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 S TREAM 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 201 3i TABLE OF CONTENTS Section Page 1.0 Introduction

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

................................ ................................ .............................. 4 3.0 Purpo se 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

- Handl ed 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 INITIAL IZATIONS AK acceptable knowledge AKSR acceptable knowl edge 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 Recon ciliation 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

Coll ection, 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 RC TR radiological characteriza tion technical report RH remote

- handled RTR real

- time radiographyiii

SCG summary category group SF scaling factor Sr strontium SRS Savannah River Site T1 Tier 1 T2 Tier 2 TMU t otal m easurement u ncertainty TRU transuranic U uranium WIPP Waste Isolation Pilot P lant WSPF Waste Stream Profile Form Y yttrium1

1.0 INTRODUCTION This report supports the U.S. Environmental Protection Agency’s (EPA’s) approv al of a Tier 1 (T1) change to add Waste Stream SR

- RH

- 235F.01 to the approved characterization program at the U.S. D epartment 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 expa nding the approval of the Mobile Characterization Services ( MCS ) / In Situ Object Counting System (ISOCS) to include provid ing the relative determinations of gamma

- emitting radionuclides irrespective of the radionuclides being measured, according to the limi tations 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: companion 1 contact

- handled (CH) debris waste streams;
a radiological characterization process that us es: o dose

- to

- curie ( DTC ); and
o scaling factors generated through use of the MCS/ ISOCS 2 ; 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 ha ve 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

- 5 6 1, “Central Characterization P rogram Remote

- H andled Transuranic Radiological Characterization

1 A companion CH waste stream has the same summary category group , same waste stream definition, and same radiological and physical prope rties 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 ( m r em/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

. T he I SOCS 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 deskt op 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 i s 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

- RC

SRS

- 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 pac kages. 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, E PA has made one substantive change to the SRS

- CCP radiological characterization T1 designations shown in Table 1 below

. Table 1 of th e EPA baseline inspection report limited u se of the MCS/ ISOCS to providing relative determinations of plutonium

- 239 ( 239 Pu) , 240 Pu and 241 Pu to americium

- 241 ( 241 Am) ; any other relative determination was identified as a T1 change that require d EPA approval before implementation

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

- CCP MCS/ISOCS to measure RH TRU wastes irrespective of t he 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 b ases 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 . U se of the MCS/ISOCS for direct quantification of RH TRU wastes for WIPP disposal is not ap proved. 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 no t 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).3

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 S RS - 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 strea m Substantive modification** to EPA

- approved AKSRs and certification confirmation tes t 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 C H 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/IS OCS 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 is otopic 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

- 5 04, 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 si te 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 re lated to the environment, safety and health; nuclear safety; or the Resource Conservation and Recovery Act, or that are editorial in n ature 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 EV ALUATIONS 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 f

orth 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 compo nents, 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 evaluat e 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 o r 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 REPO RT This report presents the results of EPA’s evaluation of a T1 chang e to add Waste Stream SR

- RH

235F.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 th is 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 3 090 Carlsbad, NM 88221

- 30905

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 ( 237 Np) . Section 6. 0 of this report detail s the radiological characterization technical elements assessed during this evaluation. 5.0 EPA EVALUATION PERSO NNEL The EPA evaluation team members consisted of the personnel liste d 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 Evalu ator

– Radiological Characterization, SC&A Patrick Kelly Technical Evaluator

– Radiological Characterization, SC&A Amir Mobasheran Technical Evaluator

– Radiological Characterization, SC&A 6.0 RADIOLOGICAL CHARACT ERIZATION TECHNICAL EVALUATION RH Wast e 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 in cluded 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 , therefor e , were assigned to RH TRU Waste Stream SR

RH

- 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

- 5 61 , 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 r evised 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 list s 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

- 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 T2 changes to EPA for review and concurrence. Waste Characterization Elem ent Description EPA evaluated t he 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 perso nnel 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 sur face of drum using a one

- curie ( Ci ) source of 241 Am and a one - Ci source of 237 Np , assumed to be the main contributor s to the dose

. Derivation of radionuclide scaling factors using isotopic ratios found through ISOCS assays and isotopic distributions from h istorical assays of companion CH W aste S tream 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 i nspection 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 th e 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 241 Am , correlat ing a drum’s external exposure (dose) rate a nd 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: Developmen t of 241 Am

- based scaling factors for 239 Pu, 240 Pu, 241 Pu, 242 Pu, 237 Np and cesium

- 137 ( 137 Cs ) based on ISOCS measurements when detected

.7

Historical information (AK) for CH Waste Stream SR

- W027

- 235F

- HET , as summarized in CCP

- AK

- SRS

- 560 4 and associated sourc e documents

. W hen isotopes are not detected by ISOCS , d evelopment of scaling factors for 238 Pu, 239 Pu, 240 Pu, 241 Pu, 242 Pu , uranium

- 233 ( 233 U ) , 234 U, 238 U, 137 Cs and strontium

- 90 ( 90 Sr ) based on past assays of the RH waste stream’s CH counterpart, Waste S tream SR

- W027

- 235F

- HET , and assumptions about the waste ’ s origins

. MCNP5 modeling to determine the correlation between the amount of 241 Am and 237 Np in each drum and the drums dose rate s at one meter
. Direct exposure rate measurements (DTC) of each waste drum

. The EPA inspection team prepared two flow diagram s 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 appropr iately documented. Any new RH waste stream not approved to date or the addition of containers to Waste Stream SR

RH

- 235F.01 that requires changing the established process of radiological characterization from wha t is documented in CCP

- RC

- SRS

- 56 1 is a T1 ch ange. (See Table 1 .) Any change to CCP

RC

- SRS

- 5 6 1 that requires CBFO approval is a T2 change. (See Table 1 .)

4 “Central Characterization Project Acceptable Knowl edge 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 measu re SFs of each RH drum for 239 Pu, 240 Pu, 24 1 Pu, 242 Pu, 237 Np and 137 C s to 241 Am

Use 239 Pu/ 237 Np ratio to d etermine if drum contains heat

- source ( 238 Pu

- dominant) waste or a non - heat

- source ( 237 Np

- dominant) waste Identify two subsets of drums in the CH database with ratios of 239 Pu/ 237 Np expected in Np target and HS was te Compile SFs unique to each drum MDA values for 233 U, 235 U and 238 U 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 241 Am

If detected:

Shapiro

- Wilkes Test found Pu isotopes, 137 Cs and 234 U 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 137 Cs , 234 U and 242 Pu 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 

### Uran ium SFs Development:

ISOCS - Derived SFs:

CH Database Derived SFs:

Source: Based on SRS

- RH

- 48, Revision 0 Figure 1 . Scaling Factor Development Flow Diagram9 Sour ce: Based on SRS

- RH

- 48 Rev 0 Source: Based on CCP

- RC

- SRS

- 561, Revision 0 U se MCNP5 to separately model the 1

- meter dose rate s from the 55

- gall on drum surface, based on a 1

- Ci source of 241 Am and 1

- Ci source of 237 Np

Develop the DTC conversion factors (mR/hr/Ci) as a function of the waste density for 241 Am

Execute DTC to derive the 241 Am activity in curies

Multiply the 241 Am activity by the SFs to determine activities of other radionuclides

Determine th e uncertainties in radionuclide activities and masses Develop drum

specific scaling factors, see Figure 1

Figure 2 . Radiological Characterization Flow Diagram10

(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 p ortable 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 co ntains 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 specif ic 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 con tainer 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 ISO CS has considerable flexibility ; i.e., the same unit could measure a 5

- ga llon 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 I n S itu O bjec t C ounting S ystem EPA previously approved a n 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 241 Am for 239 Pu, 240 Pu and 241 Pu

. These meas urements were confirmed by measurements done on an approved CH NDA system. For RH W aste S tream SR

- RH

- 235F.01 , SRS

- CCP use d ISOCS measurements to scale the previously approved isotopes ( 239 Pu, 240 Pu and 241 Pu ) to 241 Am

. It also scaled 242 Pu, 237 Np and 137 Cs to 241 Am when they wer e detected in levels above the minimum detectable activ ity ( MDA )

. SRS

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

. Because 242 Pu and 237 Np 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 contribute s significantly to the rad iological hazard of the drum

. 137 C s is a WIPP

- tracked radionuclide with a strong gamma emission that is easy to detect. EPA has previously reviewed the ISOCS s pecifications (see the SRS baseline inspection report) and finds it unnecessary to confirm the additional radionuclides ( i.e., 242 Pu and 237 Np )

.11

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

. 238 Pu was also detected in five drums; however, in the baseline inspection CCP was unable to demonstrate adequately the ability of ISOCS to characterize th is isotope. 238 Pu characterization is discussed in a subsequent section

.

Table 3 . ISOCS Results for RH Waste Stream SR - RH - 235F.01 ( in Ci) Container 239 Pu 240 Pu 241 Pu 242 Pu 241 Am 237 Np 137 Cs 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 3.18 E

- 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 S ource: CCP

- RC

- SRS

- 561, Rev ision 0

. The b lank cells in the ta ble indicate that the radio nuclide was not detected in the assay. As shown in Table 3 , not all radionuclide s were detected in each drum’s assay. If ISOCS detected a radio nuclide in the drum, that isotope was scaled to 241 Am. Scali ng 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 . ISO CS Scaling Factors for RH Waste Stream SR - RH - 235F.01 Container 239 Pu/ 241 Am 240 Pu/

241 Am 241 Pu/

241 Am 242 Pu/

241 Am 241 Am/

241 Am 237 Np/

241 Am 137 Cs/

241 Am SR513062 2.57E

- 05 1.00E+00 2.20E

- 01 8.56E

- 05 SR518761 1.00E+00 8.53E

- 01 SR520707 1.00E+00 1.0 5E+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, Rev ision 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) 238 Pu heat source fabrication and (2) 2 37 Np target fabrication. Based on what is known about these processes, waste from 237 Np target fabrication would be expected to have a low 239 Pu/ 237 Np ratio (10 or less) , while heat source material would be expecte d to have a larger ratio (2 , 100). Because 239 Pu was not detected in four drums ( Nos. SR513062 , SR518761, SR520707 and SR501117) , they can be classified as originating from 237 Np target production. The remaining three drums ( Nos. SR504231, SR518755 and SR518716) have 239 Pu/ 237 Np ratios ranging from 1 , 070 to 7 , 440 , and t hese 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 c esium, was found to be technically adequate and correctly documented. SRS Waste Stream SR

- W027

- 235F

- HET is the CH equivalent of RH W aste Stream SR

- RH

235F.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 exce eded the contact dose rate limits of 200 m rem /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 ( 238 Pu heat source fabrication and 237 Np target fabrication ), as s tated 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 241 Am for RH drums

. Approximately 1,072 CH assay records from Waste Stream SR

- W027

- 235F

- HET were available at the t ime 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 239 Pu/ 237 Np ratio s from the CH assays were used to identify drums most similar to the seven RH drums. SRS

- CCP selected d rums that ha d ratios ranging from 1.5 through 21 to represent 237 Np target material. Drums with ratios ranging from 2 , 000 to 8 , 000 represent ed heat source materials. This selection process resulted in 11 CH drums representing 237 Np target was te (hereafter referred to as “the 11

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

- drum subset”)

. SRS

- CCP chose to use t h ese two subset s of CH Waste St ream SR

- W027

- 235F

HET (hereafter referred to as “the 130

- drum subset”) on the assum ption that they would most accurately reflect the distribution of radionuclides in the seven drums in Waste Stream SR

- RH

235F.01. All 130 assays in the 130

- drum subset were decay and in

- growth corrected from their date of assa y 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 s caling factors derived from CH data. Blanks c ells in the table represent scaling factors derived through ISOCS measurements.13 Table 5 . RH Scaling Factors Based on CH N ondestructive A ssay Data Radionuclide Np Target Waste Drums H eat S ource Waste Drums

SR513062 SR518761 SR5207 07 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 1.6 1E

- 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, Rev ision 1

. Uranium I sotopes (excluding 234 U) SRS

- C CP expected U in trace quantities in this waste stream because of the nature of the waste

producing 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 237 Np target material and randomly selected 15 drums from the 119

- drum subset to represent heat source material. The MDA values of 235 U, 233 U and 238 U in each of these 26 drums (hereafter referred to as “the 26

- drum subset”) we re divided by th at drum ’ s decay - corrected 241 Am value. When an assay did not have detectable levels of a radionuclide, the average MDA f or that radionuclide was applied to that sample. Although an MDA do es not represent a drum ’s true radion uclide concentra tion, its use allows an upper end estimate of the drum ’ s content . The use of this value eliminates underestimat ion of true averages due to the measurement system’s limitations

. For the 26

- drum subset , d rum - specific scaling factors for each isotope were the n averaged geometrically to produce an average , 241 Am

- based scaling factor for 235 U, 233 U and 238 U

. These averaged MDA scaling factors were then applied to every non

- measured corresponding uranium isotope in th e 130

- drum sub set ( the 11

- drum subset represen ting 237 Np target material plus the 119

- drum subset representing heat source material) . The 130

- drum sub set was then arithmetically averaged per isotope to develop a set of 241 Am

- based U scaling factors

. Plutonium, 234 U and 137 Cs When Pu isotopes (exclud ing 238 Pu) and/or 137 Cs were not detected above the MDA on the ISOCS, CH data w ere used to bound the content of a drum. Heat source and Np target waste scaling factors are generated differently for the Pu isotopes, 234 U and 137 Cs. Each is discussed below:14

Heat Source S caling F

actors All scaling fact ors for each radio nuclide in the 119

- drum subset of the CH waste stream were conservatively assumed to be normally distribute d for the heat source material. The 231 Am

- based scaling factors for each drum in the 1 19

- drum subset were averaged. Drums without reported values for any specific radio nuclide were treated as blanks rather than zeros in averaging. This provides a conservative bounding of the drum’s radionuclide content s . N e p tunium Target S caling F actors Th e scaling factors for 238 Pu, 239 Pu and 240 Pu in the 11

- drum subset of the CH waste stream were found to be normally distributed for the 237 Np target material. The 241 Am

- based scaling factors for each drum in the 11

- drum subset were averaged for 238 Pu, 239 P u and 240 Pu. Drums that did not have reported results for any specific radio nuclide were treated as blanks rather than zeros in averaging. This technique bounds the potential content of drums. SRS

- CCP found that t he scaling factors for 241 Pu, 242 Pu, 234 U a nd 137 Cs were not normally distributed

. This required SRS

CCP to take the arithmetical average of 241 Pu, 242 Pu, 234 U and 137 Cs to d erive t he 241 Am generated scaling factors for each drum in the 11

- drum subset . This technique minimizes the effects of extrem e values on both ends of the distribution. Strontium The NDA system does not directly measure 90 Sr ; its contribution is inferred by assuming a one to

- one ratio with 137 Cs. This is a common practice in determining RH scaling factors because the isotopes a re 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 241 Am or a one - Ci source of 237 Np (just one source in each model) was uniformly distributed within the drum , that the only significant gamma emitter s w ere 241 Am an d 237 Np , and that contributions of e uropium

- 154, cobalt

- 60 or other gamma emitters were negligible. Using the scaling factor of 237 Np , the waste density and the DTC correlations, and dose partitioning allows calculation of the dose and activity from 241 Am

. The 241 Am activity is then used with the 241 Am

- 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 fact or s other than t hose documented in CCP

- RC

- SRS

- 56 1 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 l ocated in Area E, Pad 4, as part of the RH baseline inspection at SRS. The DTC process for the actual drums in the15

waste stream was perform e d on August 31, 2011 , as documented in the SRS RH b aseline i nspection r eport. 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

- 5 6 1, or subs tantive 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. SRSRHDTC1100 3. The EPA inspection team verified tha t the BDR included the following: S ite P roject M anager c hecklist, Attachment 8

. BDR c over s heet, Attachment 4

. BDR t able of c ontents, Attachment 5

. BDR n arrative s ummary, Attachment 6

. Independent Technical Reviewer r eview c hecklist, Attachment 7

. Measure ment control rreport with all parameters acceptable

. Container data s heets , Attachment 2

. Concentrations and corresponding uncertainties for all WIPP

- tracked radionuclides

. Waste c ontainer DTC c onversion r ecords with all required parameters, Attachment 3

. Evidence of signatures by the I ndependent T echnical R eviewer on Attachment 7 and a S ite P roject M anager on Attachment 8

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

. TRU determination for all containers i n Attachment 3

. Correct revision of CCP

- TP

- 504 (i.e., Revision 1 3)

. The BDR was technically adequate. (7) Remote

- handled determinations were evaluated and found to be adequate. SRS personnel measured c ontact dose rates, and SRS

- CCP provided the dose rate survey sheets for all se ven 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 repres ent the values at a distance of five centimeters , which is adequate for the purpose of this review . The se values are shown in Table 6.16 Table 6 . Summary of R emote - H andled 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) T ransuranic 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 appro priate. In all cases , the TRU alpha concentration exceeded 100 nanocuries per g ram . (9) The technical basis and documentation of t otal m easurement u ncertainty were evaluated and found to be adequate. The development of t otal m easurement u ncertainty (TMU) fo r 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. 5 The TMU deter mination included contributions of the following:

241 Am DTC correlation

—uncertainties due to MCNP® cod e , waste mass and source distribution with in drum, and waste density

. 241 Am 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

- SRS

561, Section 5, and the detailed treatment of TMU is provided in “ Uncertainty Analysis for SR

RH

- 235F.01 , ” Calculation Package SRS

- RH

- 52. The overall uncertainties are consistent with what EPA has observed for RH determinations at other RH T RU generator sites. TMU varies slightly from drum to drum because scaling factors are developed on an individual drum basis. Table 7 provides a n example of th e TMU calculation for D rum 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 239 Pu is deriv ed by taking the square root of ( 25.0 %) 2 plus ( 10%) 2 plus (26. 9 %) 2 plus (93.3 %) 2 plus (7.8 %) 2 plus (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 S caling F actors Uncertainty

in W aste D ensity Uncertainty

in Gamma TMU

233 U 25% 10.0% 26.9% 100.0% 7.8% 30.1% 111. 4% 234 U 25% 10.0% 26.9% 758.9% 7.8% 30.1% 760.5% 235 U 25% 10.0% 26.9% 108.2% 7.8% 30.1% 118.8% 238 U 25% 10.0% 26.9% 64.5% 7.8% 30.1% 81.0% 238 Pu 25% 10.0% 26.9% 78.0% 7.8% 30.1% 92.1% 239 Pu 25% 10.0% 26.9% 93.3% 7.8% 30.1% 105.5% 240 Pu 25% 10.0% 26.9 % 69.6% 7.8% 30.1% 82.5% 242 Pu 25% 10.0% 26.9% 104.6% 7.8% 30.1% 115.7% 237 Np 25% 10.0% 26.9% 32.2% 7.8% 30.1% 58.9% 241 Am 25% 10.0% 26.9% 0.0% 7.8% 30.1% 49.1% 90 Sr 25% 10.0% 26.9% 35.2% 7.8% 30.1% 60.4% 137 Cs 25% 10.0% 26.9% 35.2% 7.8% 30.1% 60.4% 90 Y 25% 10.0% 26.9% 35.2% 7.8% 30.1% 60.4% 137m Ba 25% 10.0% 26.9% 35.2% 7.8% 30.1% 60.4% Source: SRS

- RH

- 52, Rev ision 1

. 7.0 FINDINGS AND CONCERN S The EPA i nspection t eam 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 desi gnations 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 239 Pu, 240 Pu and 241 Pu to 241 Am; any other relative determination was identified as a T1 change tha t 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 mea surements 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 the18

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 o f 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 a nd historical assays of companion CH debris waste streams (see footnote 1) for assigning r adionuclide 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 t o 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 gamma

emitting radionuclides for use as scaling factors

. T he 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. Us e of the MCS/ISOCS for direct quantificatio n 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 Date s EPA Docket Number SRS R H Baseline Approval EPA

- SRS

- CCP

- RH

- 08.11

- 8 , April 2012 A

- 98

- 49; II

- A4

- 161B

- 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 Si te 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

- 56 1 , 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, 773A060 006, 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, S R513217A, 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 1 4, 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; C alculation spreadsheet provided January 22, 2013 U011, CCP Calculation Package: Determination of Reportable Radionuclides, D. Ott, SRS

- RH

49, Revision 0, September 8, 2012; Calculation spreadsheet provided November 29, 2012B

- 2

U012, CCP Calculation Package: D TC 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 U01 4 , CCP Calculation Packag e: 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: D TC Modeling and Sensitivity Studies for SRS RH Debris Waste, D. Ott, SRS

- RH

- 53, Revision 0, September 9, 2012; Calculation spreadsheet provided November 29, 2012C

- 1 ATTACHMENT C TIERING TABLE FROM B ASELINE REPORT (SUPE RSEDED, SEE TABLE 1) Tiering of RH TR U 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 SR S - 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

- 5 8 0 or CCP

- AK

- SRS

- 5 8 2 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

- 5 8 0, CCP

- AK

- SRS

- 5 8 2, 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 a t a minimum (AK11) When Add Container Memoranda have been prepared (AK5) When additional d iscrepancy r esolution r eports and n onconformance r eports have been prepared (AK4) Radiological Characterization, including Dose

- t o - Curie Use of the MCS/ISOCS to pro vide any information other than the relative determinations of 239 Pu, 240 Pu and 241 Pu to 241 Am (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 document ed 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 characteriz ation 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