs and small amounts of TRU radionuclides, primarily 238Pu, 239Pu and 241Am 

(References M1016, M1019, M1020 and M1021). In the late 1990s, SNL RWNMDD waste 
15 

handlers initially characterized RH containers with high dose8 rates using only a portable gamma 

system. SNL-CCP confirmed the list of radionuclides 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 analyses. The measurements indicated that 

PKE00044, PKE00027/54 and PKE00047, while containing many common radionuclides, also 

showed different quantities and distributions that differentiated the three PKEs. SNL-CCP found 

that the measurements were sufficiently accurate to differentiate TRU 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 radionuclide activities (References M1016, M1020 

and M1021). 

Table 3. PKE00047 Radionuclide Activity Ratio Comparison 

Radionuclide Measured Activity 

Ratio to 137Cs 

PKE00047 

Activity Ratio to 

137Cs 

Measured 

Activity Ratio to 241Am 

PKE00047 

Activity Ratio to 241Am 

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

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

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

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

147Pm 2.13E-02 --- NA NA 

241Pu 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 calculation errors compromised the original PKE00027/54 activity 

ratios. SNL-CCP performed additional sampling and analysis in 2008 to determine representative 

radionuclide activity ratios (References M1020 and M1021). Table 4 presents a summary of the 

2008 revised ratios used by SNL-CCP to characterize waste generated 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 terms “dose equivalent” or “dose equivalent rate.” The actual differences among 

these values for the purpose of this report are negligible. 
16 

Table 4. Radionuclide Activity Ratios for PKE00027/54 

Radionuclide Measured Activity 

Ratio to 137Cs 

 Measured Activity 

Ratio to 241Am 

241Am 8.99E-05 1.00E+00 

243Am 3.05E-06 3.39E-02 

238Pu 1.41E-05 1.56E-01 

239Pu 4.91E-05 5.46E-01 

242Pu 1.41E-06 1.57E-02 

90Sr 3.05E-02 NA 

137Cs 1.00E+00 NA 

147Pm 5.63E-05 NA 

241Pu 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 that the information in these tables is based on AK source 

documents and may not correspond to SNL-CCP parcel sampling results presented in CCP-AKSNL-501. However, AK radiological information adequately 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 parcels 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 baseline 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 actual 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 characterization information summary (CIS). The 

CIS is not required or mentioned in WCPIP or CCP-TP-005, Revision 24, but preparing a CIS is 
17 

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. Together, 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 Container No. C980313 was rejected because the 

summary category group is S3000, and external dose readings indicate that this container is not 

TRU waste. As a result, the AK accuracy of Waste Stream SNL-HCF-S5400-RH PKE00027/54 

containers was 25% when the AK accuracy report 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 PKE00027/54. EPA expects to receive this notification 

when the T1 request is approved. 

Waste Stream SNL-HCF-S5400-RH has a companion CH waste stream, but the CH information 

was not used to characterize this RH waste stream. If CH information is used to characterize RH 

waste, a CSSF is required. 

(9) Container data are adequately traceable and 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 information for CCP Container Nos. SNLNM7020 

(PKE00027/54) and SNLNM7024 (PKE00047). A primary 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 transferred 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 with several different identifiers, 

including: 

• Disposal Request Form. 

• Original packaging parcel number. 

• New parcel number assigned at a future date. 
18 

• SNL-assigned container into which the parcel was placed for storage. 

• Number of the 30-gallon drum into which the 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 for the two containers provided by SNL-CCP. 

Container data are in the AK record and are 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 evaluation team did not identify any AK-related 

findings or concerns relative to the inclusion of containers generated from PKE00027/54 and 

PKE00047 in Waste Stream 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 characterize 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 approves inclusion of containers generated from 

PKE00027/54 and PKE00047 in Waste Stream SNL-HCF-S5400-RH and finds that all 

procedural requirements have been met. 
19 

6.2 Radiological Characterization 

Radiological Characterization Overview

The radiological characterization of parcels PKE00027/54 and PKE00047 of SNL-CCP Waste 

Stream SNL-HCF-S5400-RH relies on DTC in conjunction with radionuclide-specific scaling 

factors. The scaling factors were developed independently for these two waste parcels, based 

primarily on two sources of information: 

• AK for Waste Stream SNL-HCF-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 PKE00027/54 and, separately, for five randomly 

selected drums from PKE00047, as summarized in CCP-AK-SNL-501, Revision 2, and 

its supporting calculation packages. 

Overviews of the radiological characterization processes used 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 used for PKE00027/54 and PKE00047 

in terms of the technical adequacy of the approach, as supported by the program’s documents, 

procedures and controls, and the 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 Characterization 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 

137Cs-based scaling factors 

for PKE00027/54 and one set 

of 137Cs-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 137Cs DTC correlation based on a 1-Ci 

source of 137Cs 

Develop DTC conversion factor (density correlation 

equation in mR/hr/Ci) for 137Cs 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 137Cs activity in curies. 

Multiply 137Cs 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 137Cs Activity:
21 

Technical Evaluation

(1) EPA evaluated the methodology and the technical approaches used to characterize 

PKE00027/54 and PKE00047 and determined that they were technically adequate. 

EPA reviewed the information that formed the basis of the radiological characterization process, 

documented in Appendices A and B of CCP-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 two PKEs and their distinction. 

• The sampling procedures implemented by SNL-CCP. 

• Collection of smear samples for PKE00027/54: Container No. P1110155 (containing 

commingled PKE00027 Parcel P2000836 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, composites of at least three samples taken 

from each container/parcel sampled. 

• The technical adequacy and documentation of the 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, 137Cs-based scaling factors using 

radiometric and spectrometric analyses of the smear samples from PKE00027/54. 

• Derivation of a single set of 137Cs-based scaling factors, using radiometric and 

spectrometric analyses of smear samples from five, randomly selected single-parcel 

containers from PKE00047. 

• Development of DTC correlation for 30-gallon drums overpacked in 55-gallon drums 

using waste densities ranging from 0.2 grams per cubic centimeter (g/cm3) to 1.8 g/cm3

based on MicroShield® modeling of the container’s external dose rate using a one-curie 

(Ci) source of 137Cs. 

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

• Determination of reportable radionuclides and the bounding analyses performed. 

• Activity in Ci and mass in grams and the associated uncertainties that were determined 

for the 10 WIPP-tracked radionuclides (233U, 234U, 238U, 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 

137Cs and 90Sr), 235U, 241Pu, curium-244 (244Cm), 245Cm, yttrium-90 (90Y) and barium137m (137mBa). 
22 

• The appropriateness of the physical constants and radionuclide-specific attributes 

(specific activity, physical half-life, decay heat, neutron cross-sections, photon transition 

probabilities, etc.) and the technical correctness of the values assigned to each attribute. 

The constants and other values in the calculation packages were taken from the appropriate 

sources and were spot-checked for accuracy. 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 input for these calculations includes: 

• Date of characterization. 

• Waste stream designation. 

• Container number. 

• Container gross weight. 

• Container net weight. 

• Measured container dose rates. 

There were no concerns regarding the methodology and the technical approaches used for the 

radiological characterization of PKE00027/54 and PKE00047. 

(2) Technical aspects and documentation of the radiological characterization process were 

evaluated and found to be acceptable. 

CCP-AK-SNL-501, Revision 2, is the main document that describes the radiological 

characterization process, supported by a series of calculation packages, which were prepared or 

reviewed by SNL-CCP radiological characterization personnel J. Holderness and J. Vance. EPA 

determined that CCP-AK-SNL-501 adequately documented 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 containers from both PKEs assuming that all 

containers were RH TRU, based on available 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 drum numbers and final 

dispositions. 
23 

Table 6. Sample Disposition Summary 

PKE Sample ID Nos. Parcel /30-Gallon/ 55-Gallon Nos. Lab. ID No. Sample Descripti

27/54 SN03081101 SN03081102 SN03081103 P2000998/P1110158/ SNLNM7020 1DG50 & 1DG50D Primary & laborator

duplicate 

27/54 SN003241101 SN003241102 SN003241103 P9800935/P1110159/ SNLNM7021 1DG51 Primary sample 27/54 SN03301101 SN03311101 SN03311102 P9800776/P1110154/ 1DG52 Primary sample 27/54 SN04141101 SN04151101 SN04151102 P2000836/P1110155/ SNLNM7023 1DG53 Primary sample, (fir

sample from ContaiNo. P1110155) 

27/54 SN04151103 SN04151104 SN04151105 P9900534/P1110155/ SNLNM7023 1DG54 

Primary sample, (nocollocated, second sample from ContaiNo. P1110155) 

47 P9800962-1 P9800962-2 P9800962-3 P9800962/P1110156 SNLNM7024 1DG61 & 1DG61D Primary & laborator

duplicate 

47 P9900529-1 P9900529-2 P9900529-3 P9900529/P1110157/ SNLNM7025 1DG62 Primary sample 47 P9800958-1 P9800958-2 P9800958-3 P9800958/P1110198 SNLNM7012 IDG63 Primary sample 47 P9900532-1 P9900532-2 P9900532-3 P9900532/P1110199/ SNLNM7017 1DG64 Primary sample 47 P9801007-1 P9801007-2 P9801007-3 P9801007/P1110201/ SNLNM7018 1DG65 Primary sample 
24 

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, however, were based on only a single RH TRU 

container (No. P1110158) out of five that were sampled. The remaining four samples 

were either non-TRU or belonged to another waste matrix. As a result only one RH 

container from this waste group was eligible for WIPP disposal. Accordingly, the postsampling memorandum for PKE00027/54 should have been revised to document the 

effects of this change on the quality assurance (QA) objectives, as stated 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 that were used to support the development of 

scaling factors and their statistical evaluation. EPA communicated these concerns to CBFO via a 

written memorandum on February 29, 2012, and CBFO provided a written response. EPA 

commented on the revised post-sampling memorandum 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 the impact of non-RH waste samples on the drumspecific radiological content of RH containers in PKE00027/54, the revised post-sampling 

memorandum contained only two footnotes to Table 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 intended for disposal at WIPP. The changes made 

did not reflect this. Subsequently on March 28, 2012, CBFO sent a response which is 

satisfactory. 

EPA approvals are based on documented objective evidence 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 stream, as asserted by CBFO. Documentation of a 

waste characterization process that CBFO presents for EPA’s approval 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 contrary. This mistake was eventually 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 specify the importance of agreement between the 

objective evidence that documents a waste characterization 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 the sample analysis were evaluated and were 

found to be acceptable. 

The same radiometric and spectrometric techniques were used for samples from PKE00027/54 

and PKE00047. The results were documented in technique-specific BDRs, which EPA evaluated 

for technical content. These are discussed separately below. 

PKE00047 

General Comments

The tamper-indicating ratchet-type 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” because the shipping container tamper-indicating 

device was intact when the container was received by the laboratory. 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 memorandum. However, the laboratory analyzed 

duplicate laboratory control standards (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 has 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 following sections discuss the pertinent details 

of each analytical technique. 

Alpha Spectrometry, BDR No. ALD11021A – 241Am and Isotopic Cm, Pu and U

The BDR narrative stated that all quality control (QC) requirements were met. The analyses 

performed on the sample leachates also included Am/Cm, 245Cm, isotopic Pu, and isotopic U 

fractions. The report narrative did not identify any problems with these analyses. The BDR 

contained a completed “Sample Receiving and Custody Review Checklist – Analytical 

Laboratory,” in which initiation of NCR No. 63602 was recorded. The BDR also contained a 

completed “Independent Technical Review Checklist – Actinides by Alpha Spectrometry.” 

“Attachment 7 – Site Project Manager Radiochemistry or ICP-MS Analytical Batch Data Report 

Checklist” was attached and completed as required. 

Gas Flow Proportional Counting, BDR No. ALD11021B – 90Sr

The BDR narrative stated that all QC requirements were met. The BDR contained a completed 

“Sample Receiving and Custody Review Checklist – Analytical Laboratory” form, in which 

initiation of NCR No. 63602 was recorded. The BDR also contained a completed “Independent 

Technical Review Checklist, Radiostrontium by Gas-Flow Proportional Counting (GFPC).” 

“Attachment 7 – Site Project Manager Radiochemistry or ICP-MS Analytical Batch Data Report 

Checklist” was attached and completed as required. 
26 

Gamma Spectrometry, BDR No. ALD11021G – 137Cs 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 Sample No. 1DG65 as a duplicate to assess precision. The BDR 

narrative stated that all QC requirements were met except for the detection limits for 134Cs in one 

sample. Gamma spectrometry was performed for 60Co, 134Cs, 137Cs, europium-154 (154Eu) and 

other gamma-emitting radionuclides. The BDR contained a completed “Sample Receiving and 

Custody Review Checklist – Analytical Laboratory” form, in which initiation of NCR No. 63602 

was recorded. The BDR also contained a completed “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 Spectrometry, BDR No. ALD11021I – Isotopic U and Pu

239Pu 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 was prepared, one for Pu and one for U, and analyzed with 

acceptable recoveries. The BDR contained a completed “Sample Receiving and Custody Review 

Checklist – Analytical Laboratory” form, in which initiation of NCR No. 63602 was recorded. 

The BDR also contained a completed “ITR Checklist, Pu and U Isotopes by Inductively Coupled 

Plasma Mass Spectrometry.” “Attachment 7 – Site Project Manager Radiochemistry or ICP-MS 

Analytical Batch Data Report Checklist” was attached and completed as required. 

Liquid Scintillation Counting, BDR No. ALD11021L – 241Pu

The Pu fraction of the leachate was separated using an approved laboratory method and was also 

used for the alpha spectrometry analyses discussed above. The BDR narrative stated that all QC 

requirements were met, although a spiking error required that a blank and an LCS be leached in 

acid a second time. The BDR contained a completed “Sample Receiving and Custody Review 

Checklist – Analytical Laboratory” form, in which initiation of NCR No. 63602 was recorded. 

The BDR also contained a completed “ITR Checklist, Determination of Pu-241 by Liquid 

Scintillation Counting (LSC).” “Attachment 7 – Site 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 opened without breaking the seal. The laboratory 

initiated NCR No. 63436 to address 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 the container was received 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 duplicate LCSs as allowed by its own QA program 

except for gamma analysis, for which Sample No. 1DG50 was processed in duplicate as required 
27 

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 has 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 discuss the pertinent details of each analytical 

technique. 

Alpha Spectrometry, BDR No. ALD11019A – 241Am 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, 245Cm, isotopic Pu and isotopic U fractions. The report 

narrative identified a possible positive bias for 233U/234U for Sample Nos. 1DG51 and 1SG52 and 

a possible high bias for 239Pu/Pu240 for Sample No. 1DG51. The BDR contained a completed 

“Sample Receiving and Custody Review Checklist – Analytical Laboratory,” in which initiation 

of NCR No. 63436 was recorded. The BDR also contained a completed “Independent Technical 

Review Checklist – Actinides by Alpha Spectrometry.” “Attachment 7 – Site Project Manager 

Radiochemistry or ICP-MS Analytical Batch Data Report Checklist” was attached and 

completed as required. 

Gas Flow Proportional Counting, BDR No. ALD11019B – 90Sr

The BDR narrative stated that all QC requirements were met. The BDR contained a completed 

“Sample Receiving and Custody Review 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 Counting (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, 137Cs 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 memorandum for PKE00027/54 identified Sample 

No. 1DG50 as the laboratory duplicate, and this was used to assess precision. The BDR narrative 

stated that all QC requirements were met except for the detection limit for 134Cs in Sample Nos. 

1DG50, 1DG50D and 1DG52. Gamma spectrometry was performed for 60Co, 134Cs, 137Cs, 154Eu 

and other gamma-emitting radionuclides. The BDR contained a completed “Sample Receiving 

and Custody Review Checklist – Analytical Laboratory,” in which initiation of NCR No. 63436 

was recorded. The BDR also contained a completed “ITR Checklist, Gamma Spectroscopy” and 

“Attachment 7 – Site Project Manager Radiochemistry or ICP-MS Analytical Batch Data Report 

Checklist,” which was completed as required. 

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

233U, 234U, 235U and 238U 

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

239Pu was at a level below required acceptance levels. The level of 240Pu detected in the 

laboratory blank was such that a positive bias in the reported result for Sample Nos. 1DG50, 

1DG51 and 1DG52 may be present. LCS/LCSD duplicate analyses demonstrated acceptance 

precision. A post-digestion spike was prepared, one for Pu and one for U, and analyzed with 
28 

acceptable recoveries. 239Pu was not detected in Sample Nos. 1DG51 and 1DG52. The BDR 

contained a completed “Sample Receiving and 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 Isotopes by Inductively Coupled Plasma Mass 

Spectrometry.” “Attachment 7 – Site Project Manager Radiochemistry or ICP-MS Analytical 

Batch Data Report Checklist” was attached and completed as required. 

Liquid Scintillation Counting, BDR No. ALD11019L – 241Pu

The Pu fraction of the leachate was separated using 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 required that one blank and an LCS be leached 

in acid a second time. The BDR contained a completed “Sample Receiving and Custody Review 

Checklist – Analytical Laboratory,” in which initiation of NCR No. 63436 was recorded. The 

BDR also contained a completed “ITR Checklist, Determination of Pu-241 by Liquid 

Scintillation Counting (LSC).” “Attachment 7 – Site 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. SNLNM007023 from PKE00027/54 (containing three 

commingled parcels) were different from those developed for the two single-parcel waste 

containers, resulting in three sets of scaling 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 container 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, Container 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. 137Cs Scaling Factors for PKE00027/54 and PKE00047, 

Ci Radionuclide/Ci 137Cs 

Radionuclide 

Scaling Factors PKE00027/54 Scaling Factors 

P1110158 P1110159 P1110155 PKE00047 241Am 6.99E-04 4.38E-03 2.38E-03 8.79E-02 242Cm 4.96E-06 5.59E-05 1.92E-05 7.49E-04 244Cm 2.35E-05 4.43E-05 1.16E-04 6.08E-04 245Cm 1.29E2.5 2.35E-04 1.30E-04 3.84E-03 238Pu 1.11E-03 9.93E-04 7.58E-03 2.28E-02 

239Pu 6.02E-05 1.41E-04 3.20E-04 6.74E-02 240Pu 8.43E-05 1.98E-04 4.49E-04 4.05E-02 241Pu 4.32E-03 1.05E-02 1.95E-02 4.66E-01 242Pu 5.64E-06 3.29E-04 4.64E-04 5.23E-06 233U 3.57E-07 2.09E-05 2.94E-05 2.08E-05 234U 3.56E-05 3.22E-05 3.89E-04 1.56E-04 235U 1.10E-06 6.68E-07 1.09E-05 4.73E-06 236U - - - 4.80E-06 238U 2.01E-07 2.05E-07 1.18E-06 3.98E-06 137Cs 1.00E+00 1.00E+00 1.00E+00 1.00E+00 

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

(6) The technical basis and derivation of total measurement uncertainty were evaluated and 

were found to be adequate. 

The development of total measurement uncertainty (TMU) for both PKEs is based on the 

propagation of uncertainties present in all aspects of the radiological characterization process. 

These aspects are assumed to be independent, which allows them to be added in quadrature.9 The 

TMU determination included contributions of the following sources of uncertainties: 

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

uncertainties. 

• 137Cs activity measurement – dose rate measurement 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 137Cs 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 appropriate 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, respectively, and the detailed treatment of TMU is 

 9

 Adding in quadrature is a standard statistical technique 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, Revision 0 (Reference U1038), and in Calculation 

Package SNL-RH-15, Revision 0 (Reference U1043). The overall uncertainties are consistent 

with what EPA has observed for RH determinations at other RH TRU generator sites. The 

overall uncertainties for PKE00027/54 and PKE00047 containers are provided below in Table 8. 

There were no concerns regarding the technical derivation and documentation of TMU for 

PKE00027/54 and PKE00047. 

Table 8. Overall Uncertainties for PKE00027/54 and PKE00047 

Radionuclide Total 137Cs Uncertainty 

Total Scaling Factor 

Uncertainty Total Uncertainty 

PKE00027/54 PKE00047 PKE00027/54 PKE00047 PKE00027/54 PKE00047 233U 28.0% 28.0% 100.0% 100.0% 103.8% 103.8% 234U 28.0% 28.0% 37.7% 57.8% 46.9% 64.2% 235U 28.0% 28.0% 45.9% 52.3% 53.7% 59.3% 238U 28.0% 28.0% 51.4% 16.8% 58.5% 32.6% 238Pu 28.0% 28.0% 18.4% 10.1% 33.5% 29.7%

239Pu 28.0% 28.0% 39.6% 32.7% 48.5% 43.1% 240Pu 28.0% 28.0% 38.8% 32.4% 47.9% 42.8% 241Pu 28.0% 28.0% 26.7% 20.0% 38.7% 34.4% 242Pu 28.0% 28.0% 100% 100% 103.8% 103.8% 241Am 28.0% 28.0% 36.2% 26.3% 45.7% 38.4% 245Cm 28.0% 28.0% 52.7% 29.1% 59.7% 40.4% 

90Sr 28.0% 28.0% 31.8% 20.8% 42.3% 34.8% 137Cs 28.0% 28.0% 0.0% 0.0% 28.0% 28.0%

90Y 28.0% 28.0% 31.8% 20.8% 42.3% 34.8% 137mBa 28.0% 28.0% 0.0% 0.0% 28.0% 28.0%

(7) Remote-handled and transuranic determinations 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 showed the external dose rates. 

(8) The technical basis of the dose-to-curie correlation and its documentation were evaluated, 

and both aspects were acceptable. 

The DTC correlation was evaluated based on DTC BDR Nos. SNLRHDTC11001 and 

SNLRHDTC11002, which addressed containers from PKE00027/54, 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 Report,” with all parameters acceptable. 

• Container data sheets for all 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 that all DTC operators and ITRs were listed on 

the list of Qualified Individuals (LOQI) for the time periods they conducted measurements. 

Four of the containers from BDR No. SNLRHDTC11001 were determined to be non-TRU by 

virtue of having TRU alpha concentrations less than 100 nCi/g, as documented in NCR Nos. 

NCR-RHSNL-2352-11 and NCR-RHSNL-2353-11. The 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 from 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 was technically adequate. 

There were no issues related to the DTC correlation 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 radiological characterization-related findings or 

concerns relative to the addition of the PKE00047 and PKE00027/54 containers to Waste Stream 

SNL-HCF-S5400-RH during this T1 evaluation. However, EPA raised 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 specify the importance of agreement between the 

objective evidence that documents a waste characterization 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 characterization tiering based on the results of this T1 

evaluation. As stated in the Executive 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 baseline approval report are applicable. 

Radiological Characterization Approval

Based on the results of this evaluation, EPA approves the process of determining the radiological 

content of the PKE00027/54 and PKE00047 portions of Waste Stream SNL-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 characterization of the containers generated from 

PKE00027/54 and PKE00047. These are discussed separately below 

PKE00047 

The VE data for PKE00047 were reported in VE BDR Nos. SNLRHVE110006, 

SNLRHVE11007, and RHSNLVE110101. SNL-CCP stated that the reason for the inconsistent 

numbering format between BDR Nos. SNLRHVE11007 and SNLRHVE11010 (year designator 

followed by 3 numbers) and RHSNLVE110006 (year designator followed by four numbers) was 

a process change. 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 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 data for four containers, SNLNM007024, 

SNLNM007025, SNLNM007017 and SNLNM007018. 

• BDR No. SNLRHVE11010 contained VE data 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 operators 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 waste 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 nonconformance reports were generated for BDR 

Nos. SNLRHVE11007 and SNLRHVE11010. The SNL-CCP LOQI that EPA reviewed 

demonstrated that VE data were generated by qualified personnel. EPA reviewed selected 

training records for the VE operators generating the data contained 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 provided 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 adequate and effective for the generation of VE 

data for RH waste. The 30-gallon Container No. P1110158 was packaged into 55-gallon 

Container No. SNLNM007020 and included general debris items; the primary contents were 

designated as “Steel.” NCR No. 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 sheet. 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. EPA 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 findings 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-related 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 characterize additional RH wastes from 

PKE00027/54, PKE000457 or PKE00044 in the future, the tiering conditions and limitations 

included in Table 1 of the final baseline approval report are applicable. 
34 

Visual Examination Approval

Based on the results of this evaluation, EPA approves the process of VE for determining the 

physical contents of the PKE00027/54 and PKE00047 portions of Waste Stream SNL-HCFS5400-RH, as described in this report. 

7.0 SUMMARY OF RESULTS 

EPA concluded that the waste characterization processes of AK, radiological characterization, 

and VE used to characterize RH TRU containers 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 findings or concerns related to AK, radiological 

characterization or VE. EPA personnel worked interactively with their SNL-CCP counterparts to 

answer questions, identify information needs and acquire necessary data and references; all 

potential issues were resolved in a timely fashion. 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 revised. 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 recurrence of the situation EPA encountered with the 

documentation for PKE00027/54. 

Tiering Changes

Based on the results of this evaluation, there are no significant changes 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 characterize additional RH wastes from 

PKE00027/54, PKE000457 or PKE00044 in the future, the tiering conditions and limitations 

included in Table 1 of the final baseline approval report are applicable. 

Approval

EPA determined that the procedures and processes used by SNL-CCP for the addition of 

PKE00047 and PKE00027/54 to RH Waste Stream SNL-HCF-S5400-RH were adequate. 

Therefore, EPA approves the addition of PKE00047 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, Sandia National Laboratory/New Mexico Waste 

Stream Number SNL-HCF-S5400-RH, Lot 2, for Audit Purposes Only, May 31, 2011 

AK Container Tracking Spreadsheet SNL RH AK Container Matrix, September 19, 2011 

Analytical Laboratory Batch Data Reports ALD11021A, ALD11021B, ALD11021G, 

ALD11021I, ALD11021L, ALD11019A, ALD11019B, ALD11019G, ALD11019I and 

ALD11019L 

Batch Data Reports SNLRHDTC11001, SNLRHDTC11002, SNLRHVE110006, 

SNLRHVE11007 and SNLRHVE11010 

CCP-AK-SNL-500, Central Characterization Project Acceptable Knowledge Summary Report 

for Sandia National Laboratories/New Mexico Remote-Handled Hot-Cell Facility Transuranic 

Waste (Debris), Waste Stream: SNL-HCF-S5400-RH, Revision 4, November 30, 2011 

CCP-AK-SNL-501, Central Characterization Project Remote-Handled Transuranic Radiological 

Characterization Technical Report for Sandia National Laboratories/New Mexico Hot-Cell 

Facility Remote-Handled Transuranic Debris Waste, Waste Stream: 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 National 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 Transuranic Debris Waste, Waste Stream: SNL-HCFS5400-RH, Revision 0, November 29, 2010 

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

CCP-TP-002, Attachment 2, CCP Waste Stream Profile Form, Waste Stream SNL-HCF-S5400-

RH, Draft for Audit Purposes, November 10, 2011 

CCP-TP-005, Attachment 4, Acceptable Knowledge Source Document Reference List, 

December 6, 2011 

CCP-TP-005, Attachment 6, Waste Form, Waste Material Parameters, Prohibited Items, and 

Packaging, April 21, 2011 

CCP-TP-005, Attachment 8, Waste Containers, July 1, 2011 
A-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 Waste 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 Stream SNL-HCF-S5400-RH, Draft, file dated 

December 20, 2011 

C1004, Reactor Accident Experiments and Funding, 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 SAP for Waste Stream SNL-HCF-S5400-RH 

Segregates the Three Principal Sources of Waste Generation into Three Radiological Categories, 

J. Kleckner, June 29, 2011 

I1020, Hot Cell Facility (HCF) Decontamination 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 Evaluations (PKE) for Radiological Ratios, 

PKE00044, PKE00047, and PKE00027/54, March 1980 through March 2004 

M1021, Memo to Record, re: Evaluation of Radionuclide 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 Characterization of Waste Arising from Hot Cell Facility 

Glovebox, Revision 1, PLA 95-28, October 12, 1995 
A-3 

P1102, Building 6580 Hot Cell Facility, Steel Containment Boxes and Zone 2A Process 

Knowledge Documentation: Isotope Production Program, Hot Cell Facility Decontamination 

Project, L. Fugelso, S. Longley, L. Bourcier, June 28, 1996 

P1104, Hot Cell Facility (HCF) Safety Analysis Report, Main Report and Appendices, 

L.F. Restrepo, SAND94-2650, October 21, 1994 

P1105, Series of Procedures Titled AHCF Campaign 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 “Analysis of Sample Data for Sandia National 

Laboratory/New Mexico (SNL/NM) Waste Stream SNL-HCF-S5400-RH, PKE00027/54,” from 

J. Holderness to I. Quintana, August 10, 2011 and Revision 1, February 29, 2012 

Post-Sampling Analysis Memorandum “Analysis of Sample Data for Sandia National 

Laboratory/New Mexico (SNL/NM) Waste Stream SNL-HCF-S5400-RH, PKE00047,” from 

J. Holderness to I. Quintana, August 26, 2011 

Radiological Characterization Concern for SNL-CCP: PKE00027/54 and PKE00047 with 

CBFO’s Response and EPA’s Assessment of CBFO’s Response, February 29, 2012 and March 

6, 2012 

RH Program – SNL List of Qualified Individuals, April 27, 2011 

RH Program – SNL List of Qualified Individuals, May 19, 2011 

RH Program – SNL List of Qualified Individuals, June 8, 2011 

RH Program – SNL List of Qualified Individuals, July 22, 2011 

RH Program – SNL List of Qualified 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: Survey 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, 

2011 
A-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 Radionuclides, J. Vance, SNL-RH-09, Revision 0, 

September 30, 2011 

U1038, Uncertainty Analysis for Drums – PKE00027, J. Holderness, SNL-RH-10, Revision 0, 

September 30, 2011 

U1039, DTC and Related Calculations for Drums – 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 Radionuclides, J. Vance, SNL-RH-14, Revision 0, 

September 30, 2011 

U1043, Uncertainty Analysis for Drums – PKE00047, J. Holderness, SNL-RH-15, Revision 0, 

September 30, 2011 

U1044, DTC and Related Calculations for Drums – PKE00047, J. Holderness, SNL-RH-16, 

Revision 0, September 30, 2011