DOCKET NO: A-98-49; II-A4-145 

WASTE CHARACTERIZATION REPORT 

EPA TIER 1 EVALUATION 

OF THE CENTRAL CHARACTERIZATION PROJECT 

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM 

FOR IDAHO NATIONAL LABORATORY: 

ADDITION OF LOT 4A CONTAINERS TO WASTE STREAM ID-HFEF-S5400-RH 

 

February-March 2011 

U.S. Environmental Protection Agency 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulations 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

March 2011
i 

TABLE OF CONTENTS 

Section Page

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

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

2.0 Purpose of a Tier 1 Evaluation............................................................................................ 5

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

4.0 Scope of This Tier 1 Evaluation ......................................................................................... 6

5.0 Technical Evaluation: Waste Stream ID-HFEF-S5400-RH, Lot 4A .................................. 6

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

5.2 Radiological Characterization ............................................................................... 15

5.3 Real-Time Radiography ........................................................................................ 23

6.0 Summary of Results .......................................................................................................... 24

7.0 Conclusions ....................................................................................................................... 24

LIST OF TABLES 

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP 

(Revised March 2011) ....................................................................................................... 3 

Table 2. T1 Evaluation Participants ................................................................................................ 6 

Table 3. Batch Data Reports Evaluated .......................................................................................... 7 

Table 4. Approximate Canister Liner Waste Contents ................................................................. 10 

Table 5. Radionuclide-Specific Scaling Factors ........................................................................... 20 

ATTACHMENTS 

Attachment A: Approval Summary for INL-CCP RH Waste Characterization Program 

Attachment B: Listing of Documents Reviewed for this Evaluation 
ii 

ACRONYMS 

A/V audio/visual 

AF accountable fissile 

AK acceptable knowledge 

AKE acceptable knowledge expert 

AKSR acceptable knowledge summary report 

Am americium 

Ba barium 

BDR batch data report 

Br bromine 

BR-3 Belgium Reactor 3 

CBFO Carlsbad Area Field Office 

CCP Central Characterization Project 

Ce cerium 

CFR Code of Federal Regulations

CH contact-handled 

Ci curie 

Cm curium 

Co cobalt 

CRR Characterization Reconciliation Report 

Cs cesium 

CSSF Correlation and Surrogate Summary Form 

DOE U.S. Department of Energy 

DQO data quality objective 

DR discrepancy resolution 

DTC dose-to-curie 

DU depleted uranium 

DUO2 depleted uranium oxide fuel 

EBR experimental breeder reactor 

EPA U.S. Environmental Protection Agency 

FCF Fuel Conditioning Facility 

g gram 
iii 

g/cm3 grams per cubic centimeter 

HFEF Hot Fuel Examination Facility 

INL Idaho National Laboratory 

INTEC Idaho Nuclear Technology and Engineering Center 

ITR Independent Technical Reviewer 

IWTS Integrated Waste Tracking System 

La lanthanum 

L&O Laboratory and Office 

m meter 

MCNP5 Monte Carlo N-Particle Transport Code RSICC Computer Code Collection, 

Oak Ridge National Laboratory 

MFC Materials and Fuel Complex 

mR/hr/Ci milli Roentgen per hour per Curie 

mrem/hr millirem per hour 

nCi/g nanocurie per gram 

NCR non-conformance report 

NDA nondestructive assay 

ORIGEN Oak Ridge Isotope Generation 

Pu plutonium 

RERTR reduced enrichment research and test reactor 

RH remote-handled 

RSWF Radioactive Scrap and Waste Facility 

RTR real-time radiography 

SPM Site Project Manager 

Sr strontium 

SURV material surveillance 

T1 Tier 1 

T2 Tier 2 

TMU total measurement uncertainty 

TRU transuranic 

U uranium 

VE visual examination 

WCPIP Waste Characterization Program Implementation Program 
iv 

WDS Waste Data System 

WIPP Waste Isolation Pilot Plant 

WMP waste material parameter 

WSPF Waste Stream Profile Form 

WWIS WIPP Waste Information System 

Y yttrium 

Zr zirconium 
1 

1.0 EXECUTIVE SUMMARY 

This report supports the U.S. Environmental Protection Agency’s (EPA) Tier 1 (T1) approval of 

retrievably-stored, remote-handled (RH) transuranic (TRU) heterogeneous debris (S5400) waste 

from the U.S. Department of Energy’s (DOE’s) Idaho National Laboratory (INL). Specifically, 

this approval supports the addition of three Lot 4A canister liners1 to Waste Stream 

ID-HFEF-S5400-RH, as requested by the Carlsbad Field Office (CBFO) on January 31, 2011. 

The Central Characterization Project (CCP) is responsible for characterizing the above wastes 

using the system of controls that EPA evaluated during the baseline inspection conducted in July 

2006, and approved in January 2007. Waste Stream ID-HFEF-S5400-RH, Lot 1A was approved 

for emplacement at the Waste Isolation Pilot Plant (WIPP) on February 1, 2010, and Lot 1B was 

approved on August 23, 2010. A summary of EPA’s approval of the INL RH TRU waste 

characterization program is included as Attachment A. 

This report presents the results of the T1 evaluation. EPA conducted a desktop review of the 

Acceptable Knowledge (AK) waste characterization process (Section 5.1), documentation 

associated with the radiological characterization waste characterization process (Section 5.2), 

and documentation associated with the Real-Time Radiography (RTR) waste characterization 

process (Section 5.3). EPA did not identify any changes to the tiering table during this T1 

review. Minor modifications to bring the table in line with previous reports and changes in 

format were made to the INL RH tiering table. The revised tiering table included as Table 1 

below applies to all RH waste characterization activities occurring at INL-CCP. 

While previous T1 changes adding RH waste streams have been container2

 limited, this approval 

is not limited to a specific number of waste containers in Waste Stream ID-HFEF-S5400-RH, 

Lot 4A. INL-CCP may add containers to the approved INL RH waste streams, if: 

• Additional containers have similar pedigree to the approved waste stream; and 

• INL-CCP can demonstrate that the radionuclide scaling factors used for the RH waste 

stream (ID-HFEF-S5400-RH, Lot 4A) are technically appropriate for use in the Dose-toCurie (DTC) determination of the radiological characterization of the additional 

containers. 

If a population of additional containers requires new or different radionuclide scaling factors, 

those additional containers will be subjected to EPA’s T1 evaluation and approval prior to 

disposal at the WIPP. 

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

canister liners from Lot 4A to RH TRU Waste Stream ID-HFEF-S5400-RH are adequate. EPA, 

therefore, approves the addition of Lot 4A containers to Waste Stream ID-HFEF-S5400-RH as a 

T1 change to INL-CCP’s RH baseline approval. 

 

1

 A canister liner is defined in CCP-AK-INL-581 as an interim waste container and not the final waste 

package. 

2

 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 

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

evaluation. This information will be provided through the EPA website and by sending e-mails 

to the WIPPNEWS list, in accordance with 40 Code of Federal Regulations (CFR) 194.8(b)(3).
3 

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Revised 

RH Waste Characterization 

Process Elements 

INL-CCP RH Waste Characterization Process – 

T1 Changes 

INL-CCP RH Waste Ch

T2 Ch

Acceptable Knowledge (AK) Addition of containers to approved Waste Streams if new or 

different radionuclide scaling factors are requiredAny new waste streams not approved under this baselineSubstantive modification(s)*** to CCP-AK-INL-5X0, CCPAK-INL-5X1, or CCP-AK-INL-5X2 that have the potential to affect the characterization process Load management for any RH waste stream 

Notification to EPA when update

have been completed: 

• All future revisions of th

Confirmation Test Plan (CCP-AK-INL-502) 

• AK accuracy reports (pre

• Attachment 4 of CCP-TP

updated AKSR Source D

• Changes to AK documen

revisions (e.g., CRR)** 

• A Correlation or Surroga

RH containers in this waupon measured dose rateassayed containers 

• The waste stream data pa

and any modifications to and AK Summary 

• Final DTC determination 

through 737, as identified 

Submission of an updated AKSR the additional containers is the sa

during baseline approval† Submission of a list of fully chara

population of additional containe

above† 

Radiological Characterization, including Dose-to-Curie (DTC) 

Application of new scaling factors for isotopic determination other than those documented in CCP-AK-INL-501 Use of any alternate radiological characterization procedure 

other than DTC with established scaling factors as documented in CCP-TP-504 or substantive modification*** 

of the DTC procedure Use of any alternate gamma detector with the OSPREYTM system characterization procedure other than the La3Br(Ce) 

Notification to EPA upon comple

INL-501 or CCP-TP-504 that reqSubmission of DTC BDRs or cal

selected by EPA from a list of ful

provided by INL-CCP† 
4 

Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Revised 

RH Waste Characterization 

Process Elements 

INL-CCP RH Waste Characterization Process – 

T1 Changes 

INL-CCP RH Waste Ch

T2 Ch

detector observed in July 2010 Any new waste stream not approved under the baseline and/or subsequent T1 evaluations or addition of containers to an approved waste stream that requires changing theestablished radionuclide scaling factors

Visual Examination of audio/video media (VE) 

Use of VE to characterize additional debris waste streams or waste from other Summary Waste Categories 

Notification to EPA upon comple

procedure(s) that require CBFO a

Submission of VE BDRs for contlist of fully characterized contain

Real-Time Radiography (RTR) Any new S5000 waste stream other than ID-ANLE-S5000 or 

wastes from an S3000 or S4000 waste stream 

Notification to EPA prior to addition of a new RTR unit(s) 

Notification to EPA upon comple

procedure(s) that require CBFO a

Submission of RTR BDRs for co

list of fully characterized contain

WIPP Waste Data System, WDS (previously known as WWIS) 

None Changes made to WDS procedure

Notes: 

* INL-CCP will report all T2 changes to EPA every three months. 

** Excluding changes that are editorial in nature or are required to address administrative concerns. New references that are included as part 

requested by EPA. 

*** Substantive modification refers to a change with the potential to affect INL-CCP’s RH waste characterization process, e.g., the use of an i

measurement instrument or the use of the high-range probe as described in CCP-TP-504. 

† INL-CCP will report this T2 change immediately. 
5 

2.0 PURPOSE OF A TIER 1 EVALUATION 

Certain changes to the waste characterization activities from the date of the site’s baseline 

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

requirements set forth in 40 CFR 194.8 regulations and incorporated in the INL-CCP RH 

Baseline Final Report cited in Attachment A. 

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 (Vol. 69, No. 136, pages 42571–42583, July 16, 2004). The purpose of 

EPA’s 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. 

Following EPA’s baseline approval, EPA is authorized to evaluate and approve changes, if 

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

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

approval prior to implementation (T1), and those requiring post-implementation [Tier 2 (T2)] 

notification, are identified in the site-specific baseline inspection reports. When evaluating 

proposed T1 changes for approval, EPA may conduct a site inspection to observe first-hand the 

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

specific to a change. DOE may choose to characterize and dispose of, at risk of subsequent EPA 

disapproval, any previously approved TRU waste using processes/procedures/equipment 

implemented as T2 changes. EPA reviews T2 changes on a quarterly basis and EPA may conduct 

continued compliance inspections to evaluate implemented T2 changes to verify adequacy. 

3.0 PURPOSE OF THIS REPORT 

This report presents the results of EPA’s evaluation of a T1 change to approve the inclusion of 

Lot 4A canister liners in Waste Stream ID-HFEF-S5400-RH (see Section 5.0, below), as 

described in CCP-AK-INL-580, Revision 2 and freeze file3

 reference C439. This report presents 

the technical basis and results of EPA’s approval decision, conveyed to DOE separately by letter. 

As discussed previously, EPA will also announce the decision on its website at 

www.epa.gov/radiation/WIPP, in accordance with 40 CFR 194.8(b)(3). 

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

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

from the following address: 

 

3 Freeze File: As a result of EPA inspections or T1 evaluations, if INL-CCP must revise documents to 

address EPA issues, INL-CCP makes those changes and provides a copy to EPA as objective evidence for the 

changes made. These revisions are then processed by INL-CCP’s document control process to generate an official 

version as the most current revision. 
6 

Manager, National TRU Program 

Carlsbad Field Office 

U.S. Department of Energy 

P.O. Box 3090 

Carlsbad, NM 88221-3090 

4.0 SCOPE OF THIS TIER 1 EVALUATION 

The scope of this evaluation covers inclusion of three canister liners of Lot 4A heterogeneous 

debris waste as described in CCP-AK-INL-500, Revision 2 and freeze file reference C439 in 

Waste Stream ID-HFEF-S5400-RH. The waste from these liners was repackaged into six 55-

gallon drums as shown in Table 3 of the AK Section below. The evaluation was performed by 

comparing elements assessed in the previous EPA approvals with information about the new 

waste containers that was provided by INL-CCP/CBFO to ensure that they fit within the 

approvals issued by EPA previously. 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. 

The RH wastes that were the subject of this T1 evaluation are retrievably-stored debris that 

INL-CCP plans to characterize for disposal at WIPP. During this evaluation, EPA examined the 

updated AK information to verify that the additional waste containers have the same pedigree as 

that of the approved ID-HFEF-S5400-RH debris waste stream and are characterized using 

appropriate radiological characterization and RTR processes. 

Personnel who participated in the T1 evaluation are listed in Table 2, along with each person’s 

affiliation and function during the evaluation. 

Table 2. T1 Evaluation Participants 

Name Affiliation & Function 

Rajani Joglekar EPA Headquarters – Lead Inspector 

Ed Feltcorn EPA Headquarters – Inspector 

Connie Walker SC&A, Technical Evaluator – Acceptable Knowledge 

Patrick Kelly SC&A, Technical Evaluator – Radiological Characterization 

Amir Mobasheran SC&A, Technical Evaluator – Radiological Characterization 

Harry Chmelynski SC&A, Statistician 

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

Scott Smith Technical Specialists – Acceptable Knowledge Expert 

Jesse Klingensmith INL-CCP – Radiological Characterization Expert 

Irene Quintana URS – Site Project Manager 

5.0 TECHNICAL EVALUATION: WASTE STREAM ID-HFEF-S5400-RH, LOT 4A 

Waste Overview

AK Summary Report (AKSR) CCP-AK-INL-580, Revision 2 and CCP-AK-INL-581, Revision 2 

describe Waste Stream ID-HFEF-S5400-RH. This waste stream consists of 85 cans of RH TRU 
7 

heterogeneous debris waste generated during hot cell and laboratory activities at the Hot Fuel 

Examination Facility (HFEF). The waste was generated from operations in two hot cells: 

Building 785, HFEF (formerly HFEF-North) and fuel fabrication and reprocessing at Building 

765, Fuel Conditioning Facility [(FCF), formerly HFEF-South]. Waste was also generated from 

analytical chemistry operations in Building 752, the Laboratory and Office (L&O) Building 

Analytical Laboratory. Pertinent aspects of these processes are described below. These wastes 

are identified as Lot 1A, Lot 1B, and Lot 4A. EPA previously approved Lot 1A and Lot 1B in 

separate T1 evaluations (see Docket Nos. A-98-49; II-A4-122 and A-98-49; II-A4-131). Lot 4A 

contains three additional canister liners that were generated in HFEF Building 785 (Nos. SN170, 

SN177 and SN178) and is the subject of this T1 evaluation. 

EPA evaluated the AK, radiological characterization, and RTR processes and associated 

information to determine whether INL-CCP demonstrated compliance with 40 CFR 194.8 to add 

Lot 4A containers. EPA concludes that INL-CCP continues to appropriately apply the system of 

controls approved by EPA during the Baseline Inspection. 

Documents, Waste Containers and Batch Data Reports Reviewed

EPA examined attachments, source documents, forms, and other data as part of this T1 

evaluation. The listing of all documentation examined is in Attachment B, and the list of Batch 

Data Reports (BDRs) examined is presented in Table 3. 

Table 3. Batch Data Reports Evaluated 

Canister Liner Drum Number RTR BDR Number DTC BDR Number 

SN170 MFC060105B INLRHRTR10019 INLRHDTC10022 

SN170 MFC060105A INLRHRTR10019 INLRHDTC10022 

SN177 MFC070118B INLRHRTR10019 INLRHDTC10022 

SN177 MFC070119A INLRHRTR10019 INLRHDTC10022 

SN178 MFC070119B INLRHRTR10019 INLRHDTC10022 

SN178 MFC070118A INLRHRTR10019 INLRHDTC10022 

5.1 Acceptable Knowledge 

EPA examined the AK process and associated information to approve the T1 request that added 

Lot 4A to RH Waste Stream ID-HFEF-S5400-RH. 

Waste Characterization Element Description

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

characterization as impacted by the proposed addition of new containers: 

• Waste stream identification and definition 

• Radionuclide content of additional waste 

• Physical composition of additional waste 

• Identification of high-level waste and spent nuclear fuel 

• Defense origin of additional waste 
8 

• AK data traceability 

• Waste Stream Profile Form (WSPF) and Characterization Reconciliation Report (CRR) 

• AK source document sufficiency 

• Modifications to the Certification Plan/Confirmatory Test Plan 

• Non-Conformance Reports (NCRs) and AK Discrepancy Resolution (DR) forms 

• AK accuracy 

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

correlation 

• Load management 

• Identification and attainment of Data Quality Objectives (DQOs)

Technical Evaluation

To assess the appropriateness of inclusion of Lot 4A in Waste Stream ID-HFEF-S5400-RH, EPA 

evaluated information related to the waste’s process origin, radiological and physical 

characteristics. EPA’s evaluation included 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 ID-HFEF-S5400-RH. Results of the analysis are presented below. When 

information presented in the text is supported directly by an AK reference, the reference is cited 

in parentheses. 

(1) The definition of Waste Stream ID-HFEF-S5400-RH was examined with respect to the 

addition of Lot 4A and found to be adequate. 

Waste Stream ID-HFEF-S5400-RH consists of heterogeneous debris generated by activities 

within the HFEF and FCF, and supported by the L&O Building Analytical Laboratory. Lot 4A 

waste consists of heterogeneous debris stored in three canister liners (SN170, SN177 and SN178) 

generated in HFEF Building 785. The wastes were generated during implementation of various 

reactor programs, including management of depleted uranium oxide fuel (DUO2), Belgium 

Reactor 3 (BR-3) fuel elements, and ZeoGlass salts from electrorefining of spent Experimental 

Breeder Reactor (EBR)-II core driver fuels. Lot 4A also includes: waste from management of a 

material surveillance (SURV)-10 subassembly, which has 19 capsules containing over 100 

individual samples that were to be examined to determine the compatibility of various materials 

with the EBR-II environment; waste from Reduced Enrichment for Research and Test Reactor 

(RERTR) fuel elements; and M5 Program commercial fuel elements that consisted of four 

commercial fuel elements from North Anna Power Station experiments conducted by Electric 

Power Research Institute and Framatome. Approximately 50% by mass of Lot 4A is 

"unattributed," i.e., waste that cannot be associated with a specific reactor program based on AK. 

INL-CCP assigned over 93% of the total accountable fissile (AF) activity to unattributed waste. 

Prior to inclusion of Lot 4A, Waste Stream ID-HFEF-S5400-RH was defined as having been 

generated from July 1997–September 2007. Lot 4A was generated between March 2005 and 

November 2007, which overlaps sufficiently with the original time frame (Reference C4100). 

The AKSR was modified by adjusting the final waste generation date from September 2007 to 

November 2007, to account for the full Lot 4A generation period. 
9 

The AKSR was updated through a freeze file modification to include a summary of programs 

associated with Lot 4A waste generation (Reference C439). Unattributed waste constitutes nearly 

50% of Lot 4A by weight, and INL-CCP assumed that the radiological composition of this waste 

is similar to that of Waste Stream ID-HFEF-S5400-RH based upon waste generation location 

and other factors. EPA accepts this assumption. EPA examined the process origin, traceability, 

physical composition and radiological composition of Lot 4A and found it was bounded by the 

previously approved Waste Stream ID-HFEF-S5400-RH description (References C4092, C4100, 

C4125, C4126, P029, P083, P092, P105, P254, P261, P262, P266, P876, P877, P 4053, P4115, 

P4116, P4117, U483, U484, U541, U552, U729, U4014 and U4020). This conclusion is based on 

the waste generation locations, dates, and processes and radiological and physical composition, 

as described above. Based on this information, the waste stream is adequately defined. Specific 

aspects of this analysis are detailed in Items (2), (3), (4), (5) and (7). 

 

(2) The radiological characteristics of Lot 4A were assessed with respect to their similarity to 

Waste Stream ID-HFEF-S5400-RH and found to be adequate. 

The majority of Waste Stream ID-HFEF-S5400-RH was generated from processing fuel 

assemblies and experiments associated with EBR-II irradiated fuels, most commonly binary and 

ternary fuels4

 (References C028, C033, C072, C127, C465, C503, C4092, C4100, P085, P263, 

U196, U483, U484, U541, U551 and U552). U-fissium5 fuels were the second most common 

EBR-II irradiated fuels examined in the HFEF or FCF, and these included several depleted 

uranium (DU)-bearing materials and items (References C465, C503, C4092, P263, U483, U484, 

U541, U551 and U552). Approximately 10% of Waste Stream ID-HFEF-S5400-RH consists of 

waste materials generated by examination of fuels from other reactors. Based on generator data, 

the two most predominant radionuclides for the waste stream are 235U and 238U, while over 95% 

of the total activity in the waste stream is from fission products (References C463, C522, C4092, 

C4095, C4100, P067, P083, P092, U483, U484, U541, U551, U552 and U607). 

As described in Item (1) above, 93% of the AF activity in Lot 4A is from unattributed waste, and 

is described by the general ID-HFEF-S5400-RH composition presented in the previous 

paragraph. The remaining Lot 4A AF activity is derived from three specific waste generation 

programs that contained fuel specimens, as follows: 

• 6.27% - electrorefining process of spent EBR-II core driver fuels (ZeoGlass salts) 

• 0.22% - light water reactor fuel specimens associated with the irradiation in the BR-3 

• 0.19% - DU or DUO2 outer blanket fuel specimens 

INL-CCP also determined that waste not associated with these programs, including unattributed 

waste, has the same radiological composition as Lot 1 waste, i.e., it is primarily EBR-II-related 

waste (see Table 5 in the AKSR). Table A1-2 in CCP-AK-INL-581, Revision 2 presents general 

AF mass and activity percentages for the different waste generation programs and verifies the 

 

4

 Approximate percent compositions for binary and ternary fuels are 90% uranium (U) and 10% zirconium 

(Zr) and 67% U, 25% plutonium (Pu), and 10% Zr, respectively. 

5 Fissium is an equilibrium mixture of fission products in reactor fuel that improves the stability of uranium 

and uranium-plutonium fuel alloys under fast neutron irradiation. 
10 

fraction of reported activity for each of these components in Waste Stream ID-HFEF-S5400-RH. 

INL-CCP examined the general radiological composition of each liner based on waste container 

and disposal logs, the SeaLion database, and Integrated Waste Tracking System (IWTS) 

container profiles and concluded that the radiological properties of Lot 4A were consistent with 

Waste Stream ID-HFEF-S5400-RH (Reference C4100). The approximate waste contents of the 

three liners were as described in Table 4. 

Table 4. Approximate Canister Liner Waste Contents 

Canister Liner Portion of Contents That 

are Unattributed Waste 

Portion of Total AF Activity 

in Liner 

SN170 76% 6.68% 

SN177 22% 58.31% 

SN178 10% 35.01% 

 

As described in Sections (1) and (6), the AKSR required minor modifications and INL-CCP 

provided a freeze file change clarifying the radiological composition of Lot 4A waste (Reference 

C439). Based on these data, the radiological composition of Lot 4A fits within the general 

radiological composition of Waste Stream ID-HFEF-S5400-RH based on Lot 1. 

(3) Physical characteristics of Lot 4A were assessed with respect to the physical 

characteristics of Waste Stream ID-HFEF-S5400-RH and found to be adequate. 

Lot 4A is composed of canister liners SN170, SN177 and SN178, each of which was divided 

upon repackaging into two drums, as described in Item (7) below. The drums are listed in Table 

3 and all underwent RTR, which provided detailed information for each liner as described below. 

Canister liner SN170 is predominantly unattributed waste and includes materials described in 

Items (1) and (2) above. RTR results indicated that the drums contain scrap metal, paint cans and 

lids, various metal cans, absorbent, sanding discs, plastic or poly bags and scrap plastic, glass 

beakers, and paint brushes. 

Canister liner SN177 contains wastes associated only with the RERTR and M5 programs, as 

described in Items (1) and (2) above, including grinding plates/papers and polishing cloths. AK 

records indicate that the waste is associated with the examination and disposal of fuel specimens, 

but AK documents indicated that no specific fuel specimens were in the waste. The SN177 

Waste Can Loading Log indicates that the majority of the AF activity is unattributed waste with 

a very small contribution from the RERTR program. RTR results indicate that the drums contain 

scrap metal, wire, light bulbs, sanding discs, plastic bags and scrap plastics, plastic bottles with 

solidified material, and glass waste. 

The majority of waste indicated in the SN178 Waste Can Loading Log is associated with 

subassembly hardware as described in Items (1) and (2) above. AK documentation indicated that 

the waste included hex can pieces, shanks and pole pieces from various EBR-II subassemblies. 

RTR results indicated the presence of glass labware, plastic bags and bottles, absorbent, scrap 

metal and metal pipes. 
11 

The AKSR states that Waste Stream ID-HFEF-S5400-RH is composed of approximately 30% 

organic waste materials and 70% inorganic waste materials, with significant variation between 

individual drums. INL-CCP calculated the waste material parameters (WMPs) for each liner 

based on waste item weights and estimates in the IWTS container profiles, and showed that the 

WMP estimates for each liner were bounded by the waste stream weight percentages (Reference 

C4100). The WMPs in the six drums fall within the general physical composition of Waste 

Stream ID-HFEF-S5400-RH. Based on this information, the physical composition of Lot 4A is 

adequately defined and is consistent with Waste Stream ID-HFEF-S5400-RH. 

(4) The identification of Lot 4A waste as transuranic and not high-level waste or spent 

nuclear fuel was examined and found to be adequate.

INL-CCP provided a freeze file modification to the AKSR (Reference C439), clarifying that Lot 

4A does not contain spent nuclear fuel or high-level waste because the items are test specimens 

associated with research and development. Analysis of these specimens did not include the 

reprocessing of constituent elements from reactor fuel. INL-CCP concluded that Waste Stream 

ID-HFEF-S5400-RH does not contain spent nuclear fuel or high-level waste prior to the addition 

of Lot 4A, so inclusion of Lot 4A does not alter this original determination. EPA agrees with this 

conclusion. 

(5) The identification of Lot 4A as defense waste was examined and found to be adequate. 

The WIPP requires generator sites to use AK to determine that a TRU waste stream meets the 

definition of TRU defense waste. TRU waste is eligible for disposal at the WIPP if it has been 

generated in whole or in part by one of the atomic energy defense activities listed in 

Section 10101(3) of the Nuclear Waste Policy Act. Waste in canister liners that originated from 

non-defense sources, such as BR-3 and M5 fuels, are not defense related. However, each of the 

waste liners also contains waste associated with defense-related activities, particularly since the 

unaccounted waste was attributed to EBR-II-based programs. The AKSR concludes that as a 

result of the inherent commingling of materials originating from the numerous defense activities, 

segregation of non-defense waste streams is not possible. Therefore, Waste Stream ID-HFEFS5400-RH is eligible for disposal at the WIPP as a waste stream generated “in part” by atomic 

energy defense activities, and the inclusion of Lot 4A does not alter this determination 

(Reference P001). EPA accepts these arguments. 

(6) Sufficiency of the Acceptable Knowledge Summary Report and implementation of the 

acceptable knowledge process were evaluated and found to be adequate. 

The AKSR was modified through a freeze file (Reference C439) to add information about Lot 

4A, including a description of the lot, process origin information, radiological composition of the 

lot, high-level waste/spent nuclear fuel content and defense origin. The AKSR is adequate as 

modified by freeze file changes. 
12 

(7) Data traceability of Lot 4A was examined and found to be adequate. 

Lot 4A waste was originally placed in canister liners SN170, SN177 and SN178. Each canister 

liner, or liner, was repackaged into two 30-gallon drums, each of which was over-packed into a 

55-gallon drum, resulting in a total Lot 4A population of six 55-gallon drums (Reference 

C4100). References U552 and P180 present traceability information about the liners, and include 

the following forms, lists, and database printouts:

• Radioactive Scrap Waste Storage/Disposal Request and Authorization 

• RH TRU Fissionable Material Content Summary, by SN number 

• RH TRU Waste Can Loading Log, by SN number 

• INL radiological database System Query, Waste Container Log 

• Hot Fuel Examination Facility, Zone Inventory Report Zone 2M 

• List of Accountable Materials Thrown Away in S/N Can IWC-170 

• Loaded SN Type Inner Waste Can “Rad.” Reading Diagram 

• SeaLion Database Searchable Liner Online, F-7 and F-25 

• Integrated Waste Tracking System Waste Profile Form

• Integrated Waste Tracking System Radiological Reports 

• Radioactive Scrap and Waste Facility (RSWF) Transfer Evaluation Sheet 

• RSWF Material Acceptance Checklist 

• Material Acceptance for Storage documentation 

• External Material Shipment and Receipts Form 

• Accountable Nuclear Material Disposition Form 

• Calculated Material and Fissile Content Work Sheets

• Evaluation of Radiological Contents by TRU Waste Cans 

• Weld Data Sheets 

• Analytical Laboratory Reports, various 

Reference U992 contains the RH Container Repackaging datasheets for each of the three liners. 

INL-CCP also used the above information to link liner contents with various programs, and this 

information was subsequently used to evaluate the physical and radiological contents of each 

liner (Reference C4100). Canister liner SN170 was generated at workstation 2M, and includes 

ceramics, ZeoGlass salts, debris from sampling of DU subassemblies, subassembly SURV-10 

and BR-3 fuel specimens. The majority of waste in liner SN170 was not associated with specific 

subassemblies or fuel elements and was packaged in 2007, and sent directly to the Idaho Nuclear 

Technology and Engineering Center (INTEC) for repackaging. Canister liner SN177 was also 

generated at workstation 2M and consisted of debris from the examination and disposal of 

unspecified fuel and subassemblies of RERTR and M5 fuel. Canister liner SN178 was generated 

at various HFEF work stations (i.e., 1M, 4M, 10M, 11M and 15M) and the Main Cell and 

contained hardware from numerous subassemblies and specimen material, including a General 

Electric control blade velocity limiter, Neutron Radiography facility hardware, and Decladding 

by Oxidation waste. Liners SN177 and SN178 were first sent to the RSWF and were later 

shipped to INTEC, where they were repackaged into drums as described above. Evaluation of the 

data presented confirms the general radiological content and waste forms associated with each 
13 

liner, as well as waste generation, disposition and repackaging. Traceability of supporting AK 

data is adequately supported. 

(8) Modifications of the Waste Stream Profile Form and related Characterization 

Reconciliation Report were examined and found to be adequate. 

A draft CRR was provided that identified the six 55-gallon drums in Lot 4A. The CRR showed 

that the WCPIP requirement to prepare a CRR was adequately demonstrated for these six drums. 

The WSPF dated February 12, 2010, was provided, but the form was not yet updated through a 

Change Request to include Lot 4A. Notification of availability of an updated WSPF remains a 

T2 change. 

(9) Sufficiency of acceptable knowledge support documents and related document tracking 

with respect to the addition of Lot 4A references was evaluated and found to be adequate. 

Attachment 4, the CCP-AK-INL-580, Revision 2 reference list, the CCP-AK-INL-581, Revision 

2 reference list, and the list of new references provided as part of the T1 review indicate that 

many must be updated. For example, Attachment 4, dated November 10, 2010, does not include 

references presented in CCP-AK-INL-581, which was approved November 16, 2010. Also, new 

references have been either generated (Reference C439) or obtained (Reference C4100) as part 

of the T1 Lot 4A evaluation, and these must be added to the AKSR reference list and Attachment 

4. EPA expects the AKSR and Attachment 4 to be updated to include all relevant references, 

including those cited in CCP-AK-INL-581. The AKSR reference list will be updated in 

conjunction with text modifications [see Item (6) above]. Notification of availability of updates 

to the AKSR and Attachment 4 remain T2 changes. 

(10) Interpretation of the Waste Characterization Program Implementation Plan, with respect 

to contents of the Certification Plan and the Confirmatory Test Plan, was evaluated and 

found to be adequate. 

 

CCP-AK-INL-582, Central Characterization Project RH TRU Waste Certification Plan for 40 

CFR Part 194 Compliance and Confirmation Test Plan for INL RH Waste Stream: ID-HFEFS5400-RH, Revision 2, November 24, 2010 was adequately revised to include Lot 4A. The 

Certification Plan includes the general characterization approach for the Lot 4A containers in 

Waste Stream ID-HFEF-S5400-RH, which was to develop a single set of composite scaling 

factors for Lot 4A based on the assumption that the unattributed waste has the same isotopic 

composition as Lots 1A and 1B. The contributions were weighted in the composite set of scaling 

factors based upon the percentage of total AF material. RERTR, M5 program and SURV-10 

program wastes are present in Lot 4A, but no fuel elements were identified so no AF material 

could be assigned to the waste. The Certification Plan concludes that Lot 4A is part of the waste 

stream because of overlapping waste generation dates and the presence of several common fuel 

types (e.g. BR-3 fuels and significant quantities of subassembly hardware). 
14 

(11) Personnel training records were evaluated and found to be adequate. 

Personnel training records for Irene Quintana and Scott Smith were verified during the T1 

review. EPA examined the RH AK qualification cards for Mr. Smith, the RH Site Project 

Manager (SPM) Qualification Card for Ms. Quintana, and the INL-specific AK Qualification 

Card for Mr. Smith. EPA concludes that INL-CCP personnel continue to be adequately trained. 

(12) Non-conformance reports and discrepancy resolution forms were examined and found to 

be adequate. 

An NCR was not prepared for drums in Lot 4A. INL-CCP representatives indicated that 

Discrepancy Resolution (DR) forms were also not prepared for Lot 4A. EPA recently reviewed 

Non-conformance Report (NCR) and DR preparation as part of a continued compliance 

inspection (Inspection No. EPA-INL-CCP-09.08-24, see EPA Docket No. A-98-49, II-A4-142) 

and found both to be adequate. EPA concludes that the NCR and DR processes continue to be 

adequately implemented as part of the Lot 4A characterization process. 

(13) Acceptable knowledge accuracy was assessed and found to be adequate. 

INL-CCP provided a draft AK accuracy report dated February 16, 2011, for Waste Stream IDHFEF-S5400-RH, Lots 1-186

, as well as a final AK accuracy report dated February 23, 2011. 

The final report concluded that to date, no significant radiological information discrepancies 

have been noted with the containers in this waste stream. None of the accepted containers were 

reassigned to a different Summary Category Group, but two AK accuracy discrepancies were 

identified wherein two containers were found to have TRU alpha activity concentrations less 

than 100 nanocuries per gram (nCi/g). The waste stream accuracy was 98.3%. Lots 1-18 consist 

of 146 containers, but do not include Lot 4A because these drums were not yet certified by INLCCP for shipment when the AK accuracy report was prepared. The AK accuracy report is 

adequate. 

(14) Use of a Correlation and Surrogate Summary Form was evaluated and found to be not 

applicable. 

Completion of a (Correlation and Surrogate Summary Form) CSSF is required when AK 

information from a related CH waste stream is used in the RH waste characterization process. 

CH data were not used in this manner for Waste Stream ID-HFEF-S5400-RH, so a CSSF was 

not required or prepared for this waste stream. 

(15) Load management was evaluated and found to be not applicable. 

Load management is not intended for Waste Stream ID-HFEF-S54500-RH and this will not 

change with inclusion of Lot 4A. Implementation of load management remains a T1 change. 

 

6

 AK Accuracy reports are prepared by characterization lots assigned by INL-CCP, which are unrelated to

the drum Lots 1A, 1B and 4A assigned by INL. 
15 

(16) Attainment of data quality objectives through acceptable knowledge qualification was 

evaluated and found to be adequate. 

As a result of the analyses presented in Items (1) - (15) above, EPA assessed how each of the 

following DQOs was addressed: 

• Defense determination 

• TRU waste determination 

• RH waste determination 

• Activity determination (total and per canister, including quantification and identification 

of the 10 EPA WIPP-tracked radionuclides) 

• Residual liquids 

• Physical form, including metals, cellulose, plastic and rubber 

When evaluated as a whole, CCP-AK-INL-580, Revision 2, CCP-AK-INL-581, Revision 2, 

CCP-AK-INL-582, Revision 2, Reference C439, and the supporting source documents presented 

in Attachment B of this report indicate that the DQOs, as specified in the Waste Characterization 

Program Implementation Plan, have been met. 

Summary of Acceptable Knowledge

Findings or Concerns 

The EPA evaluation team did not identify any findings or concerns relative to the addition of Lot 

4A to Waste Stream ID-HFEF-S5400-RH during this T1 change evaluation. 

Tiering Changes 

Based on the results of this T1 evaluation, there are no changes to the AK T1 and T2 

designations identified during the Baseline Inspection and subsequent T1 evaluations. Table 1 

shows the current INL-CCP RH tiering table. 

Conclusions 

Based on the results of this evaluation, EPA is approving the T1 request for addition of Lot 4A to 

Waste Stream ID-HFEF-S5400-RH. 

5.2 Radiological Characterization 

EPA evaluated the radiological characterization process to determine whether INL-CCP 

demonstrated compliance with 40 CFR 194.8 for a proposed T1 change to add Lot 4A to Waste 

Stream ID-HFEF-S5400-RH. As stated above, Lot 4A consists of a total of six 55-gallon drums 

that are part of Waste Stream ID-HFEF-S5400-RH and these six drums are the subject of this T1 

evaluation. 
16 

Radiological Characterization Overview

The overall approach to characterizing the Lot 4A drums is Dose-to-Curie (DTC) in conjunction 

with radionuclide-specific scaling factors, a technique that EPA has observed and approved at 

several RH sites. The scaling factor for a radionuclide is defined as the ratio of the activity of 

that radionuclide to the activity of another radionuclide, usually cesium-137 (137Cs). A single 

composite set of 137Cs-based scaling factors for all six drums of Lot 4A waste was derived based 

on the weighted arithmetic mean of four sets of 137Cs-based scaling factors from the contribution 

of DUO2 fuel specimens, BR-3 fuel specimens, ZeoGlass salts from the electrorefining process 

of EBR-II core drivers and HFEF Lot 1 debris. The fractional contribution of each source to the 

total AF activities was used as its statistical weight. 

The four sets of scaling factors were determined based on ORIGEN2.2 computer runs. 

Information on pre-irradiation fuel composition, burnup and decay period (from the removal date 

from the reactor to the assumed shipping date of March 1, 2011) was incorporated in the 

ORIGIN2.2 inputs. The resultant radionuclide activities were used to determine four individual 

sets of scaling factors, one for each of the four waste sources comprising Lot 4A: 

1. For the unattributed debris waste, or hot cell contamination, no specific fuel elements 

were identified in the Lot 4A Waste Can Loading Logs. Debris waste from the RERTR, 

M5 program and four specific subassemblies were referenced, and therefore used as input 

to the ORIGEN2.2 computer runs. The resultant activities were added to the results for 

the 129 fuel pins involved in Lot 1 analysis to develop scaling factors. The Lot 1A 

scaling factors were used because of the similarities between the Lot 1A and Lot 4A 

wastes and the overlap of their generation periods. The adjustment factors, as discussed 

for Lot 1A, were applied to the fast reactor pins and subassemblies and are based on 

benchmark analysis of 400 fast reactor pins and account for neutron spectrum 

differences. 

2. For the irradiated BR-3 fuel, scaling factors were developed based on activities at 

nominal burnup for a single ORIGEN2.2 case. 

 

3. For ZeoGlass salts, running several hundred ORIGEN2.2 cases provided radionuclide 

activities for 97 subassemblies (61 U fuel pins per assembly), 133 U fuel pins and 350 UPu fuel pins. The U fuel pins and the U-Pu fuel pins comprised approximately 94% and 

6%, respectively, and two sets of scaling factors were developed, one for U fuel pins and 

one for U-Pu fuel pins. A weighted combination of the two sets of scaling factors (equal 

weights for all fuel pins) led to a single set of scaling factors for the ZeoGlass salts. 

4. For the irradiated DUO2, the scaling factors were determined from running 25 

ORIGEN2.2 cases for 25 DU outer blanket EBR-II subassemblies and their range of 

typical burnups. 

The statistically weighted sum of the four sets of scaling factors discussed above led to the 

development of a single set of 137Cs-based scaling factors for the Lot 4A waste. The percentages 

of AF activities used as the statistical weights were 0.22% (BR-3), 6.27% (ZeoGlass), 0.19% 
17 

(DUO2 fuel), and 93.32% (other). Details of the scaling factor calculations are provided in CCPAK-INL-581, Revision 2, Appendix A and supporting calculation packages. An overview of the 

radiological characterization process used for the Lot 4A waste is provided in Figure 1 below. 

The DTC measurement aspect of the radiological characterization process for Lot 4A was not 

directly assessed during this T1 evaluation. This aspect was originally evaluated during the INLCCP baseline inspection and again more recently during the T1 evaluation of the OSPREY 

gamma system at INTEC (see EPA Docket Nos. A-98-49; II-A4-72 and A-98-49; II-A4-131, 

respectively). There have been no significant changes to the DTC process at INTEC. EPA did 

evaluate the technical adequacy of the radiological characterization process used for Lot 4A of 

Waste Stream ID-HFEF-S5400-RH, as supported by the INL-CCP documents, procedures, and 

controls and involved personnel knowledge and understanding. 

Figure 1. Flow Diagram of the Characterization Process: ID-HFEF-S5400-RH, Lot 4A 

Determine Scaling Factors: Determine DTC Conversion Factor:

Use MCNP5 to model the gamma dose rate as a function of waste 

density to develop a 137Cs and a 60Co DTC correlation based on a 

1-Ci source of 137Cs and a 1-Ci source of 60Co 

Develop DTC correlation factors (mR/hr/Ci)-density relationships 

for both 137Cs and 60Co 

Locate and retrieve relevant records

Develop four sets of 137Cs-based 

scaling factors for each of the four 

components using ORIGEN2.2 

Execute DTC to Determine Drum’s 137Cs Activity: 

Find mean gamma dose rate at 1 m from the drum surface based 

on four measurements; determine the waste density based on the 

actual weight of drum contents and fill factor 

Using the correlation factors and the activity ratio of 60Co to 137Cs 

determine the “combined” DTC conversion factor 

Divide the mean measured dose rate by the “combined” DTC 

conversion factor to find the 137Cs activity in Ci* 

Multiply the 137Cs activity by the scaling factors to determine the

activities of the radionuclides of interest 

Find the weighted sum of the four 

sets of scaling factors to develop a 

single set for Lot 4A waste 

* If the fractional dose rates are provided by the Canberra OspreyTM system, the 137Cs activity can simply be 

found by dividing the share of 137Cs from the total dose rate by the 137Cs DTC correlation factor.
18 

Technical Evaluation

(1) Correlation of the waste records for the six 55-gallon drums of ID-HFEF-S5400-RH, Lot 

4A with the 137Cs concentration was found to be adequate. 

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

the radiological data for the four sources contributing to the Lot 4A waste. Specifically, this 

included information from the Waste Can Loading Logs, as documented in the technical report 

CCP-AK-INL-581, Revision 2, Appendix A and its supporting calculation packages. The curie 

(Ci) estimates of the radionuclide contents of all fuel subassemblies/fuel pins contributing to Lot 

4A had been determined via reactor physics calculations performed using ORIGEN2.2. These Ci 

quantities were used to find the single set of 137Cs-based scaling factors for Lot 4A waste as a 

statistical composite of four sets of 137Cs-based scaling factors, corresponding to four “types” of 

waste associated with the four sources. 

The composite set of scaling factors, the relationship between a waste drum’s easily measurable 

137Cs gamma dose and cobalt-60 (60Co) gamma dose, and the waste density were used to 

determine the Ci amounts of all reportable radionuclides. These activities are documented in 

INL-RH-32, INL-RH-33, INL-RH-36 and INL-RH-65 (References U4015, U4016, U4019 and 

U652, respectively) and incorporate the following information: 

• Activity estimates of a relatively large number of radionuclides, including the actinides 

and fission products, contained in the sources for the waste as calculated using 

ORIGEN2.2 

• Derivation of four sets of scaling factors for the four types of waste comprising Lot 4A 

waste, using the above-mentioned radionuclide activity estimates 

• Use of Lot 1A scaling factors as the basis, and incorporation of adjustment factors, for 

determination of scaling factors for hot cell contamination 

• Additional calculations to confirm modeling approach selected 

Calculation of the 137Cs activity of a container allows for calculation of the following quantities 

for each RH container measured: 

• Activity in Ci and mass in grams (g) for each of the 10 WIPP-tracked radionuclides, i.e., 

137Cs, americium-241 (241Am), 238Pu, 239Pu, 240Pu, 242Pu, strontium-90 (90Sr), 233U, 234U 

and 238U 

• Associated uncertainty for all radionuclide values listed in previous bullet 

• Fissile Gram Equivalent 

• Pu Equivalent Ci 

• Decay heat in Watts 
19 

INL-CCP used the constants and other values required for these calculations from the 

appropriate sources (e.g., TRAMPAC) and EPA verified by spot-checking the calculations for 

accuracy. 

Similar to Lot 1 analysis, shielding calculations were performed using MCNP® with the 1-Ci 

source of 137Cs and 1-Ci source of 60Co uniformly distributed throughout a 55-gallon waste drum 

for a range of waste densities from 0.1 g per cubic centimeter (g/cm3) to 2.0 g/cm3. The results of 

these were used to derive a DTC correlation as a function of density for 137Cs and 60Co, as shown 

in CCP-AK-INL-581, Revision 2, Figures 6-1 and 6-2. The actual DTC calculations are 

performed using an Excel spreadsheet [see Item (3) below] where the inputs include: 

• Drum identification number 

• Drum gross weight 

• Fill height in percent 

• Fill height material type (concrete, organic or steel) 

• Four measurements of each drum’s external gamma dose from 137Cs and 60Co 

There were no concerns regarding the correlation of waste records with 137Cs concentrations for 

the six Lot 4A 55-gallon drums. 

(2) The development of radionuclide scaling factors was evaluated and was found to be 

technically adequate and appropriately documented. 

EPA evaluated the following aspects: 

• Activity values derived from modeling and statistical metrics using the mean and 

standard deviation values for each radionuclide 

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

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

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

attribute 

• Isotopic activity values correlated to the radionuclides whose physical half-lives are such 

that they could be responsible for the measured external dose rate, i.e., 137Cs for these IDHFEF-S5400-RH wastes 

• Adjustment of the source distribution inside the drums for 137Cs and 60Co using earlier 

MCNP5 calculations, calculated as a function of bulk waste density 

• Potential contributions of the short-lived radionuclides to the total measured dose rate 

• Appropriate decay correction according to INL-CCP procedure (CCP-TP-504, 

Revision 8) of all radionuclide values for purposes of model development 

Note: Decay corrections should be made to the actual shipping date. 

• The ORIGEN2.2 results are used to develop radionuclide-specific scaling factors that are 

used to determine activity levels of the radionuclides of interest in conjunction with the 

137Cs activity obtained from the measured external dose rates and the DTC relationship 
20 

• Activity and uncertainty values determined for the ten WIPP-Tracked radionuclides 

(

233U, 234U, 238U, 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 137Cs and 90Sr) 

• The determination of the contribution of all radionuclides to the radiological hazard7

• Shielding and other calculations supporting the scaling factors performed using MCNP5

to derive the appropriate DTC relationships as a function of waste density for the 

appropriate geometry following repackaging (30-gallon drum inside a 55-gallon drum) 

The radionuclide-specific scaling factors for these ID-HFEF-S5400-RH wastes that were 

developed, as shown in Table 5 below, are taken from INL-RH-33 (Reference U4016): 

Table 5. Radionuclide-Specific Scaling Factors 

Radionuclide DTC Scaling Factor 

137Cs 1.00E+00 

137mBa 9.46E-01 

90Sr 8.44E-01 

90Y 8.44E-01 

233U 6.09E-05 

234U 9.17E-05 

235U 8.35E-06 

236U 8.92E-06 

238U 1.33E-06 

238Pu 1.26E-02 

239Pu 2.56E-02 

240Pu 1.01E-02 

241Pu 2.06E-01 

242Pu 4.66E-06 

241Am 1.03E-02 

244Cm 4.53E-03 

In evaluating CCP-AK-INL-581, errors and a lack of clarity related to the formulas on pages 74 

and 75 were noted. Specifically, the formulas for the calculation of percent standard deviation of 

radionuclide X for the binary fuel and the ternary fuel were not correct. The standard deviation 

formula had incorrectly involved the activities of X and their mean obtained from the 

ORIGEN2.2 runs for the source components, instead of the scaling factors of X and their means

from the same sources. Also, the statistical weight of 1/61 had been used incorrectly in the 

second term of the numerator of the radicand in each of the two formulas. The unclear variables 

were those representing the activities of X and 137Cs, and their corresponding means. EPA 

communicated the errors and the lack of clarity to INL-CCP staff, Jesse Klingensmith, who had 

performed the calculations. As a result, INL-CCP corrected the formulas, redid the statistical 

calculations, and clarified the terms and summation notations. Regarding the impacts of the 

 

7

 Although the determination of a waste container’s radiological hazard is not an EPA requirement, this

information may be useful in understanding other aspects of a container’s radiological characterization. 
21 

corrections on the final results, INL-CCP staff stated that the impact on the error estimates for 

the final scaling factors is less than or equal to 0.1%. EPA expects the corrected formulas will be 

incorporated in a revision of CCP-AK-INL-581. There are no issues related to the technical 

adequacy or documentation of radionuclide scaling factors for ID-HFEF-S5400-RH, Lot 4A. 

(3) The technical basis of the Dose-to-Curie correlation and its documentation were 

evaluated and both aspects found acceptable. 

 

EPA evaluated the DTC correlation based on DTC BDR No. INLRHDTC10022 which contains 

all six Lot 4A drums to verify that the DTC BDR includes the following: 

• The correct version of the DTC Excel spreadsheet was used for the calculations (SCO 

1140 ID-HFEF-S5400-RH, Lot 4A) 

• The radionuclide scaling factors used were the same as documented in INL-RH-34 

(Reference U4017) 

• The current version of the DTC operating procedure was used (CCP-TP-504, Revision10) 

• All six drums were clearly TRU, i.e., had TRU alpha concentrations greater than 100 

nCi/g, with a range of approximately 1,140 to 694,000 nCi/g 

• All six containers were clearly RH waste, i.e., had contact dose rates in excess of 200 

millirem per hour (mrem/hr), with a range of 7 to 97 rem per hour (7,000 to 97,000 

mrem/hr) 

• All six containers identified the 10 WIPP-tracked radionuclides and quantified the 

uncertainty associated with each 

• All quality control parameters were performed and all were acceptable 

• The BDR had all required signatures, i.e., Independent Technical Reviewer (ITR) and 

SPM 

• The BDR contained a memorandum from Bryce Woodbury (DTC Expert Analyst) that 

provided revised ratios for Cs/Co as a result of identifying the need to apply a correction 

for 134Cs in drum Nos. MFC070118A and MFC070118B 

There were no issues related to the DTC correlation and its documentation for the Lot 4A wastes. 

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

evaluated and found to be adequate. 

CCP-AK-INL-581, Revision 2, Appendix A is the main document that describes the radiological 

characterization process that INL-CCP used for the Lot 4A RH TRU wastes. This document is 

supported by a series of 13 calculation packages, listed in CCP-AK-INL-581, Revision 2, Table 

A7-1 that were reviewed in the process of evaluating the Lot 4A wastes. These packages had 

been prepared and reviewed initially by Jene Vance, Jim Holderness, Dave Moody and Jessie 

Klingensmith to support several CCP RH TRU evaluations. There were no issues related to the 
22 

technical adequacy or documentation of the radiological characterization process for the Lot 4A 

wastes. 

(5) The technical basis and derivation of Total Measurement Uncertainty were evaluated and 

found to be adequate. 

 

The development of Total Measurement Uncertainty (TMU) for Waste Stream ID-HFEF-S5400-

RH waste is based on the propagation of uncertainties present in all aspects of the determination 

of the radiological constituents of RH TRU waste. These aspects are assumed to be independent, 

which allows them to be added in quadrature. The TMU determination included contributions of 

the following: 

• DTC correlation – including drum weight measurement, MCNP®

 code, and modeling 

uncertainties 

• Measurement uncertainty – including dose rate uncertainty from 137Cs and 60Co 

• Scaling factor uncertainty – including ORIGEN2.2 uncertainty

• Contributions of other gamma emitters 

• Drum-to-drum variation 

A general treatment of TMU for RH TRU Waste Stream ID-HFEF-S5400-RH, Lot 4A is 

presented in CCP-AK-INL-581, Appendix A and Calculation Package INL-RH-34, HFEF Lot 

4A Uncertainty Calculation (Reference U4017). The principal sources of uncertainty are 

uncertainties in 137Cs activity, ORIGEN2.2 benchmarking, and drum-to drum contribution. There 

were no concerns regarding the technical derivation and documentation of TMU for INL-CCP 

Waste Stream ID-HFEF-S5400-RH, Lot 4A. 

Summary of Radiological Characterization

Findings or Concerns 

The EPA inspection team did not identify any findings or concerns related to radiological 

characterization of the Lot 4A drums. 

 

Tiering Changes 

Based on the results of this T1 evaluation, there are no changes to the radiological 

characterization T1 and T2 designations identified during the INL-CCP RH Baseline Inspection 

and subsequent RH T1 evaluations. Table 1 shows the current INL-CCP tiering table. 

Conclusion 

EPA evaluated the radiological characterization process to determine whether INL-CCP 

demonstrated compliance with 40 CFR 194.8 to add six drums of Lot 4A to Waste Stream IDHFEF-S5400-RH. EPA concludes that INL-CCP continues to appropriately apply the system of 
23 

controls approved by EPA during the Baseline Inspection and EPA therefore approves the T1 

change to include Lot 4A in INL-CCP Waste Stream ID-HFEF-S5400-RH. EPA concludes that 

INL-CCP appropriately applied the EPA approved system of controls for radiological 

characterization when characterizing containers for Lot 4A waste and EPA therefore approves 

the addition of six containers in Lot 4A to INL-CCP Waste Stream ID-HFEF-S5400-RH which 

was approved for Lot 1A containers in February 2010 and Lot 1B containers in August 2010. 

5.3 Real-Time Radiography 

INL-CCP was approved to use RTR to characterize this waste stream previously and their 

approval was unaffected by this proposed T1 change. EPA did evaluate the one RTR BDR that 

contained the results of all six Lot 4A drums, as described below. 

Technical Evaluation

EPA reviewed RTR data that INL-CCP generated for six containers in Waste Stream ID-HFEFS5400-RH, Lot 4A, containers MFC060105A, MFC060105B, MFC070118A, MFC070118B, 

MFC0701119A and MFC070119B. The RTR results were reported in RTR BDR 

INLRHRTR10019 which INL-CCP generated using Procedure CCP-TP-508, CCP RH Standard 

Real-Time Radiography Inspection Procedure. EPA reviewed this procedure and determined it 

was adequate for providing clear instructions for RTR operations and records generation. INLCCP tracks operator/ITR (Independent Technical Reviewer) qualification by use of a List of 

Qualified Individuals. By reviewing these records, EPA determined that the RTR examinations 

in BDR INLRHRTR10019 were performed by qualified personnel. BDR INLRHRTR10019 

included successful RTR Measurement Control Reports for the 2 days when containers were 

examined. RTR operations require a second operator to perform quality control examinations in 

each batch, specifically an Independent Observation and Replicate Scan. The Independent 

Technical Review was performed by another CCP-qualified RTR operator, as required. The 

documentation for BDR INLRHRTR10019 demonstrates that RTR data were generated and 

reviewed in accordance with requirements. No NCRs were associated with this batch. 

Summary of Real-Time Radiography

Findings or Concerns 

The EPA inspection team did not identify any findings or concerns related to RTR for the Lot 4A 

drums. 

 

Tiering Changes 

Based on the results of this T1 evaluation, there are no changes to the RTR T1 and T2 

designations identified during the INL-CCP RH Baseline Inspection and subsequent RH T1 

evaluations. Table 1 shows the current INL-CCP tiering table. 
24 

Conclusion 

EPA evaluated RTR to determine whether INL-CCP demonstrated compliance with 40 CFR 

194.8 to add six drums of Lot 4A to Waste Stream ID-HFEF-S5400-RH. EPA concludes that 

INL-CCP continues to appropriately apply the system of controls approved by EPA during the 

Baseline Inspection and EPA therefore approves the T1 change to include Lot 4A in INL-CCP 

Waste Stream ID-HFEF-S5400-RH. 

6.0 SUMMARY OF RESULTS 

Findings and Concerns 

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

Lot 4A to Waste Stream ID-HFEF-S5400-RH during this T1 change evaluation. 

Tiering Changes 

There are no changes to the T1 and T2 designations identified during the INL-CCP RH Baseline 

Inspection and subsequent RH T1 evaluations. Table 1 shows the current INL-CCP tiering table. 

7.0 CONCLUSIONS 

During this T1 change evaluation, EPA examined the addition of Lot 4A to Waste Stream IDHFEF-S5400-RH. Based on the results of this evaluation, EPA is approving addition of Lot 4A 

to Waste Stream ID-HFEF-S5400-RH with the limitations discussed above. 
A-1 

ATTACHMENT A 

APPROVAL SUMMARY FOR INL RH WASTE CHARACTERIZATION PROGRAM 

Specific INL RH Approval Date EPA Docket Number 

INL RH Baseline Approval January 2007 A-98-49; II-A4-72 

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

Tier 1 Change – Approval of Visual Examination of A/V Records January 2007 A-98-49; II-A4-75 

Tier 1 Change – Approval of Real Time Radiography February 2007 A-98-49; II-A4-80 

Tier 1 Change – Approval of K-Cell Wastes January 2008 A-98-49; II-A4-97 

Tier 1 Change – Approval of High Range Gamma Probe for DTC April 2008 A-98-49; II-A4-98 

Tier 1 Change – Approval of Visual Examination Technique September 2009 A-98-49; II-A4-118 

Tier 1 Change – Addition of Twelve Containers to Waste Stream 

ID-ANLE-S5000 and Approval of Waste Stream 

ID-HFEF-S5400-RH, Lot 1A 

February 2010 A-98-49; II-A4-122 

Tier 1 Change – Approval of Waste Stream ID-MFC-S5400-RH June 2010 A-98-49; II-A4-126 

Tier 1 Change – Approval of Waste Stream ID-INTEC- RH August 2010 A-98-49; II-A4-130 

Tier 1 Change – Addition of Lot 1B to Waste Stream ID-HFEFS5400-RH and Approval of OSPREY System August 2010 A-98-49; II-A4-131 

Tier 1 Change – Approval of Waste Stream IN-ID-NRF-153 November 2010 A-98-49; II-A4-135 

Tier 1 Change – Approval of Waste Stream ID-RTC-S3000 November 2010 A-98-49; II-A4-137 
B-1 

ATTACHMENT B

LISTING OF DOCUMENTS REVIEWED FOR THIS EVALUATION 

Acceptable Knowledge Accuracy Report Waste Stream INL-ID-HFEF-S5400, incorporating Lot 

4A, Draft, February 16, 2011, Final February 26, 2011 

Acceptable Knowledge Expert Qualification Card for Remote Handled (RH) AKE for Idaho 

National Laboratory, Scott Smith, February 1, 2010 

Acceptable Knowledge Expert Qualification Card for Scott Smith, December 3, 2002 

CCP-AK-INL-580, Central Characterization Project Acceptable Knowledge Summary Report 

For Remote-Handled Transuranic Debris Waste From Materials and Fuels Complex Hot Fuel 

Examination Facility at the Idaho National Laboratory, Waste Stream ID-HFEF-S5400-RH, 

Revision 2, June 1, 2010 

CCP-AK-INL-581, Central Characterization Project Remote-Handled Transuranic Radiological 

Characterization Technical Report For Remote-Handled Transuranic Debris Waste from the Hot 

Fuel Examination Facility (HFEF) at the Idaho National Laboratory, Revision 2, November 16, 

2010 

CCP-AK-INL-582, Central Characterization Project RH TRU Waste Certification Plan for 40 

CFR Part 194 Compliance and Confirmation Test Plan for INL RH Waste Stream: ID-HFEFS5400-RH, Revision 2, November 24, 2010 

CCP-TP-005, Attachment 4, Reference List, November 10, 2010 

CCP-TP-005, Attachment 6, Waste Material Parameters, November 12, 2009 

CCP-TP-005, CCP Acceptable Knowledge Documentation, Carlsbad, New Mexico, Washington 

TRU Solutions, LLC., Revision 20, November 1, 2010 

Characterization Reconciliation Report, CRR-INL-ID-HFEF-S5400-RH-Lot 4A, provided 

February 4, 2011 

DOE/WIPP-02-3214, Remote-Handled TRU Waste Characterization Program Implementation 

Plan, Carlsbad, New Mexico, U.S. DOE Carlsbad, Revision 0d, October 30, 2003 

Remote Handled Site Qualification Card, Irene Quintana, Site Project Manager, September 17, 

2009 

C028, Argonne National Laboratory Intra-Laboratory Memo to W.N. Beck, re: Technical 

Feasibility of Lead IFR Experiments in EBR-II, R.G. Pahl, April 27, 1984 
B-2 

C033, Argonne National Laboratory Intra-Laboratory Memo to R.G. Pahl, re: Assignment of 

Identification Numbers for Three Lead IFR Experimental Subassemblies, J.L. Welker, June 4, 

1984 

C072, Packet of Letters Including: Argonne National Laboratory Intra-Laboratory Memo to D.C. 

Wade, re: Response to MC&A Questions in Support of HFEF-S Fuel Reprocessing Operations, 

R. Villarreal, January 24, 1989 

C127, Argonne National Laboratory Intra-Laboratory Memo to W.N. Beck, re: NDT Review of 

Sixty-one (61) IFR Fuel Elements from ANL Scheduled for Experimental S/A X419, G.K. 

Whitham, February 11, 1985 

C439, Freeze File Changes for AK Summary Report CCP-AK-INL-580 and Remote-Handled 

Transuranic Radiological Characterization Technical Report CCP-AK-INL-581, Scott Smith, 

February 2011 

C463, Evaluation of Volume, Period Generation, and Calculation of Individual and Total 

Radionuclide Masses and Activities for Waste Stream ID-HFEF-S5400-RH, Jim Schoen, April 

20, 2009 

C465, Evaluation and Summary of the Process Work Sheets (PWS), Various 

C503, Argonne National Laboratory Intra-Laboratory Memo to Distribution, re: Identification of 

EBR-II Assemblies, W.T. Steinman, July 16, 1987 

C522, Evaluation of Volume, Period Generation, and Calculation of Individual and Total 

Radionuclide Masses and Activities for Waste Stream ID-HFEF-S5400-RH – Phase II, Jim 

Schoen, undated 

C4092, Evaluation of Three HFEF-5 Waste Containers Stored at the MFC Radioactive Scrap and 

Waste Facility to be Added to Waste Stream ID-HFEF-S5400-RH, Scott Smith, March 15, 2010 

C4095, Re-evaluation of Volume, Period Generation, and Calculation of Individual and Total 

Radionuclide Masses and Activities for Waste Stream ID-HFEF-S5400-RH – Phase II, Scott 

Smith, February 9, 2010 

C4100, Evaluation of 3 HFEF-5 Waste Containers Stored at the MFC Radioactive Scrap and 

Waste Facility to be added to Waste Stream ID-HFEF-S5400-RH, Memorandum from Scott 

Smith, CCP AKE, to CCP Records, March 15, 2010 

C4125, Argonne National Laboratory Intra-Laboratory Memo to Distribution, re: Batch Naming 

Convention Revisited, D. Vaden, June 7, 2000 

C4126, E-mail to Kathy Pere re: GE Control Blade Project, Doug Porter, February 9, 2010 
B-3 

P001, The Defense Programs Origin of Transuranic Waste at Argonne National Laboratory – 

West, H. F. McFarlane, ANL-NT-192, November 2001 

P029, Nuclear Technology Division, Analytical Laboratory Operating Procedure: Standard Test 

Method for Determining Chemical Durability of Nuclear Waste Glasses and Ceramics – Product 

Consistency Test, S. Johnson and D. D. Standfield, W0630-0059-OP, Revision 1, December 16, 

2003 

P067, Safeguards and Security Plan for IFR – EFL, R. Villarreal, May 1984 

P070, Waste Preparation Procedure for Analytical Laboratory Waste Disposal, J.R. Krsul, 

W0660-0035-OP, Revision 0, August 19, 1991 

P083, Engineering Design File, Radiological Properties of Remote-Handled Transuranic Waste 

Inventory at the Radioactive Waste Management Complex, Cecilia R. Hoffman, EDF-4687, 

Revision 1, May 20, 2005 

P085, Test Description for the Integral Fast Reactor Subassemblies X419, X420, and X421, R.G. 

Pahl, C.E. Lahm, G.E. Hudman, ANL-IFR-19, July 1985

P092, Engineering Design File, ANL-W Radioactive Inserts Stored at ILTSF, P. Kuan, EDF4208, Revision 0, November 18, 2003 

P093, Design Description and Safety Analysis for X-447, J. F. Koenig, C. E. Lahm, R. G. Pahl, 

D. L. Porter, November 1, 1987 

P105, Engineering Design File, Baseline Estimate of the Volume of Remote Handled 

Transuranic Waste Stored at the Radioactive Waste Management Complex, Cecilia R. Hoffman, 

EDF-4379, Revision 0, March 29, 2004 

P180, Integrated Waste Tracking System Material and Waste Characterization Profile 3799P: 

RH-TRU (Misc. Metal/Plastic/Cellulosic Debris, SAD & SAMs – sample residue) Profile 3799P, 

N. Stewart, April 11, 2003 

P254, Operation and Maintenance Manual: Waste Cask – HFEF-5 W0087-0024-SA-01, P.L. 

Coomer, HFEF OMM 6104, Revision 3, December 4, 1985

P261, Operation and Maintenance Manual: Out-of-Cell Waste Handling – FEF/N W0201-0003-

ES-02, S. Stantliff, HFEF/N OMM 6611, Revision 2, September 19, 1988 

P262, Operation and Maintenance Manual: Out-of-Cell Waste Handling – FEF/S W0351-0002-

ES-02, S. Stantliff, HFEF/S OMM 6612, Revision 2, September 19, 1988 

P266, Operation and Maintenance Manual: Remote Handled Solid Waste Handling – HFEF/S 

W0351-0003-ES-01, S. Stantliff, HFEF/S OMM 6623, Revision 1, February 20, 1986 
B-4 

P876, The Ceramic Waste Form Process at Idaho National Laboratory, Stephen Priebe, 

INL/CON-07-12580, May 2007 

P877, Internal Report, Production and Sampling Plan for Ceramic Waste Form Process 

Qualification, S.M. Frank, K. Bateman, T.P. O’Holleran, M.F. Simpson, INL/INT-08-14586, 

September 2008 

P4053, Engineering Evaluation/Cost Analysis for the EBR-II Final End State, U.S. Department 

of Energy, DOE-Idaho Operations Office, DOE/ID-11398, Revision 0, January 2010 

P4115, Test Plan, Hot Cell Examination of M5 Fuel Rods and Guide Tubes, Idaho National 

Laboratory, PLN-2030, Revision 0, January 16, 2007 

P4116, Quality Assurance Project Plan, Hot Cell Examination of M5 Fuel Rods and Guide 

Tubes, Idaho National Laboratory, PLN-964, Revision 1, October 19, 2005 

P4117, INL USQ Process Proposed Change Form, MFC-Hot Fuels Examination Facility, PostIrradiation Examination of a GE Reactor Control Blade, CRADA Project 25945, Henry A. 

Harper, MFC-USQ-2006-251, April 25, 2006 

U196, Design Description and Safety Analysis for X-419, X-420, and X-421, C.E. Lahm and 

R.G. Pahl, December 1984 

U484, Radioactive Scrap & Waste Storage/Disposal Request and Authorization Forms and 

related documents, undated 

U541, Shipping Papers Gathered from MFC for ILTSF HFEF-5 Inserts, February 10, 1983 

U551, Compilation of HFEF Process Work Sheets and HFEF Procedure Change Notices; 

includes HFEF PWS Log Subassemblies, PWS Nos., and PCN Nos., various dates 

U552, Compilation of MFC Liner Documents, various dates 

U607, Excel Spreadsheet: Information for 108 MFC RH-TRU Liners, Reese Gannon, February 

11, 2009 

U652, Hot Fuel Examination Facility (HFEF) at Idaho National Laboratory (INL) RH TRU 

Radiological Characterization - Dose-to-Curie Calculations for Co-60 and Cs-137 for HFEF 

Drum Characterization, J.J. Klingensmith, INL-RH-65, Revision 0, September 23, 2009 

U729, Collection of Documents Pertaining to Material Surveillance Subassemblies SURV-9 and 

SURV-10, various authors, no date specified 

U992, RH TRU Drum Repackaging Datasheets for Waste Stream ID-HFEF-S5400-RH, FRM880 INL CWI, various dates 
B-5 

U996, Operations Division Safety Review Committee Meeting Checklist, Subject: Proposed 

Waste Salt Processing Demonstration Program in HFEF with Associated Documentation, F0000-

0042-AK-00, March 4, 1998 

U4014, HFEF Lot 4A Waste Can Loading Log Information Input Check, Dave Moody, INL-RH31, Revision 0, October 4, 2010 

U4015, HFEF Lot 4A ORIGEN2.2 Calculations, J.J. Klingensmith, INL-RH-32, Revision 0, 

October 4, 2010 

U4016, HFEF Lot 4A Scaling Factor Development, J.J. Klingensmith, INL-RH-33, Revision 0, 

October 4, 2010 

U4017, HFEF Lot 4A Uncertainty Calculation, J.J. Klingensmith, INL-RH-34, Revision 0, 

October 4, 2010 

U4018, HFEF Lot 4A Reportable Radionuclide Calculation, J.J. Klingensmith, INL-RH-35, 

Revision 0, October 4, 2010 

U4019, HFEF Lot 4A ID-HFEF-S5400-RH Dose-to-Curie Spreadsheet, Jesse Klingensmith, 

INL-RH-36, Revision 0, December 2, 2010 

U4020, Analytical Sample Record SURV-10, April 13, 1984