DOCKET NO: A-98-49; II-A4-136

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT

ADDITION OF 100 ALPHA GAMMA HOT CELL FACILITY DEBRIS WASTE 

CONTAINERS TO THE REMOTE-HANDLED DEBRIS WASTE STREAM AERHDM 

CERTIFIED IN OCTOBER 2008 AT THE ARGONNE NATIONAL LABORATORY 

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air

Center for Federal Regulations

1200 Pennsylvania Avenue, NW

Washington, DC 20460

September 2010
i

TABLE OF CONTENTS

Section Page

Acronyms and Abbreviations ......................................................................................................... ii

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

2.0 Purpose of Tier 1 Evaluations..............................................................................................5

3.0 Purpose of This Report ........................................................................................................5

4.0 Scope of This Evaluation.....................................................................................................6

5.0 Evaluation of the Addition of 100 Drums of Newly-Generated Debris Waste from Alpha 

Gamma Hot Cell Facility.....................................................................................................6

5.1 Acceptable Knowledge ........................................................................................... 7

5.2 Radiological Characterization and Visual Examination Batch Data Reports....... 11

5.3 Summary of Evaluation of Newly-Generated Alpha Gamma Hot Cell Facility 

Waste..................................................................................................................... 13

6.0 Summary of Results...........................................................................................................14

ATTACHMENTS

Attachment A: Approval Summary for ANL RH Waste Characterization Program

Attachment B: List of Documents Reviewed by EPA during T1 Evaluation
ii

ACRONYMS AND ABBREVIATIONS

AGHCF Alpha Gamma Hot Cell Facility

AK Acceptable Knowledge

AKE Acceptable Knowledge Expert

AKSR Acceptable Knowledge Summary Report

ANL Argonne National Laboratory

ANL-E Argonne National Laboratory – East

BDR Batch Data Report

CBFO Carlsbad Field Office

CCP Central Characterization Project

CFR Code of Federal Regulations

CH Contact-Handled

CRR Characterization Reconciliation Report

CSSF Correlation and Surrogate Summary Form

CTP Confirmatory Test Plan

D&D Decontamination and Decommissioning

DOE U.S. Department of Energy

DQO Data Quality Objective

DR Discrepancy Resolution

DTC Dose-to-Curie

EPA U. S. Environmental Protection Agency

ITR Independent Technical Reviewer

NCR Non-Conformance Report

RH Remote-Handled

SPM Site Project Manager

T1 Tier 1

T2 Tier 2

TRU Transuranic

VE Visual Examination

WCPIP Remote-Handled TRU Waste Characterization Program Implementation Plan
iii

WIPP Waste Isolation Pilot Plant

WSPF Waste Stream Profile Form
4

1.0 EXECUTIVE SUMMARY

This report presents the results of the U.S. Environmental Protection Agency (EPA)’s review of 

information supporting the addition of 100 newly-generated remote-handled (RH) transuranic 

(TRU) debris waste containers from the Alpha Gamma Hot Cell Facility (AGHCF) to Waste 

Stream AERHDM at the U.S. Department of Energy’s (DOE’s) Argonne National Laboratory 

(ANL). The Central Characterization Project (CCP) at ANL has been characterizing these 

containers since the Carlsbad Field Office (CBFO) certified their addition in October 2008.

Recently, EPA requested that the CBFO provide EPA with information supporting this addition. 

The CBFO provided the pertinent revision of the Acceptable Knowledge Summary Report 

(AKSR), radiological characterization report, and a list of fully-characterized containers.1 Based 

on a review of Dose-to-Curie (DTC) and Visual Examination (VE) batch data reports (BDRs), 

EPA concludes that the additional 100 containers of newly-generated RH debris from AGHCF 

belong to Waste Stream AERHDM and the waste characterization processes remain technically 

adequate and acceptable. 

In accordance with 40 Code of Federal Regulations (CFR) 194.8(b), the EPA conducted 

Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8 of the CCP waste characterization program 

at ANL on September 12-14, 2006. On January 16, 2007, EPA approved CCP’s waste 

characterization processes for disposal of Waste Stream AERHDM at the Waste Isolation Pilot 

Plant (WIPP). This baseline approval applied to 452containers of legacy RH debris waste drums.

The ANL Baseline Final Inspection Report (see EPA Docket No. A-98-49; II-A4-73) documents 

the approval of the Acceptable Knowledge (AK), radiological characterization using DTC and 

VE processes specific to Waste Stream AERHDM and subject to the conditions and limitations 

specific to ANL-CCP’s RH waste characterization program as outlined in the Baseline Report.

Table 1 of that report cited the inclusion of any additional containers of debris wastes as a Tier 1 

(T1) change that requires EPA approval prior to implementation. A summary of EPA’s approval 

of the ANL RH TRU waste characterization program is included as Attachment A.

This report serves as EPA’s public notification of the results of the proposed T1 changes and 

their evaluations. This information will be provided through the EPA website and by sending 

e-mails to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3).

 

1 Containers is a generic term which applies to cans, canisters, drums, and any other types of waste packaging units 

that may be characterized individually for their radiological and physical contents.

2 The Baseline approval was written for 45 containers; however, documentation from ANL-CCP indicates that the 

original waste stream contained 44 drums. Therefore, throughout this report the size of Waste Stream AERHDM 

varies depending on which document is being referenced. 
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2.0 PURPOSE OF TIER 1 EVALUATIONS

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 ANL 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 purpose of a baseline inspection is to approve the site’s waste 

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

applicable conditions and limitations, can adequately characterize TRU wastes and comply with 

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

inspection team conducts the 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 

specified which subsequent waste characterization program changes or modifications must 

undergo further EPA inspection or approval under 40 CFR 194.24. This was accomplished by 

assigning a tier level to each aspect of the ANL-CCP’s characterization program. T1 activities 

have more stringent reporting requirements and require that DOE notify EPA, and that EPA 

provide approval prior to implementation. 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).

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluation of characterization information specific to 

six containers that were selected from the newly-generated RH debris containers that have been 

characterized since October 2008, when 100 such drums were certified by the CBFO for addition 

to Waste Stream AERHDM. 

The DOE documents that EPA reviewed for this evaluation are cited in different sections 

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

from the following address:
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Carlsbad Field Office

Manager, National TRU Program

U.S. Department of Energy

P O Box 3090

Carlsbad, NM 88221-3090

4.0 SCOPE OF THIS EVALUATION

The scope of this evaluation was to review objective evidence of waste characterization activities 

as implemented by ANL-CCP to characterize 100 containers of newly-generated RH debris 

waste added to Waste Stream AERHDM by the CBFO in October 2008. The evaluation was 

performed by comparing elements assessed in the previous EPA approval with information about 

the new waste containers provided by ANL-CCP/CBFO to ensure that they fit within the 

approval issued previously by EPA. Because this evaluation involved expanding an existing 

waste stream to incorporate new containers and not the addition of a new Summary Category 

Group or waste stream, inspection checklists were not used.

As part of this evaluation, EPA examined the relevant AK information (CCP-AK-ANLE-500, 

Revision 3) to verify that the additional waste containers had the same pedigree as the approved 

AERHDM debris waste stream and were characterized using the same radiological 

characterization process and/or radionuclide scaling factors. This examination applies to the 100 

30-gallon drums of newly-generated AGHCF debris waste added to Waste Stream AERHDM 

and certified by the CBFO in October 2008.

Personnel who participated in the T1 evaluation are listed in Table 1, along with each person’s 

affiliation and function during the evaluation.

Table 1: T1 Evaluation Participants

Name Affiliation & Function 

Rajani Joglekar Lead Inspector, U.S. EPA 

Connie Walker Technical Evaluator – Acceptable Knowledge, SC&A

Kira Darlow Technical Evaluator – Acceptable Knowledge, SC&A 

Patrick Kelly Technical Evaluator – Radiological Characterization, SC&A 

Dorothy Gill Technical Evaluator – Real-Time Radiography, SC&A

Irene Quintana Site Project Manager, ANL-CCP 

5.0 EVALUATION OF THE ADDITION OF 100 DRUMS OF NEWLY-GENERATED 

DEBRIS WASTE FROM ALPHA GAMMA HOT CELL FACILITY

This evaluation addresses the 100 30-gallon drums of newly-generated AGHCF debris waste that 

the CBFO certified in October 2008 for addition to the previously certified Waste Stream

AERHDM. As indicated in the AKSR, Revision 3, up to 100 additional 30-gallon containers 

(11.4 cubic meters) were expected to be generated during packaging of the waste contained in 

the hot cells and ongoing Decontamination and Decommissioning (D&D) operations of the 

AGHCF. 
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In January 2007, EPA approved 45 30-gallon drums of legacy waste from this population for 

disposal at the WIPP facility (see EPA Docket No. A-98-49; II-A4-73). Subsequently, the CBFO 

added 100 additional 30-gallon drums of newly-generated AGHCF debris waste to Waste Stream 

AERHDM for disposal at WIPP. EPA did not receive a T1 change request or supporting 

documentation to add these 100 drums as a T1 change prior to the October 2008 CBFO 

certification of these 100 containers. EPA did, however, receive a draft certification 

memorandum for review, with which EPA concurred. 

5.1 Acceptable Knowledge

EPA examined the AK process and associated information to determine whether the ANL-CCP 

waste characterization program demonstrated compliance with the requirements of 40 CFR 194.8 

for the addition of approximately 100 newly-generated 30-gallon drums of RH TRU AGHCF

debris waste to ANL Waste Stream AERHDM.

Waste Characterization Element Description

As part of the inspection, EPA reviewed the following with respect to the use of AK for waste 

characterization as impacted by the addition of new containers: 

 Waste stream identification and definition

 Radionuclide content of additional waste

 Physical composition of additional waste

 Sufficiency of modified AKSR to include the additional waste 

 Drum data traceability

 Defense origin of additional waste

 Identification of high-level waste and spent nuclear fuel

 AK source document sufficiency 

 Modifications to the Confirmatory Test Plan (CTP)

 Modifications to the Waste Stream Profile Form (WSPF) and Characterization 

Reconciliation Report (CRR)

 Correlation and Surrogate Summary Form (CSSF) and Contact-Handled (CH)-RH 

correlation

 Personnel training

 Non-Conformance Reports (NCRs) and AK Discrepancy Resolution (DR) Forms

 AK accuracy

 Load management

 Identification and attainment of Data Quality Objectives (DQOs)

Documents Provided

EPA evaluated the documentation that ANL-CCP had prepared to support the inclusion of 

approximately 100 newly-generated 30-gallon drums of AGHCF debris waste in Waste Stream 

AERHDM. Several attachments, source documents, required forms, and other data were 

provided to EPA, and relevant sources were examined as part of this evaluation; see Attachment 
8

B for a listing of all documentation reviewed. EPA based their evaluation on CCP-AK-ANLE500, Revision 3, because that was the approved version of the AKSR in October 2008 when the 

100 newly-generated drums were added to Waste Stream AERHDM. 

Technical Evaluation

To assess inclusion of approximately 100 newly-generated 30-gallon RH debris drums from the 

AGHCF based on their radiological and physical characteristics, EPA determined the following:

how these data had been integrated, impacts of the information on the waste stream, changes to 

the radiological and physical characteristics of the waste and other elements that could affect 

pertinent characteristics of Waste Stream AERHDM. Results of the analysis are presented below.

When information presented in the text is supported directly by one of the AK references, that 

reference is cited in parentheses.

(1) The definition of Waste Stream AERHDM, including radionuclide content and physical 

composition, was examined with respect to the addition of the newly-generated waste and 

found to be adequate.

The RH TRU Waste Characterization Program Implementation Plan (WCPIP) defines a waste 

stream as “waste material generated from a single process or activity, or as waste with similar 

physical, chemical, and radiological properties.” Waste Stream AERHDM is a debris waste 

stream that was generated in the ANL-E AGHCF and includes wastes that are currently in 

drums, as well as waste awaiting packaging that still resides in the hot cell. After reviewing the 

modified documentation, EPA concluded that inclusion of newly-generated AGHCF waste in 

Waste Stream AERHDM is adequately supported.

During the Baseline Inspection, EPA evaluated inclusion of both retrievably-stored and newlygenerated AGHCF debris waste in Waste Stream AERHDM and found that the waste stream was 

adequately defined. The approval, however, did not include newly-generated waste. As indicated 

in the AKSR Revision 3 and described in the EPA Baseline Report (EPA Docket No. A-98-49; 

II-A4-73), the waste stream consisted of: approximately 45 drums of waste generated from 

February 1993 through February 2002 and additional material that would be packaged in the 

future as newly-generated waste. Revision 3 of the AKSR estimates that between 50-100 drums 

of newly-generated waste will be packaged from the waste created during the same time period 

that remained in the hot cell and waste created during ongoing D&D of the AGHCF. 

The analysis of the physical characteristics of Waste Stream AERHDM as presented in the EPA 

Baseline Report does not change with inclusion of the newly-generated waste. ANL-CCP 

indicated that the newly-generated containers will consist predominantly of inorganic materials 

consistent with the retrievably-stored drums, because the AGHCF process remained relatively 

unchanged throughout history. The newly-generated waste, however, may contain more metal 

debris as a result of D&D activities (P378). A brief review of VE BDRs created during 

characterization of the newly-generated containers supports these statements. Based on this 

information and the process history associated with the stream, the waste stream has been 

appropriately assigned with respect to physical characteristics.
9

EPA evaluated the AK radiological data pertaining to the content of the waste drums as impacted 

by the addition of newly-generated waste containers and found that there is no change to the 

analysis presented in the Baseline Report. EPA concludes that the waste stream was 

appropriately defined based on the similarity of radiological components.

(2) Data traceability of newly-generated Alpha Gamma Hot Cell Facility waste was 

examined and was found to be adequate.

A copy of the Attachment 8 container list was provided that does not include the newlygenerated AGHCF debris waste. Several additional container memoranda and a current Waste 

Container Tracking Spreadsheet were provided, indicating that the process is in place to formally 

update Attachment 8. EPA expects that Attachment 8 will eventually be formally updated to 

include the newly-generated AGHCF wastes. Notification that the Attachment 8 container list 

has been formally updated is a Tier 2 (T2) change.

(3) Sufficiency of Acceptable Knowledge support documents and related document tracking 

with respect to the addition of newly-generated Alpha Gamma Hot Cell Facility debris 

waste references were evaluated and were found to be adequate.

An AK Source Document Reference List was prepared using unique identifiers for the different 

document types, following the format typically used by ANL-CCP for RH wastes. The listing is 

complete, and is easy to understand. ANL-CCP identified a few additional references specific to 

newly-generated AGHCF wastes. Available information indicates that the evaluated references 

support the overall inclusion of newly-generated waste into the existing AERHDM stream. EPA 

only examines the documentation specific to the technical elements discussed in the AKSR and 

not the individual documents used by the AK Expert (AKE) to prepare the AK basis for the 

waste stream in question (see Attachment B and the Baseline Report for lists of reviewed 

references).

(4) Modifications to the waste stream profile form and related characterization reconciliation 

report were assessed and were found to be adequate.

ANL-CCP representatives indicated that revisions to the WSPF and CRR have not yet been 

prepared. EPA has previously evaluated WSPFs and CRRs related to Waste Stream AERHDM

and found them to be adequate. As required in EPA’s baseline approval, revision of the WSPF 

and related attachments including the CRR is a T2 change, and EPA will receive notification of 

these changes when they are made.

(5) Non-Conformance Reports and Discrepancy Resolution Forms were examined and were 

found to be adequate.

EPA examined NCRs and DR Forms related to Waste Stream AERHDM during Baseline 

Inspection No. EPA-ANL-CCP-RH-9.06-8 and found the preparation of these documents to be 

adequate. Several NCRs are available in the provided VE BDRs for the newly-generated 

AGHCF wastes. DR016 and DR017 were added to the AK record for Revision 3. They address 

the presence of prohibited items in AGHCF debris drums. Based on these NCRs and DR Forms, 
10

and those evaluated during previous reviews, EPA expects that the process EPA evaluated in the 

past will continue to be used to develop these documents when necessary.

(6) Acceptable Knowledge accuracy was assessed and was found to be adequate.

The latest AK Accuracy Report was completed on May 13, 2010, and includes evaluation of the 

AK accuracy for 100 AGHCF retrievably-stored and newly-generated debris drums. There are 

no discrepancies to report; therefore, AK Accuracy of Waste Stream AERHDM, including the 

newly-generated AGHCF debris containers, is 100%. EPA’s baseline approval includes changes 

or updates to the AK Accuracy Report as a T2 change.

(7) Several items reviewed by EPA as part of this Technical Evaluation were determined to 

not be impacted by the addition of newly-generated Alpha Gamma Hot Cell Facility 

debris containers to Waste Stream AERHDM. See the Baseline Report (EPA Docket No. 

A-98-49; II-A4-73) for a full discussion of each of the items listed below. 

● Defense Origin was assessed and found to be adequate 

● Identification of high-level waste and spent nuclear fuel was assessed and found to be 

adequate 

● The AK Summary and implementation of AK as required in Attachment A of the WCPIP 

were evaluated and were found to be adequate

● Interpretation of WCPIP with respect to contents of the Certification Plan and CTP was 

evaluated and found to be satisfactory

● Personnel training was evaluated and was found to be adequate

● Attainment of DQOs were evaluated and found to be adequate 

(8) Use of a Correlation and Surrogate Summary Form and use of Load Management were

evaluated and were determined to not apply to this waste stream.

Completion of a CSSF is required when AK information from a related CH waste stream is used

in the RH waste characterization process. During Baseline Inspection No. EPA-ANL-CCP-RH9.06-8, an ANL-CCP representative indicated that CH data were not used in this manner. 

Inclusion of newly-generated AGHCF debris waste in Waste Stream AERHDM also did not 

require completion of a CSSF.

ANL-CCP indicated that load management is not intended for Waste Stream AERHDM, and this 

will not change with inclusion of the newly-generated AGHCF debris wastes that comprise this 

evaluation. EPA’s baseline inspection report indicated that the implementation of load 

management is a T1 change requiring EPA prior approval.

Summary of Acceptable Knowledge

Findings or Concerns

The EPA Inspection Team did not identify any findings or concerns relative to the inclusion of 

100 newly-generated 30-gallon drums of AGHCF debris waste during this evaluation.
11

Tiering Changes

Based on the results of this evaluation, there are no changes to the T1 or T2 designations as 

assigned during the baseline inspection and subsequent T1 reviews. 

5.2 Radiological Characterization and Visual Examination Batch Data Reports 

5.2.1 Evaluation of Dose-to-Curie Batch Data Reports

EPA evaluated the DTC BDRs that ANL-CCP generated in support of the inclusion of 

approximately 100 30-gallon drums of newly-generated AGHCF heterogeneous debris waste in 

Waste Stream AERHDM. The listing of specific BDRs reviewed is presented in Table 2 below.

EPA technical personnel verified that the DTC BDRs included the following for the six 

randomly selected drums listed in Table 2 below:

● BDR Cover Sheet, Attachment 4

● BDR Table of Contents, Attachment 5

● BDR Narrative Summary, Attachment 6

● Independent Technical Reviewer (ITR) Checklist, Attachment 7

● Measurement Control Report, Attachment 1

● Container Data Sheet(s), Attachment 2

● Waste Container DTC Conversion Record(s), Attachment 3

● Evidence of signatures by the ITR and a Site Project Manager (SPM)

● Type of waste in each container (steel, concrete, organics)

● Fill height of the container: < 25% full; 25% - 66% full; 66% - 90% full; > 90% full

● Clear demonstration that all waste containers were TRU, i.e., contained more than 100 

nanoCuries per gram of transuranic radionuclides

● Clear demonstration that all containers were RH, i.e., had an external contact dose rate 

greater than 200 millirem per hour 

There were no issues related to the DTC BDRs for the containers in Waste Stream AERHDM.

Table 2. Dose-to-Curie Containers and Batch Data Reports Reviewed

Container Number DTC BDR Number

874 ANLRHDTC09001

879 ANLRHDTC09002

883, 897 ANLRHDTC09003

923, 928 ANLRHDTC10002

5.2.2 Evaluation of Visual Examination Batch Data Reports

As part of the requested T1 change for the addition of containers to ANL-CCP Waste Stream 

AERHDM, EPA evaluated VE records for randomly selected containers from five VE BDRs as 

listed below in Table 3.
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Table 3. Visual Examination Containers and Batch Data Reports Reviewed

BDR RHANLVE090001

30-gallon Container Date Packaged Inner 7-gallon Containers Date Packaged

867 10/02/08 397 07/17/08

400 07/08/08

873 11/11/08 388 07/24/08

399 07/10/08

874 10/02/08 385 07/24/08

393 07/17/08

875 11/13/08 392 07/15/08

344 07/03/08

BDR RHANLVE090002

879 03/24/09

366 12/02/08

465 12/03/08

883 03/31/09 452 12/18/08

441 01/15/09

885 04/01/09 442 12/18/08

475 01/22/09

888 04/02/09 422 01/15/09

440 03/20/09

BDR RHANLVE090003

890 09/08/09 428 08/12/09

444 08/12/09

894 09/10/09 421 09/10/09

413 08/13/09

897 09/11/09

409 08/31/09

477 07/30/09

BDR RHANLVE100002

915 02/03/10 519 01/29/10

490 01/08/10

920 02/05/10 420 01/08/10

521 01/28/10

923 02/09/10 488 01/29/10

522 01/08/10

BDR RHANLVE100003

925 03/10/10 414 02/25/10

500 02/24/10

926 03/11/10 496 02/24/10

517 02/23/10

928 10/03/10 495 02/24/10

503 02/25/10

930 03/16/10 501 02/26/10

487 02/23/10

Waste was packaged into 7-gallon cans and recorded on Attachment 1, VE Data Form contained 

in procedure CCP-TP-500, Remote-Handled Waste Visual Examination. Two 7-gallon cans were 

later packaged into a 30-gallon container; this VE event also was recorded on Attachment 1 of 
13

the procedure. EPA has previously reviewed this procedure and determined it to be technically 

adequate. Packaging activities were spread over several years and two different revisions of 

CCP-TP-500 were used. EPA verified that the applicable revision of the procedure was used 

during each VE event and also determined that VE records were completed as required. Two 

operators signed the data forms and the BDRs were reviewed at both data generation and project 

level. Two NCRs were issued for BDR RHANLVE100002 as follows:

NCR-RH-0001-09 was generated because:

VE of waste packaged into Can 420 was originally performed and documented on

12-4-08 as a smaller container that will be later combined into a final container in 

accordance with CCP-TP-500. During normal Host Site radiation survey operations, the 

can was identified as exceeding inter-site transportation dose limits. The waste will be 

removed from the can and individual waste items surveyed and segregated for re-packing 

per Host Site procedures. 

NCR-RH-0002-09 was generated because:

VE of waste packaged into Can 480 was originally performed and documented on 

8-13-09 as a smaller container that will be later combined into a final container in 

accordance with CCP-TP-500. During normal Host Site radiation survey operations, the 

can was identified as exceeding inter-site transportation dose limits. The waste will be 

removed from the can and individual waste items surveyed and segregated for repackaging per Host Site procedures.

Both NCRs were processed and closed as required by CCP procedure CCP-QP-005, CCP TRU 

Nonconforming Item Reporting and Control.

EPA did not identify any findings or concerns related to VE of the containers reported in the 

BDRs listed above.

5.3 Summary of Evaluation of Newly-Generated Alpha Gamma Hot Cell Facility Waste

Findings or Concerns

The EPA Inspection Team did not identify any findings or concerns relative to the inclusion of 

approximately 100 newly-generated 30-gallon drums of AGHCF heterogeneous debris waste 

during this evaluation.

Tiering Changes

Based on the results of this evaluation of 100 containers added in October 2008, there are no 

additional changes to the T1 and T2 designations that were assigned to AK for ANL-CCP during 

the baseline approval. 
14

Conclusion

Based on the results of this evaluation, EPA concurs with the October 2008 inclusion of 100 

newly-generated 30-gallon drums of AGHCF debris waste in Waste Stream AERHDM. 

6.0 SUMMARY OF RESULTS

Findings and Concerns

The EPA Inspection Team did not identify any findings or concerns relative to the inclusion of 

approximately 100 30-gallon containers of newly-generated AGHCF debris waste to Waste 

Stream AERHDM during this T1 change evaluation.

Tiering Changes

No change to the tiering designations resulting from this review has been necessary. 

Conclusions

EPA evaluated AK information and objective evidence (BDRs) for fully characterized containers 

from 100 30-gallon containers added to the AERHDM waste stream in October 2008. Based on 

the results of this evaluation, EPA concludes that debris in these additional containers has the 

same pedigree as the original 45 containers of AERHDM waste stream that EPA approved in 

January 2007.
A-1

ATTACHMENT A

APPROVAL SUMMARY FOR ANL RH WASTE CHARACTERIZATION 

PROGRAM

Specific ANL RH Approval Date EPA Docket Number

ANL RH Baseline Approval January 2007 A-98-49; II-A4-73

Tier 1 Change – Approval of WIPP Waste Information System January 2007 A-98-49; II-A4-74

Tier 1 Change – Approval of Visual Examination for NewlyGenerated Waste June 2008 A-98-49; II-A4-102

Tier 1 Change – Addition of K-Wing Debris Waste to Waste Stream 

AERHDM September 2010 A-98-49; II-A4-132

Tier 1 Change – Addition of 100 containers of AGHCF debris waste 

to Waste Stream AERHDM September 2010 A-98-49;II-A4-134
B-1

ATTACHMENT B

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION

CCP-AK-ANLE-500 Central Characterization Project Acceptable Knowledge Summary Report 

for Argonne Remote-Handled Debris Waste, Waste Stream: AERHDM, Revision 3, May 8, 2008

CCP-AK-ANLE-501, Central Characterization Project Remote-Handled Transuranic 

Radiological Characterization Technical Report for Remote-Handled Transuranic Debris Waste 

from Argonne National Laboratory-East, Revision 2, May 10, 2010

CCP-AK-ANLE-502, Central Characterization Project RH TRU Waste Certification Plan for 40 

CFR Part 194 Compliance and Confirmation Test Plan for ANL RH Waste Stream: AERHDM, 

Revision 2, Draft A, 2010

CCP-AK-ANL-505A, Central Characterization Project Sampling and Analysis Plan for Argonne 

Remote Handled Debris Waste, Waste Stream AERHDM, Revision 0, December 9, 2009

Inter-Office Correspondence from I. S. Quintana to CCP Records Custodian, RE: Transmittal of 

Waste Stream Profile Form, Attachment 4, for Remote-Handled Waste Stream AEHRDM at the 

Argonne National Laboratory, July 23, 2008

Inter-Office Correspondence, from C. M. Gomez to M. Sensibaugh, Acceptable Knowledge 

Accuracy Report, Argonne National Laboratory, Waste Stream Number AERHDM, Lots 1-5, 

May 13, 2010

Memorandum to Hillari Neeley and Irene Quintana, CCP SPMs, from Kevin Peters, CCP AKE, 

RE: Addition of 10 Containers to Waste Stream AERHDM, March 10, 2009

Memorandum to Hillari Neeley, CCP SPM, from Kevin Peters, CCP AKE, RE: Addition of 2 

Containers to Waste Stream AERHDM, March 10, 2010

Memorandum to Hillari Neeley, CCP SPM, from Kevin Peters, CCP AKE, RE: Addition of 5 

Containers to Waste Stream AERHDM, March 22, 2010

Memorandum to Hillari Neeley and Irene Quintana, CCP SPMs, from Kevin Peters, CCP AKE 

RE: Addition of 15 Containers to Waste Stream AERHDM, April 16, 2009

Memorandum to Irene Quintana, CCP SPM, from Kevin Peters, CCP AKE, RE: Addition of 6 

Containers to Waste Stream AERHDM, May 20, 2008

Memorandum to Hillari Neeley and Irene Quintana, CCP SPM, from Kevin Peters, CCP AKE, 

RE: Addition of 2 Containers to Waste Stream AERHDM, June 27, 2008

Memorandum to Hillari Neeley and Irene Quintana, CCP SPMs, from Kevin Peters, CCP AKE, 

RE: Addition of 9 Containers to Waste Stream AERHDM, September 14, 2009
B-2

RH Tiering of TRU Waste Characterization Processes Implemented by CCP at ANL (Based on 

EPA Baseline Inspection No. EPA-ANL-CCP-RH-9.06-8) Docket No. A-98-49; II-A4-73, 

September 2008

P378, Argonne National Laboratory-East Building 212 Energy Technology Division AlphaGamma Hot Cell Facility Preliminary Decontamination and Decommissioning Plan, HFS-003, 

T. S. Bray, October 08, 2003