DOCKET NO: A-98-49; II-A4-154

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT:

EVALUATION OF CONTACT-HANDLED TRANSURANIC S3000 WAS TE STREAM

“RLCCPPUNIT” AT THE HANFORD CENTRAL CHARACTERIZATIO N PROJECT

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

November 2011i TABLE OF CONTENTS

Section Page

Acronyms ..........................................

................................................... ........................................... ii

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

................................................... ................................1

2.0 Approval Summary for Hanford-CCP Contact-Handle d Waste Characterization Program ..3

3.0 Purpose of Tier 1 Evaluations .................

................................................... .............................3

4.0 Purpose of This Report ........................

................................................... ................................3

5.0 Scope of the Tier 1 Evaluation.................

................................................... ............................4

6.0 Performance of the Tier 1 Evaluation ..........

................................................... ........................4

6.1 Acceptable Knowledge, Non-Destructive Assay and Real Time Radiography .........4

7.0 Summary of Results and Conclusions ............

................................................... ...................18

LIST OF TABLES

Table 1. Revised Tiering of TRU Waste Characteriza tion Processes Implemented by

Hanford-CCP .......................................

................................................... ....................... 2
Table 2. EPA Inspection Team Members .............

................................................... ...................... 4
Table 3. Batch Data Reports Examined, Waste Stream RLCCPPUNIT ....................................... 5
Table 4. Plutonium and Uranium Isotopic Distributi ons ............................................... ................ 8
Table 5. Default Percentage 240 Pu 20-Year Aged Mass Fraction ..................... ............................. 9
Table 6. Traceability of Select Containers in Wast e Stream RLCCPPUNIT .............................. 13ii ACRONYMS

AK acceptable knowledge

AKE Acceptable Knowledge Expert

AKSR AK summary report

Am americium

Ba barium

BDR batch data report

CAR Corrective Action Report

CBFO Carlsbad Area Field Office

CCP Central Characterization Project

Cf californium

CFR Code of Federal Regulations

CH contact-handled

CIS Characterization Information Summary

Cm curium

CML Critical Mass Laboratory

Co cobalt

CRA Compliance Recertification Application

Cs cesium

CWC Central Waste Complex

DMS data management system

DOE U.S. Department of Energy

DQO data quality objective

DR discrepancy resolution

EA expert analyst

EPA U.S. Environmental Protection Agency

ES&H environmental safety and health

Eu europium

FR Federal Register

GEA-A Gamma Energy Analysis Unit A

GEA-B Gamma Energy Analysis Unit B

HLW high-level wasteiii

ITR Independent Technical Reviewer

K potassium

LOQI list of qualified individuals

LWA Land Withdrawal Act

Nb niobium

nCi/g nanocuries per gram

NCR nonconformance report

NDA non-destructive assay

NDE nondestructive examination

Np neptunium

NWPA Nuclear Waste Policy Act

ORIA Office of Radiation and Indoor Air

PFP Plutonium Finishing Plant

PRF Plutonium Reclamation Facility

Pu plutonium

QA quality assurance

Ra radium

RCRA Resource Conservation and Recovery Act

RECUPLEX Recovery of Uranium and Plutonium by Extra ction

RTR real-time radiography

SCG Summary Category Group

SNF spent nuclear fuel

SPM Site Project Manager

Sr strontium

SWITS Solidified Waste Information Tracking System

T1 Tier 1

T2 Tier 2

Th thorium

TRU transuranic

U uranium

VE visual examination

VET visual examination technique

WAC waste acceptance criteriaiv

WAP Waste Analysis Plan

WDS Waste Data System

WIPP Waste Isolation Pilot Plant

WMC waste matrix code

WMP waste material parameter

WRAP Waste Reprocessing and Packaging

WSPF Waste Stream Profile Form1

1.0 EXECUTIVE SUMMARY

This report supports the U.S. Environmental Protect ion Agency (EPA or the Agency) approval of the proposed Tier 1 (T1) change to the EPA-appro ved transuranic (TRU) waste characterization program at the Hanford Site. This approval allows the Hanford Central Characterization Project (CCP) to dispose of retrie vably-stored, contact-handled (CH) TRU solidified inorganic (S3000) Waste Stream RLCCPPUNI T at the Waste Isolation Pilot Plant (WIPP). The approval does not include other S3000 w aste such as the Hanford Tank waste or KBasin waste, which must be addressed in separate T1 requests. Hanford-CCP characterized this waste using the system of controls the EPA evaluate d during a baseline inspection performed in April 2010, which was approved December 15, 2010.

The reason for this limited approval is two-fold. F irst, EPA has determined that the waste characterization information provided for this wast e stream RLCCPPUNIT is not likely to be applicable for other unique Hanford solid waste str eams such as the Hanford Tank Waste or KBasin waste. Second, due to the budgeting constrain ts, in Fiscal Year 2012 and beyond, no CH

TRU waste characterization will occur at Hanford. A s a result, at Hanford, no CH TRU solid waste is being characterized at this time. In the f uture, when TRU waste characterization at Hanford is reactivated, EPA’s evaluation of TRU was te characterization program for the December 2010-approved debris waste (S5000), new so lid waste streams, and soils (S4000) will be necessary.

In accordance with 40 CFR 194.8(b), the EPA conduct ed a baseline inspection of the CCP’s CH TRU waste characterization program at the Hanford S ite near Richland, Washington. As a result of this baseline inspection, EPA approved the Hanfo rd-CCP CH TRU waste characterization program with conditions and limitations, as discuss ed in the Hanford Baseline Final Inspection Report (see Docket No. A-98-49; II-A4-138). This ap proval was limited to retrievably-stored and newly-generated TRU debris waste (S5000), and waste from any other summary category group (SCG) was identified as a T1 change.

On April 5, 2011, the Carlsbad Field Office (CBFO) requested EPA approval of the addition of

CH Waste Stream RLCCPPUNIT from the S3000 SCG to th e Hanford-CCP baseline approval as a T1 change. During June and July 2011, EPA conduct ed a desktop evaluation of the requested T1 change by reviewing documents and records in the technical areas of Acceptable Knowledge (AK), Non-Destructive Assay (NDA), and Nondestructi ve Examination (NDE), specifically Real-Time Radiography (RTR). During the evaluation, EPA did not identify any findings or concerns and, based on this evaluation, EPA approve s the addition of the S3000 CH Waste Stream RLCCPPUNIT at Hanford-CCP. This EPA approval required revisions to the T1 designations, which are reflected in the revised ti ering table, Table 1, below.

This report serves as EPA’s public notification of the approval of this T1 change. This information will be provided through the EPA web si te and by sending e-mails to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3 ).2Table 1. Revised Tiering of TRU Waste Characterization Processes Implemented by Hanford-CCP (November2011)(Original Tiering Based on the Baseline Inspectionissued on December 15, 2010)Process ElementsHanford-CCP T1 Changes Needing EPA Review andApprovalHanford-CCP T2 ChangesaAcceptable Knowledge (AK) Implementation of load management (AK 13)Implementation of AK for wastes other thanretrievably storedand newly generated S5000 debris and S3000 Waste StreamRLCCPPUNIT. (AK 1)Notification to EPA upon completion of new versionsor updates/substantivechangesbof the following:-Modification of CCP-TP-005, Revision 18 (AK 4)-Availability of modifications to the AKSR (AK 5)-Availability of all final WSPF with related attachments (AK 9)-Availability of all AK Accuracy Reports (AK 12)-Availability of successful training records (AK 10)-Availability of the AK-NDA memorandum (AK 14)Non-Destructive Assay (NDA) New equipment or physical modifications to approvedequipmentc(NDA 1)Extension or changes to approved calibration rangefor approvedequipment (NDA 2)Notification to EPA upon completion of changes to software for approvedequipment, operating range(s), and site proceduresthat require CBFOapproval (NDA 2)Real-Time Radiography (RTR) There are no T1 changesat this time Notification to EPA upon the following:-Modificationcto approved equipment, RTR units A and B (RTR 2)-Completion of changes to site RTR procedures requiring CBFO approval(RTR 2)-Addition of new SCG to the RTR processes that are subject to thisapproval (RTR 2)-Implementation of a different type of RTR equipment(RTR 2)Visual Examination (VE) Performance of VE by any method other than using two trainedoperators to perform actual VE at the time of packaging (VE 1)Notification to EPA upon the following:-Completion of changes to site VE procedures requiring CBFO approval(VE 2)-Addition of new SCG to the VE processes that are subject to this approval(VE 2)Waste Data System (WDS) There are no T1 changes atthis time Notification to EPA upon the following:-Completion of changes to WDS procedure(s) requiringCBFO approval(WDS 2)-Changes to the Excel spreadsheet titled WDS MasterTemplate.xls,Revision 2, Addendum #2, SCO #1065 (WDS 2)aUpon receiving EPA approval, Hanford-CCP will report all T2 changes to EPA at the end of each fiscal year quarter. Note: EPA may request specific T2 change items before theend of a fiscal quarter.b“Substantive changes” means changes with the potential to impact the site’s waste characterization activities or documentation thereof, excluding changesthat are solely relatedto ES&H, nuclear safety, RCRA or are editorial in nature.cModifications to approved equipment include all changes with the potential to affect NDA data relativeto waste isolation and exclude minor changes, suchas the addition ofsafety-related equipment.3

2.0 APPROVAL SUMMARY FOR HANFORD-CCP CONTACT-HANDLED WA STE

CHARACTERIZATION PROGRAM

EPA provided a formal baseline approval of the Hanf ord-CCP CH waste characterization program in December 2010. Since then, EPA has appro ved one T1 change to the HanfordCCP CH waste characterization program, the addition of the Super High Efficiency Neutron Counter “A” NDA system in March 2011; see Docket No . A-98-49; II-A4-146.

3.0 PURPOSE OF TIER 1 EVALUATION

Any changes to the waste characterization activitie s from the date of the baseline inspection must be reported to and, if applicable, approved by EPA according to the tiering requirements set forth in the Hanford Baseline Final Report cited above. U nder the changes to 40 CFR 194.8 promulgated in the July 16, 2004, Federal Register notice, EPA must perform a single baseline inspection of a TRU waste generator site’s waste ch aracterization program. The rule under which baseline inspections are conducted can be found in the Federal Register (Vol. 69, No. 136, pages 42571–42583 of July 16, 2004). The baseline inspect ion leads to approval of the site’s TRU waste characterization program, based on the demons tration that the program’s components, with applicable conditions and limitations, can adequate ly characterize TRU wastes. During the baseline inspection, EPA determines whether the sit e can adequately comply with the regulatory requirements imposed on TRU wastes destined for dis posal at the WIPP. An EPA inspection team conducts an on-site baseline inspection to ver ify that the site’s system of controls is technically adequate and properly implemented.

Following EPA’s approval of waste characterization processes evaluated during the baseline inspection, EPA is authorized to evaluate and appro ve, if necessary, changes to the site’s approved waste characterization program by conducti ng additional inspections under the authority of 40 CFR 194.24(h). Under 40 CFR 194.24, EPA has the authority to conduct continued compliance inspections to verify that the site continues to use only the approved waste characterization processes to characterize the wast e and remains in compliance with all the regulatory requirements. Based on the adequacies of the waste characterization processes demonstrated during the baseline inspection, includ ing all conditions and limitations, EPA specifies which subsequent waste characterization p rogram changes or modifications must undergo further EPA approvals. This is accomplished by assigning a tier level to each aspect of the waste characterization program. T1 activities h ave more stringent reporting requirements and the U.S. Department of Energy (DOE) must notify EPA of the proposed T1 change, which EPA must evaluate and approve prior to implementation.

4.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluatio n of the addition of S3000 Waste Stream RLCCPPUNIT to the Hanford-CCP approval as a T1 chan ge. This report documents the basis for EPA’s approval, and explains the results of the technical evaluation of these wastes. EPA’s approval of S3000 Waste Stream RLCCPPUNIT has been conveyed to DOE separately by letter. As discussed previously, EPA will also announce the decision on its web site at www.epa.gov/radiation/WIPP , in accordance with 40 CFR 194.8(b)(3).4

5.0 SCOPE OF THE TIER 1 EVALUATION

The scope of the T1 evaluation was the addition of Hanford-CCP S3000 CH Waste Stream RLCCPPUNIT. The approval does not include other S30 00 waste streams such as Hanford Tank

wastes or K-Basin wastes.

6.0 PERFORMANCE OF THE TIER 1 EVALUATION

EPA conducted its evaluation of AK, NDA and NDE as a desktop review. Members of the EPA Inspection Team and Hanford-CCP personnel who parti cipated in this evaluation are listed in Table 2, along with each person’s position during t he evaluation and affiliation.

Table 2. EPA Inspection Team Members

Inspection Team Member Position Affiliation

Ed Feltcorn Lead Evaluator U.S. EPA
Connie Walker Technical Inspector, AK S. Cohen & As sociates, Inc.

Dorothy Gill Technical Inspector, NDE S. Cohen & As sociates, Inc.

Patrick Kelly Technical Inspector, NDA S. Cohen & A ssociates, Inc

Rose Gogliotti Technical Inspector, NDA S. Cohen & Associates, Inc.

Sherri Nance Acceptable Knowledge Expert CCP

Steve Schafer Acceptable Knowledge Expert CCP

Mark Doherty Acceptable Knowledge Expert CCP

Veronica Waldram Site Project Manager CCP

The three waste characterization technical areas of AK, NDA and NDE are addressed in one section of the report. The AK evaluation was compre hensive because the documentation for these wastes had not been previously reviewed. The NDA and NDE reviews were limited, and focused primarily on evaluating NDA and RTR BDRs.

6.1 Acceptable Knowledge, Non-Destructive Assay and Rea l-Time Radiography

EPA examined the AK process and associated informat ion specific to radiological and physical

contents of the waste stream to determine whether H anford-CCP’s proposed addition of CH retrievably-stored and newly-generated S3000 Waste Stream RLCCPPUNIT complies with 40

CFR 194.24 and 194.8. EPA also reviewed NDA and RTR BDRs for technical adequacy, and the results of this evaluation are presented below.

Waste Characterization Element Description

EPA examined the following AK technical elements:

• Waste stream identification and definition

• Radionuclide content of waste

• Physical composition of waste5

• Overall procedural technical sufficiency and scope

• Ability to follow the AK characterization process f or containers including AK assembly, compilation and verification

• Sufficiency of AK Summary Report (AKSR) including s ource document integration

• Drum traceability

• Defense origin of waste

• Presence of spent nuclear fuel (SNF) and high level waste (HLW)

• Waste Stream Profile Form (WSPF)

• Personnel training

• Non Conformance Reports (NCRs)

• AK accuracy

• Load Management

• AK-NDA communication

Documents Reviewed

EPA inspectors examined documents related to AK, wh ich were provided in electronic format. The list of all documents reviewed is presented in Attachment A. The following RTR and NDA

BDRs were examined:

Table 3. Batch Data Reports Examined, Waste Stream RLCCPPUNIT

Drum Number RTR BDR No. NDA BDR No.

RL0005912 RLRTRA0174 RLGEAB0143

RL0006945 RLRTRA0174 RLGEAB0143

RL0006943 RLRTRA0174 RLGEAB0143

RL0005656 RLRTRB0156 RLGEAB0143

RL0005833 RLRTRB0156 RLGEAB0143

RL0005866 RLRTRB0156 RLGEAB0143

Technical Evaluation

Hanford-CCP completed characterization of a single S3000 CH waste stream, RLCCPPUNIT, composed of retrievably-stored solidified plutonium (Pu) nitrate solutions from several sources on site at Hanford. These materials were originallyslated for Pu recovery, but later were redesignated as waste. EPA evaluated the adequacy of AK information specific to this CH TRU retrievably-stored waste stream in the following ar eas.6

(1) The definition of waste stream was evaluated and fo und to be adequate.

S3000 SCG Waste Stream RLCCPPUNIT consists of solid ified Pu nitrate solutions, as described in the AK Summary Report (AKSR) CCP-AK-RL-116, Revi sion 1. These solutions originated in the Plutonium Finishing Plant (PFP), Plutonium Recl amation Facility (PRF), Building 325 Laboratory, and the 209-E Critical Mass Laboratory (CML), and resulted from laboratory experiments and flushing the PRF process lines. Ope rations in the PFP began in 1949 and were conducted in several buildings, as described below:

• Building 234-5Z is the main facility at PFP that ho used storage vaults, lines, sumps, rooms, and laboratories; the Recovery of Uranium an d Plutonium by Extraction (RECUPLEX) was the main plutonium processing/recove ry process in Building 234-5Z (References P071 and P153)

• Building 236-Z PRF was constructed in 1963 and is r eferred to as the Plutonium Nitrate Production Facility (Reference P239); it replaced t he RECUPLEX facility. PRF is now inactive, but was used to recover plutonium through incineration and solvent recovery (Reference P052) and was designed to concentrate li quids, process solid material, and recover Pu from aqueous streams via solvent extract ion. Waste Stream RLCCPPUNIT contains Pu nitrate solutions that were generated f rom flushing the PRF process lines in 1988, 1994 and 1995 (References C219, C223 and C229 )

• Building 2736-ZB was a Product Shipping and Receivi ng Facility constructed in 1981– 1983 to support storage operations in Building 2736 -Z, the PFP Plutonium Storage Facility (References P130 and P232)

• 325 Building Radiochemical Processing Laboratory (3 25 Building Laboratory) began operation in 1953, and currently supports a variety of site operations, including: laboratory analyses of fuel reactor samples; charac terization of the chemical and physical properties of tank wastes and immobilized forms of plutonium, and tests involving HLW. The 325 Building Laboratory’s contribution to Waste Stream RLCPUNNIT was generated in 1975 and 1976, and represents the unus ed portions of plutonium-uranium (Pu-U) and plutonium-thorium (Pu-Th) nitrate soluti ons generated for experimental use. Hanford-CCP representatives stated that the 325 Bui lding Laboratory Pu nitrate solutions were managed in closed containers and were not cros s contaminated with other materials. Building 325 Laboratory solutions originated in PFP and reflect distributions of Pu and

transuranic radionuclides consistent with material generated in PFP (References P041 and P153).

• The 209-E Building Critical Mass Laboratory (CML) w as constructed in 1960 and was used to bring Pu and U into critical configurations (References P968, P972 and P978). The facility was shut down in the late 1980s (Refer ences P968 and P971). Hanford-CCP representatives stated that while CML experiments u sed Pu nitrate solutions of varied concentrations, PFP was the source of all CML Pu (R eferences C227, C229, C442, M147, P968, P970, P971, P972 and P978).

The Pu nitrate solutions generated from the facilit ies described above were held for recovery in ten-liter cans and were eventually transferred to B uilding 2736-Z. In 2001, DOE decided to7

discard cans of Pu nitrate material that were too l ow in Pu concentration or were too difficult to recover, as waste. This waste stream includes 49 te n-liter cans from the 325 Building Laboratory, one ten-liter can from the CML, and 50 cans from th e PRF line-flushing activities. These cans were transferred from storage to Room 185 in Buildi ng 234-5Z, where they were processed into 68 55-gallon drums of waste. One additional drum wa s created for use as an NDA standard; this drum contains three 1-gallon cartons with Pu nitrat e absorbed on diatomaceous earth and consists of three different, known quantities of Pu in nitric acid (Reference M149). The waste

stream contains a total of 69 drums—68 of solidifie d Pu nitrate waste and one standard, all of which originated from PFP. All 69 drums were transf erred to the Hanford Central Waste Complex (CWC) to be held prior to disposal at WIPP.

CCP-TP-005, Revision 22 defines a waste stream as w aste materials that have common physical form, that contain similar hazardous constituents [ similar radiological properties for Waste Acceptance Criteria (WAC) compliance], and that are generated from a single process or activity. Hanford-CCP states that the "single proce ss or activity" is the solidification of Pu nitrate using a consistent and defined process. As presente d in the AKSR, various activities conducted in three separate areas generated the Pu nitrate so lutions, and it could be argued that these activities constitute separate processes. However, EPA accepts Hanford-CCP’s interpretation of the waste generation process because the material w as defined as waste in 2001 and, in part, because of compositional similarities of the cans’ contents. EPA examined the waste stream and found that while the drums contained various quanti ties of U, Th and other radionuclides, the Pu composition fell within a specified range and the P u originated from PFP. Hanford-CCP stated that the nitrate solutions operated in a closed loo p, supporting the presence of a defined radiological and chemical composition; EPA agrees t hat the consistent chemical composition of the solidified nitrate supports this assertion, as does the physical form of the waste stream. EPA accepts the single waste stream determination for t his waste stream. See Items (2) and (3), below, for additional information pertaining to the physic al and radiological composition of this waste

stream.

(2) Acceptable knowledge information pertaining to the radiological characteristics of

transuranic wastes was examined and found to be ade quate.

During its early years of operation, PFP fabricated Pu for weapons parts, which included conversion of Pu nitrate to metal and Pu casting an d machining. In the 1960s, the mission shifted to supporting the commercial nuclear industry, and the isotopic distribution of the Pu at the PFP changed, as reflected in the Pu nitrate generated. Based on the commonality of plutonium from, to and among the PRF line flush, CML and 325 Buildi ng Laboratory, Hanford-CCP determined that a range of isotopic distributions may be prese nt in this waste stream.

The Hanford site performed NDA on 68 of the 69 cont ainers in this waste stream using EPAapproved NDA systems at the Waste Receiving and Pro cessing (WRAP), specifically the Gamma Energy Analysis Systems A and B (GEA-A and GE A-B). The 69 th drum was made of standard. The WRAP Data Management System summarize d the radionuclide composition of the

RLCCPPUNIT waste stream in Table 4 of the AKSR. Dat a examined indicate that the waste

contains 238 Pu, 239 Pu, 240 Pu, 241 Pu, and 242 Pu and lesser quantities of 232 U, 233 U, 234 U, 235 U, 236 U

and 238 U (References C037, C060, M148 and P130). These dat a show that 239 Pu and 238 U are the8

predominant radionuclides by weight, and 239 Pu and 241 Pu are the predominant radionuclides by activity. Hanford-CCP representatives also evaluate d the isotopic distribution based on the Solid Waste Information Tracking System (SWITS). These ra nges are presented in Table 4, below.

Table 4. Plutonium and Uranium Isotopic Distributi ons

Pu and Associated Distributions Uranium Distributions Isotope Wt% Distribution Isotope Wt% Distribution

Pu-238 0.01 – 0.05% U-232 Trace

Pu-239 74.78 – 97.77% U-233 Trace

Pu-240 2.13 – 20.72% U-234 0.006 – 0.008%

Pu-241 0.02 – 0.81% U-235 0.57 – 0.97%

Pu-242 0.001 – 0.66% U-236 0.07 – 0.08%

Am-241 0.07 – 2.88% U-238 98.95 – 99.35% Np-237 0.00 – 0.09%

Table 4 was generated assuming americium-241 ( 241 Am) is present due to decay of 241 Pu and that

the 241 Am content will increase over time, as will trace q uantities of 237 Np arising from 241 Am decay. AK data show that 241 Am may also be present in waste generated from the Waste Treatment Complex, which may impact PFP wastes as a whole. Therefore, the estimated percentage of 241 Am may be greater than what is presented (Reference C031). Uranium content may also vary from the above ranges based on uraniu m sources and radiation history (References P183, P278 and P1201). The AKSR also states that pl utonium product specifications do not preclude inclusion of trace impurities including 243 Am, californium-249 ( 249 Cf), 228 Th, and 232 Th, and other isotopes of calcium, carbon, iron, nickel , and neptunium, as well as barium-133 ( 133 Ba), cobalt-60 ( 60 Co), europium-152 ( 152 Eu), curium-243 ( 243 Cm), niobium-94 ( 94 Nb), and radium-226 ( 226 Ra) (Reference M106). Reference P1201 (also cited a s Reference 3 in the AKSR)

states that the waste stream contains "non-trace" a mounts of 234 U, 235 U, and 238 U, 241 Am, and

237 Np, as well as trace amounts of other 232 U, 233 U, 137 Cs, 154 Eu, 22 Na, and 90 Sr. The Pu content of the standard drum discussed in (1), above, is consi stent with Table 4.

EPA examined the data presented in several source d ocuments (References C004, C219, C398 and M381) to better understand the overall radionuc lide composition of the waste stream and to verify that the major waste stream components (325 Building Laboratory, PRF line flushes, and CML) did not indicate unexpected radionuclides. EPA 's review showed that the information presented in Tables 3 and 4 of the AKSR were verifi ed by site-specific data, and the Pu distributions in the wastes observed via assay were consistent with the anticipated ranges.

Default distributions for several Pu mixes were dev eloped by the Hanford Site (Reference P976, also cited as Reference 15 in the AKSR) and were ad opted by Hanford-CCP [see Item (14), below]. The three most frequent percent plutonium i sotopic distributions based on 6%, 12% and

23% 240 Pu are presented in Table 5, below, and were create d using radiological data for about 4,655 containers originating from PFP, as presented in the Solidified Waste Information Tracking System (SWITS) database. The categories re presented by this table were developed based upon the 240 Pu identified in each container, so a drum associat ed with a category would

have a 240 Pu concentration at or below the value in that cate gory, but above the value in the next category (Reference P976). The weight percentages i n the table below are the default plutonium isotopic distributions as of June 30, 1993. EPA's b aseline report concluded that these9

distributions are reasonable. The ranges continue t o be acceptable for Waste Stream RLCCPPUNIT, because AK indicates that the Pu origin ated in the PFP.

Table 5. Default Percentage 240 Pu 20-Year Aged Mass Fraction

Isotope Default 6% Default 12% Default 23%

Weight

Percent Uncertainty

(1 σ) Weight

Percent Uncertainty

(1 σ) Weight

Percent Uncertainty

(1 σ)

Pu-238 0.0302 0.0030 0.0815 0.0082 0.0924 0.0092

Pu-239 93.6784 9.3678 85.5498 8.5550 72.4474 7.2447

Pu-240 6.0503 0.6050 13.2172 1.3217 24.4844 2.4484

Pu-241 0.2211 0.0221 1.1210 0.1121 1.6419 0.1642

Pu-242 0.0201 0.0020 0.0306 0.0031 1.3340 0.1334

Am-241 0.5025 0.0502 1.7833 0.1783 2.6167 0.2617

(3) Radioassay batch data reports were evaluated an d were found to be adequate.

EPA also examined the Hanford-CCP NDA BDRs listed i n Table 3, above. The NDA values for Waste Stream RLCCPPUNIT were obtained using GEA-B. At the time of the inspection, only six containers had been assayed and the assays were documented in BDR No. RLGEAB0143. The EPA inspection team verified that this BDR incl uded the following:

• Site Project Manager (SPM) Checklist, Attachment 3

• BDR Cover Sheet, Attachment 1

• BDR Table of Contents, Attachment 2

• NDA Batch Report Narrative Summary, Attachment 3

• Independent Technical Review (ITR) Review Checklist , Attachment 4

• Assay Report for each container listed on Attachmen t 1

• Radioassay Data Sheet for each container listed on Attachment 1

• Automated ITR for each container listed on Attachme nt 1

• Genie Quality Assurance (QA) Reports

• CCP Records Transmittal/Receiving Form, Attachment 2

• Evidence of signatures by the ITR on Attachment 1, an SPM on Attachment 3 and an EA on the Automated ITR report for each container list ed on Attachment 1

• Correct revision of CCP-TP-001, Revision 19 and CCP -TP-072, Revision 1

The GEA-B reports activities and uncertainties for 238 Pu, 239 Pu, 240 Pu, 242 Pu, 241 Am, 233 U, 234 U,

238 U, 90 Sr and 137 Cs. Values for 90 Sr, 242 Pu, 234 U and 90 Sr are derived using scaling factors or correlation. Each assayed drum contained greater th an 100 nCi/g of TRU radionuclides. There were no concerns regarding the radionuclide documen tation in NDA BDR No. RLGEAB0143

for Waste Stream RLCCPPUNIT.10

(4) Identification of physical form including waste mat erial parameters and prohibited items was assessed and found to be adequate.

Waste Stream RLCCPUNNIT is composed almost entirely of Pu nitrate solutions that were solidified using amorphous silica or diatomaceous e arth, as well as a small amount of debris, iron-based metals, paper, clothes and rubber bands. Waste packaging records generated in 2001 and 2002 document the waste material parameters (WM Ps) and physical form of the waste at the time of drum packaging (Reference M149). The Hanfor d site performed RTR of the closed containers, and this original NDE information (Refe rence M380) was transferred to the WRAP Data Management System (DMS). Waste material parame ter estimates from the WRAP DMS

indicate that Waste Stream RLCCPUNIT consists of be tween 95.6%-98.6% inorganic matrices by weight, with small quantities of plastics (1.0%- 14.6%), iron-base metals (1.0%-3.2%), and other WMPs. EPA noted that assuming the minimum val ue ranges presented in Table 2 of the AKSR, the sum of the weights is not 100%. Hanford-C CP representatives indicated that the minimum value in the range is the lowest percentage observed and the minimum values would therefore not necessarily total 100%. Hanford-CCP a dded a footnote to the table explaining this and the change was acceptable. Because the waste wa s previously examined using an EPAapproved system and these data were used as the bas is to assign WMPs, the physical composition of each container is well understood.

Hanford-CCP representatives stated that they would perform NDE of each container to determine its physical composition, and this will a lso identify the presence of prohibited items (i.e., liquids). Based on this information, the doc umented physical composition of the waste stream is expected to agree with the material antic ipated in the waste stream as a whole.

(5) Acceptable knowledge procedural adequacy and implem entation were assessed and found to be adequate (assembly compilation, interpr etation, confirmation, discrepancy resolution).

CCP-TP-005, Revision 22 was approved April 21, 2011 , and was in place when the latest version of the AKSR was prepared. It includes processes and procedures for the following activities

related to AK:

• Documentation Management

• Compiling Documentation

• Recording Documentation

• Review and Submittal of AK Documentation

• Waste Stream Characterization

• Determining AK Documentation Accuracy

• Re-evaluating AK Documentation

• Resolving AK Discrepancies

• Updating AK for Additional Waste Stream Containers

• Container Tracking Spreadsheet Development and Main tenance

CCP-TP-005, Revision 22 also includes several attac hments:11

• Attachment 1 – Acceptable Knowledge Documentation C hecklists

• Attachment 2 – Record of Communication

• Attachment 3 – Acceptable Knowledge Source Document Summary

• Attachment 4 – Acceptable Knowledge Source Document Reference List

• Attachment 5 – Hazardous Constituents

• Attachment 6 – Waste Form, WMPs, Prohibited Items, and Packaging

• Attachment 7 – Radionuclides

• Attachment 8 – Waste Containers List

• Attachment 9 – Waste Characterization Data Cross-Re ference

• Attachment 10 – Acceptable Knowledge Re-evaluation Checklist

• Attachment 11 – Acceptable Knowledge Source Documen t Discrepancy Resolution Form

• Attachment 12 – Form and Content Guide for AKSRs

• Attachment 13 – CCP Waste Stream Characterization C hecklist

• Attachment 14 – CCP Acceptable Knowledge Accuracy R eport

• Attachment 15 – CCP TRU Waste Correlation and Surro gate Summary Form

EPA examined the provided attachments, the AKSR and source documents and interviewed the AKEs via telephone. EPA determined that compilation and review of AK documentation did not address technical areas described in Item (5), and the AKE submitted a revised AKSR that adequately integrated missing AK information. Hanfo rd-CCP representatives explained the AK source document limitations and contents, and verif ied that the waste stream includes only the 69

containers addressed in the AKSR. Container trackin g information was provided; no discrepancy resolution (DR) reports were prepared by Hanford-CC P, because the necessary reports were previously prepared by the Hanford site and were in cluded as source documents. EPA also verified that AK source documents are provided to C CP document control as electronic records, but only CCP-generated documents (e.g., CCP-TP-005 Attachments, and AKSRs) are retained as CCP QA records. Hanford-CCP provided Attachments 1, 4, 5, 6, 7, 8, 13 and 14. Attachment 6 and Attachment 7 are addressed under Item (2), abov e. Attachment 8 presents the number of drums in the waste stream; no additional containers will be generated or identified. Attachment 14 is addressed under Item (14), below. EPA found t hat some of the attachments were prepared using forms provided in CCP-TP-005, Revision 21, no t Revision 22. The general content of the forms applicable to CH waste did not change substan tially between Revisions 21 and 22, and the forms were prepared when Revision 0 of the AKSR was in process. In the future, EPA expects

CCP-TP-005 attachments to reflect the version of th is procedure in place at the time the final AKSR was prepared.

EPA found it difficult to examine the AK Source Doc ument Summaries (Attachment 3) separate from the Source Documents (they are usually attache d to the source documents). CCP-Hanford elected to separate the Attachment 3 AK Source Docu ment Summaries from their associated reports because while the Attachment 3 is a CCP QA record, the original source documents are not. EPA expects all source documents to be availab le for EPA review upon request (e.g., prior to or as part of EPA inspections). EPA determined t hat Hanford-CCP demonstrated the ability to follow the AK procedure for the elements examined.12

(6) The acceptable knowledge summary report was assesse d and found to be adequate.

The AKSR was examined to determine whether major te chnical components were present, and to ensure that the document adequately justified and d escribed the waste stream. EPA found that the AKSR did not address the following:

• Contain sufficient information pertaining to the or igin of Pu nitrate solutions from the 325 Building “unique experiments”

• Explain HLW experiments with respect to potential c ontamination of nitrate solutions

• Adequately describe the WMP ranges in the waste str eam

• Address management of the nitrate solutions post-ge neration and pre-solidification

Hanford-CCP representatives provided a freeze-file 1 modification representing the changes in progress. These changes were adequate and appropria te and were necessary to clarify the contents of the AKSR. Hanford-CCP will provide a re vised AKSR incorporating freeze-file changes prior to EPA approval of this T1 request.

(7) Drum traceability and the ability to follow the acc eptable knowledge process for containers was assessed and found to be adequate.

EPA selected five drums for traceability analysis: RL0005912 (325 Building Pu/U nitrate), RL0005435 (PRF flush), RL0005418 (CML), RL0005924 ( 325 Building Pu/Th nitrate) and RL0005625 (standards drum). Table 6 presents the ge neral history of each drum showing (left to right) the progression from individual cans to can solidification in drums through final disposition to the CWC for storage prior to charact erization. Several references address container-specific data and material transfers, spe cifically References C227, C223, 229 and M149. Can and drum-specific data in Reference M149 include:

• TRU Mixed Waste Inventory Sheet

• SWITS Container Listing Report

• SWITS Receipt Report

• Hanford container management Waste Container Cover Sheet

• Radioassay data sheet(s)

Table 6 shows that each can is traceable to the bui lding of origin. While paperwork showing the movement and storage of cans prior to solidificatio n is not available, information about solidification and subsequent transfer to CWC is av ailable, as are Hanford-site NDE and NDA

data in the WRAP database. Information examined sho wed that Hanford-CCP personnel could

obtain historic information for drums within the wa ste stream, had access to site databases to

1 As a result of an inspection-related EPA issue, CC P-Hanford may have to revise a document. CCPHanford makes the change(s) and provides the revise d document to EPA as a freeze file to serve as obje ctive evidence for the inspection. CCP’s document control process in Carlsbad then generates an official ver sion of the

revised document.13Table 6. Traceability of Select Containers in Waste Stream RLCCPPUNITCanNumber1ItemNumber1Can Origin2Date of CanGenerationReceipt at PFP3CanManagementLocationSolidificationLocation4SolidificationDate4HanfordDrumNumber5Transfer toCWC: Dateand Number6NDE NDADate9CCP DrumNumberCCP NDENDA BDRsR476 R-476 CML 9/13/76Receipt Report A276ShippingReceiving Report5016Stored inBuilding 2376-ZB vault; nodocumentationavailableBuilding 234-5Z, Room 18511/29/01 RHZ-222-00054182/14/02B2017NDA7/10/07NDE 5/10/070005418 Not yetavailableE320 RCR-36-09-007PRF Flush 9/28/76 Stored inBuilding 2376-ZB vault; nodocumentationavailableBuilding 234-5Z, Room 18512/4/01 RHZ-222-00054352/26/02B2022NDA7/17/07NDE 5/10/070005435 Not yetavailableR244R35897-75-05-46497-75-05-465Bldg 325Pu/U5/12/755/12/75Stored inBuilding 2376-ZB vault; nodocumentationavailableBuilding 234-5Z, Room 18511/14/01PR Cans R244and R358combinedRHZ-222-00059122/14/02B2019NDA7/17/07NDE 5/10/070005912RLRTRA0174,RLGEAB0143R549R32684-75-06-54584-75-06-546Bldg 325Pu/Th5/16/755/16/75Stored inBuilding 2376-ZB vault; nodocumentationavailableBuilding234-5Z, Room185-T10/8/01PR Cans R549and R326combinedRHZ-222-A2603512/3/01A2047NDA7/10/07NDE 5/10/070005924 Not yetavailableN/A N/A Standards Prior to 07/01 Not availableused in NDABuilding 234-5Z8/28/02(managementdate)RHZ-222-000562510/17/02B2187NDA7/12/07NDE 5/10/070005625 Not yetavailable1References C227, M1492References C223, C2273References C227, C229, M140, M1494Reference M1495Reference C2276References M149, C2277Personal communication with S. Nance, who obtainedthe information from the WRAP database, July 21, 2011N/A = not applicable14

verify drum contents and transfer information, and could trace container information from AK through the characterization process.

(8) Defense origin of transuranic wastes was examined a nd found to be adequate.

The TRU waste streams to be emplaced in the WIPP mu st be “defense” waste. Hanford-CCP states that, based on DOE guidance, a waste is defe nse in origin if it was generated “in whole or part by one of the atomic energy defense activities listed in section 10101(3) of the Nuclear Waste Policy Act of 1982 (NWPA).” AK data indicate that the radionuclides fr om PFP, CML and 325 Building Laboratory in this waste stream we re generated from energy defense activities, including nuclear material processing and fabricati on of weapons, defense nuclear waste materials by-products management, and defense resea rch and development (References C004, P041, P050, P053, P239, P401 and P978). Based on th e AKSR, the supporting references and DOE’s guidance regarding defense waste, this waste stream is defense in origin.

(9) The presence of Spent Nuclear Fuel and High-Level W aste Status was evaluated and this waste stream was found to be in compliance with the Waste Isolation Pilot Plant Land

Withdrawal Act.

The WIPP Land Withdrawal Act (LWA) prohibits the di sposal of SNF and HLW as defined by

the NWPA at WIPP. The NWPA states that SNF is “fuel that has been withdrawn from a nuclear reactor following irradiation, the constituent elem ents of which have not been separated by reprocessing. SNF may not include test specimens ir radiated for research and development only (i.e., these may be classified as waste when it is technically infeasible, cost prohibitive, or would increase worker exposure).” HLW is defined by the N WPA as “the highly radioactive material resulting from the reprocessing of spent nuclear fu el, including liquid waste produced directly in reprocessing and any solid material derived from su ch liquid waste that contains fission products in sufficient concentrations, and other highly radi oactive material that the Commission, consistent with existing law, determines by rule re quires permanent isolation.”

The AKSR and Hanford-CCP AKEs indicate that PFP did not reprocess SNF, as this waste contains only unirradiated materials. Therefore, th is waste is not SNF and PFP could not have generated HLW because they did not process SNF. Sim ilarly, while the experiments performed at CML dealt with nuclear fuels, this facility did not generate SNF and is therefore not included

in this waste stream. Several references indicate t hat HLW was managed in the 325 Building Laboratory during the time period in which this was te stream was generated (1975–1976). A Hanford-CCP representative stated that the 325 Buil ding Laboratory Pu-U and Pu-Th nitrate

solutions in this waste stream "do not include wast e from the experiments conducted with the solutions or HLW from experiments conducted in the building (Reference C001, C219, C223, M140, and P041)." EPA accepts Hanford-CCP’s SNF and HLW determinations.

(10) Waste Stream Profile Form preparation and completen ess was evaluated and found to be adequate.

A draft Waste Stream Profile Form (WSPF) was provid ed for EPA review to demonstrate Hanford-CCP’s ability to prepare this required docu ment. The WSPF includes the Profile Form,15

Characterization Information Summary (CIS), Data Qu ality Objective (DQO) Reconciliation Checklist, and Summation of Aspects of the AK Summa ry Report: RLCCPPUNIT. Comparison of the WSPF and the AKSR revealed discrepancies wit h respect to the exact number of containers in the waste stream, i.e., 68 are identi fied on the WSPF, while the AKSR identifies 69. Also, the WSPF references Revision 0 of the AKSR; h owever, the current version is Revision 1. The WSPF indicates that the production of defense m aterial supports the defense determination, but the AKSR implies that research and development activities also took place. The attached Summation of Aspects makes no mention of the CML an d 325 Building Laboratories and related process, and does not provide summary information a bout the Pu nitrate sources that were solidified in Building 234-5Z, Room 185. When the f inal WSPF is prepared, EPA expects that the correct AKSR will be referenced, all necessary changes to tables, figures, and section references will be made, and references will be add ed to the Supplemental Document listing on

the WSPF. The draft WSPF demonstrates Hanford-CCP’s ability to prepare this document and

associated attachments.

(11) Training for acceptable knowledge personnel was exa mined and found to be adequate.

CCP-TP-005, Revision 22 references CCP-QP-002, Revi sion 31 for AK training. This requires that personnel assigned to compile, evaluate and re solve AK discrepancies have training in the following areas:

• WIPP Waste Analysis Plan (WAP) Briefing

• WAC knowledge

• Federal and State Resource Conservation and Recover y Act (RCRA) regulations

associated with solid and hazardous waste determina tions

• Knowledge of CCP procedures associated with:

o Waste characterization using AK

o CCP AK records development including AK discrepancy resolution.

o Nonconformance Report (NCR)/Corrective Action Repor t (CAR) Process

o Knowledge of resolving and managing prohibited item s as noted in nonconformance reporting

The CCP lead SPM is responsible for ensuring that C CP personnel are qualified and trained to perform their assigned job functions. EPA indicated in its baseline approval that training

documentation associated with AKEs will be verified at future inspections. Verification was performed during this T1 review. Training documenta tion was provided for Sheri Nance, Mark Doherty, Veronica Waldram, and Steve Schafer. The Q ualification Cards provided during the T1 inspection for Ms. Nance, Mr. Doherty, and Mr. Scha fer were signed in 2003 or 2004, and did not indicate they had been trained to the most rece nt regulatory documents or internal procedures, specifically the WAP, WAC, CCP-TP-005, and EPA’s Compliance Recertification Application (CRA). Site-specific Hanford AK trainin g took place for these three individuals in 2010. Ms. Waldram received SPM training in 2009, an d the objective evidence indicated that

AKEs were familiar with the relevant waste characte rization procedures. EPA obtained updated Qualification Cards for Sheri Nance, Mark Doherty, Steve Schafer and Veronica Waldram in16

June 2011, which showed that they were re-qualified to the current revisions of the relevant procedures.

(12) Preparation of Nonconformance Reports was evaluated and found to be adequate.

Hanford-CCP provided three NCRs for this waste stre am, all of which were initiated because

RTR had identified a sealed container with a volume greater than four liters inside a waste drum.

All three drums were returned to the Host Site for remediation or other disposition. These examples show that Hanford-CCP adequately documents the NCR process. The NCRs and

affected drums are as follows:

• NCR-RL-212011 for Drum No. RL0007027

• NCR-RL-6043-11 for Drum No. RL0005923

• NCR-RL-2122110 for Drum No. RL0006981

(13) Acceptable Knowledge accuracy was assessed and foun d to be adequate.

Hanford-CCP provided a Draft Acceptable Knowledge A ccuracy Report dated June 29, 2011, and completed CCP-TP-005, Attachment 14 that addres sed Waste Stream RLCCPPUNIT, Lot 1. The report concluded that the S3000 SCG was verifie d through RTR; all contained greater than 50% homogeneous solids and agreed with AK. The repo rt states that the AK identified 239 Pu and

238 U as the most predominant radionuclides by mass (61 .72% and 31.68%, respectively), but also

stated that none of the containers included in the lot had yet undergone NDA. Enclosure 2 of the AK accuracy report shows that the Lot 1 containers included only those that were sampled as required by the RCRA permit and did not include any drums that had undergone NDA. The Draft AK Accuracy Report will be finalized and futu re Accuracy Reports will evaluate NDA information. The Draft AK Accuracy Report and compl eted Attachment 14 demonstrate Hanford-CCP's ability to complete this required ele ment.

(14) Load management was found to be not applicable.

Hanford-CCP personnel indicated that load managemen t would not be performed by HanfordCCP.

(15) Non-destructive assay–acceptable knowledge communic ation was assessed and found to be adequate.

CCP-TP-005, Revision 22, Section 4.4.25, requires t he preparation of an NDA memorandum

that evaluates the radionuclide characterization of the waste stream. The memorandum is required to document how NDA personnel will apply A K during assay and address the

limitations associated with AK-based information. I t must describe the assay methods, and requires that NDA issues be discussed and resolved for measured and calculated radionuclides.

The NDA-AK memorandum for Waste Stream RLCCPPUNIT s ummarizes the physical and radiological composition of the waste stream as des cribed in the AKSR, and includes the information presented in Table 5, above. Assays wil l be performed using the WRAP GEA systems, and the NDA Memorandum states that the def ault isotopics presented in Table 5 will be17

used for any assay that does not yield a "reasonabl e isotopic distribution." Additionally, the memorandum presents how 242 Pu, 234 U and 90 Sr will be determined and discusses potential

interferences. EPA examined the NDA BDRs and found that none of the six containers assayed used AK-based isotopic distributions [see (2), abov e]. The NDA memorandum is adequate. EPA anticipates that the memorandum will be updated to include more accurate descriptions of the waste stream’s radiological composition consistent with the recently revised AKSR.

(16) Nondestructive examination was evaluated via batch data reports and was found to be adequate.

The RTR data for these S3000 wastes were generated on the following dates:

• BDR Nos. RLRTRB0156 and RLRTRB0174 were generated o n March 03, 2011, in accordance with procedure CCP-TP-053 , CCP Standard Real-Time Radiography (RTR) Inspection Procedure, Revision 9

• BDR No. RLRTRA0175 was generated on March 09, 2011, and BDR No. RLRTRA0176 was generated on March 10, 2011, both in accordance with procedure CCP-TP-053 , CCP Standard Real-Time Radiography (RTR) Inspection Pro cedure, Revision 10

A successful Measurement Control Report was perform ed prior to the RTR examinations for each BDR. An RTR Operator Trainee performed RTR ope rations for BDR No. RLRTRA0174 under the supervision of a trained and qualified op erator as part of his on-the-job-training. EPA reviewed the LOQI for the time periods covering RTR data generation and determined that RTR examinations were carried out by qualified, or appr opriately supervised, RTR operators. An Independent Observation and Replicate Scan for e ach BDR was performed by a different RTR operator from the one who performed the initial scan. The drum liners were not vented and correctly determined to be sealed containers greate r than 4 liters for BDR Nos. RLRTRA0175 and LRTRA0176, and Hanford-CCP correctly rejected a ll drums. One drum from BDR No.

RLRTRB0156 and one drum from BDR No. RLRTRB0174 wer e rejected for the same reason. NCR Nos. NCR-RL-0644-11, NCR-RL-0643-11, NCR-RL2124 110, and NCR-RL2122110 were correctly initiated and processed to address these prohibited items.

Hanford-CCP RTR operators identified WMPs, assigned WMP weights, and verified the WMC for each drum. The operators recorded RTR data on t he correct forms and signed these forms as required. EPA determined that the required reviews by the ITR and SPM were performed and appropriately recorded for each BDR.

EPA did not identify any concerns or findings durin g review of these BDRs and qualification records, and determined that Hanford-CCP characteri zed this S3000 waste in accordance with procedure and regulatory requirements.

Summary of Findings and Concerns

EPA did not identify any findings or concerns durin g this T1 evaluation and there are no open

issues relative to this T1 evaluation.18

Tiering Changes

Based on the results of this T1 evaluation, EPA has revised the AK T1 designations assigned during the SRS-CCP baseline approval to recognize E PA's approval of the Waste Stream RLCCPPUNIT belonging t0 SSCG S3000 characterized by Hanford-CCP, as reflected in Table 1 of this report. All of the T2 elements listed under AK in Table 1 for consistency apply to all approved CH TRU waste streams and SCGs at Hanford-C CP.

7.0 SUMMARY OF RESULTS AND CONCLUSIONS

Conclusion

EPA concluded that the waste characterization proce sses of AK, NDA and RTR that HanfordCCP used to characterize the retrievably stored S30 00 CH TRU Waste Stream RLCCPPUNIT are adequate. There were no concerns, and there are no open issues relative to this T1 evaluation.

Approval

This T1 change consisted of the waste characterizat ion processes of AK, NDA and RTR as evidenced by the records Hanford-CCP generated in c haracterizing S3000 CH TRU Waste Stream RLCCPPUNIT. Based on this evaluation, EPA ap proves this T1 change. Hanford-CCP is approved to characterize S3000 CH TRU Waste Stream RLCCPPUNIT, consistent with the limitations specified in this report. EPA’s approva l does not include S3000 Hanford Tank or KBasin waste.

Tiering Changes

Based on the results of this evaluation, EPA has re vised the T1 designations assigned to AK during the Hanford-CCP baseline approval, as reflec ted in Table 1 of this report. No revision of Tier 2 (T2) requirements was warranted. All of the T2 elements listed under AK in Table 1 for consistency apply to all approved CH TRU waste stre ams and SCGs at Hanford-CCP. Consistent with EPA’s authority under 40 CFR 194.24(h), EPA ma y request any information relative to these activities if EPA deems it necessary to ensur e continued compliance with EPA regulations. There are no changes to the T1 and T2 designations assigned to NDA, VE/VET or RTR during the Hanford-CCP baseline approval as a result of th is T1 evaluation.19 ATTACHMENT A

AKE Qualification Card for Steve Schafer October 20 03

AKE Qualification Card Addendum L Hanford-Specific Card for Steve Schafer, March 2010

AKE Qualification Card for Sheri Nance, December 20 04

AKE Qualification Card Addendum L Hanford-Specific Card for Sheri Nance, March 2010

AKE Qualification Card for Veronica Waldram, August and November 2009

AKE Qualification Card for Mark Doherty June 2003

AKE Qualification Card Addendum L Hanford-Specific Card for Mark Doherty, March 2010

CCP AK Tracking Spread Sheet, Waste Stream RLCCPPUN IT, downloaded July 8, 2011

CCP-AK-RL-116, Central Characterization Project Acc eptable Knowledge Summary Report For Hanford Plutonium Finishing Plant (PFP) Contact-Han dled Transuranic Solidified Plutonium Nitrate Waste, Waste Stream: RLCCPPUNIT, Revision 2 , February 24, 2011, and Revision 1, June 7, 2011

CCP-QP-002, CCP Training and Qualification Plan, Re vision 31, April 21, 2011

CCP-TP-001, CCP Project Level Data Validation and V erification, Revision 19, December 29,

2010

CCP-TP-005, Revisions 21 and 22, CCP Acceptable Kno wledge Documentation, Effective Date December 29, 2010, and April 21, 2011, and example Attachments 1, 4, 5, 6, 7, 8, 13 and 14 provided June and July 2011

CCP-TP-072, CCP Gamma Energy Assay (GEA) Data Revie w, Validation, and Reporting Procedure, Revision 1, January 28, 2011

C001, Record of Communication, B. Crawford intervie w of Wayne Larson, PNNL, Re: Hanford Building 325, September 11, 2003

C004, Isotopic Analysis for Containers Generated fr om the Building 325 Radiochemistry Lab and HLW Annexes Assays, D. Guerin, October 27, 2003

C031, E-mail From Karl Husted, Re: Two most prevale nt isotopes in RLMPFPCD waste originating in 242-Z , December 12, 2007

C037, Memorandum from R. Clinton to P.J. Crane conc erning Transmittal of AK

Re-evaluation checklist for Waste Stream NPFPD 3T00 0-PJC-01-043, March 21, 200120

C060, Record of Communication with Karl Husted, Oct ober 12, 2007 re: Adding U-232 as a trace radionuclide to MPUREXD and MPFPD AK, M.I. Ro llosson, October 12, 2007

C219, Internal Letter - Subject: Disposal of Unproc essable Scrap at 224-T Vault 65940-84R, L. Hall, September 4, 1984

C223, Record of Communication - Subject: History of PFP absorbed Pu Nitrate Solutions, J. Stewart, March 27, 2008

C227, E-mail-Subject: Blend Plan Rev 2.xls, E. Grea ger, March 3, 2008

C229, Memorandum - Subject: Unique Solution Process ing 65240-79-180, W.F. Skiba, December 11, 1979

C398, Memorandum-Subject: Final Results for Plutoni um Finishing Plant Direct Discard Project Samples Analyzed During Fiscal Year 2001–2002, B350 0-RAB-02-045, R.A. Bushaw, April 3,

2002

C442, Lot RLPUNIT.001.001 - Data Quality Objectives Reconciliation, Solids Sampling and Analysis Report, and Acceptable Knowledge Character ization Checklist for 50 Containers in Waste Stream RLPUNIT 3C500-TRU-08-020, Addendum 1, D.I. Rollosson, February 26, 2009

Inter-Office Correspondence, from Veronica Waldram to Ron Reeves, Re: (Draft) Acceptable Knowledge Accuracy Report: Hanford Waste Stream Num ber RLCCPPUNIT, Lot 1, June 29,

2011

M106, NDA Data for Containers from Hanford Waste St ream RLMPDT.001, WWIS May 21,

2009

M140, Shipping and Receiving Reports for SS Materia ls, 1975–1976

M147, AK Source Document Discrepancy Drum Liners, A D. Rollosson, February 13, 2009

M148, Analytical Laboratory Report, February 1975, March 1975, June 1975, B.R. Fitzpatrick,

1975

M149, CWC Receipt Reports for 69 RLPUNIT Waste Stre am Containers, 2002

M380, Waste Material Parameter Evaluation for RLCCP PUNIT, M. Doherty, December

2010

M381, Isotopic Evaluation for RLCCPPUNIT, NCR-RL-21 2001, NCR-RL-6043 and NCR 2122110 for Waste Stream RLCCPPUNIT, M. Doherty, De cember 201021

P041, Past Practices Technical Characterization Stu dy-300 Area - Hanford Site WHC-MR-0388, M.S. Gerber, December 1992

P050, Analytical Chemistry Laboratory Manual, Volum e 2, Analytical Chemistry Methods for Mixed Uranium-Plutonium Oxide Fuels MG-28, Revision 2, W.L. Delvin, October 1978

P052, Hanford Site Transuranic Waste Management Pro gram Acceptable Knowledge Documentation for Retrievably Stored Contact-Handle d Waste HNF-3461, Revision 0, D.A. Arrenholz, October 2006

P053, Testing and Analysis of Consolidated Sludge S amples from the 105 K East Basin Floor and Canisters P.R. Bredt, C.H., Delegard, A.J. Schm idt, K.L. Silvers, PNNL-13341, December

1999

P071, History and Stabilization of the PFP Complex, Hanford Site HNF-EP-0924, M.S. Gerber,

March 1997

P130, Engineering Evaluation/Cost Analysis for the Plutonium Finishing Plant Above-Grade Structures, DOE/RL-2004-05, Revision 1, undated

P153, WST History of the Plutonium Production Facil ities at the Hanford Site Historic District 1943-1990, DOE/RL-97-1047, T.E. Marceau, D.W. Harve y, et al., June, 2002

P232, PRF Engineering Training Manual, RHO-MA-246, J. E. Ludowise, undated

P239, PFP Final Safety Analysis Report, WHC-SD-CP-S AR-021, Revision 0, J.E. Shapely

P401, ORAU Team NIOSH Dose Reconstruction Project T echnical Basis Document for the Hanford Site – Site Description ORAUT·TKBS·0006-2 R evision 00, J. Selby, December 29,

2004

P968, Authorization Basis for the 209-E Building HN F-3337, Revision 0, M.S. Tiffany, October 12, 1998

P970, Preliminary Hazards Study of the Hanford Plut onium Critical Mass Laboratory HW-57603 J.A. Berberet, J.W. Healy, and E.D. Clayton, Septem ber 30, 1958

P971, Safety Evaluation Report for the 209-E Buildi ng Critical Mass Laboratory 10 CFR 830 Safety Basis 0301288/03-ABD-0060, M.W. Jackson, K.A. Klein, March 2003

P972, 209-E Building, Critical Mass Laboratory Emer gency Preparedness Hazards Assessment HNF-77S, Revision 0, P.A. Polus, March 2001

P976 (Reference 15), Radioisotopic Characterization of Retrievably Stored Transuranic Waste Containers at the Hanford Site WHC-SD-WM-TI-517, Ma y 1970 through June 30, 1993, Revision 1, Westinghouse Hanford Company, J.P. Joyc e, November 12, 199322

P978, Historic Property Inventory Form, H.K. Chambe rlain, July 1, 1997

P1201, HNF-38161, (Reference 3) Acceptable Knowledg e Document for Hanford Site Plutonium Finishing Plant Absorbed Plutonium Nitrat e Solutions Waste Stream, RLPUNIT, prepared by D.I. Rollosson, CH2MHill, July 2009

Waste Stream Profile Form for Hanford Site, Waste S tream Profile Form Number RLCCPPUNIT, Draft, Undated, provided by V. Waldram, June 17, 2011