DOCKET NO: A-98-49; II-A4-170

WASTE CHARACTERIZATION TIER 1 CHANGE REPORT

EPA TIER 1 EVALUATION

OF THE CENTRAL CHARACTERIZATION PROJECT

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM

FOR THE SAVANNAH RIVER SITE:

ADDITION OF WASTE STREAM SR-RH-235F.01

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air

Center for Federal Regulations

1200 Pennsylvania Avenue, NW

Washington, DC 20460

February 2013
i

TABLE OF CONTENTS

Section Page

1.0 Introduction..........................................................................................................................1

2.0 Purpose of Tier 1 Evaluations..............................................................................................4

3.0 Purpose of This Report ........................................................................................................4

4.0 Scope of The Tier 1 Evaluation ...........................................................................................5

5.0 EPA Evaluation Personnel...................................................................................................5

6.0 Radiological Characterization Technical Evaluation...........................................................5

7.0 Findings and Concerns.......................................................................................................17

8.0 Conclusions........................................................................................................................17

TABLE OF TABLES

Table 1. Tiering of Remote-Handled Transuranic Waste Characterization Processes Implemented 

by SRS-CCP.................................................................................................................................... 3

Table 2. EPA Tier 1 Evaluation Team Members............................................................................ 5

Table 3. ISOCS Results for RH Waste Stream SR-RH-235F.01 (in Ci)...................................... 11

Table 4. ISOCS Scaling Factors for RH Waste Stream SR-RH-235F.01 .................................... 11

Table 5. RH Scaling Factors Based on CH Nondestructive Assay Data ...................................... 13

Table 6. Summary of Remote-Handled Dose Rate Determinations............................................. 16

Table 7. Overall Uncertainty of Example Drum No. SR513062.................................................. 17

TABLE OF FIGURES

Figure 1. Scaling Factor Development Flow Diagram................................................................... 8

Figure 2. Radiological Characterization Flow Diagram................................................................. 9

ATTACHMENTS

Attachment A: Approval Summary for Savannah River Site Remote-Handled Waste 

Characterization Program

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

Attachment C: Tiering Table from Baseline Report (Superseded, see Table 1)
ii

ACRONYMS AND INITIALIZATIONS

AK acceptable knowledge

AKSR acceptable knowledge summary report

Am americium

Ba barium

BDR batch data report

CBFO Carlsbad Field Office

CCP Central Characterization Project

CFR Code of Federal Regulations

CH contact-handled

Ci curie

CIS Characterization Information Summary

CRR Characterization Reconciliation Report

Cs cesium

DOE U.S. Department of Energy

DTC dose-to-curie

EPA U.S. Environmental Protection Agency

FR Federal Register

HS heat source

ISOCS In Situ Object Counting System

MCNP5 Monte Carlo N-Particle Transport Code RSICC Computer Code 

Collection, Oak Ridge National Laboratory

MCS Mobile Characterization Services

MDA minimum detectable activity

mR/hr/Ci milliroentgen per hour per curie

mrem/hr millirem per hour

NDA nondestructive assay

Np neptunium

Pu plutonium

RCTR radiological characterization technical report

RH remote-handled

RTR real-time radiography
iii

SCG summary category group

SF scaling factor

Sr strontium

SRS Savannah River Site

T1 Tier 1

T2 Tier 2

TMU total measurement uncertainty

TRU transuranic

U uranium

WIPP Waste Isolation Pilot Plant

WSPF Waste Stream Profile Form

Y yttrium
1

1.0 INTRODUCTION

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

(T1) change to add Waste Stream SR-RH-235F.01 to the approved characterization program at 

the U.S. Department of Energy’s (DOE’s) Savannah River Site (SRS). In April 2012, EPA 

approved the Central Characterization Project (CCP) to characterize remote-handled (RH) waste 

at SRS. On November 28, 2012, the Carlsbad Field Office (CBFO) requested EPA approval of a 

T1 change to add Waste Stream SR-RH-235F.01. Using the EPA-approved waste 

characterization processes discussed in this report, SRS-CCP can characterize Waste Stream 

SR-RH-235F.01 for disposal at the Waste Isolation Pilot Plant (WIPP). EPA is also expanding 

the approval of the Mobile Characterization Services (MCS)/In Situ Object Counting System 

(ISOCS) to include providing the relative determinations of gamma-emitting radionuclides 

irrespective of the radionuclides being measured, according to the limitations described in this 

report.

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

conducted Baseline Inspection No. EPA-SRS-CCP-RH-08.11-8 of the CCP waste 

characterization program at SRS on August 30–September 1 and December 6–7, 2011. The April 

2012 SRS baseline final inspection report (see EPA Docket No. A-98-49; II-A4-161) documents 

EPA’s approval of the acceptable knowledge (AK) process for RH transuranic (TRU) debris 

waste streams that have:

companion1contact-handled (CH) debris waste streams;

a radiological characterization process that uses:

o dose-to-curie (DTC); and 

o scaling factors generated through use of the MCS/ISOCS2; and

o historical assays of companion CH debris waste streams for assigning 

radionuclide values for RH waste; and 

real-time radiography (RTR) processes specific to SRS-CCP’s RH waste characterization 

program. 

The companion CH waste stream for RH Waste Stream SR-RH-235F.01 is Waste Stream 

SR-W027-235F-HET. Because the AK and RTR processes have not changed since the baseline 

approval, EPA limited the scope of this T1 review to the radiological characterization process. 

Waste Stream SR-RH-235F.01 is characterized by DTC, as described in CCP-RC-SRS-561, 

“Central Characterization Program Remote-Handled Transuranic Radiological Characterization 

 

1 A companion CH waste stream has the same summary category group, same waste stream definition, and 

same radiological and physical properties as the subject RH waste stream. In this case, the only difference between 

containers in the companion CH waste stream and those in the subject RH waste stream is the waste’s external dose 

rate; i.e., less than or greater than 200 millirem per hour (mrem/hr), which makes the waste CH or RH, respectively.

2 Unlike other NDA instruments in CH programs, the ISOCS is not a direct characterization method; it is 

used exclusively for obtaining the relative ratios of radionuclides, i.e., scaling factors. The ISOCS data had been 

confirmed by measurements done on an approved CH NDA system.
2

Technical Report for Savannah River Site Remote-Handled Transuranic Debris Waste, Waste 

Stream: SR-RH-235F.01,” Revision 0, dated October 18, 2012. The scaling factors are 

determined using the MCS/ISOCS and the results are compared with the CH nondestructive 

assay (NDA) results from characterization of Waste Stream SR-W027-235F-HET.

Because there were no new equipment or additional new processes on site at SRS as part of the 

T1 request, EPA conducted a desktop review of this change, concluding that the SRS-CCP plan 

to use the EPA-approved system of controls to characterize the 55-gallon containers of Waste 

Stream SR-RH-235F.01 is acceptable. EPA did not identify any findings or concerns during this 

evaluation. SRS-CCP provided EPA with revised calculation packages and a draft of CCP-RCSRS-561, Revision 1, prior to the conclusion of this T1 evaluation. Attachment B is a list of all 

documentation reviewed, including batch data reports (BDRs) and calculation packages. EPA 

expects formal revision of CCP-RC-SRS-561 to be completed by June 30, 2013, and submitted 

as part of SRS-CCP’s fiscal year 2013 third quarter submission of Tier 2 (T2) changes to EPA 

for review and concurrence.

As a result of this evaluation, EPA has made one substantive change to the SRS-CCP 

radiological characterization T1 designations shown in Table 1 below. Table 1 of the EPA 

baseline inspection report limited use of the MCS/ISOCS to providing relative determinations of 

plutonium-239 (239Pu), 

240Pu and 241Pu to americium-241 (241Am); any other relative 

determination was identified as a T1 change that required EPA approval before implementation.

Based on the technical merit of information reviewed during this T1 evaluation, EPA approves 

the SRS-CCP MCS/ISOCS to measure RH TRU wastes irrespective of the radionuclides being 

measured and confirmatory measurements are not required. Essentially, the MCS/ISOCS is an 

approved measurement modality for RH TRU wastes at SRS limited to providing relative 

determinations of gamma-emitting radionuclides for use as scaling factors. Use of the 

MCS/ISOCS to provide any information other than the relative determinations of gammaemitting radionuclides for use as scaling factors is a new T1 change. The technical bases for the 

derivation of the radionuclide-specific scaling factors that are used in conjunction with the 

MCS/ISOCS are still subject to evaluation as a T1 change. Use of the MCS/ISOCS for direct 

quantification of RH TRU wastes for WIPP disposal is not approved.

EPA also made minor modifications to the tiering table as part of EPA’s ongoing efforts to 

harmonize the format and language of the tiering tables for all RH waste characterization 

programs. T1 or T2 changes that were only revised for style are not shown in bold. (A copy of 

the unmodified tiering table from the baseline report is provided for comparison in 

Attachment C.) All of the T1 and T2 changes that were established during the baseline approval 

remain in effect and are listed as applicable in section 6.0.

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 emails to the 

WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3). 
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Table 1. Tiering of Remote-Handled Transuranic Waste Characterization Processes Implemented by SRS-CCP

(Based on August 20–September 1, 2011, and December 6–7, 2011, Baseline Inspection, Updated February 2013)

Process Elements SRS-CCP RH Waste Characterization Process – T1 Changes SRS-CCP RH Waste Characterization Process – T2 Changes*

Acceptable Knowledge Any new SCG S3000 or S4000 RH waste stream 

Any new SCG S5000 RH waste stream that does not have a companion 

CH waste stream 

Substantive modification** to EPA-approved AKSRs and certification 

confirmation test plans (e.g., CCP-AK-SRS-580, CCP-AK-SRS-582, 

CCP-CP-SRS-562)

Notification to EPA upon characterization of any new SCG S5000 RH 

waste stream that does have a companion CH waste stream 

Notification to EPA upon availability or nonsubstantive modification** of 

AKSRs and certification confirmation test plans (e.g., CCP-AK-SRS-580, 

CCP-AK-SRS-582, CCP-CP-SRS-562)

Notification to EPA upon availability or modification of: 

CCP-TP-005 or nonconformance and corrective action procedures 

requiring CBFO approval 

CCP-TP-005 attachments, including when Attachment 4 is generated to 

reflect the updated AKSR Source Document Reference List 

WSPF, CIS, CRR and related attachments, and any subsequent 

revisions to these documents 

AK accuracy reports (annually, at a minimum) 

Add Container Memoranda 

Additional discrepancy resolution reports and nonconformance reports 

Radiological 

Characterization, including 

Dose-to-Curie 

Use of the MCS/ISOCS to provide any information other than the 

relative determinations of gamma-emitting radionuclides for use as 

scaling factors

Future use of the ORTEC/ISOCS for any RH TRU waste 

Application of new (i.e., not EPA-approved) scaling factor processes for 

isotopic determination (applies to new RH waste streams and to the 

addition of containers to an approved waste stream) 

Substantive modification** to EPA-approved procedures or radiological 

characterization technical reports (e.g., CCP-TP-504, CCP-AK-SRS-581, 

CCP-RC-SRS-561) 

Notification to EPA upon: 

Characterization of any new RH waste stream using an approved 

scaling factor process for isotopic determination 

Modification of the procedures or radiological characterization 

technical reports (e.g., CCP-TP-504, CCP-AK-SRS-581, 

CCP-RC-SRS-561) requiring CBFO approval 

Availability of calculation package CCP-SRS-44 or equivalent records 

Real-Time Radiography Real-time radiography by any new process Notification to EPA upon: 

Substantive modification** to site procedures requiring CBFO 

approval

Characterization of SCG S3000 or S4000 RH waste by an approved 

process 

New T1s, T2s and significant modifications to existing T1s or T2s are in bold text; T1s or T2s that were only revised for style are not shown in bold.

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

** “Substantive modification” refers to a change with the potential to affect SRS-CCP’s RH waste characterization processes or documentation of them, excluding changes that are solely related to 

the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act, or that are editorial in nature or are required to address administrative concerns. EPA may 

request copies of new references that DOE adds during a document revision.
4

2.0 PURPOSE OF TIER 1 EVALUATIONS

Certain changes to the waste characterization activities after 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 and incorporated into the SRS-CCP RH baseline final 

report (see EPA Docket No. A-98-49; II-A4-161).

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, Federal Register notice 

(Vol. 69, No. 136, pages 42571–42583), EPA must perform a single baseline inspection of a 

TRU waste generator site’s waste characterization program. 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 notification (T2) 

are identified in the site-specific baseline inspection reports. When evaluating proposed T1 

changes for approval, EPA may conduct a site inspection to observe at first hand the 

implementation of the change or can decide to conduct a desktop review of information provided 

specific to a change. DOE may choose to characterize and dispose of any previously approved 

TRU waste using processes, procedures or equipment implemented as T2 changes at risk of 

subsequent EPA disapproval. EPA reviews T2 changes on a quarterly basis and 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 add Waste Stream SR-RH235F.01 to SRS-CCP’s approved waste characterization program. This report presents the 

technical basis for and results of EPA’s approval decision. EPA’s approval decision regarding 

the addition of Waste Stream SR-RH-235F.01 has been conveyed to DOE separately by letter. 

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:

Manager, National TRU Program

Carlsbad Field Office

U.S. Department of Energy

P O Box 3090

Carlsbad, NM 88221-3090
5

4.0 SCOPE OF THE TIER 1 EVALUATION

The scope of EPA’s T1 evaluation is the radiological characterization approach used to 

characterize Waste Stream SR-RH-235F.01, specifically, the use of the MCS/ISOCS to develop 

an isotopic ratio for use quantifying neptunium-237 (237Np). Section 6.0 of this report details the 

radiological characterization technical elements assessed during this evaluation.

5.0 EPA EVALUATION PERSONNEL

The EPA evaluation team members consisted of the personnel listed in Table 2 with their 

affiliation and function. EPA relied primarily on reviews of documents and information provided 

by SRS-CCP. When additional information or clarifications were needed, EPA had discussions 

with Irene Joo,

3

the CCP RH Project Manager, who served as the point of contact for this T1 

evaluation.

Table 2. EPA Tier 1 Evaluation Team Members

Name Affiliation & Function 

Ed Feltcorn Lead Inspector, EPA 

Rajani Joglekar Inspector, EPA 

Rose Gogliotti Technical Evaluator – Radiological Characterization, SC&A

Patrick Kelly Technical Evaluator – Radiological Characterization, SC&A 

Amir Mobasheran Technical Evaluator – Radiological Characterization, SC&A 

6.0 RADIOLOGICAL CHARACTERIZATION TECHNICAL EVALUATION

RH Waste Overview

The RH TRU wastes generated during the production of nuclear materials and related support 

activities (from 1973 to 1983) at the F-Area Materials Storage Facilities at SRS comprise Waste 

Stream SR-RH-235F.01. This waste stream was originally included in CH TRU Waste Stream 

SR-W027-235F-HET, stored in 55-gallon drums and characterized under a CH TRU program 

based on actual nondestructive assays. However, seven drums had surface dose rates exceeding 

the 200 mrem/hr limit for CH waste and, therefore, were assigned to RH TRU Waste Stream SRRH-235F.01. These seven drums of TRU waste are the subject of this T1 report.

Documents, Waste Containers, and Batch Data Reports and Calculation Packages

EPA evaluated the SRS-CCP documentation that supported radiological characterization of

Waste Stream SR-RH-235F.01. SRS-CCP provided CCP-RC-SRS-561, Revision 0, to EPA as 

the main document for review. EPA’s review identified several technical issues that necessitated 

the revision of CCP-RC-SRS-561, Revision 0, and several calculation packages. Copies of 

revised calculation packages and a draft of CCP-RC-SRS-561, Revision 1, were provided to 

EPA before the conclusion of this T1 evaluation. Attachment B lists all documentation reviewed

 

3

Irene Joo was formerly called Irene Quintana, and both names are used in the documentation reviewed for 

this evaluation.
6

by EPA, including BDRs and calculation packages. EPA expects formal revision of CCP-RCSRS-561 to be completed by June 30, 2013, and submitted as part of SRS-CCP’s fiscal year 

2013 third quarter submission of T2 changes to EPA for review and concurrence.

Waste Characterization Element Description

EPA evaluated the radiological characterization of SRS-CCP RH Waste Stream SR-RH-235F.01

in terms of its technical adequacy, as supported by the program’s documents, procedures and 

controls, and the knowledge and understanding of the personnel involved in the RH waste 

characterization program. During this RH inspection, the EPA inspection team evaluated the 

following elements of the SRS-CCP radiological characterization program:

ISOCS and DTC measurements made at SRS during two periods: (1) from December 

2011 through February 2012 and (2) during August 2012.

Development of two DTC correlations for 55-gallon drums based on Monte Carlo 

N-Particle Transport Code (MCNP5) separate modeling of the drum’s gamma dose rate 

at one meter from the surface of drum using a one-curie (Ci) source of 241Am and a 

one-Ci source of 237Np, assumed to be the main contributors to the dose.

Derivation of radionuclide scaling factors using isotopic ratios found through ISOCS 

assays and isotopic distributions from historical assays of companion CH Waste Stream 

SR-W027-235F-HET.

Representativeness and technical adequacy of the analytical data used to support the 

scaling factors.

Each of these is discussed in the sections that follow.

Technical Evaluation

The EPA inspection team evaluated the following aspects:

(1) The overall radiological characterization process and its documentation were evaluated 

and found to be adequate.

The radiological characterization process for Waste Stream SR-RH-235F.01 uses the ISOCS as 

the measurement modality in conjunction with radionuclide-specific scaling factors, a process 

that EPA approved at the SRS RH baseline. SRS-CCP scaled the measured and modeled

radionuclide values to 241Am, correlating a drum’s external exposure (dose) rate and its

radionuclide contents. Development of the radionuclide-specific scaling factors is the main 

technical aspect of SRS-CCP’s radiological characterization. The SRS-CCP RH radiological 

characterization program incorporated five main aspects:

Development of 241Am-based scaling factors for 239Pu, 240Pu, 241Pu, 242Pu, 237Np and

cesium-137 (

137Cs) based on ISOCS measurements when detected.
7

Historical information (AK) for CH Waste Stream SR-W027-235F-HET, as summarized 

in CCP-AK-SRS-5604and associated source documents.

When isotopes are not detected by ISOCS, development of scaling factors for 238Pu,

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

based on past assays of the RH waste stream’s CH counterpart, Waste Stream SR-W027-

235F-HET, and assumptions about the waste’s origins.

MCNP5 modeling to determine the correlation between the amount of 241Am and 237 Np

in each drum and the drums dose rates at one meter.

Direct exposure rate measurements (DTC) of each waste drum.

The EPA inspection team prepared two flow diagrams to accurately reflect this process, shown 

in Figures 1 and 2 below. EPA determined that the radiological characterization process for 

Waste Stream SR-RH-235F.01 was technically adequate and appropriately documented. Any 

new RH waste stream not approved to date or the addition of containers to Waste Stream SRRH-235F.01 that requires changing the established process of radiological characterization from 

what is documented in CCP-RC-SRS-561 is a T1 change. (See Table 1.) Any change to CCPRC-SRS-561 that requires CBFO approval is a T2 change. (See Table 1.)

 

4

“Central Characterization Project Acceptable Knowledge Summary Report for Savannah River Site 

Remote-Handled Transuranic Waste: Waste Streams: SR-RH-235F.01,” CCP-AK-SRS-560, Revision 1, 

June 7, 2012.
8

 

 

 

Use ISOCS to measure SFs of each 

RH drum for 239Pu, 240Pu, 241Pu, 

242Pu, 237Np and 137Cs to 241Am

Use 239Pu/237Np ratio to 

determine if drum contains 

heat-source (238Pu-dominant) 

waste or a non-heat-source 

(

237Np-dominant) waste 

Identify two subsets of 

drums in the CH 

database with ratios of

239Pu/237Np expected in 

Np target and HS waste

Compile SFs 

unique to each 

drum

MDA values for 233U, 235U and 238U 

were averaged in a subset of CH 

drums containing Np target and HS 

waste

Averaged MDAs for U were 

applied to CH data and used to 

develop SF to 241Am

If detected:

Shapiro-Wilkes Test found Pu 

isotopes, 137Cs and 234U SFs to be 

normally distributed; SFs were 

averaged in CH HS subset Averaged SFs 

applied to HS 

drums without 

measured SFs SFs for Pu isotopes, SFs are 

normally distributed and averaged 

in CH subset

SFs for 137Cs, 

234U and 242Pu are not 

normally distributed in CH subset; 

SFs were average arithmetically 

Heat 

Source 

Subset

NP Target 

Subset

Averaged SFs 

applied to Np 

target drums 

without 

measured SFs

Shapiro-Wilkes Test 

applied to Np target CH 

waste subset SFs

Uranium SFs Development:

ISOCS-Derived SFs:

CH Database Derived SFs:

Source: Based on SRS-RH-48, 

Revision 0

Figure 1. Scaling Factor Development Flow Diagram
9

 

Source: Based on CCP-RC-SRS-561, Revision 0

Use MCNP5 to separately model the 1-meter dose 

rates from the 55-gallon drum surface, based on a 

1-Ci source of 241Am and 1-Ci source of 237Np

Develop the DTC conversion factors (mR/hr/Ci) as 

a function of the waste density for 241Am 

Execute DTC to derive the 241Am activity in curies

Multiply the 241Am activity by the SFs to 

determine activities of other radionuclides

Determine the uncertainties in radionuclide 

activities and masses

Develop drumspecific scaling 

factors, see 

Figure 1

Figure 2. Radiological Characterization Flow Diagram
10

(2) Use of the In Situ Object Counting System to derive isotopic ratios (scaling factors) was

found to be correctly implemented and appropriately documented.

In Situ Object Counting System Description 

An ISOCS is a portable assembly consisting of a gamma detector, a cryostat and supporting 

electronics. These components are installed on a moveable cart, which can be positioned in 

proximity to the item being measured—in this case, an RH waste drum. The ISOCS software 

contains predetermined geometries that can be applied to a variety of sizes and shapes in the field 

without moving the item. These aspects provide two important advantages for using the ISOCS 

in the field.

First, the source-to-detector distance for a specific item is determined in the field based on the 

item’s external dose rate, allowing the user to optimize the measurement efficiency. When 

measuring a number of items, a user can get close to a low-dose-rate waste container and far 

from a high-dose-rate container with minimum adjustments, addressing potentially problematic 

issues like excessive dead time typically associated with RH TRU drums.

Second, the predetermined geometries allow a user to derive an efficiency calibration for each 

item in the field by matching field conditions with an established geometry without repositioning 

or manipulating the item. Because the system’s use is not tied to a specific waste configuration, 

the ISOCS has considerable flexibility; i.e., the same unit could measure a 5-gallon pail, a 

30-gallon drum or a 55-gallon drum with minor adjustments in the field. Limitations include 

background interferences from other radionuclide-bearing items in the area as well as typical 

measurement control issues.

Application of In Situ Object Counting System

EPA previously approved an ISOCS instrument to assay WIPP-bound RH TRU waste drums at 

the SRS RH baseline during 2011. Unlike other NDA instruments in CH programs, the ISOCS is 

not a direct characterization method; it is used exclusively for obtaining the relative ratios of 

radionuclides. During the SRS RH baseline, EPA approved the use of scaling factors relative to 

241Am for 239Pu, 240Pu and 241Pu. These measurements were confirmed by measurements done on 

an approved CH NDA system.

For RH Waste Stream SR-RH-235F.01, SRS-CCP used ISOCS measurements to scale the 

previously approved isotopes (239Pu, 240Pu and 241Pu) to 241Am. It also scaled 242Pu, 237Np and 

137Cs to 241Am when they were detected in levels above the minimum detectable activity (MDA). 

SRS-CCP did not perform confirmation runs for 242Pu, 237Np and 137Cs on an NDA system. 

Because 242Pu and 237Np are not WIPP-tracked radionuclides, they do not require the same 

degree of confirmation, but SRS-CCP must report their contribution to each drum to comply 

with shipping requirements in that each contributes significantly to the radiological hazard of the 

drum.

137Cs is a WIPP-tracked radionuclide with a strong gamma emission that is easy to detect. 

EPA has previously reviewed the ISOCS specifications (see the SRS baseline inspection report) 

and finds it unnecessary to confirm the additional radionuclides (i.e., 242Pu and 237Np).
11

Each of the seven RH drums was assayed by the ISOCS; the results are shown in Table 3. 

238Pu 

was also detected in five drums; however, in the baseline inspection CCP was unable to 

demonstrate adequately the ability of ISOCS to characterize this isotope. 238Pu characterization is 

discussed in a subsequent section.

Table 3. ISOCS Results for RH Waste Stream SR-RH-235F.01 (in Ci)

Container 239Pu 240Pu 241Pu 242Pu 241Am 237Np 137Cs

SR513062 9.86E-06 3.83E-01 8.41E-02 3.28E-05

SR518761 6.33E-02 5.40E-02

SR520707 5.03E-02 5.30E-02

SR501117 6.89E+01 3.18E-06 7.09E+00 1.17E-02

SR504231 1.16E00 7.18E00 1.53E-05 2.71E+01 1.08E-03

SR518755 3.80E-01 7.11E-04 1.30E+00 1.69E-04 5.29E-05

SR518716 4.06E-01 9.18E+00 5.27E-04 4.97E-01 5.46E-05

Source: CCP-RC-SRS-561, Revision 0.

The blank cells in the table indicate that the radionuclide was not detected in the assay. As shown

in Table 3, not all radionuclides were detected in each drum’s assay. If ISOCS detected a

radionuclide in the drum, that isotope was scaled to 241Am. Scaling factors generated from 

ISOCS results are listed in Table 4. If ISOCS did not detect a particular isotope, SRS-CCP used 

historical CH assays to generate scaling factors [see Item (3) below].

Table 4. ISOCS Scaling Factors for RH Waste Stream SR-RH-235F.01

Container 239Pu/241Am 240Pu/241Am 241Pu/241Am 242Pu/241Am 241Am/241Am 237Np/241Am 137Cs/241Am

SR513062 2.57E-05 1.00E+00 2.20E-01 8.56E-05

SR518761 1.00E+00 8.53E-01

SR520707 1.00E+00 1.05E+00

SR501117 9.72E+00 4.49E-07 1.00E+00 1.65E-03

SR504231 4.28E-02 2.65E-01 5.65E-07 1.00E+00 3.99E-05

SR518755 2.92E-01 5.47E-04 1.00E+00 1.30E-04 4.07E-05

SR518716 8.17E-01 1.85E+01 1.06E-03 1.00E+00 1.10E-04

Source: SRS-RH-48, Revision 1.

Additionally, SRS-CCP used ISOCS results to identify the origin of each drum. The acceptable 

knowledge summary report indicates that waste from CH Waste Stream SR-W027-235F-HET 

came from two major activities: (1) 238Pu heat source fabrication and (2) 237Np target fabrication. 

Based on what is known about these processes, waste from 237Np target fabrication would be 

expected to have a low 239Pu/237Np ratio (10 or less), while heat source material would be 

expected to have a larger ratio (2,100). Because 239Pu was not detected in four drums 

(Nos. SR513062, SR518761, SR520707 and SR501117), they can be classified as originating 

from 237Np target production. The remaining three drums (Nos. SR504231, SR518755 and

SR518716) have 239Pu/237Np ratios ranging from 1,070 to 7,440, and these drums can be 

classified as originating from heat source fabrication. These classifications are used to better 

characterize scaling factors obtained through the use of historical CH data.
12

(3) Use of nondestructive assay data from CH Waste Stream SR-W027-235F-HET to 

develop scaling factors for uranium isotopes, unmeasured plutonium isotopes and fission 

products, including cesium, was found to be technically adequate and correctly 

documented.

SRS Waste Stream SR-W027-235F-HET is the CH equivalent of RH Waste Stream SR-RH235F.01, and all seven 55-gallon RH drums in Waste Stream SR-RH-235F.01 were originally 

generated and managed as part of the CH waste stream. They fell out of the waste stream when 

drum contact dose readings met or exceeded the contact dose rate limits of 200 mrem/hr. As 

such, these RH drums are assumed to have the same ratios of radionuclides as the CH drums 

generated from the same two dominant processes (

238Pu heat source fabrication and 237Np target 

fabrication), as stated in Item (2) above. This assumption is the basis for using historical CH 

assays to derive the ratios of Pu, U and fission products to 241Am for RH drums. 

Approximately 1,072 CH assay records from Waste Stream SR-W027-235F-HET were available 

at the time CCP-AK-SRS-560 was completed. SRS-CCP selected a subset of assays to represent 

wastes generated from Np-target and Pu heat source production. The 239Pu/237Np ratios from the 

CH assays were used to identify drums most similar to the seven RH drums. SRS-CCP selected 

drums that had ratios ranging from 1.5 through 21 to represent 237Np target material. Drums with 

ratios ranging from 2,000 to 8,000 represented heat source materials. This selection process

resulted in 11 CH drums representing 237Np target waste (hereafter referred to as “the 11-drum 

subset”) and 119 drums representing heat source materials (hereafter referred to as “the 119-

drum subset”). SRS-CCP chose to use these two subsets of CH Waste Stream SR-W027-235FHET (hereafter referred to as “the 130-drum subset”) on the assumption that they would most 

accurately reflect the distribution of radionuclides in the seven drums in Waste Stream SR-RH235F.01. All 130 assays in the 130-drum subset were decay and in-growth corrected from their 

date of assay to a reference date of May 15, 2012, to better reflect the current contents of the 

drums.

Due to the complexities of the waste, each radionuclide scaling factor was calculated separately. 

Table 5 summarizes scaling factors derived from CH data. Blanks cells in the table represent 

scaling factors derived through ISOCS measurements.
13

Table 5. RH Scaling Factors Based on CH Nondestructive Assay Data

Radionuclide Np Target Waste Drums Heat Source Waste Drums

SR513062 SR518761 SR520707 SR501117 SR504231 SR518755 SR518716

U-233 3.52E-02 3.52E-02 3.52E-02 3.52E-02 3.52E-02 3.52E-02 3.52E-02

U-234 1.16E-03 1.16E-03 1.16E-03 1.16E-03 1.55E-01 1.55E-01 1.55E-01

U-235 9.69E-06 9.69E-06 9.69E-06 9.69E-06 9.69E-06 9.69E-06 9.69E-06

U-238 1.13E-04 1.13E-04 1.13E-04 1.13E-04 1.13E-04 1.13E-04 1.13E-04

Pu-238 3.25E+00 3.25E+00 3.25E+00 3.25E+00 8.57E+02 8.57E+02 8.57E+02

Pu-239 3.04E-01 3.04E-01 3.04E-01 3.04E-01

Pu-240 2.34E-01 2.34E-01 2.34E-01 2.34E-01 3.88E-01 3.88E-01

Pu-242 1.61E-06 1.61E-06

Am-241

Np-237

Sr-90 8.56E-05 5.55E-06 5.55E-06 5.55E-06 1.83E-03 4.07E-05 1.83E-03

Cs-137 5.55E-06 5.55E-06 5.55E-06 1.83E-03 1.83E-03

Source: SRS-RH-48, Revision 1.

Uranium Isotopes (excluding 234U)

SRS-CCP expected U in trace quantities in this waste stream because of the nature of the wasteproducing processes. Less than 5% of the CH assays in Waste Stream SR-W027-235F-HET had 

positive values for U. To develop the scaling factors, SRS-CCP used the entire 11-drum subset to

represent 237Np target material and randomly selected 15 drums from the 119-drum subset to 

represent heat source material. The MDA values of 235U, 233U and 238U in each of these 26 drums 

(hereafter referred to as “the 26-drum subset”) were divided by that drum’s decay-corrected 

241Am value. When an assay did not have detectable levels of a radionuclide, the average MDA 

for that radionuclide was applied to that sample. Although an MDA does not represent a drum’s 

true radionuclide concentration, its use allows an upper end estimate of the drum’s content. The 

use of this value eliminates underestimation of true averages due to the measurement system’s 

limitations. For the 26-drum subset, drum-specific scaling factors for each isotope were then 

averaged geometrically to produce an average,

241Am-based scaling factor for 235U, 233U and 

238U. These averaged MDA scaling factors were then applied to every non-measured 

corresponding uranium isotope in the 130-drum subset (the 11-drum subset representing 237Np 

target material plus the 119-drum subset representing heat source material). The 130-drum subset 

was then arithmetically averaged per isotope to develop a set of 241Am-based U scaling factors.

Plutonium, 234U and 137Cs

When Pu isotopes (excluding 238Pu) and/or 137Cs were not detected above the MDA on the 

ISOCS, CH data were used to bound the content of a drum. Heat source and Np target waste

scaling factors are generated differently for the Pu isotopes, 234U and 137Cs. Each is discussed 

below:
14

Heat Source Scaling Factors

All scaling factors for each radionuclide in the 119-drum subset of the CH waste stream were 

conservatively assumed to be normally distributed for the heat source material. The 231Am-based

scaling factors for each drum in the 119-drum subset were averaged. Drums without reported 

values for any specific radionuclide were treated as blanks rather than zeros in averaging. This

provides a conservative bounding of the drum’s radionuclide contents.

Neptunium Target Scaling Factors

The scaling factors for 238Pu, 239Pu and 240Pu in the 11-drum subset of the CH waste stream were 

found to be normally distributed for the 237Np target material. The 241Am-based scaling factors 

for each drum in the 11-drum subset were averaged for 238Pu, 239Pu and 240Pu. Drums that did not 

have reported results for any specific radionuclide were treated as blanks rather than zeros in 

averaging. This technique bounds the potential content of drums. SRS-CCP found that the 

scaling factors for 241Pu, 242Pu, 234U and 137Cs were not normally distributed. This required SRSCCP to take the arithmetical average of 241Pu, 242Pu, 234U and 137Cs to derive the 241Am generated

scaling factors for each drum in the 11-drum subset. This technique minimizes the effects of 

extreme values on both ends of the distribution.

Strontium

The NDA system does not directly measure 90Sr; its contribution is inferred by assuming a oneto-one ratio with 137Cs. This is a common practice in determining RH scaling factors because the 

isotopes are both fission products.

(4) Computer modeling to develop the dose-to-curie correlation was evaluated and was 

found to be adequate.

SRS-CCP used MCNP5 to develop the DTC correlation for a 55-gallon drum filled with debris 

waste and its external dose rate at one meter. The computer modeling was based on the 

assumption that either a one-Ci source of 241Am or a one-Ci source of 237Np (just one source in 

each model) was uniformly distributed within the drum, that the only significant gamma emitters

were

241Am and 237Np, and that contributions of europium-154, cobalt-60 or other gamma 

emitters were negligible. Using the scaling factor of 237Np, the waste density and the DTC

correlations, and dose partitioning allows calculation of the dose and activity from 241Am. The 

241Am activity is then used with the 241Am-based scaling factors to determine the activities of the 

radionuclides of interest. Each drum’s MCNP5 results are documented in Calculation Package 

SRS-RH-53. 

The use of any method to determine scaling factors other than those documented in 

CCP-RC-SRS-561 is a T1 change. (See Table 1.)

(5) Execution and documentation of the dose-to-curie technique was assessed and found to 

be adequate.

EPA observed the DTC technique on August 30, 2011, in the DTC alcove located in Area E, 

Pad 4, as part of the RH baseline inspection at SRS. The DTC process for the actual drums in the 
15

waste stream was performed on August 31, 2011, as documented in the SRS RH baseline 

inspection report.

The use of any alternate radiological characterization procedure other than DTC with procedure 

CCP-TP-504 in conjunction with scaling factors documented in CCP-RC-SRS-561, or 

substantive modification thereof, continues to be a T1 change. (See Table 1.)

(6) Radionuclide documentation in dose-to-curie batch data reports was assessed and found

to be adequate.

The DTC results for all containers were documented in BDR No. SRSRHDTC11003. The EPA 

inspection team verified that the BDR included the following:

Site Project Manager checklist, Attachment 8.

BDR cover sheet, Attachment 4.

BDR table of contents, Attachment 5.

BDR narrative summary, Attachment 6.

Independent Technical Reviewer review checklist, Attachment 7.

Measurement control rreport with all parameters acceptable.

Container data sheets, Attachment 2.

Concentrations and corresponding uncertainties for all WIPP-tracked radionuclides.

Waste container DTC conversion records with all required parameters, Attachment 3.

Evidence of signatures by the Independent Technical Reviewer on Attachment 7 and a 

Site Project Manager on Attachment 8.

Type of waste in each container (organic and inorganic) in Attachment 3.

TRU determination for all containers in Attachment 3.

Correct revision of CCP-TP-504 (i.e., Revision 13).

The BDR was technically adequate. 

(7) Remote-handled determinations were evaluated and found to be adequate.

SRS personnel measured contact dose rates, and SRS-CCP provided the dose rate survey sheets 

for all seven drums of Waste Stream SR-RH-235F.01. EPA reviewed these SRS records, which

indicated that each container in the waste stream was RH (i.e., had a contact dose rate in excess 

of 200 mrem/hr). The contact dose rate readings for all seven containers represent the values at a 

distance of five centimeters, which is adequate for the purpose of this review. These values are 

shown in Table 6. 
16

Table 6. Summary of Remote-Handled Dose Rate Determinations

Drum 

Number

Contact Dose Rate 

(mrem/hr)

Measurement 

Date

SR513062 274 3/20/2009

SR518761 200 11/24/2008

SR520707 220 12/14/2009

SR501117 250 12/2/2009

SR504231 240 6/8/2009

SR518755 350 6/26/2008

SR518716 210 10/10/2006

Source: Radiological Survey Reports, October 10, 2006–December 14, 2009.

(8) Transuranic determinations were evaluated and were found to be adequate.

The DTC BDR No. SRSRHDTC11003 contained activity and mass values with the associated 

uncertainties for the 10 WIPP-tracked radionuclides plus other radionuclides, as appropriate. In 

all cases, the TRU alpha concentration exceeded 100 nanocuries per gram.

(9) The technical basis and documentation of total measurement uncertainty were evaluated 

and found to be adequate.

The development of total measurement uncertainty (TMU) for Waste Stream SR-RH-235F.01 is 

based on the propagation of uncertainties present in the determination of the waste stream’s 

radiological constituents. These aspects are assumed to be independent, which allows them to be 

added in quadrature.5The TMU determination included contributions of the following:

241Am DTC correlation—uncertainties due to MCNP® code, waste mass and source 

distribution within drum, and waste density.

241Am activity measurement—dose rate measurement uncertainty and uncertainty due to

the contribution of other gamma-emitting radionuclides.

Scaling factor uncertainty—ISOCS modeling uncertainties, waste density uncertainties 

and scaling factor uncertainty in CH data.

A general treatment of TMU for Waste Stream SR-RH-235F.01 is presented in CCP-RC-SRS561, Section 5, and the detailed treatment of TMU is provided in “Uncertainty Analysis for SRRH-235F.01,” Calculation Package SRS-RH-52. The overall uncertainties are consistent with 

what EPA has observed for RH determinations at other RH TRU generator sites. TMU varies 

slightly from drum to drum because scaling factors are developed on an individual drum basis. 

Table 7 provides an example of the TMU calculation for Drum No. SR513062.

 

5 Adding in quadrature is a standard statistical technique that allows one to combine the square root of the 

sum of each contributor to uncertainty squared, resulting in a lower value than what would be obtained if the values 

were simply added. For example, the TMU for 239Pu is derived by taking the square root of (25.0%)2plus (10%)2

plus (26.9%)2plus (93.3%)2plus (7.8%)2plus (30.1%)

2

, which equals 105.5%, which is less than the value obtained 

by simply summing the individual uncertainty values (i.e., 193.1%, as shown in Table 7).
17

Table 7. Overall Uncertainty of Example Drum No. SR513062

Radionuclide

Uncertainty 

in Dose Rate 

Measurement

MCNP5 

Code 

Uncertainty

Uncertainty 

of DTC 

Model

Uncertainty 

in Scaling 

Factors

Uncertainty 

in Waste 

Density

Uncertainty 

in Gamma

TMU

233U 25% 10.0% 26.9% 100.0% 7.8% 30.1% 111.4%

234U 25% 10.0% 26.9% 758.9% 7.8% 30.1% 760.5%

235U 25% 10.0% 26.9% 108.2% 7.8% 30.1% 118.8%

238U 25% 10.0% 26.9% 64.5% 7.8% 30.1% 81.0%

238Pu 25% 10.0% 26.9% 78.0% 7.8% 30.1% 92.1%

239Pu 25% 10.0% 26.9% 93.3% 7.8% 30.1% 105.5%

240Pu 25% 10.0% 26.9% 69.6% 7.8% 30.1% 82.5%

242Pu 25% 10.0% 26.9% 104.6% 7.8% 30.1% 115.7%

237Np 25% 10.0% 26.9% 32.2% 7.8% 30.1% 58.9%

241Am 25% 10.0% 26.9% 0.0% 7.8% 30.1% 49.1%

90Sr 25% 10.0% 26.9% 35.2% 7.8% 30.1% 60.4%

137Cs 25% 10.0% 26.9% 35.2% 7.8% 30.1% 60.4%

90Y 25% 10.0% 26.9% 35.2% 7.8% 30.1% 60.4%

137mBa 25% 10.0% 26.9% 35.2% 7.8% 30.1% 60.4%

Source: SRS-RH-52, Revision 1.

7.0 FINDINGS AND CONCERNS

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

Waste Stream SR-RH-235F.01 during this T1 change evaluation. There are no open issues 

relative to this T1 evaluation.

8.0 CONCLUSIONS

Changes to Tiering

As a result of this evaluation, EPA has made one substantive change to the SRS-CCP 

radiological characterization T1 designations shown in Table 1 of this report. Table 1 of the EPA 

baseline inspection report limited use of the MCS/ISOCS to providing relative determinations of 

239Pu, 240Pu and 241Pu to 241Am; any other relative determination was identified as a T1 change 

that required EPA approval before implementation. Based on the technical merit of information 

reviewed during this T1 evaluation, EPA approves the SRS-CCP MCS/ISOCS to measure RH 

TRU wastes irrespective of the radionuclides being measured and confirmatory measurements 

are not required. Essentially, the MCS/ISOCS is an approved measurement modality for RH 

TRU wastes at SRS limited to providing relative determinations of gamma-emitting 

radionuclides for use as scaling factors. Use of the MCS/ISOCS to provide any information other 

than the relative determinations of gamma-emitting radionuclides for use as scaling factors is a 

new T1 change. The technical bases for the derivation of the radionuclide-specific scaling factors 

that are used in conjunction with the MCS/ISOCS are still subject to evaluation as a T1 change. 

Use of the MCS/ISOCS for direct quantification of RH TRU wastes for WIPP disposal is not 

approved.

EPA also made minor modifications to Table 1 as part of EPA’s ongoing efforts to harmonize 

the format and language of the tiering tables for all RH waste characterization programs. All the 
18

T1 and T2 changes that were established during the baseline approval remain in effect and are 

listed as applicable in section 6.0.

Approval

This T1 change consisted of the radiological characterization process used to characterize SRS

Waste Stream SR-RH-235F.01 using DTC and scaling factors generated through use of the 

MCS/ISOCS and historical assays of companion CH debris waste streams (see footnote 1) for 

assigning radionuclide values. Based on the results of this evaluation, EPA approves this T1 

change consistent with the limitations specified in this report. SRS-CCP may continue to 

characterize RH debris waste streams that have companion CH waste streams using RTR to 

identify the waste material parameters and the radiological characterization approach approved 

during the baseline approval and expanded upon during this T1 evaluation (see EPA Docket No. 

A-98-49; II-A4-161). 

EPA also approves the SRS-CCP MCS/ISOCS to measure RH TRU wastes irrespective of the 

radionuclides being measured. Essentially, the MCS/ISOCS is an approved measurement 

modality for RH TRU wastes at SRS limited to providing relative determinations of gammaemitting radionuclides for use as scaling factors. The technical bases for the derivation of the 

radionuclide-specific scaling factors that are used in conjunction with the MCS/ISOCS are still 

subject to evaluation as a T1 change. Use of the MCS/ISOCS for direct quantification of RH 

TRU wastes for WIPP disposal is not approved.
A-1

ATTACHMENT A

APPROVAL SUMMARY FOR SAVANNAH RIVER SITE REMOTE-HANDLED 

WASTE CHARACTERIZATION PROGRAM

Approved Activity EPA Inspection Number, Approval Dates EPA Docket Number

SRS RH Baseline Approval EPA-SRS-CCP-RH-08.11-8,April 2012 A-98-49; II-A4-161
B-1

ATTACHMENT B

LIST OF DOCUMENTS REVIEWED BY EPA DURING THE T1 EVALUATION

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

Characterization Technical Report for Savannah River Site Remote-Handled Transuranic Debris 

Waste, Waste Stream: SR-RH-FBL.01, Revision 0, August 11, 2011 

CCP-AK-SRS-6 NDA Memo from Jeff Harrison, CCP AKE, to CCP Central Records, Re: 

Evaluation of the Radiological Characterization of Savannah River Site Waste Stream 

SR-W027-235F-HET, Revision 2, July 26, 2007

CCP-RC-SRS-561, Central Characterization Program Remote-Handled Transuranic Radiological 

Characterization Technical Report for Savannah River Site Remote-Handled Transuranic Debris 

Waste, Waste Stream: SR-RH-235F.01, Revision 0, October 18, 2012; Revision 1, draft

CCP-TP-504, Dose-to-Curie Survey Procedure for Remote-Handled Transuranic Waste, 

Revision 13

DTC BDR No. SRSRHDTC11003, November 5, 2012

MCS ISOCS Report, ISOCS DTC-RH Waste Drums, SRS Submittal #121511, data from ISOCS 

measurements performed December 8–15, 2011

MCS ISOCS Report, ISOCS DTC-RH Waste Drums, SRS Submittal #022212, data from ISOCS 

measurements performed February 20–22, 2012

Radiological Survey Reports for Drum Nos. 773A020001, 773A060006, SR108108, SR108112, 

SR110756, SR110845, SR118870, SR410740, SR501028, SR501504, SR501634, SR501918, 

SR502509, SR502512, SR503550, SR503732, SR504233, SR504242, SR504716, SR505616, 

SR506901, SR509714, SR510588, SR512002, SR512011, SR512190, SR513049, SR513217A, 

SR513779, SR514465A, SR514725, SR515078, SR515079, SR516716, SR518755, SR518781, 

SR520707, SR524227, SR526215, SR526627, SR526767, SR570546, SR80930, SR90971, 

SR97970, SR98029A, SR98042, SR98064 and SR98089, dates ranging June 26, 2008–

December 14, 2009

U002, Mark 61 Target Fabrication Process Description for Initial Production, J.M. Boswell, et 

al., E.I. du Pont de Nemours & Company, DPST-70-277, March 11, 1970 

U003, CCP Calculation Package: DTC Values and Sensitivity Studies for 580, J. Vance, 

SRS-RH-43, Revision 1, December 6, 2011

U010, CCP Calculation Package: Determination of Scaling Factors for SRS-560 Drums, D. Ott, 

SRS-RH-48, Revision 0, September 9, 2012; Calculation spreadsheet provided November 29, 

2012; Revision 1, January 11, 2013; Calculation spreadsheet provided January 22, 2013

U011, CCP Calculation Package: Determination of Reportable Radionuclides, D. Ott, SRS-RH49, Revision 0, September 8, 2012; Calculation spreadsheet provided November 29, 2012
B-2

U012, CCP Calculation Package: DTC and Related Calculations for SR-RH-235F.01, D. Ott, 

SRS-RH-50, Revision 2, October 25, 2012; Calculation spreadsheet provided November 29, 

2012; Revision 3, January 11, 2013; Calculation spreadsheet provided January 20, 2013

U014, CCP Calculation Package: Uncertainty Analysis for SR-RH-235F.01, D. Ott, SRS-RH-52, 

Revision 0, October 11, 2012; Calculation spreadsheet provided November 29, 2012; Revision 1, 

January 11, 2013; Calculation spreadsheet provided January 20, 2013

U015, CCP Calculation Package: DTC Modeling and Sensitivity Studies for SRS RH Debris 

Waste, D. Ott, SRS-RH-53, Revision 0, September 9, 2012; Calculation spreadsheet provided 

November 29, 2012
C-1

ATTACHMENT C

TIERING TABLE FROM BASELINE REPORT (SUPERSEDED, SEE TABLE 1)

Tiering of RH TRU Waste Characterization Processes Implemented by SRS-CCP (April 2012)

(Based on August 20–September 1, 2011, and December 6–7, 2011, Baseline Inspection)

RH Waste 

Characterization Process 

Elements

SRS-CCP RH Waste Characterization Process – T1 Changes SRS-CCP RH Waste Characterization Process – T2 Changes*

Acceptable Knowledge Any new RH S3000 or S4000 waste stream (AK Summary)

Any new RH S5000 waste stream that does not have a companion CH waste 

stream (AK Summary)

Substantive modification(s)** to CCP-AK-SRS-580 or CCP-AK-SRS-582 that 

have the potential to affect the characterization process (AK2, AK6)

Any new RH S5000 waste stream that does have a companion CH waste stream 

(AK Summary)

Notification to EPA: 

Upon completion of revisions to CCP-AK-SRS-580, CCP-AK-SRS-582, 

CCP-TP-005, or nonconformance and corrective action procedures that 

require CBFO approval*** (AK2, AK5, AK6)

Upon completion of revisions to any CCP-TP-005 attachments, including 

when Attachment 4 is generated to reflect the updated AKSR Source 

Document Reference List (AK5, AK11)

When the final or revised WSPF, CIS, CRR and related attachments are 

available and upon completion of any subsequent revisions to these 

documents (AK10)

When AK accuracy reports are completed, prepared annually at a minimum 

(AK11)

When Add Container Memoranda have been prepared (AK5)

When additional discrepancy resolution reports and nonconformance reports 

have been prepared (AK4)

Radiological Characterization, 

including Dose-to-Curie 

Use of the MCS/ISOCS to provide any information other than the relative 

determinations of 239Pu, 240Pu and 241Pu to 241Am (RC2)

Future use of the ORTEC/ISOCS for any RH TRU waste (RC2)

Application of a new scaling factor processes for isotopic determination other than 

those documented in CCP-AK-SRS-581, Revision 1 (applies to new RH waste 

streams and to the addition of containers to an approved waste stream) (RC1, RC4, 

RC5)

Substantive modification(s)** to CCP-TP-504 or CCP-AK-SRS-581 that have the 

potential to affect the characterization process (RC4, RC5)

Any new RH waste stream characterized using an approved scaling factor process 

for isotopic determination (RC Summary)

Notification to EPA upon completion of revisions to CCP-AK-SRS-581 or 

CCP-TP-504 that require CBFO approval*** (RC1, RC5)

Notification to EPA when calculation package(s) CCP-SRS-44, or equivalent 

record(s), are available (RC Summary)

Real-Time Radiography RTR by any new process (RTR Summary) Notification to EPA upon completion of changes to RTR procedure(s) that require 

CBFO approval*** (RTR1)

Addition of a new SCG to any approved RTR process (RTR2)

Notes:

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

** Substantive modification refers to a change with the potential to affect SRS-CCP’s RH waste characterization process; e.g., the use of an inherently different type of 

measurement instrument or the use of probes not described in CCP-TP-504, excluding changes related solely to safety or to address administrative concerns.

*** Notification to EPA is not necessary when document updates are editorial in nature or are required solely to address administrative concerns