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 NAT IONAL LABORATORY

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

September 2010i TABLE OF CONTENTS

Section Page

Acronyms and Abbreviations

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

1.0 Executive Summary

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

2.0 Purpose of T ier 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 EP A during T1 Evaluationii ACRONYMS AND A BBREVIATIONS

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 P lan

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 Planiii

WIPP Waste Isolation Pilot Plant

WSPF Waste Stream Profile Form4

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 F acility (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 A ERHDM 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 characteriza tion p rogram at ANL on September 12

- 14, 2006. O n January 16, 2007, EPA approved CCP’s waste characterization processes for disposal of W aste S tream AERHDM at the Waste Isolation Pilot Plant (WIPP). This baseline approval applied to 45 2 containers 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 su bject to the conditions and limitations specific to ANL

- CCP’s RH waste characterization program as outlined in the Bas e line Report. Table 1 of that report cited the inclusion of any additional containers of debris wastes as a Tier 1 (T1) change that requir es 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 evaluati ons. 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 generi c 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.5

2.0 PURPOSE OF TIER 1 EV ALUATIONS

Any changes to the waste characterization activities from the date of the ba seline 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, ch anges 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 continu es 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 inspecti on, 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 eac h 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 REPO RT

This report presents the results of EPA’s evaluation of characterization information specific to six containers that were selected from the n ewly

- 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 sectio ns throughout the report and are listed in Attachment B. Any of these documents can be requested from the following address:6

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 adde d to Waste Stream AERHDM by the CBFO in October 2 008. 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 evalua tion 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 Evalua tor

– 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 AD DITION OF 100 DRUMS OF NEWLY

- GENERATED DEBRIS WASTE FROM AL PHA GAMMA HOT CELL F ACILITY

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) operat ions of the AGHCF.7

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

- genera ted 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, how ever, 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 follo wing 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 modif

ied 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 t o 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 D iscrepancy R esolution (D R) 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 dru ms 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 Attachment8

B for a listing of all documentation reviewed . EPA based their evaluation on CCP

- AK

- ANLE

500, 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 appr oximately 100 newly

- generated 30

- gallon RH debris drums from the AGHCF based on their radiological and physical characteristics, EPA determine d the following: how these data had been integrated, impacts of the information on the waste stream, changes to th e 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 i s 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 newly

generated 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 w aste 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 inc lusion 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 hi story. 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 newly

generated AGHCF debris waste. Several add it i onal 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. Notificati on that the Attachment 8 container list has been formally updated is a T ier 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 d ebris

waste references w ere 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 exis ting AERHDM stream. EPA only examines the documentation specific to the technical elements discussed in the AK SR 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 list s 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 represe ntatives indicated that revision s to the WSP F and CRR ha ve not yet been prepared. EPA has previously evaluated WSPFs and CRR s 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 c hange, and EPA will receive notification of these changes when they are made.

(5) N on

- Conformance Reports and D iscrepancy R esolution Forms were examined and were found to be adequate.

EPA examined NCRs and DR Form s related to Waste Stream AERHDM during Base line 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. B ased 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) A cceptable K nowledge accuracy was assessed and was found to be adequate.

The la test 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 include s changes or updates to the AK Accuracy Report as a T2 change.

(7) Several i tems 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

- 7 3) for a full discussion of each of the items listed below.

● Defense Origin w as assessed and found to be adequate

● I dentification of high

- level waste and spent nuclear fuel w as assessed and found to be adequate

● The AK S ummary 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

- RH

9.06

- 8, an ANL

- CCP representative indicated that CH data were not used in this manner. Inclusion of newly

- gen erated AGHCF debris waste in Waste Stream AERHDM also did not require completion of a CSSF.

A NL

- CCP indicated that load man agement 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 ident ify 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 assi gned 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 B atch Data Reports

EPA evaluated the DTC BDRs that ANL

- CCP generated in support of the inclusion of approximately 1 0 0 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 Cont rol 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

. D ose - to

- Curie Containers and Batch Data Report s Reviewed

Container Number DTC BDR Number 874 ANLRHDTC09001 879 ANLRHDTC09002 883, 897 ANLRHDTC09003 923, 928 ANLRHDTC10002

5 .2.2 Evaluation of V isual E xamination 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 3.12

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
51 7 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 of13

the procedure. EPA has previously reviewed this procedure and determined it to be technically adequate. Packaging activities were spread ov er 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 for ms 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

- 50 0 . During normal Host Site radiation survey operations, the

can was i dentified 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 in dividual waste items surveyed and segregated for re

packaging 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 co ncerns 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 1 0 0 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 t o 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 f rom 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 A NL RH Approval Date EPA Docket Number

A NL RH Baseline Approval January 2007 A

- 98

- 49; II

- A4

- 7 3

Tier 1 Change

– Approval of WIPP Waste Inform ation System January 2007 A

- 98

- 49; II

- A4

- 7 4

Tier 1 Change

– Approval of Visual Examination for Newly

Generated Waste June 200 8 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

Ti er 1 Change

– Addition of 100 containers of AGHCF debris waste

to Waste Stream AERHDM September 2010 A

- 98

- 49;II

- A4

- 134B

- 1 

### ATTACHMENT B

LIST OF DOCUMENTS REVIEWED BY EPA DURING T1 EVALUATION

CCP

- AK

- ANLE

- 500 Central Characterization Project Acceptable Knowl edge Summary Report f or 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 Trans uranic Debris Waste f rom 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 Rec ords 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 Accur acy 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

Memora ndum 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 Conta iners 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, 2009B

- 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 Alpha

Gamma Hot Cell Facility Preliminary Decontamination and Decommissioning Plan, HFS

- 003, T. S. Bray, October 08, 2003