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

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT: 

EVALUATION OF CONTACT-HANDLED TRANSURANIC S3000 WASTE STREAM 

“RLCCPPUNIT” AT THE HANFORD CENTRAL CHARACTERIZATION 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 2011
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TABLE OF CONTENTS 

Section Page

Acronyms ........................................................................................................................................ ii 

1.0 Executive Summary ................................................................................................................1 

2.0 Approval Summary for Hanford-CCP Contact-Handled 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 Characterization 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 Distributions ............................................................... 8

Table 5. Default Percentage 240Pu 20-Year Aged Mass Fraction .................................................. 9

Table 6. Traceability of Select Containers in Waste Stream RLCCPPUNIT .............................. 13
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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 waste 
iii 

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 Extraction 

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 criteria 
iv 

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 Form 
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1.0 EXECUTIVE SUMMARY 

This report supports the U.S. Environmental Protection Agency (EPA or the Agency) approval 

of the proposed Tier 1 (T1) change to the EPA-approved transuranic (TRU) waste 

characterization program at the Hanford Site. This approval allows the Hanford Central 

Characterization Project (CCP) to dispose of retrievably-stored, contact-handled (CH) TRU 

solidified inorganic (S3000) Waste Stream RLCCPPUNIT at the Waste Isolation Pilot Plant 

(WIPP). The approval does not include other S3000 waste 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 evaluated during a baseline inspection performed in 

April 2010, which was approved December 15, 2010. 

The reason for this limited approval is two-fold. First, EPA has determined that the waste 

characterization information provided for this waste stream RLCCPPUNIT is not likely to be 

applicable for other unique Hanford solid waste streams such as the Hanford Tank Waste or KBasin waste. Second, due to the budgeting constraints, in Fiscal Year 2012 and beyond, no CH 

TRU waste characterization will occur at Hanford. As a result, at Hanford, no CH TRU solid 

waste is being characterized at this time. In the future, when TRU waste characterization at 

Hanford is reactivated, EPA’s evaluation of TRU waste characterization program for the 

December 2010-approved debris waste (S5000), new solid waste streams, and soils (S4000) will 

be necessary. 

In accordance with 40 CFR 194.8(b), the EPA conducted a baseline inspection of the CCP’s CH 

TRU waste characterization program at the Hanford Site near Richland, Washington. As a result 

of this baseline inspection, EPA approved the Hanford-CCP CH TRU waste characterization 

program with conditions and limitations, as discussed in the Hanford Baseline Final Inspection 

Report (see Docket No. A-98-49; II-A4-138). This approval 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 the Hanford-CCP baseline approval as 

a T1 change. During June and July 2011, EPA conducted 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 Nondestructive Examination (NDE), specifically 

Real-Time Radiography (RTR). During the evaluation, EPA did not identify any findings or 

concerns and, based on this evaluation, EPA approves 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 tiering 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 site and by sending e-mails to the 

WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3).
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Table 1. Revised Tiering of TRU Waste Characterization Processes Implemented by Hanford-CCP (N

(Original Tiering Based on the Baseline Inspection issued on December 15, 2010)

Process Elements Hanford-CCP T1 Changes Needing EPA Review and 

Approval 

Hanford-CCP T2 

Acceptable Knowledge (AK) Implementation of load management (AK 13) 

Implementation of AK for wastes other than retrievably stored 

and newly generated S5000 debris and S3000 Waste Stream RLCCPPUNIT. (AK 1) 

Notification to EPA upon completion of ne

changesb of the following: - Modification of CCP-TP-005, Revision 

- Availability of modifications to the AK- Availability of all final WSPF with rela

- Availability of all AK Accuracy Report- Availability of successful training recor

- Availability of the AK-NDA memorand

Non-Destructive Assay (NDA) New equipment or physical modifications to approved 

equipmentc (NDA 1) 

Extension or changes to approved calibration range for approved 

equipment (NDA 2) 

Notification to EPA upon completion of ch

equipment, operating range(s), and site procapproval (NDA 2) 

Real-Time Radiography (RTR) There are no T1 changes at this time Notification to EPA upon the following: - Modificationc to approved equipment, R

- Completion of changes to site RTR pro

(RTR 2) - Addition of new SCG to the RTR proceapproval (RTR 2) - Implementation of a different type of R

Visual Examination (VE) Performance of VE by any method other than using two trained 

operators to perform actual VE at the time of packaging (VE 1) 

Notification to EPA upon the following: - Completion of changes to site VE proce

(VE 2) - Addition of new SCG to the VE proces

(VE 2) 

Waste Data System (WDS) There are no T1 changes at this time Notification to EPA upon the following: - Completion of changes to WDS proced

(WDS 2) - Changes to the Excel spreadsheet titled Revision 2, Addendum #2, SCO #1065 

a Upon receiving EPA approval, Hanford-CCP will report all T2 changes to EPA at the end of each fiscal year quarter. Note: EPA may request s

end of a fiscal quarter. 

b “Substantive changes” means changes with the potential to impact the site’s waste characterization activities or documentation thereof, excludi

to ES&H, nuclear safety, RCRA or are editorial in nature. 

c Modifications to approved equipment include all changes with the potential to affect NDA data relative to waste isolation and exclude minor ch

safety-related equipment. 
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2.0 APPROVAL SUMMARY FOR HANFORD-CCP CONTACT-HANDLED WASTE 

CHARACTERIZATION PROGRAM 

EPA provided a formal baseline approval of the Hanford-CCP CH waste characterization 

program in December 2010. Since then, EPA has approved 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 activities 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. Under 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 characterization 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 inspection leads to approval of the site’s TRU 

waste characterization program, based on the demonstration that the program’s components, with 

applicable conditions and limitations, can adequately characterize TRU wastes. During the 

baseline inspection, EPA determines whether the site can adequately comply with the regulatory 

requirements imposed on TRU wastes destined for disposal at the WIPP. An EPA inspection 

team conducts an on-site baseline inspection to verify 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 approve, if necessary, changes to the site’s 

approved waste characterization program by conducting 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 waste and remains in compliance with all the 

regulatory requirements. Based on the adequacies of the waste characterization processes 

demonstrated during the baseline inspection, including all conditions and limitations, EPA 

specifies which subsequent waste characterization program 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 have 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 evaluation of the addition of S3000 Waste Stream 

RLCCPPUNIT to the Hanford-CCP approval as a T1 change. 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). 
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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 S3000 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 participated in this evaluation are listed in 

Table 2, along with each person’s position during the 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 & Associates, Inc. 

Dorothy Gill Technical Inspector, NDE S. Cohen & Associates, Inc. 

Patrick Kelly Technical Inspector, NDA S. Cohen & Associates, 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 comprehensive 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 Real-Time Radiography 

EPA examined the AK process and associated information specific to radiological and physical 

contents of the waste stream to determine whether Hanford-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 waste 
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• Overall procedural technical sufficiency and scope 

• Ability to follow the AK characterization process for containers including AK assembly, 

compilation and verification 

• Sufficiency of AK Summary Report (AKSR) including source 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, which 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 originally slated 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 areas. 

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

S3000 SCG Waste Stream RLCCPPUNIT consists of solidified Pu nitrate solutions, as described 

in the AK Summary Report (AKSR) CCP-AK-RL-116, Revision 1. These solutions originated in 

the Plutonium Finishing Plant (PFP), Plutonium Reclamation Facility (PRF), Building 325 

Laboratory, and the 209-E Critical Mass Laboratory (CML), and resulted from laboratory 

experiments and flushing the PRF process lines. Operations 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 housed storage vaults, lines, sumps, 

rooms, and laboratories; the Recovery of Uranium and Plutonium by Extraction 

(RECUPLEX) was the main plutonium processing/recovery process in Building 234-5Z 

(References P071 and P153) 

• Building 236-Z PRF was constructed in 1963 and is referred to as the Plutonium Nitrate 

Production Facility (Reference P239); it replaced the RECUPLEX facility. PRF is now 

inactive, but was used to recover plutonium through incineration and solvent recovery 

(Reference P052) and was designed to concentrate liquids, process solid material, and 

recover Pu from aqueous streams via solvent extraction. Waste Stream RLCCPPUNIT 

contains Pu nitrate solutions that were generated from flushing the PRF process lines in 

1988, 1994 and 1995 (References C219, C223 and C229) 

• Building 2736-ZB was a Product Shipping and Receiving 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 (325 Building Laboratory) began 

operation in 1953, and currently supports a variety of site operations, including: 

laboratory analyses of fuel reactor samples; characterization 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 unused portions of plutonium-uranium 

(Pu-U) and plutonium-thorium (Pu-Th) nitrate solutions generated for experimental use. 

Hanford-CCP representatives stated that the 325 Building Laboratory Pu nitrate solutions 

were managed in closed containers and were not cross 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) was 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 (References P968 and P971). Hanford-CCP 

representatives stated that while CML experiments used Pu nitrate solutions of varied 

concentrations, PFP was the source of all CML Pu (References C227, C229, C442, 

M147, P968, P970, P971, P972 and P978). 

The Pu nitrate solutions generated from the facilities described above were held for recovery in 

ten-liter cans and were eventually transferred to Building 2736-Z. In 2001, DOE decided to 
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discard cans of Pu nitrate material that were too low in Pu concentration or were too difficult to 

recover, as waste. This waste stream includes 49 ten-liter cans from the 325 Building Laboratory, 

one ten-liter can from the CML, and 50 cans from the PRF line-flushing activities. These cans 

were transferred from storage to Room 185 in Building 234-5Z, where they were processed into 

68 55-gallon drums of waste. One additional drum was created for use as an NDA standard; this 

drum contains three 1-gallon cartons with Pu nitrate 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 solidified Pu nitrate waste and one standard, all of 

which originated from PFP. All 69 drums were transferred 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 waste 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 process or activity" is the solidification of Pu nitrate

using a consistent and defined process. As presented in the AKSR, various activities conducted 

in three separate areas generated the Pu nitrate solutions, 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 was 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 quantities of U, Th and other radionuclides, the Pu 

composition fell within a specified range and the Pu originated from PFP. Hanford-CCP stated 

that the nitrate solutions operated in a closed loop, supporting the presence of a defined 

radiological and chemical composition; EPA agrees that 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 this waste stream. See Items (2) and (3), below, 

for additional information pertaining to the physical 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 adequate. 

During its early years of operation, PFP fabricated Pu for weapons parts, which included 

conversion of Pu nitrate to metal and Pu casting and 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 Building Laboratory, Hanford-CCP determined 

that a range of isotopic distributions may be present in this waste stream. 

 

The Hanford site performed NDA on 68 of the 69 containers in this waste stream using EPAapproved NDA systems at the Waste Receiving and Processing (WRAP), specifically the 

Gamma Energy Analysis Systems A and B (GEA-A and GEA-B). The 69th drum was made of 

standard. The WRAP Data Management System summarized the radionuclide composition of the 

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

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

and 238U (References C037, C060, M148 and P130). These data show that 239Pu and 238U are the 
8

predominant radionuclides by weight, and 239Pu and 241Pu are the predominant radionuclides by 

activity. Hanford-CCP representatives also evaluated the isotopic distribution based on the Solid 

Waste Information Tracking System (SWITS). These ranges are presented in Table 4, below. 

Table 4. Plutonium and Uranium Isotopic Distributions 

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 (241Am) is present due to decay of 241Pu and that 

the 241Am content will increase over time, as will trace quantities of 237Np arising from 241Am 

decay. AK data show that 241Am 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 241Am may be greater than what is presented (Reference C031). Uranium content 

may also vary from the above ranges based on uranium sources and radiation history (References 

P183, P278 and P1201). The AKSR also states that plutonium product specifications do not 

preclude inclusion of trace impurities including 243Am, californium-249 (249Cf), 228Th, and 232Th, 

and other isotopes of calcium, carbon, iron, nickel, and neptunium, as well as barium-133 

(

133Ba), cobalt-60 (60Co), europium-152 (152Eu), curium-243 (243Cm), niobium-94 (94Nb), and 

radium-226 (226Ra) (Reference M106). Reference P1201 (also cited as Reference 3 in the AKSR) 

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

237Np, as well as trace amounts of other 232U, 233U, 137Cs, 154Eu, 22Na, and 90Sr. The Pu content of 

the standard drum discussed in (1), above, is consistent with Table 4. 

EPA examined the data presented in several source documents (References C004, C219, C398 

and M381) to better understand the overall radionuclide 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 verified 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 developed by the Hanford Site (Reference P976, 

also cited as Reference 15 in the AKSR) and were adopted by Hanford-CCP [see Item (14), 

below]. The three most frequent percent plutonium isotopic distributions based on 6%, 12% and 

23% 240Pu are presented in Table 5, below, and were created using radiological data for about 

4,655 containers originating from PFP, as presented in the Solidified Waste Information 

Tracking System (SWITS) database. The categories represented by this table were developed 

based upon the 240Pu identified in each container, so a drum associated with a category would 

have a 240Pu concentration at or below the value in that category, but above the value in the next 

category (Reference P976). The weight percentages in the table below are the default plutonium 

isotopic distributions as of June 30, 1993. EPA's baseline report concluded that these 
9

distributions are reasonable. The ranges continue to be acceptable for Waste Stream 

RLCCPPUNIT, because AK indicates that the Pu originated in the PFP. 

Table 5. Default Percentage 240Pu 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 and were found to be adequate. 

EPA also examined the Hanford-CCP NDA BDRs listed in 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 included 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 Attachment 1 

• Radioassay Data Sheet for each container listed on Attachment 1 

• Automated ITR for each container listed on Attachment 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 listed 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 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 233U, 234U, 

238U, 90Sr and 137Cs. Values for 90Sr, 242Pu, 234U and 90Sr are derived using scaling factors or 

correlation. Each assayed drum contained greater than 100 nCi/g of TRU radionuclides. There 

were no concerns regarding the radionuclide documentation in NDA BDR No. RLGEAB0143 

for Waste Stream RLCCPPUNIT. 
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(4) Identification of physical form including waste material 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 earth, 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 (WMPs) and physical form of the waste at the 

time of drum packaging (Reference M149). The Hanford site performed RTR of the closed 

containers, and this original NDE information (Reference M380) was transferred to the WRAP 

Data Management System (DMS). Waste material parameter estimates from the WRAP DMS 

indicate that Waste Stream RLCCPUNIT consists of between 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 value ranges presented in Table 2 of the 

AKSR, the sum of the weights is not 100%. Hanford-CCP 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 added a footnote to the table explaining this 

and the change was acceptable. Because the waste was previously examined using an EPAapproved system and these data were used as the basis 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 also identify the presence of prohibited items 

(i.e., liquids). Based on this information, the documented physical composition of the waste 

stream is expected to agree with the material anticipated in the waste stream as a whole. 

(5) Acceptable knowledge procedural adequacy and implementation were assessed and 

found to be adequate (assembly compilation, interpretation, 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 Maintenance 

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

• Attachment 1 – Acceptable Knowledge Documentation Checklists 

• 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-Reference 

• Attachment 10 – Acceptable Knowledge Re-evaluation Checklist 

• Attachment 11 – Acceptable Knowledge Source Document Discrepancy Resolution Form 

• Attachment 12 – Form and Content Guide for AKSRs 

• Attachment 13 – CCP Waste Stream Characterization Checklist 

• Attachment 14 – CCP Acceptable Knowledge Accuracy Report 

• Attachment 15 – CCP TRU Waste Correlation and Surrogate 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. Hanford-CCP representatives explained the AK 

source document limitations and contents, and verified that the waste stream includes only the 69 

containers addressed in the AKSR. Container tracking information was provided; no discrepancy 

resolution (DR) reports were prepared by Hanford-CCP, because the necessary reports were 

previously prepared by the Hanford site and were included as source documents. EPA also 

verified that AK source documents are provided to CCP 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), above. 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 that some of the attachments were prepared 

using forms provided in CCP-TP-005, Revision 21, not Revision 22. The general content of the 

forms applicable to CH waste did not change substantially 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 this procedure in place at the time the final 

AKSR was prepared. 

EPA found it difficult to examine the AK Source Document Summaries (Attachment 3) separate 

from the Source Documents (they are usually attached to the source documents). CCP-Hanford 

elected to separate the Attachment 3 AK Source Document 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 available for EPA review upon request (e.g., prior 

to or as part of EPA inspections). EPA determined that Hanford-CCP demonstrated the ability to 

follow the AK procedure for the elements examined. 
12

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

The AKSR was examined to determine whether major technical components were present, and to 

ensure that the document adequately justified and described the waste stream. EPA found that 

the AKSR did not address the following: 

• Contain sufficient information pertaining to the origin of Pu nitrate solutions from the 

325 Building “unique experiments” 

• Explain HLW experiments with respect to potential contamination of nitrate solutions 

• Adequately describe the WMP ranges in the waste stream 

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

Hanford-CCP representatives provided a freeze-file1 modification representing the changes in 

progress. These changes were adequate and appropriate and were necessary to clarify the 

contents of the AKSR. Hanford-CCP will provide a revised AKSR incorporating freeze-file 

changes prior to EPA approval of this T1 request. 

(7) Drum traceability and the ability to follow the acceptable 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 general 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 characterization. Several references address 

container-specific data and material transfers, specifically 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 building of origin. While paperwork showing the 

movement and storage of cans prior to solidification is not available, information about 

solidification and subsequent transfer to CWC is available, as are Hanford-site NDE and NDA 

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

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

 

1

 As a result of an inspection-related EPA issue, CCP-Hanford may have to revise a document. CCPHanford makes the change(s) and provides the revised document to EPA as a freeze file to serve as objective 

evidence for the inspection. CCP’s document control process in Carlsbad then generates an official version of the 

revised document. 
13

Table 6. Traceability of Select Containers in Waste Stream RLCCPPUNIT 

Can Number1

Item Number1

Can Origin2 Date of Can 

Generation Receipt at PFP3

Can Management Location

Solidification Location4

SolidificationDate4

Hanford Drum Number5 

Transfer to CWC: Date and Number6

NDE NDDate9

R476 R-476 CML 9/13/76 

Receipt Report A276 Shipping Receiving Report 5016 

Stored in Building 2376-ZB vault; no documentation available 

Building 234-5Z, Room 185

11/29/01 RHZ-222-

0005418 

2/14/02 B2017 

NDA7/10/07 NDE 5/

E320 RCR-36-09-

007 

PRF Flush 9/28/76 Stored in 

Building 2376-ZB vault; no documentation available 

Building 234-5Z, Room 185

12/4/01 RHZ-222-

0005435 

2/26/02 B2022 

NDA7/17/07 NDE 5/

R244 R358 

97-75-05-464 97-75-05-465 

Bldg 325 Pu/U 

5/12/75 5/12/75 

Stored in Building 2376-ZB vault; no documentation available 

Building 234-5Z, Room 185

11/14/01 PR Cans R244 and R358 combined 

RHZ-222-0005912 

2/14/02 B2019 

NDA7/17/07 NDE 5/

R549 R326 

84-75-06-545 84-75-06-546 

Bldg 325 Pu/Th 

5/16/75 5/16/75 

Stored in Building 2376-ZB vault; no documentation available 

Building 234-5Z, Room 

185-T 

10/8/01 

PR Cans R549 and R326 combined 

RHZ-222-A26035 

12/3/01 A2047 

NDA7/10/07 NDE 5/

N/A N/A Standards Prior to 07/01 Not availableused in NDA Building 234- 5Z 8/28/02 (management 

date) 

RHZ-222-0005625 

10/17/02 B2187 

NDA7/12/07 NDE 5/

1References C227, M149 2References C223, C227 3References C227, C229, M140, M149 4Reference M149 5Reference C227 6References M149, C227 7Personal communication with S. Nance, who obtained the information from the WRAP database, July 21, 2011 

N/A = not applicable
14 

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 and found to be adequate. 

The TRU waste streams to be emplaced in the WIPP must be “defense” waste. Hanford-CCP 

states that, based on DOE guidance, a waste is defense in origin if it was generated “in whole or 

part by one of the atomic energy defense activities listed in section 10101(3) of the Nuclear 

Waste Policy Act of 1982 (NWPA).” AK data indicate that the radionuclides from PFP, CML 

and 325 Building Laboratory in this waste stream were generated from energy defense activities, 

including nuclear material processing and fabrication of weapons, defense nuclear waste 

materials by-products management, and defense research and development (References C004, 

P041, P050, P053, P239, P401 and P978). Based on the 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 Waste 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 disposal 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 elements of which have not been separated by 

reprocessing. SNF may not include test specimens irradiated 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 NWPA as “the highly radioactive material 

resulting from the reprocessing of spent nuclear fuel, including liquid waste produced directly in 

reprocessing and any solid material derived from such liquid waste that contains fission products 

in sufficient concentrations, and other highly radioactive material that the Commission, 

consistent with existing law, determines by rule requires permanent isolation.” 

The AKSR and Hanford-CCP AKEs indicate that PFP did not reprocess SNF, as this waste 

contains only unirradiated materials. Therefore, this waste is not SNF and PFP could not have 

generated HLW because they did not process SNF. Similarly, 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 that HLW was managed in the 325 Building 

Laboratory during the time period in which this waste stream was generated (1975–1976). A 

Hanford-CCP representative stated that the 325 Building Laboratory Pu-U and Pu-Th nitrate 

solutions in this waste stream "do not include waste 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 completeness was evaluated and found to be 

adequate. 

A draft Waste Stream Profile Form (WSPF) was provided for EPA review to demonstrate 

Hanford-CCP’s ability to prepare this required document. The WSPF includes the Profile Form, 
15 

Characterization Information Summary (CIS), Data Quality Objective (DQO) Reconciliation 

Checklist, and Summation of Aspects of the AK Summary Report: RLCCPPUNIT. Comparison 

of the WSPF and the AKSR revealed discrepancies with respect to the exact number of 

containers in the waste stream, i.e., 68 are identified on the WSPF, while the AKSR identifies 69. 

Also, the WSPF references Revision 0 of the AKSR; however, the current version is Revision 1. 

The WSPF indicates that the production of defense material 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 and 325 Building Laboratories and related 

process, and does not provide summary information about the Pu nitrate sources that were 

solidified in Building 234-5Z, Room 185. When the final 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 added 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 examined and found to be adequate. 

CCP-TP-005, Revision 22 references CCP-QP-002, Revision 31 for AK training. This requires 

that personnel assigned to compile, evaluate and resolve AK discrepancies have training in the 

following areas: 

• WIPP Waste Analysis Plan (WAP) Briefing 

• WAC knowledge 

• Federal and State Resource Conservation and Recovery Act (RCRA) regulations 

associated with solid and hazardous waste determinations 

• 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 Report (CAR) Process 

o Knowledge of resolving and managing prohibited items as noted in 

nonconformance reporting 

The CCP lead SPM is responsible for ensuring that CCP 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 documentation was provided for Sheri Nance, Mark 

Doherty, Veronica Waldram, and Steve Schafer. The Qualification Cards provided during the T1 

inspection for Ms. Nance, Mr. Doherty, and Mr. Schafer were signed in 2003 or 2004, and did 

not indicate they had been trained to the most recent regulatory documents or internal 

procedures, specifically the WAP, WAC, CCP-TP-005, and EPA’s Compliance Recertification 

Application (CRA). Site-specific Hanford AK training took place for these three individuals in 

2010. Ms. Waldram received SPM training in 2009, and the objective evidence indicated that 

AKEs were familiar with the relevant waste characterization procedures. EPA obtained updated 

Qualification Cards for Sheri Nance, Mark Doherty, Steve Schafer and Veronica Waldram in 
16 

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 stream, 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 found to be adequate. 

Hanford-CCP provided a Draft Acceptable Knowledge Accuracy Report dated June 29, 2011, 

and completed CCP-TP-005, Attachment 14 that addressed Waste Stream RLCCPPUNIT, Lot 1. 

The report concluded that the S3000 SCG was verified through RTR; all contained greater than 

50% homogeneous solids and agreed with AK. The report states that the AK identified 239Pu and 

238U 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 future Accuracy Reports will evaluate NDA 

information. The Draft AK Accuracy Report and completed Attachment 14 demonstrate 

Hanford-CCP's ability to complete this required element. 

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

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

(15) Non-destructive assay–acceptable knowledge communication was assessed and found to 

be adequate. 

CCP-TP-005, Revision 22, Section 4.4.25, requires the 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 AK during assay and address the 

limitations associated with AK-based information. It 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 summarizes the physical and 

radiological composition of the waste stream as described in the AKSR, and includes the 

information presented in Table 5, above. Assays will be performed using the WRAP GEA 

systems, and the NDA Memorandum states that the default isotopics presented in Table 5 will be 
17 

used for any assay that does not yield a "reasonable isotopic distribution." Additionally, the 

memorandum presents how 242Pu, 234U and 90Sr 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), above]. 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 on 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 Procedure, Revision 10 

A successful Measurement Control Report was performed prior to the RTR examinations for 

each BDR. An RTR Operator Trainee performed RTR operations for BDR No. RLRTRA0174 

under the supervision of a trained and qualified operator 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 appropriately supervised, RTR operators. 

An Independent Observation and Replicate Scan for each 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 greater than 4 liters for BDR Nos. RLRTRA0175 

and LRTRA0176, and Hanford-CCP correctly rejected all drums. One drum from BDR No. 

RLRTRB0156 and one drum from BDR No. RLRTRB0174 were rejected for the same reason. 

NCR Nos. NCR-RL-0644-11, NCR-RL-0643-11, NCR-RL2124110, 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 the 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 during review of these BDRs and qualification 

records, and determined that Hanford-CCP characterized this S3000 waste in accordance with 

procedure and regulatory requirements. 

Summary of Findings and Concerns

EPA did not identify any findings or concerns during 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 EPA'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-CCP. 

7.0 SUMMARY OF RESULTS AND CONCLUSIONS 

Conclusion 

EPA concluded that the waste characterization processes of AK, NDA and RTR that HanfordCCP used to characterize the retrievably stored S3000 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 characterization processes of AK, NDA and RTR as 

evidenced by the records Hanford-CCP generated in characterizing S3000 CH TRU Waste 

Stream RLCCPPUNIT. Based on this evaluation, EPA approves 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 approval does not include S3000 Hanford Tank or KBasin waste. 

Tiering Changes 

Based on the results of this evaluation, EPA has revised the T1 designations assigned to AK 

during the Hanford-CCP baseline approval, as reflected 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 streams and SCGs at Hanford-CCP. Consistent 

with EPA’s authority under 40 CFR 194.24(h), EPA may request any information relative to 

these activities if EPA deems it necessary to ensure 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 this T1 evaluation. 
19 

ATTACHMENT A

AKE Qualification Card for Steve Schafer October 2003 

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

AKE Qualification Card for Sheri Nance, December 2004 

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 RLCCPPUNIT, downloaded July 8, 2011 

CCP-AK-RL-116, Central Characterization Project Acceptable Knowledge Summary Report For 

Hanford Plutonium Finishing Plant (PFP) Contact-Handled 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, Revision 31, April 21, 2011 

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

2010 

CCP-TP-005, Revisions 21 and 22, CCP Acceptable Knowledge 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 Review, Validation, and Reporting 

Procedure, Revision 1, January 28, 2011 

C001, Record of Communication, B. Crawford interview of Wayne Larson, PNNL, Re: Hanford 

Building 325, September 11, 2003 

C004, Isotopic Analysis for Containers Generated from the Building 325 Radiochemistry Lab 

and HLW Annexes Assays, D. Guerin, October 27, 2003

C031, E-mail From Karl Husted, Re: Two most prevalent isotopes in RLMPFPCD waste 

originating in 242-Z , December 12, 2007 

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

Re-evaluation checklist for Waste Stream NPFPD 3T000-PJC-01-043, March 21, 2001 
20 

C060, Record of Communication with Karl Husted, October 12, 2007 re: Adding U-232 as a 

trace radionuclide to MPUREXD and MPFPD AK, M.I. Rollosson, October 12, 2007 

C219, Internal Letter - Subject: Disposal of Unprocessable 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. Greager, March 3, 2008 

C229, Memorandum - Subject: Unique Solution Processing 65240-79-180, W.F. Skiba, 

December 11, 1979 

C398, Memorandum-Subject: Final Results for Plutonium Finishing Plant Direct Discard Project 

Samples Analyzed During Fiscal Year 2001–2002, B3500-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 Characterization 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 Number RLCCPPUNIT, Lot 1, June 29, 

2011 

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

2009 

M140, Shipping and Receiving Reports for SS Materials, 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 Stream Containers, 2002 

M380, Waste Material Parameter Evaluation for RLCCPPUNIT, M. Doherty, December 

2010 

M381, Isotopic Evaluation for RLCCPPUNIT, NCR-RL-212001, NCR-RL-6043 and NCR 

2122110 for Waste Stream RLCCPPUNIT, M. Doherty, December 2010 
21 

P041, Past Practices Technical Characterization Study-300 Area - Hanford Site WHC-MR-0388, 

M.S. Gerber, December 1992 

P050, Analytical Chemistry Laboratory Manual, Volume 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 Program Acceptable Knowledge 

Documentation for Retrievably Stored Contact-Handled Waste HNF-3461, Revision 0, D.A. 

Arrenholz, October 2006 

P053, Testing and Analysis of Consolidated Sludge Samples from the 105 K East Basin Floor 

and Canisters P.R. Bredt, C.H., Delegard, A.J. Schmidt, 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 Facilities at the Hanford Site Historic District 

1943-1990, DOE/RL-97-1047, T.E. Marceau, D.W. Harvey, 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-SAR-021, Revision 0, J.E. Shapely 

P401, ORAU Team NIOSH Dose Reconstruction Project Technical Basis Document for the 

Hanford Site – Site Description ORAUT·TKBS·0006-2 Revision 00, J. Selby, December 29, 

2004 

P968, Authorization Basis for the 209-E Building HNF-3337, Revision 0, M.S. Tiffany, October 

12, 1998 

P970, Preliminary Hazards Study of the Hanford Plutonium Critical Mass Laboratory HW-57603 

J.A. Berberet, J.W. Healy, and E.D. Clayton, September 30, 1958 

P971, Safety Evaluation Report for the 209-E Building 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 Emergency 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, May 1970 through June 30, 1993, 

Revision 1, Westinghouse Hanford Company, J.P. Joyce, November 12, 1993 
22 

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

P1201, HNF-38161, (Reference 3) Acceptable Knowledge Document for Hanford Site 

Plutonium Finishing Plant Absorbed Plutonium Nitrate Solutions Waste Stream, RLPUNIT, 

prepared by D.I. Rollosson, CH2MHill, July 2009 

Waste Stream Profile Form for Hanford Site, Waste Stream Profile Form Number 

RLCCPPUNIT, Draft, Undated, provided by V. Waldram, June 17, 2011