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 P ROGRAM

FOR IDAHO NATIONAL LABORATORY:
ADDITION OF LOT 4A CONTAINERS TO WASTE STREAM ID-HF EF-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 2011i 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 P rocesses 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 thi s Evaluationii 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

DUO 2 depleted uranium oxide fuel

EBR experimental breeder reactor

EPA U.S. Environmental Protection Agency

FCF Fuel Conditioning Facility

g gramiii

g/cm3 grams per cubic centimeter

HFEF Hot Fuel Examination Facility

INL Idaho National Laboratory

INTEC Idaho Nuclear Technology and Engineering Cent er
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 C omputer 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 Programiv

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 zirconium1

1.0 EXECUTIVE SUMMARY

This report supports the U.S. Environmental Protect ion 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 liners 1 to Waste Stream ID-HFEF-S5400-RH, as requested by the Carlsbad Fiel d Office (CBFO) on January 31, 2011.

The Central Characterization Project (CCP) is respo nsible for characterizing the above wastes using the system of controls that EPA evaluated dur ing 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 app roval of the INL RH TRU waste characterization program is included as Attachment A.

This report presents the results of the T1 evaluati on. EPA conducted a desktop review of the Acceptable Knowledge (AK) waste characterization pr ocess (Section 5.1), documentation associated with the radiological characterization w aste characterization process (Section 5.2),
and documentation associated with the Real-Time Rad iography (RTR) waste characterization process (Section 5.3). EPA did not identify any cha nges to the tiering table during this T1 review. Minor modifications to bring the table in l ine with previous reports and changes in format were made to the INL RH tiering table. The r evised tiering table included as Table 1 below applies to all RH waste characterization acti vities occurring at INL-CCP.

While previous T1 changes adding RH waste streams h ave been container 2 limited, this approval is not limited to a specific number of waste contai ners 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 scali ng 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 chara cterization of the additional
containers.

If a population of additional containers requires n ew or different radionuclide scaling factors, those additional containers will be subjected to EP A’s T1 evaluation and approval prior to disposal at the WIPP.

EPA determined that the procedures and processes us ed 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 containe rs 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 c ontainer 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 individua lly 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 throu gh 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).3Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Revised March 2011)RH Waste CharacterizationProcess ElementsINL-CCP RH Waste Characterization Process –T1 ChangesINL-CCP RH Waste Characterization Process –T2 Changes*Acceptable Knowledge (AK)Addition of containers to approved Waste Streams ifnew ordifferent 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 potentialto affect the characterization processLoad management for any RH waste streamNotification to EPA when updates to the following documentshave been completed:•All future revisions of the AKSR, and CertificationConfirmation Test Plan (e.g., CCP-AK-INL-500 andCCP-AK-INL-502)•AK accuracy reports (prepared annually, at a minimum)•Attachment 4 of CCP-TP-005 is generated to reflecttheupdated AKSR Source Document Reference List•Changes to AK documentation as a result of WCPIPrevisions (e.g., CRR)**•A Correlation or Surrogate Summary Form for each oftheRH containers in this waste stream identified as CH, basedupon measured dose rates that present NDA results forassayed containers•The waste stream data package for debris waste streamand any modifications to the WSPF, including the CRRand AK Summary•Final DTC determination for RH containers numbers 728through 737, as identified in AK Reference P030Submission of an updated AKSR documenting that thepedigree ofthe additional containers is the same as the containers approvedduring baseline approval†Submission of a list of fully characterized containers from apopulation of additional containers proposed as a T2 change,above†Radiological Characterization, includingDose-to-Curie (DTC)Application of new scaling factors for isotopic determinationother than those documented in CCP-AK-INL-501Use of any alternate radiological characterizationprocedureother than DTC with established scaling factors asdocumented in CCP-TP-504 or substantive modification***of the DTC procedureUse of any alternate gamma detector with the OSPREYTMsystem characterization procedure other than the La3Br(Ce)Notification to EPA upon completion of revisions ofCCP-AKINL-501 or CCP-TP-504 that require CBFO approvalSubmission of DTC BDRs or calculation packagesfor containersselected by EPA from a list of fully characterizedcontainersprovided by INL-CCP†4Table 1. Tiering of RH TRU Waste Characterization Processes Implemented by INL-CCP (Revised March 2011)RH Waste CharacterizationProcess ElementsINL-CCP RH Waste Characterization Process –T1 ChangesINL-CCP RH Waste Characterization Process –T2 Changes*detector observed in July 2010Any new waste stream not approved under the baselineand/or subsequent T1 evaluations or addition of containers toan approved waste stream that requires changing theestablished radionuclide scaling factorsVisual Examination of audio/video media(VE)Use of VE to characterize additional debris waste streams orwaste from other Summary Waste CategoriesNotification to EPA upon completion of changes to VEprocedure(s) that require CBFO approvalSubmission of VE BDRs for containers selected by EPA from alist of fully characterized containers provided byINL-CCP†Real-Time Radiography (RTR) Any new S5000 waste stream other than ID-ANLE-S5000 orwastes from an S3000 or S4000 waste streamNotification to EPA prior to addition of a new RTRunit(s)Notification to EPA upon completion of changes to RTRprocedure(s) that require CBFO approvalSubmission of RTR BDRs for containers selected by EPA from alist of fully characterized containers provided byINL-CCP†WIPP Waste Data System, WDS(previously known as WWIS)NoneChanges made to WDS procedure(s) that require CBFOapprovalNotes:* INL-CCP will report all T2 changes to EPA everythree months.** Excluding changes that are editorial in natureor are required to address administrative concerns.New references that are included as part of the document revision may berequested by EPA.***Substantive modificationrefers to a change with the potential to affect INL-CCP’s RH waste characterization process, e.g., theuse of an inherently different type ofmeasurement instrument or the use of the high-rangeprobe 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 activ ities 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 th e 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 4 2571–42583, 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 a pplicable 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 authorize d to evaluate and approve changes, if necessary, to the site’s approved waste characteriz ation 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 re quiring post-implementation [Tier 2 (T2)] notification, are identified in the site-specific b aseline 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 characteriz e and dispose of, at risk of subsequent EPA disapproval, any previously approved TRU waste usin g processes/procedures/equipment implemented as T2 changes. EPA reviews T2 changes o n a quarterly basis and EPA may conduct continued compliance inspections to evaluate implem ented T2 changes to verify adequacy.

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluatio n of a T1 change to approve the inclusion of
Lot 4A canister liners in Waste Stream ID-HFEF-S540 0-RH (see Section 5.0, below), as described in CCP-AK-INL-580, Revision 2 and freeze file 3 reference C439. This report presents the technical basis and results of EPA’s approval d ecision, 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 C FR 194.8(b)(3).

The DOE documents that EPA reviewed for this evalua tion 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 t he 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 th ree canister liners of Lot 4A heterogeneous debris waste as described in CCP-AK-INL-500, Revisi on 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 app rovals 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 ev aluation 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 n ot used.

The RH wastes that were the subject of this T1 eval uation 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 additiona l 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 p rocesses.

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 – Acceptabl e Knowledge Patrick Kelly SC&A, Technical Evaluator – Radiologi cal Characterization
Amir Mobasheran SC&A, Technical Evaluator – Radiolo gical Characterization Harry Chmelynski SC&A, Statistician Dorothy Gill SC&A, Technical Evaluator – Real-Time Radiography Scott Smith Technical Specialists – Acceptable Kno wledge Expert Jesse Klingensmith INL-CCP – Radiological Character ization 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 TRU7

heterogeneous debris waste generated during hot cel l and laboratory activities at the Hot Fuel Examination Facility (HFEF). The waste was generate d from operations in two hot cells: Building 785, HFEF (formerly HFEF-North) and fuel f abrication and reprocessing at Building 765, Fuel Conditioning Facility [(FCF), formerly HF EF-South]. Waste was also generated from analytical chemistry operations in Building 752, th e Laboratory and Office (L&O) Building Analytical Laboratory. Pertinent aspects of these p rocesses are described below. These wastes are identified as Lot 1A, Lot 1B, and Lot 4A. EPA p reviously approved Lot 1A and Lot 1B in separate T1 evaluations (see Docket Nos. A-98-49; I I-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 eval uation.

EPA evaluated the AK, radiological characterization , and RTR processes and associated
information to determine whether INL-CCP demonstrat ed compliance with 40 CFR 194.8 to add
Lot 4A containers. EPA concludes that INL-CCP conti nues to appropriately apply the system of controls approved by EPA during the Baseline Inspec tion.

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 examin ed 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 informat ion 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 follow ing with respect to the use of AK for waste characterization as impacted by the proposed additi on 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 nuclea r fuel

• Defense origin of additional waste8

• AK data traceability

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

• AK source document sufficiency

• Modifications to the Certification Plan/Confirmator y Test Plan

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

• AK accuracy

• Correlation and Surrogate Summary Form (CSSF) and C ontact-Handled (CH)-RH
correlation

• Load management

• Identification and attainment of Data Quality Objec tives (DQOs)

Technical Evaluation

To assess the appropriateness of inclusion of Lot 4 A in Waste Stream ID-HFEF-S5400-RH, EPA evaluated information related to the waste’s proces s origin, radiological and physical
characteristics. EPA’s evaluation included the foll owing: how these data had been integrated, impacts of the information on the waste stream, cha nges to the radiological and physical characteristics of the waste, and other elements th at could affect pertinent characteristics of Waste Stream ID-HFEF-S5400-RH. Results of the analy sis are presented below. When information presented in the text is supported dire ctly 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 heterogen eous debris generated by activities within the HFEF and FCF, and supported by the L&O B uilding Analytical Laboratory. Lot 4A waste consists of heterogeneous debris stored in th ree canister liners (SN170, SN177 and SN178) generated in HFEF Building 785. The wastes were gen erated during implementation of various reactor programs, including management of depleted uranium oxide fuel (DUO 2 ), 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 dete rmine the compatibility of various materials with the EBR-II environment; waste from Reduced Enr ichment for Research and Test Reactor (RERTR) fuel elements; and M5 Program commercial fu el elements that consisted of four
commercial fuel elements from North Anna Power Stat ion experiments conducted by Electric Power Research Institute and Framatome. Approximate ly 50% by mass of Lot 4A is "unattributed," i.e., waste that cannot be associat ed 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 gener ation period.9

The AKSR was updated through a freeze file modifica tion 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 t he 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 o f Lot 4A and found it was bounded by the previously approved Waste Stream ID-HFEF-S5400-RH d escription (References C4092, C4100, C4125, C4126, P029, P083, P092, P105, P254, P261, P 262, P266, P876, P877, P 4053, P4115, P4116, P4117, U483, U484, U541, U552, U729, U4014 a nd U4020). This conclusion is based on the waste generation locations, dates, and processe s 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 adequ ate.

The majority of Waste Stream ID-HFEF-S5400-RH was g enerated from processing fuel assemblies and experiments associated with EBR-II i rradiated fuels, most commonly binary and ternary fuels 4 (References C028, C033, C072, C127, C465, C503, C4 092, C4100, P085, P263, U196, U483, U484, U541, U551 and U552). U-fissium 5 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 (Reference s C465, C503, C4092, P263, U483, U484, U541, U551 and U552). Approximately 10% of Waste St ream ID-HFEF-S5400-RH consists of waste materials generated by examination of fuels f rom other reactors. Based on generator data, the two most predominant radionuclides for the wast e stream are 235 U and 238 U, while over 95% of the total activity in the waste stream is from f ission products (References C463, C522, C4092, C4095, C4100, P067, P083, P092, U483, U484, U541, U 551, U552 and U607).

As described in Item (1) above, 93% of the AF activ ity in Lot 4A is from unattributed waste, and is described by the general ID-HFEF-S5400-RH compos ition presented in the previous paragraph. The remaining Lot 4A AF activity is deri ved from three specific waste generation programs that contained fuel specimens, as follows:

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

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

• 0.19% - DU or DUO 2 outer blanket fuel specimens

INL-CCP also determined that waste not associated w ith 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 te rnary fuels are 90% uranium (U) and 10% zirconium (Zr) and 67% U, 25% plutonium (Pu), and 10% Zr, res pectively.

5 Fissium is an equilibrium mixture of fission products in r eactor fuel that improves the stability of uranium and uranium-plutonium fuel alloys under fast neutro n irradiation.10

fraction of reported activity for each of these com ponents in Waste Stream ID-HFEF-S5400-RH. INL-CCP examined the general radiological compositi on of each liner based on waste container and disposal logs, the SeaLion database, and Integr ated Waste Tracking System (IWTS) container profiles and concluded that the radiologi cal properties of Lot 4A were consistent with Waste Stream ID-HFEF-S5400-RH (Reference C4100). Th e 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 requ ired minor modifications and INL-CCP provided a freeze file change clarifying the radiol ogical composition of Lot 4A waste (Reference C439). Based on these data, the radiological compos ition of Lot 4A fits within the general radiological composition of Waste Stream ID-HFEF-S5 400-RH based on Lot 1.

(3) Physical characteristics of Lot 4A were assesse d with respect to the physical
characteristics of Waste Stream ID-HFEF-S5400-RH an d 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 It em (7) below. The drums are listed in Table 3 and all underwent RTR, which provided detailed in formation 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 onl y with the RERTR and M5 programs, as described in Items (1) and (2) above, including gri nding 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 sp ecimens were in the waste. The SN177 Waste Can Loading Log indicates that the majority o f the AF activity is unattributed waste with a very small contribution from the RERTR program. R TR results indicate that the drums contain scrap metal, wire, light bulbs, sanding discs, plas tic 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 mat erials, with significant variation between
individual drums. INL-CCP calculated the waste mate rial parameters (WMPs) for each liner based on waste item weights and estimates in the IW TS container profiles, and showed that the WMP estimates for each liner were bounded by the wa ste stream weight percentages (Reference C4100). The WMPs in the six drums fall within the g eneral 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 Str eam ID-HFEF-S5400-RH.

(4) The identification of Lot 4A waste as transuran ic 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-leve l 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 f uel. INL-CCP concluded that Waste Stream ID-HFEF-S5400-RH does not contain spent nuclear fue l or high-level waste prior to the addition of Lot 4A, so inclusion of Lot 4A does not alter th is original determination. EPA agrees with this
conclusion.

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

The WIPP requires generator sites to use AK to dete rmine that a TRU waste stream meets the definition of TRU defense waste. TRU waste is eligi ble 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 de fense-related activities, particularly since the unaccounted waste was attributed to EBR-II-based pr ograms. The AKSR concludes that as a result of the inherent commingling of materials ori ginating from the numerous defense activities, segregation of non-defense waste streams is not pos sible. 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 fou nd to be adequate.

The AKSR was modified through a freeze file (Refere nce C439) to add information about Lot 4A, including a description of the lot, process ori gin information, radiological composition of the lot, high-level waste/spent nuclear fuel content an d defense origin. The AKSR is adequate as modified by freeze file changes.12

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

Lot 4A waste was originally placed in canister line rs 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 populat ion of six 55-gallon drums (Reference C4100). References U552 and P180 present traceabili ty information about the liners, and include the following forms, lists, and database printouts:

• Radioactive Scrap Waste Storage/Disposal Request an d 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 Conta iner Log

• Hot Fuel Examination Facility, Zone Inventory Repor t Zone 2M

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

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

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

• Integrated Waste Tracking System Waste Profile Form

• Integrated Waste Tracking System Radiological Repor ts

• Radioactive Scrap and Waste Facility (RSWF) Transfe r 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 Ca ns

• Weld Data Sheets

• Analytical Laboratory Reports, various

Reference U992 contains the RH Container Repackagin g datasheets for each of the three liners.
INL-CCP also used the above information to link lin er contents with various programs, and this information was subsequently used to evaluate the p hysical and radiological contents of each liner (Reference C4100). Canister liner SN170 was g enerated at workstation 2M, and includes ceramics, ZeoGlass salts, debris from sampling of D U subassemblies, subassembly SURV-10 and BR-3 fuel specimens. The majority of waste in l iner 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 repac kaging. 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, 1 1M and 15M) and the Main Cell and
contained hardware from numerous subassemblies and specimen material, including a General Electric control blade velocity limiter, Neutron Ra diography facility hardware, and Decladding by Oxidation waste. Liners SN177 and SN178 were fir st sent to the RSWF and were later shipped to INTEC, where they were repackaged into d rums as described above. Evaluation of the data presented confirms the general radiological co ntent and waste forms associated with each13

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 ade quately 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 a vailability of an updated WSPF remains a T2 change.

(9) Sufficiency of acceptable knowledge support doc uments and related document tracking with respect to the addition of Lot 4A references w as evaluated and found to be adequate.

Attachment 4, the CCP-AK-INL-580, Revision 2 refere nce list, the CCP-AK-INL-581, Revision 2 reference list, and the list of new references pr ovided as part of the T1 review indicate that many must be updated. For example, Attachment 4, da ted November 10, 2010, does not include references presented in CCP-AK-INL-581, which was a pproved November 16, 2010. Also, new references have been either generated (Reference C4 39) or obtained (Reference C4100) as part of the T1 Lot 4A evaluation, and these must be adde d to the AKSR reference list and Attachment 4. EPA expects the AKSR and Attachment 4 to be upda ted to include all relevant references, including those cited in CCP-AK-INL-581. The AKSR r eference list will be updated in conjunction with text modifications [see Item (6) a bove]. Notification of availability of updates to the AKSR and Attachment 4 remain T2 changes.

(10) Interpretation of the Waste Characterization P rogram Implementation Plan, with respect
to contents of the Certification Plan and the Confi rmatory 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 characteriz ation 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 we re weighted in the composite set of scaling factors based upon the percentage of total AF mater ial. RERTR, M5 program and SURV-10 program wastes are present in Lot 4A, but no fuel e lements were identified so no AF material could be assigned to the waste. The Certification P lan concludes that Lot 4A is part of the waste stream because of overlapping waste generation date s and the presence of several common fuel types (e.g. BR-3 fuels and significant quantities o f subassembly hardware).14

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

Personnel training records for Irene Quintana and S cott 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 pers onnel continue to be adequately trained.

(12) Non-conformance reports and discrepancy resolu tion forms were examined and found to be adequate.

An NCR was not prepared for drums in Lot 4A. INL-CC P representatives indicated that Discrepancy Resolution (DR) forms were also not pre pared 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, se e EPA Docket No. A-98-49, II-A4-142) and found both to be adequate. EPA concludes that t he NCR and DR processes continue to be adequately implemented as part of the Lot 4A charac terization process.

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

INL-CCP provided a draft AK accuracy report dated F ebruary 16, 2011, for Waste Stream IDHFEF-S5400-RH, Lots 1-18 6 , as well as a final AK accuracy report dated Febru ary 23, 2011. The final report concluded that to date, no signifi cant radiological information discrepancies
have been noted with the containers in this waste s tream. None of the accepted containers were reassigned to a different Summary Category Group, b ut two AK accuracy discrepancies were
identified wherein two containers were found to hav e TRU alpha activity concentrations less than 100 nanocuries per gram (nCi/g). The waste str eam accuracy was 98.3%. Lots 1-18 consist of 146 containers, but do not include Lot 4A becaus e these drums were not yet certified by INLCCP for shipment when the AK accuracy report was pr epared. The AK accuracy report is adequate.

(14) Use of a Correlation and Surrogate Summary For m 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 Stre am 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 characterizati on 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, inc luding 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 DQ Os, 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 findin gs 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 a re no changes to the AK T1 and T2 designations identified during the Baseline Inspect ion and subsequent T1 evaluations. Table 1 shows the current INL-CCP RH tiering table.

Conclusions

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

Waste Stream ID-HFEF-S5400-RH.

5.2 Radiological Characterization

EPA evaluated the radiological characterization pro cess to determine whether INL-CCP demonstrated compliance with 40 CFR 194.8 for a pro posed T1 change to add Lot 4A to Waste Stream ID-HFEF-S5400-RH. As stated above, Lot 4A co nsists 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 d rums is Dose-to-Curie (DTC) in conjunction with radionuclide-specific scaling factors, a techn ique that EPA has observed and approved at several RH sites. The scaling factor for a radionuc lide is defined as the ratio of the activity of that radionuclide to the activity of another radion uclide, usually cesium-137 ( 137 Cs). A single composite set of 137 Cs-based scaling factors for all six drums of Lot 4 A waste was derived based on the weighted arithmetic mean of four sets of 137 Cs-based scaling factors from the contribution
of DUO 2 fuel specimens, BR-3 fuel specimens, ZeoGlass salt s from the electrorefining process
of EBR-II core drivers and HFEF Lot 1 debris. The f ractional contribution of each source to the
total AF activities was used as its statistical wei ght.

The four sets of scaling factors were determined ba sed on ORIGEN2.2 computer runs. Information on pre-irradiation fuel composition, bu rnup and decay period (from the removal date from the reactor to the assumed shipping date of Ma rch 1, 2011) was incorporated in the ORIGIN2.2 inputs. The resultant radionuclide activi ties were used to determine four individual sets of scaling factors, one for each of the four w aste sources comprising Lot 4A:

1. For the unattributed debris waste, or hot cell cont amination, no specific fuel elements were identified in the Lot 4A Waste Can Loading Log s. Debris waste from the RERTR, M5 program and four specific subassemblies were ref erenced, and therefore used as input to the ORIGEN2.2 computer runs. The resultant activ ities were added to the results for the 129 fuel pins involved in Lot 1 analysis to dev elop scaling factors. The Lot 1A scaling factors were used because of the similariti es 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 a nd subassemblies and are based on benchmark analysis of 400 fast reactor pins and acc ount 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 perassembly), 133 U fuel pins and 350 UPu fuel pins. The U fuel pins and the U-Pu fuel pin s comprised approximately 94% and 6%, respectively, and two sets of scaling factors w ere developed, one for U fuel pins and one for U-Pu fuel pins. A weighted combination of t he two sets of scaling factors (equal weights for all fuel pins) led to a single set of s caling factors for the ZeoGlass salts.

4. For the irradiated DUO 2 , the scaling factors were determined from running 25
ORIGEN2.2 cases for 25 DU outer blanket EBR-II suba ssemblies 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 137 Cs-based scaling factors for the Lot 4A waste. The percentages of AF activities used as the statistical weights we re 0.22% (BR-3), 6.27% (ZeoGlass), 0.19%17

(DUO 2 fuel), and 93.32% (other). Details of the scaling factor calculations are provided in CCPAK-INL-581, Revision 2, Appendix A and supporting c alculation 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 char acterization process for Lot 4A was not directly assessed during this T1 evaluation. This a spect was originally evaluated during the INLCCP baseline inspection and again more recently dur ing 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 chang es 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 under standing. Figure 1. Flow Diagram of the Characterization Proc ess: ID-HFEF-S5400-RH, Lot 4A Determine Scaling Factors: Determine DTC Conversion Factor:

Use MCNP5 to model the gamma dose rate as a functio n of waste density to develop a 137 Cs and a 60 Co DTC correlation based on a
1-Ci source of 137 Cs and a 1-Ci source of 60 Co

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

for both 137 Cs and 60 Co Locate and retrieve relevant records

Develop four sets of 1 37 Cs-based scaling factors for each of the four components using ORIGEN2.2
Execute DTC to Determine Drum’s 137 Cs Activity:

Find mean gamma dose rate at 1 m from the drum surf ace based on four measurements; determine the waste density b ased on the actual weight of drum contents and fill factor

Using the correlation factors and the activity rati o of 60 Co to 137 Cs
determine the “combined” DTC conversion factor

Divide the mean measured dose rate by the “combined ” DTC
conversion factor to find the 137 Cs activity in Ci*

Multiply the 137 Cs 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 Ca nberra Osprey TM system, the 137 Cs activity can simply be found by dividing the share of 137 Cs from the total dose rate by the 137 Cs 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 137 Cs 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 contribu ting to the Lot 4A waste. Specifically, this included information from the Waste Can Loading Log s, as documented in the technical report CCP-AK-INL-581, Revision 2, Appendix A and its supp orting 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 calculat ions performed using ORIGEN2.2. These Ci quantities were used to find the single set of 137 Cs-based scaling factors for Lot 4A waste as a statistical composite of four sets of 137 Cs-based scaling factors, corresponding to four “ty pes” of
waste associated with the four sources.

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

137 Cs gamma dose and cobalt-60 ( 60 Co) gamma dose, and the waste density were used to determine the Ci amounts of all reportable radionuc lides. These activities are documented in INL-RH-32, INL-RH-33, INL-RH-36 and INL-RH-65 (Refe rences U4015, U4016, U4019 and U652, respectively) and incorporate the following i nformation:

• 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 activ ity estimates

• Use of Lot 1A scaling factors as the basis, and inc orporation of adjustment factors, for determination of scaling factors for hot cell conta mination

• Additional calculations to confirm modeling approac h selected

Calculation of the 137 Cs activity of a container allows for calculation o f the following quantities
for each RH container measured:

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

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

• Associated uncertainty for all radionuclide values listed in previous bullet

• Fissile Gram Equivalent

• Pu Equivalent Ci

• Decay heat in Watts19

INL-CCP used the constants and other values require d for these calculations from the appropriate sources (e.g., TRAMPAC) and EPA verifie d by spot-checking the calculations for

accuracy.

Similar to Lot 1 analysis, shielding calculations w ere performed using MCNP ® with the 1-Ci
source of 137 Cs and 1-Ci source of 60 Co uniformly distributed throughout a 55-gallon was te drum for a range of waste densities from 0.1 g per cubic centimeter (g/cm 3 ) to 2.0 g/cm 3 . The results of
these were used to derive a DTC correlation as a fu nction of density for 137 Cs and 60 Co, 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 ste el)

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

There were no concerns regarding the correlation of waste records with 137 Cs 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 statistic al metrics using the mean and
standard deviation values for each radionuclide

• The appropriateness of the choice of physical const ants and radionuclide-specific attributes (specific activity, physical half-life, decay heat, neutron cross-sections, photon transition probabilities, etc.) and the technical c orrectness of the values assigned to each
attribute

• Isotopic activity values correlated to the radionuc lides whose physical half-lives are such that they could be responsible for the measured ext ernal dose rate, i.e., 137 Cs for these IDHFEF-S5400-RH wastes

• Adjustment of the source distribution inside the dr ums for 137 Cs and 60 Co using earlier MCNP5 calculations, calculated as a function of bul k waste density

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

• Appropriate decay correction according to INL-CCP p rocedure (CCP-TP-504, Revision 8) of all radionuclide values for purposes of model development

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

• The ORIGEN2.2 results are used to develop radionucl ide-specific scaling factors that are used to determine activity levels of the radionucli des of interest in conjunction with the

137 Cs activity obtained from the measured external dos e rates and the DTC relationship20

• Activity and uncertainty values determined for the ten WIPP-Tracked radionuclides ( 233 U, 234 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 242 Pu, 241 Am, 137 Cs and 90 Sr)

• The determination of the contribution of all radion uclides to the radiological hazard 7

• Shielding and other calculations supporting the sca ling factors performed using MCNP5 to derive the appropriate DTC relationships as a fu nction of waste density for the appropriate geometry following repackaging (30-gall on 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 fro m INL-RH-33 (Reference U4016):

Table 5. Radionuclide-Specific Scaling Factors

Radionuclide DTC Scaling Factor

137 Cs 1.00E+00

1 37m Ba 9.46E-01

90 Sr 8.44E-01

90 Y 8.44E-01

233 U 6.09E-05

234 U 9.17E-05

235 U 8.35E-06

236 U 8.92E-06

238 U 1.33E-06

238 Pu 1.26E-02

239 Pu 2.56E-02

240 Pu 1.01E-02

241 Pu 2.06E-01

242 Pu 4.66E-06

241 Am 1.03E-02

244 Cm 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 t he 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 o f 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 eac h of the two formulas. The unclear variables were those representing the activities of X and 137 Cs, 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 co rrected 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 as pects of a container’s radiological characterizatio n.21

corrections on the final results, INL-CCP staff sta ted 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 f actors for ID-HFEF-S5400-RH, Lot 4A.

(3) The technical basis of the Dose-to-Curie correl ation 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 inc ludes the following:

• The correct version of the DTC Excel spreadsheet wa s 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 694,0 00 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 9 7 rem per hour (7,000 to 97,000 mrem/hr)

• All six containers identified the 10 WIPP-tracked r adionuclides and quantified the uncertainty associated with each

• All quality control parameters were performed and a ll were acceptable

• The BDR had all required signatures, i.e., Independ ent 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 id entifying the need to apply a correction
for 134 Cs 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 rad iological 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, l isted in CCP-AK-INL-581, Revision 2, Table A7-1 that were reviewed in the process of evaluatin g 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 evaluati ons. There were no issues related to the22

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

wastes.

(5) The technical basis and derivation of Total Mea surement Uncertainty were evaluated and found to be adequate.

The development of Total Measurement Uncertainty (T MU) for Waste Stream ID-HFEF-S5400- RH waste is based on the propagation of uncertainti es present in all aspects of the determination of the radiological constituents of RH TRU waste. T hese aspects are assumed to be independent, which allows them to be added in quadrature. The TM U determination included contributions of the following:

• DTC correlation – including drum weight measurement , MCNP ® code, and modeling
uncertainties

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

• Scaling factor uncertainty – including ORIGEN2.2 un certainty

• 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 Calcula tion Package INL-RH-34, HFEF Lot 4A Uncertainty Calculation (Reference U4017). The principal sources of uncertainty are
uncertainties in 137 Cs activity, ORIGEN2.2 benchmarking, and drum-to dr um 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 findin gs or concerns related to radiological
characterization of the Lot 4A drums.

Tiering Changes

Based on the results of this T1 evaluation, there a re 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 pro cess to determine whether INL-CCP demonstrated compliance with 40 CFR 194.8 to add si x drums of Lot 4A to Waste Stream IDHFEF-S5400-RH. EPA concludes that INL-CCP continues to appropriately apply the system of23

controls approved by EPA during the Baseline Inspec tion 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 syst em 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 thi s 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 d escribed below.

Technical Evaluation

EPA reviewed RTR data that INL-CCP generated for si x containers in Waste Stream ID-HFEFS5400-RH, Lot 4A, containers MFC060105A, MFC060105B , MFC070118A, MFC070118B,
MFC0701119A and MFC070119B. The RTR results were re ported in RTR BDR INLRHRTR10019 which INL-CCP generated using Procedu re 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 R TR operations and records generation. INLCCP tracks operator/ITR (Independent Technical Revi ewer) 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 pe rsonnel. 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-quali fied RTR operator, as required. The
documentation for BDR INLRHRTR10019 demonstrates th at RTR data were generated and reviewed in accordance with requirements. No NCRs w ere associated with this batch.

Summary of Real-Time Radiography

Findings or Concerns

The EPA inspection team did not identify any findin gs or concerns related to RTR for the Lot 4A
drums.

Tiering Changes

Based on the results of this T1 evaluation, there a re no changes to the RTR T1 and T2 designations identified during the INL-CCP RH Basel ine Inspection and subsequent RH T1
evaluations. Table 1 shows the current INL-CCP tier ing table.24

Conclusion

EPA evaluated RTR to determine whether INL-CCP demo nstrated 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 findin gs 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 evaluat ion, EPA is approving addition of Lot 4A
to Waste Stream ID-HFEF-S5400-RH with the limitatio ns 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 Identificati on 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 F ebruary 2007 A-98-49; II-A4-80
Tier 1 Change – Approval of K-Cell Wastes January 2 008 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 Tech nique September 2009 A-98-49; II-A4-118
Tier 1 Change – Addition of Twelve Containers to Wa ste 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-S54 00-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-S30 00 November 2010 A-98-49; II-A4-137B-1 ATTACHMENT B

LISTING OF DOCUMENTS REVIEWED FOR THIS EVALUATION

Acceptable Knowledge Accuracy Report Waste Stream I NL-ID-HFEF-S5400, incorporating Lot 4A, Draft, February 16, 2011, Final February 26, 20 11

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 Ac ceptable Knowledge Summary Report
For Remote-Handled Transuranic Debris Waste From Ma terials and Fuels Complex Hot Fuel Examination Facility at the Idaho National Laborato ry, Waste Stream ID-HFEF-S5400-RH, Revision 2, June 1, 2010

CCP-AK-INL-581, Central Characterization Project Re mote-Handled Transuranic Radiological Characterization Technical Report For Remote-Handle d Transuranic Debris Waste from the Hot Fuel Examination Facility (HFEF) at the Idaho Natio nal 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 Characte rization Program Implementation Plan, Carlsbad, New Mexico, U.S. DOE Carlsbad, Revi sion 0d, October 30, 2003

Remote Handled Site Qualification Card, Irene Quint ana, 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, 1984B-2

C033, Argonne National Laboratory Intra-Laboratory Memo to R.G. Pahl, re: Assignment of Identification Numbers for Three Lead IFR Experimen tal 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 Sh eets (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 Stor ed 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 Pr oject, Doug Porter, February 9, 2010B-3

P001, The Defense Programs Origin of Transuranic Wa ste at Argonne National Laboratory – West, H. F. McFarlane, ANL-NT-192, November 2001

P029, Nuclear Technology Division, Analytical Labor atory Operating Procedure: Standard Test Method for Determining Chemical Durability of Nucle ar 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 La boratory Waste Disposal, J.R. Krsul, W0660-0035-OP, Revision 0, August 19, 1991

P083, Engineering Design File, Radiological Propert ies of Remote-Handled Transuranic Waste Inventory at the Radioactive Waste Management Compl ex, Cecilia R. Hoffman, EDF-4687, Revision 1, May 20, 2005

P085, Test Description for the Integral Fast Reacto r 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 In serts 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 M anagement 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, S eptember 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, S eptember 19, 1988

P266, Operation and Maintenance Manual: Remote Hand led Solid Waste Handling – HFEF/S W0351-0003-ES-01, S. Stantliff, HFEF/S OMM 6623, Re vision 1, February 20, 1986B-4

P876, The Ceramic Waste Form Process at Idaho Natio nal 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’Holle ran, 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-1139 8, Revision 0, January 2010

P4115, Test Plan, Hot Cell Examination of M5 Fuel R ods and Guide Tubes, Idaho National Laboratory, PLN-2030, Revision 0, January 16, 2007

P4116, Quality Assurance Project Plan, Hot Cell Exa mination 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-Ho t Fuels Examination Facility, PostIrradiation Examination of a GE Reactor Control Bla de, 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 Re quest and Authorization Forms and related documents, undated

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

U551, Compilation of HFEF Process Work Sheets and H FEF Procedure Change Notices; includes HFEF PWS Log Subassemblies, PWS Nos., and PCN Nos., various dates

U552, Compilation of MFC Liner Documents, various d ates

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 Calcu lations 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 Materia l 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 datesB-5

U996, Operations Division Safety Review Committee M eeting 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 Informatio n Input Check, Dave Moody, INL-RH31, Revision 0, October 4, 2010

U4015, HFEF Lot 4A ORIGEN2.2 Calculations, J.J. Kli ngensmith, 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. Kl ingensmith, INL-RH-34, Revision 0, October 4, 2010

U4018, HFEF Lot 4A Reportable Radionuclide Calculat ion, J.J. Klingensmith, INL-RH-35, Revision 0, October 4, 2010

U4019, HFEF Lot 4A ID-HFEF-S5400-RH Dose-to-Curie S preadsheet, Jesse Klingensmith, INL-RH-36, Revision 0, December 2, 2010

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