DOCKET NO: A-98-49, II-A4-120

WASTE CHARACTERIZATION REPORT

EPA TIER 1 EVALUATION

OF THE CENTRAL CHARACTER IZATION PROJECT (CCP)

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION

PROGRAM FOR OAK RIDGE NAT IONAL LABORATORY (ORNL): SETF PERIOD WASTES (NOVEM BER 1978 – NOVEMBER 1991) July 7-8, 2009

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

November 2009i TABLE OF CONTENTS

Section Page

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

2.0 Purpose of Tier 1 Evaluation .............................................................................................. 1

3.0 Scope of the Tier 1 Evaluation............................................................................................ 2

4.0 Tier 1 Evaluation.......................................................................................................... ....... 2
4.1 Acceptable Knowledge ........................................................................................... 3
4.2 Radiological Characterization............................................................................... 19

5.0 Findings or Concerns ....................................................................................................... . 28

6.0 Conclusions................................................................................................................ ....... 28

Attachment 1: EPA Evaluation Issue Tracking Form – Acceptable Knowledge

Attachment 2: EPA Evaluation Issue Track ing Form – Radiological Characterization1 1.0 EXECUTIVE SUMMARY

This report supports the U.S. E nvironmental Protection Agency’s (EPA or the Agency) approval of retrievably stored, remote-handled (RH) transuranic (TRU) debris (S5000) from the November 1978 – November 1991 time period [refe rred to as SETF (Solvent Extraction Test Facility) 1 wastes] generated at and packaged by th e Oak Ridge National Laboratory (ORNL) for disposal at the Waste Isolation Pilot Plant (WI PP). The Central Charac terization Project (CCP) is responsible for characterizing this waste using the system of controls which EPA evaluated during the baseline inspection conducted in July 2008 and appr oved in February 2009 (see EPA

Docket No. A-98-49, II-A4-111). The base line approval included retr ievably stored RH TRU debris wastes that were gene rated from November 1991 through February 2007, and are referred to by ORNL-CCP as HFIR and Mark-42 wastes. ORNL RH TRU wastes from the SETF and pre-SETF (pre-1978) periods were specifica lly excluded from the baseline approval.

On May 6, 2009, Carlsbad Field Office (CBFO) re quested that EPA revi ew a proposed Tier 1 (T1) change in the form of adding the SETF wastes to the ORNL-CCP approved RH TRU waste characterization program. Because there was no ne w equipment or processes on site at ORNL to examine, EPA conducted the evaluation at EPA Headquarters in Washington, DC, on July 7-8, 2009, with CBFO and ORNL-CCP program and proj ect personnel. This report presents the

results of this T1 evaluation. EPA identified tw o concerns during the ev aluation, both of which were resolved subsequent to the Washington, DC , meeting and no issues remain open relative to this T1 change. EPA determined that the proc edure and processes used by ORNL-CCP for the SETF RH TRU wastes were adequate. EP A, therefore, approves this T1 change.

2.0 PURPOSE OF TIER 1 EVALUATION

Certain changes to the waste characterization act ivities from the date of the site’s baseline inspection must be reported to and, if a pplicable, approved by EPA according to the tiering requirements set forth in 40 CFR 194.8 regulatio ns and incorporated in the ORNL-CCP RH Baseline Final Report cited above.

Under the changes to 40 CFR 194.8 promulgated in the July 16, 2004, Federal Register notice, EPA must perform a single ba seline inspection of a TRU waste generator site’s waste characterization program (Vol. 69, No. 136, pages 42571–42583, July 16, 2004). The purpose of EPA’s baseline inspection is to approve the site’s waste characteri zation program, based on the demonstration that the program’s component s, with applicable conditions and limitations, can adequately characterize TRU wastes and co mply with the regulatory requirements imposed on TRU wastes destined for disposal at the WIPP.

Following EPA’s baseline approval, EPA is author ized to evaluate and approve changes, if necessary, to the site’s approved waste char acterization program by conducting additional inspections under the authority of 40 CFR 194.24(h). Changes requiring EPA notification and approval prior to implementation (T1), a nd those requiring post-implementation (T2) notification, are iden tified in the site-speci fic baseline inspection reports. When evaluating proposed T1 changes for approval, EPA may conduc t a site inspection to observe first-hand the

1 SETF is the radiochemical facility at ORNL where these RH TRU wastes were generated.2 implementation of the change, or can opt to condu ct a “desktop” review of information provided specific to a change. DOE may choose to characteri ze and dispose of, at risk of subsequent EPA disapproval, any previously approved TRU wa ste using processes/procedures/equipment implemented as T2 changes. EPA reviews T2 changes on a quarterly basis and EPA may conduct continued compliance inspections to ev aluate implemented T2 changes to verify adequacy.

3.0 SCOPE OF THE TIER 1 EVALUATION

Waste stream OR-REDC-RH-HET is composed of retrievably stored debris that ORNL-CCP plans to characterize and repackage for shipment to WIPP. EPA’s baseline approval of this waste stream applied only to RH TRU wastes generated between 1991 and 2007. The scope of this T1 evaluation was to broaden this approval to include RH TRU debris (S5000) wastes that were generated from 1978-1991, referred to as the SETF wastes. These wastes were not examined at the ORNL-CCP baseline inspection a nd were identified as needing a T1 change in the ORNL-CCP baseline inspection report. A to tal of 81 casks of RH TRU materials were generated during the SETF period and these casks are the subject of this T1 evaluation.

4.0 TIER 1 EVALUATION

This evaluation included two waste characteriza tion areas: acceptable knowledge (AK) and radiological characterization. Each of these is addressed in a sepa rate section of this report. Personnel who participated in the T1 evaluation are listed in Table 1, along with each person’s affiliation and function during the evaluation.

Table 1. T1 Evaluation Participants

Name Affiliation & Function
Rajani Joglekar EPA Headquarters, Lead Inspector

Ed Feltcorn EPA Headquarters, Inspector
Lindsey Bender EPA Headquarters, Inspector

Connie Walker SC&A, Technical Evaluator – AK
Patrick Kelly SC&A, Technical Evaluator – Radiological Characterization

Jim Holderness CCP, Technical Support – Radiological Characterization
Irene Quintana CCP, AK Expert

Jene Vance CCP, Technical Support Radiological Characterization
Mike Seinsabaugh CCP, Management Support

J.R. Stroble CBFO, Acting NTP Manager

Jim Oliver CTAC Observer3 4.1 Acceptable Knowledge

AK Overview

EPA examined the AK process and associated information to determine whether ORNL-CCP demonstrated compliance with 40 CFR 194.8 requirements for a T1 change to add wastes from the SETF time period (1978 – 1991) of RH waste stream OR-REDC-RH-HET. CCP-AKORNL-501 provides radiological in formation that distinguishes portions of the waste stream based on radiological characteri stics of the waste generated during specified time periods.

Waste Characterization Overview

As part of the inspection, EP A reviewed the following with re spect to the use of AK for RH

waste characterization at ORNL:

 Baseline approval requirements for T1 changes

 Inspection scope and waste stream identification

 Identification of waste types—high-level wast e (HLW), TRU, low-level wastes (LLW) and spent nuclear fuel (SNF)

 Adequacy of the AK Summary Report (AKSR)

 AK data traceability

 AK source document references

 Confirmatory Test Plan (CTP) preparation and plan adequacy

 Waste Stream Profile Form (WSPF) and Ch aracterization Reconciliation Report (CRR) adequacy

 Correlation and Surrogate Summary form and CH-RH correlation

 Data Limitations, Non-conformance reports (NCRs) and AK discrepancy resolutions (DRs)

 AK accuracy

 Plans for load management

 Identification of the method for determ ining data quality objectives (DQOs)

 DQOs attained through AK Qualification

Documents Reviewed

The following documents were provided fo r review of relevant information:

 CCP-AK-ORNL-500, Central Characterization Project Acceptable Knowledge Summary Report for Oak Ridge National Laboratory Radi ochemical Engineering Development Center, Remote-Handled Transuranic Waste, Wa ste Stream OR-REDC- RH-HET, Revision 1, October 3, 2008 (AKSR)4  CCP-AK-ORNL-501, Central Characterization Project, Remote-Handled Transuranic Radiological Characterization, Technical Report For Remote -Handled Transuranic Waste From Oak Ridge National Laboratory Radioc hemical Engineering Development Center,

Waste Stream: OR-REDC-RH -HET Revision 2, April 27, 2009

 CCP-AK-ORNL-502, Central Characterization Proj ect RH TRU Waste Cert ification Plan for 40 CFR Part 194 Compliance and Confirmati on Test Plan for Oak Ridge National Laboratory REDC RH Waste Stream: OR -REDC-RH-HET, Revision 2, February 19, 2009 (CTP)

 CCP-AK-ORNL-503, Central Characterization Project Oak Ridge National Laboratory Quality Assurance Equivalency Report and Procedure Matrix For Remote-Handled Transuranic Debris Waste, Revision 1, February 13, 2009

 CCP-AK-ORL-505B, Central Characterization Pr oject Nondestructive Assay Sampling Plan for Oak Ridge National Labor atory Radiochemical Engine ering Development Center

Remote-Handled Transuranic Wa ste (SETF), Revision 0, May 21, 2009

 CCP-TP-005, Revision 18: Attachment 1, Accepta ble Knowledge Documentation Checklist, Oak Ridge National Laboratory REDC RH Debris Waste from Hot Cells, June 23, 2009; and Attachment 4, Acceptable Knowledge Source Do cument Reference List for OR-REDC-RHHET provided July 8, 2009

 Inter-Office Correspondence, from J.E. Hoff to Distribution, Transmittal of Washington TRU Solutions LLC Audit Report E08-11, September 5, 2008

 Historic Data Sheets, CH Drums X10C9311909, X10C9312455, including 2109 forms, Data/manifest packaging logs, or iginal CH assay (2004), Reques t for Storage Disposal Forms and Tracking Update Forms (various dates, 1981–1993)

 Interoffice Correspondence, C. Gomez to M. Sensibaugh, Acceptable Knowledge Accuracy Report: Oak Ridge National Laboratory Waste Stream Number OR-REDC-HET, Lot 1, June 15, 2009

 RH CRR Container Data Work Sheets (e xamples only, OR-REDC-RH-HET Stream, 1991- 2007 time period waste), provided July 8, 2009

 Waste Stream Profile Form for OR-REDC-RH -HET, at the Oak Ridge National Laboratory (WSPF), (does not include SETF waste), incl uding Characterization Reconciliation Report (CRR), June 3, 2009

 Memorandum, from S. Shafer to CCP Records, RE: Waste Material Parameter Estimates for Waste Stream OR-REDC-RH-HET, Oak Ri dge National Laboratory Radiochemical Engineering Development Center, Mixed Hete rogeneous Debris Waste (does not include SETF waste), April 24, 2008

 DOE/WIPP-02-3122, Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant, Revision 6.3, U.S. Department of Ener gy Carlsbad Field Office, February 5, 2009

 Remote Handled TRU Waste Characterizati on Program Implementation Plan, Revision 0d, (Subject to Approval), U.S. De partment of Energy Carlsbad Field Office, October 30, 20035  C601, Correlation and Surrogate Summary Form (CSSF) for OR-REDC-RH-HET Waste Stream, K. Peters, July 1, 2008

 DR003, Discrepancy Resolution: Generati on Location Discrepancies, June 27, 2008

 DR004, Discrepancy Resolution: Radiol ogical Discrepancies, January 12, 2009

 DR009, Discrepancy Resolution: High Level Waste Determination for REDC Waste, September 29, 2008

 DR600, Discrepancy Resolution: Packaging Documentation Discrepancies for Cask X10C0601826, DR600, June 24, 2008

 DR601, Discrepancy Resolution Regarding the Presen ce of Debris Items in Poly Blocks, July 1, 2008

 P083, Analytical Chemistry Division Annual Progress Report for Period Ending December 31, 1982, W.D. Shults and W.S. Lyon, ORNL-5949, May, 1983

 P185, Measurements of Fission and Activation Products for Oak Ridge National Laboratory

Transuranic Waste Characteriz ation, ORNL/TM-13292, June 1997

 P625, U-233 Hexone Extraction Method, 123920, February 2, 1988

 U011, Safety Analysis: Transuranium Pr ocessing Plant, Building 7920, ORNL/TM-7688, Chapter 4, December 1984

 U090, Mark 42 Period-HFIR 2 and SETF-ORNL RH TRU Da ta Extracted from REDC Process Information Package for Radiological Characterization for Campaigns 69, 69, 70, 73, and M1, Various Authors, undated, provided July 8, 2009

 U092, SETF Period, HFIR and SETF-ORNL RH TRU Data Extracted from REDC Process Information Package for Radiological Char acterization for Campaigns 55, 46, 47, 58, 59, 60, 61, 62, 63, 65, 66, 67-SETF, Various authors, and undated, provided July 8, 2009

 U604, Inventory Information Input Check for HFIR Campaigns in SETF, ORNL-RH-04, J. Vance, May 29, 2009

 U606, Develop SETF Campaigns Inventory In formation, ORNL-RH-06, J. Vance, April 19,

2008

 U607, Develop DTC Correlation for Cs-137, Eu-152 and Eu-154, ORNL-RH-07, J. Vance, May 23, 2008

 U613, MCNP5 Analysis for DTC Uncertaint y, ORNL-RH-13, J. Vance, April 19, 2008

 U619, Scaling Factor Development for SETF Time Period, ORNL-RH-19, J. Vance, May 29,

2009

 U622, Sr-90 Scaling Factor Development, ORNL-RH-22, J. Vance, May 14, 2008

 U625, Uncertainty Calculation for the SETF Time Period, ORNL-RH-25, J. Vance, June 1,

2009

2 HFIR is the High Flux Isotope reactor at ORNL that was used for the production of transcurium

radionuclides.6  U626, Development of Ratios of Contact to One Meter Neutron Dose Rates, ORNL-RH-26, J. Vance, May 23, 2008

 U627, Development of Ratios of Contact to One Meter Gamma Dose Rates, ORNL-RH-27, J. Vance, May 23, 2008

 U628, Neutron Dose Rate in DTC Alcove , ORNL-RH-28, J. Vance, August 10, 2008

 U629, Neutron Dose Rate for 3 Drums in Cask, ORNL-RH-29, J. Vance, August 10, 2008

 U636, Self Assessment of Conduc t of Maintenance in the Radiochemical Engineering Development Center (REDC) , Self Assessment of NSR-19, J.B. Knauer, 0049284, REDCDCC, March 14, 1996

 U647, Does Oak Ridge Have HLW?, Oak Ridge Internal Position Paper, J.E. Patterson, November 19, 1999

 U648, Sr-90 Partition Factor Estimate, ORNL-RH-30, J. Vance, April 6, 2009

 U651, DTC Spreadsheet for SETF Peri od, ORNL-RH-33, J. Vance, June 1, 2009

 U654, Determination of Reportable Isotopes– SETF Period, ORNL-RH-36, J. Vance, June 29, 2009

 U656, Cs-137 Partition Factor Development for All Campaigns, ORNL-RH-38, J. Vance, June 29, 2009

 U657, Direct Assay Data Input Check-S ETF, ORNL-RH-39, J. Vance, April 6, 2009

 U659, Direct Assay Data Analysis-S ETF, ORNL-RH-41, J. Vance, May 29, 2009

 U663, Typical Cs-137 Activity in HFIR Target s for Missing Inventory Values, ORNL-RH45. J. Vance, April 6, 2009

 U667, Alternative Scaling Factor Models Using Regression Analysis, ORNL-RH-49, J. Vance, April 6, 2009

 U668, Mark 42 Alternative Scaling Factor Method Using Campaign Partition Factors, ORNL-RH-50, J. Vance, April 6, 2009

Technical Evaluation

The EPA inspection team evaluated the following aspects:

(1) Adequacy of AK documentation and their compliance with EPA requirements were

assessed and were determined to be ad equate upon resolutio n of EPA’s concern.

EPA anticipated evaluating the SETF time pe riod wastes during the ORNL-CCP baseline inspection of Waste Stream OR-REDC-RH-HET. EPA’s base line approval cited several requirements pertinent to the addi tion of the SETF or pre-SETF time periods in Section 8 of the baseline inspection report. Some of these items from baseline report that are pertinent to this T1 evaluation are excerpted below:7  EPA expects that any such T1 change request will include the following AK documents, at a minimum, to facilitate EPA’s review of the proposed change: CCP-AK-ORNL-501 (revised) and AK Accuracy Reports (current revision at the time of the proposed T1 change); Correlation and Surrogate Summary Form (CSSF) pertinent to the waste population to be added; all revisions to the WSPF that have been amended to include the subject population; and modifications of the CTP to incorporate the added population.

 Revisions to or updates of the CSSF are T1 changes when associated with identification of new radionuclide scaling fa ctors for waste outside thatpresented in CCP-AK-ORNL501. Other revisions are T2 changes.

 Revisions to the AKSR are T1 changes when they are associated w ith the identification and/or development of new scaling factors and waste outside those presented in CCPAK-ORNL-500; other revisions are T2 changes. EPA expects forthcoming AKSummaries to ensure a thorough link between CCP-AK-ORNL-500 and CCP-AK-ORNL501. CCP-AK-ORNL-500 must include suffic ient information to support the waste stream designation and present, at a minimum, summary descriptions of data used in CCP-AK-ORNL-501 as part of the radi ological characterization process.

 Revisions to the CTP are T1 changes when th ey are associated with new scaling factors and/or wastes outside those presented in CCP -AK-ORNL-500. Other revisions to this document are T2 changes.

ORNL-CCP staff provided Revisi on 1 of the AKSR, and Revisi on 2 of the CTP and WSPF. ORNL-CCP representatives stated that they ha d not revised these docum ents specifically to incorporate the SETF time period, and thus did not consider it necessary to provide the documents as T1 changes. Instead, the documents were provided as part of the modifications to CCP-AK-ORNL-501, as required by EPA. EPA’s review of the documen ts raised several questions, which were discussed with ORNL- CCP AK personnel during the T1 evaluation in Golden, Colorado. These questions were pres ented as five items under EPA Issue No. EPA

ORNL-CCP-RH-SETF-T1-09-01CR, and included as Attachment 1 to this report. The general

text of the concern is as follows:

EPA-ORNL-CCP-RH-SETF-T1-09-01CR: Several documents were reviewed in conjunction

with the T1 evaluation of the SETF-time period waste, includ ing CCP-AK-ORNL-500, CCP-AK-ORNL-502, and the AK Accuracy Memo (dated June 19, 2009). CCP-AK-ORNL-500

should be revised to include addi tional justification and inform ation pertaining to SNF, waste campaign commingling, and SETF-specific radi ological information. Additionally, the Certification Plan (CCP-AK-ORNL-502) must be updated to include the SETF time period, and the next revision of the AK Accuracy Report sh ould address waste ch aracterization program implementation plan (WCPIP) requirements regard ing identification of significant radiological discrepancies. Attachment 1 specifies the it ems that ORNL-CCP addressed through freeze file modifications of the specific documents.8 (2) The scope of the T1 and the waste stream definition were examined for Waste Stream OR-REDC-RH-HET, and were found to be adequate.

The scope of this T1 evaluation was the approva l of wastes from the SETF time period. CCPAK-ORNL-501, Revision 2 states that the SETF time period is the second of three campaign groupings that compose Waste Stream OR-RED C-RH-HET, stating that this second grouping consists of: “LWR and Mixed Oxide fuels [tha t] were processed in SETF campaigns, which were sequenced with the HFIR campaigns...A to tal of 81 RH TRU casks were generated from the HFIR and SETF campaigns over this peri od. These casks are the subject of this characterization report.”

The AKSR indicates that the waste stream consis ts of three campaign gr oupings called the preSETF, SETF, and Mark-42 time periods. Th e SETF time period includes several SETF campaigns that were processed in sequence w ith HFIR campaigns. The SETF, pre-SETF and Mark-42 time periods all contai n waste generated from HFIR campaigns. CCP-AK-ORNL-502 Revision 2 implies that every time period has a common HFIR component , therefore all REDC waste generated from 1972 to 2007 are a single waste stream. CCP-AK-ORNL-502 Revision 2

states:

The first grouping is predominately target fabrication and separations waste from targets exposed in the High Flux Isotope Reactor (HFIR) (Pre-Solvent Extraction Test Facility [Pre-SETF]). The second grouping included light water reactor (LWR) fuel and fuel from the Fast Flux Test Facility ( FFTF) reactor; and therefore, larger quantities of Cs-137 (SETF). In addition, the LWR and FFTF fuel introduced the uranium isotopes and different distributio ns and quantities of the plutonium isotopes, both of which woul d require different scaling factors from those developed for HFIR campaigns only. The third grouping includes Mark-42 fuel and even more Cs-137. The parts are designated by generation date as follows:

• 1 st Grouping – Pre-SETF, April 1972–November 1978

• 2 nd Grouping – SETF, December 1978–October 1991

• 3 rd Grouping – Mark-42, November 1991–February 2007

CCP-AK-ORNL-502 Revision 2 states that altho ugh the waste stream has three radiologically distinct waste groupings based on generation dates, it is still a single waste stream. ORNL-CCP states that “the [waste] generating processes were the same” and the waste stream also has “similar radiological characteristics.” With regard to the different radiological characteristics of the various time periods, CCP-AK- ORNL-502 Revision 2 states that:

CCP will be able to refine the radiological characterization of the waste on a cask-by-cask basis using the time of gene ration....The ability to generate isotopic ratios to apply cask-by-cask is no different than the use of a segmented gamma system that also provides a unique set of isotopics for each drum assayed

.9 ORNL-CCP did not cite common ph ysical, chemical, or radiologica l properties as the basis for the waste stream. Instead, CCP-AK-ORNL-502, Re vision 2 states: “Based on the multiple use of process equipment across campaigns, the comm on use of the laboratory facilities, and the ongoing maintenance activities, this material is considered a single process or activity and therefore is a single waste stream.”

The WCPIP, Section 2.3, states: “A waste stream is defined as waste material generated from a single process or activity, or as waste with similar physical , chemical, and radiological properties.” EPA found that common process ar gument made by ORNL-CCP regarding a single waste stream could be interpreted differentl y, so EPA examined the physical, chemical, and radiological aspects of the waste stream defin ition to better support the assignment of these wastes to a single waste stream.

The AKSR states that the waste stream is compos ed of debris generated in chemical processing, target fabrication, analytical laboratory and process developmen t, which have diverse physical compositions and descriptions. At the time of the inspection, ORNL-CCP had not evaluated inventory data for the SETF time period to determ ine whether the physical characteristics of the SETF component agreed with the physical desc ription in the AKSR. With regard to waste generating processes, ORNL-C CP cites the repackaging pr ocess as the methodology for homogenizing the waste, but EPA questioned th e degree of the waste stream’s homogeneity, particularly with respect to re packaging [see Item (7), below]. ORNL-CCP ultimately assigned three distinct scaling factors to groupings within the SETF time period, implying that the wastes are sufficiently distinct to apply both cask-by-cas k partition factors (see Section 4.2) and three different scaling factors.

EPA questioned whether the radi ological waste stream descri ption presented in CCP-TP-500 Revision 2 adequately identified and addressed radiological informati on presented in CCP-TP501 [see Item (7), below]. ORNL-CCP’s respons e was to provide revisions to CCP-TP-500 as

freeze file modifications. ORNL-CCP also elected to better define the physical characteristics of

the waste stream as a whole in a freeze f ile revision to the CCP-TP-005 (Attachment 6 Memorandum), which verified the commonality of physical waste composition for the three time periods.

Upon examination of this information, EPA determined that the physical composition and radiological data supported the phys ical and radiological similari ties of the various campaign groupings. EPA recognizes that the radiol ogical compositions based on campaign input information imply that there are three distinct populations, which is further supported by the

choice to use three different scal ing factors. In the case of th is waste stream, EPA accepts the explanation that various scali ng factors are used to define individual cask/drum radiological components much like a radioassay of a CH drum , because the radiological characterization is well supported and explained in CCP-TP-501, and now in CCP-TP-500 [see Item (7), below].

(3) The correlation record for the waste was examined and was found to be adequate.

ORNL-CCP prepared a CSSF included in the AK record as AK Reference C601. Since 1978, ORNL segregated CH and RH wastes generate d in the REDC based upon external exposure10 (surface dose rate) measurements alone. This means that, with the exception of surface dose rate, no effort was made to se gregate containers in Waste Stream OR-REDC-RH-HET based upon physical, chemical or material characteristics. This is an important distinction, because ORNL-CCP chose to sample from the CH popul ation to obtain containers for nondestructive assay (NDA), the results of which were used to support dose-to-curie (DTC)-related modeling.

To verify that the CH containers were comparable to the overall RH waste stream as asserted by the CSSF, EPA examined container Nos. X10C9311909 and X10C9312455, both of which were identified as part of the CH TRU population. Container data packages for each were examined, including the following:

 Historic Data Sheets for CH Drums, including 2109 forms

 Data/manifest packaging logs

 Original CH assay (2004)

 Request for Storage Disposal Forms and Tr acking Update Forms (various dates, 1981- 1993)

 Waste Transportation, Storage and Disposal (TSD) Record

The container data examined by EPA were lim ited and did not indica te that the physical compositions of the containers fell outside the AK -identified material that may be within the waste stream, based on 1991–2007 (Mark- 42 time period) waste. The general radionuclide relationships compare better w ith the overall scaling factor s, i.e., the major radionuclide contributors ( 246 Cm and 238 Pu) identified by radioassay are reflected appropriately in the scaling factors. However, no other radiological correl ations can be drawn between the surrogate drums

and the RH waste stream. Based on this informa tion, data do not indicate that the physical and radiological compositions of the two CH drums are outside of the generalized waste envelope for the SETF time period drums. Both containers are on the AK Tracking Spreadsheet downloaded September 3, 2009.

(4) Traceability of wastes was examined and was found to be adequate.

ORNL-CCP had not characterized individual cont ainers from the SETF time period using DTC at the time of the EPA inspection. Additiona lly, none of the original SETF time period containers had undergone repackaging, so batch da ta reports (BDRs) from visual examination (VE) or visual examination technique (VET) we re not available for EPA review. Since BDRs were not available, this element of traceability could not be performed. However, ORNL-CCP provided several historic data sheets and forms, e.g., canister data from the SETF time period casks X10CSATN01937, X10SATN02627, X10SAT N02632, and X10C0402983e. While these other documents did not completely replace BDRs, they did demonstrate a degree of traceability.

Closure dates for the casks were presented on the Request for Storag e or Disposal of Radioactive Solid Waste or Special Materials Forms a nd they ranged from 1979 to 1985. ORNL-CCP representatives indicated that the “ATN” number on the Forms is cross-referenced with other forms such as the Data/Manifest Package Logs. ORNL-CCP representatives also indicated that

because Cask X10C0402983e had a closure date of September 24, 1979, it was assumed to11 contain waste from the HFIR campaigns 57 ( campaign date July 25, 1979) and 58 (campaign date August 27, 1979). ORNL-CCP re presentatives also indicated th at the content data for the casks varies, and more detailed data are sometim es available from log books that were recorded on the Data/Manifest Package Change Log.

(5) The identification of HLW, TRU versus LLW, and SNF was examined and was found to be adequate in the re vised CCP-AK-ORNL-500.

The AK Summary CCP-AK-OR NL-500, Revision 1 states the follo wing with regard to SNF and HLW management:

The WIPP LWA bans the disposal of sp ent nuclear fuel (SNF) and high-level waste (HLW), as defined by the NWPA (R eference 10). According to the NWPA, “spent nuclear fuel” is defined as “fuel that has been withdrawn from a nuclear reactor following irradiation, the constituent elements of which have not been separated by reprocessing.” “High-level wa ste” is defined by the NWPA as “the highly radioactive material resulting from the reprocessing of spent nuclear fuel, including liquid waste produced directly in reprocessing and any solid material derived from such liquid waste that c ontains fission products in sufficient concentrations, and other highly radi oactive material that the Commission, consistent with existing law, determines by rule requires permanent isolation.” These requirements are also defined in DOE M 435.1-1 which is the mandatory requirements manual for implementi ng DOE Order 435.1 (References I022 and I023)...The SNF and HLW requirements were reviewed by the ORNL operating contractor (Bechtel Jacobs Company, LLC) and DOE-Oak Ridge Operations.

Based on this evaluation it was determin ed that the REDC did not process SNF and therefore does not generate HLW (References U038 and U647). For this reason, the HLW requirements defined in DOE M 435.1-1 are not applicable to the REDC and these requirements were not included in the ORNL Implementation Plan for DOE Order 435.1 (Reference P569) . Therefore, waste stream ORREDC-RH-HET does not contain SNF or HLW (Reference DR009).

The above information alone does not sufficiently clarify the SNF-HLW-TRU

determination for the REDC waste stream. EPA had to obtain and examine the source document, Reference U647 before EPA could unde rstand the pedigree of the waste. This

reference elaborates on the SNF-HLW mana gement issue, and presents various arguments supporting the waste status of fuels managed in REDC saying “Targets processed at the REDC are (and were) not i rradiated for production of either power or weapons grade plutonium, but rather for pr oduction of TRU elements for other defense

related uses and for a wide range of non-defense applica tions, but particularly for research on heavy elements....Irradiated target s processed are not spent nuclear reactor fuels under the primary definition adopte d in the NWP and DOE Order 435.1”. .

The AKSR states that the debris created in Bu ilding 7920 was generated th rough: “fabrication of target rods containing plutonium , americium, and curium, and to separate and purify heavy actinide elements including 249 Bk, 252 Cf, 253 Es, and 257 Fm isotopes from the irradiated12 targets...some uranium fuel cycle developmen t work...[and] research, chemical process development, and analytical chemistry” activ ities that were performed in Building 7920.

Discussions in the revised AKSR mentioned above and Reference U647 together provide sufficient technical basis supporting DOE’s cla im that the debris is not SNF or HLW.

EPA noted that the U647 reference does not addr ess Dresden and H.B. Robinson fuels, which are included in the SETF time period wastes. To en sure that these fuels are addressed in the SNF/HLW arguments, EPA posed the following question as part of the concern described in (1),

above and discussed below:

EPA Concern EPA-ORNL-CCP-RH-SETF-T 1-09-01CR Attachment 1, Item 1 : Examine CCP-AK-ORNL-501 with respect to the discussion of fuel (e.g., material from Dresden and H.B. Robinson) and modify the SNF discussi on within CCP-AK-ORNL-500 for clarity.

CCP-AK-ORNL-501 should also be m odified to clarify whether fuel is considered experimental or to identify whatever argument is called upon to ensure that this material is not SNF.

Concern Resolution : In response to EPA’s concern, OR NL-CCP offered the following freeze

file modification to CCP-AK-ORNL-500:

The SNF and HLW requirements were reviewed by the ORNL operating contractor (Bechtel Jacobs Company, LLC) and DOE-Oak Ridge Operations.

Based on this evaluation it was determined that the targets processed in the

REDC are not SNF. Add itionally, the LWR and fast reactor test specimens associated with the SETF program invol ved the processing of these materials for development of separation and recovery technologies (References U038 and U647). For these reasons, the HLW re quirements defined in DOE M 435.1-1 are not applicable to the REDC and these re quirements were not included in the ORNL Implementation Plan for DOE Order 435.1 (Reference P569). Therefore,

waste stream OR-REDC-RH-HET does not contain SNF or HLW (Reference DR009)

.

Status of Concern : EPA accepts this modification. Item 1 of this concern is closed.

(6) Waste defense determination was eval uated and was found to be adequate.

The AK Summary Report CCP-AK-ORNL-500 Re vision 1 states that a formal defense determination was approved by CBFO in April 2006. ORNL-CCP states:

This determination conclude d that the wastes generate d by operations in the REDC are irretrievably commingled with ma terials generated, in part, by the following atomic energy defense activities (Reference M023):

• Naval reactors development • Defense nuclear materials production • Defense nuclear waste a nd by-products management • Defense research and development activities13 ORNL-CCP states that the HFIR target campaigns that produced 252 Cf that was fabricated into

neutron sources and included in the SETF time period waste had de fense-related applications. The AKSR also states: “Due to the similarity of contamination in the REDC hot cells from prior HFIR target campaigns, the waste generated from SETF and Mark-42 campaigns have not been segregated from waste generated by the HFIR ta rget campaigns,” thus implying all are defenserelated due to inseparable commingling of waste.

(7) The AK Summary was evaluated, including physi cal and radiological composition of the waste stream as presented in the AKSR, and it was determined to be sufficient.

The AKSR Revision 1 was not revised to addre ss the SETF waste stream. However, EPA’s

review of the document in concert with CCP-A K-ORNL-501, Revision 1 re vealed shortcomings in CCP-AK-ORNL-500, Revision 1 with respect to specific assumptions and data. EPA

discussed this issue with ORNL-CCP personnel and in cluded two items relative to CCP-AK-ORNL-500, Revision 1 as pa rt of the concern described in (1), above, and they are

discussed below:

EPA Concern EPA-ORNL-CCP-RH-SETF-T 1-09-01CR, Attachment 1, Item 2 : CCP-AK-ORNL-501 relies heavily on waste commingli ng to justify using a single scaling factor for the SETF time period. However, the AKS R doesn’t provide much support of this commingling argument. CCP-AK-ORNL-500 shoul d better support CCP-AK-ORNL-501 in this

area.

EPA Concern EPA-ORNL-CCP-RH-SETF-T 1-09-01CR, Attachment 1, Item 3 : CCP-AK-ORNL-501 includes additional detail pert aining to RH AK in formation that CCP should consider including in CCP-AK-ORNL-50 0. Specifically, those data in CCP-AK-ORNL501 Appendix A that are AK-based that are not yet included in the AKSR (references P083, U090 and U092 at a minimum), but which in clude AK data, should be evaluated for consideration. For example, Section A.1.1 discusses the SETF time period and provides a good summary of AK information pertaining to the campai gns specific to this time period. Also, the discussion in A.3.0 appears to include information/re ferences to information pertaining to AK. It is understandable that CCP may be reluctant to include informati on from CCP-AK-ORNL-501

that are calculation-based in CCP-AK-ORNL-50 0, and that ultimately define the CCP-derived radiological composition of the waste (ana logous to NDA procedur es/characterization processes). However, if CCP-AK-ORNL-501 cont ains information useful to defining the radiological properties of a specific time period th at has specific radiological characteristics,

relevant information should be in cluded in CCP-AK-ORNL-500.

Concern Resolution : ORNL-CCP responded by offering several freeze file changes to address EPA’s concerns, the most signifi cant of which are excerpted from the text and presented below:

 Table 4-2 identifies the pro cessing sequence for the HFIR, SETF, and Mark-42 campaigns conducted during the time frame of generation for waste stream OR-REDC-RH-HET. Table 4-2 shows the breakdown of the three time periods for radiological characterization including the Pre-SETF, SETF, and Mark-42 time periods. Refer to Section 5.4.3 for14 discussion of ORNL-CCP's radiological characterization approach for Waste Stream ORREDC-RH-HET. [Table 4-2 was added to the text]

 ....Based on the waste management practices and a detailed review of the cask documentation, no deliberate segregation of the waste based on area or program of generation was conducted in the RE DC (References M100, P161, and U011).

 5.4.3, CCP Radiological Characterization: The overall approach to the radiological characterization implemented by CCP for Waste Stream OR-REDC-RH-HET repackaged drums is a dose-to-curie (DTC) approach. Th e approach is documented in CCP-AK-ORNL501, CCP Remote-Handled Transuranic Radiologi cal Characterization Technical Report For Remote-Handled Transuranic Waste From Oak Ridge National Laboratory Radiochemical Engineering Development Center , (Reference 17). In this approach, the dose rate is measured for an individual waste container, and the Cs-137 concentration is determined from the dose rate. From the Cs -137 concentration, scaling factors developed from modeling of the contami nation deposition on waste mate rials are used to derive the concentrations of the remainder of the radionuc lides that are required to be reported.

The RH waste from the REDC hot cells was generated from April 1972 to February 2007. The waste generated prior to this date has alre ady been disposed of. In the time period after April 1972, there were a total of 66 pro cessing campaigns: 40 HFIR, 10 SETF, and 16 Mark-42 (Reference 17).

In reviewing the radiological information and data collected for thes e processing campaigns conducted from April 1972 to the present, CCP determined that, although the processing equipment and waste-generating activities were essentially the same from campaign to campaign, there were potential differences in the radionuclide dist ributions on the waste because of the differences in the starting fu el and target materials processed in each campaign. It was concluded that three groupings of the campaigns would be appropriate for the purpose of developing scaling factors that would be used in the characterization of the waste. The three periods are identified as Pre-SETF, SETF, and Mark-42. The bases for groupings are the average inventory ratios of the actinides to Cs-137 and the relative distribution of the actinides. The first grouping includes 22 HFIR campaigns, conducted from April 1972 to November 1978, where cu rium purification, target fabrication, and transcurium recovery and purification were the principal activities (Reference 17).

The second grouping includes both SETF and HFIR campaigns that were conducted alternately over a 13-year period. This second grouping includes 11 HFIR campaigns, 2 americium and curium purification cam paigns (Campaigns 57 and 58), and 10 SETF campaigns. With the addition of the LWR and Fast Flux Test Facility (FFTF) fuels from the SETF campaigns into the processing cells, si gnificantly larger quantities of Cs-137 were introduced into the hot cells, which would have the affect of altering the scaling factors developed for the HFIR campaigns. In add ition, the LWR and FFTF fuel introduced the uranium isotopes and different distributions and quantities of the plutonium isotopes, both of which would require different scaling facto rs from those developed for HFIR campaigns only. It is anticipated that waste origina ting from Campaigns 57 and 58 will have different15 scaling factors from the rest of the SETF pe riod because these two ca mpaigns were not HFIR processing campaigns, but rather purificati on campaigns of Am-Cm oxide slugs and Am slugs (Reference 17).

The third grouping included both Mark-42 and HFIR campaigns that were conducted alternately from November 1991 to February 2007. This third grouping includes 5 HFIR campaigns and 16 Mark-42 campaigns. As with the second grouping, the inclusion of the Mark-42 campaigns introduced even larger quantities of Cs-137 into the hot cells and altered the distributions of the actinides somewhat.

Although Waste Stream OR-REDC-RH-HET will be segregated into 3 or more populations for the purposes of implementing the DTC characterization approac h, as containers of REDC debris waste are generated during repac kaging in the TWPC, the container specific

documentation will be reviewed to assure that each container included in Waste Stream ORREDC-RH-HET meets the WIPP-WAP and the WCPI P waste stream definitions of waste material generated from a single process or fr om an activity that is similar in material, physical form, hazardous constituents, and radi ological constituents (References 1, 2, M100, and U038).

Status of Concern : EPA accepted these changes and determin ed that they adequately addressed

Items 2 and 3 of the concern. These items of the concern are closed.

(8) Sufficiency of AK Support Documents and Re lated Document Tracking were evaluated with respect to completeness and found to be adequate.

ORNL-CCP expends significant effort to id entify and acquire AK Support Documents. CCP-TP-005, Revision 18, Attachment s 1 and 4 present the referen ces for the waste stream and overall support documents, respect ively, and these forms are typically complete and adequately cross-referenced. However, some of the refe rences in CCP-AK-ORNL-501 Revision 2 were not

in the CCP-AK-ORNL-500 Revision 1 reference list (e.g., P083, U090, U092); not all references cited in the body of CCP-AK-ORNL -501 are included in the refere nce list within this same document; and at least one reference cited in CCP-AK-ORNL-501 is not included in the Attachment 4 master reference list. EPA expects that the next revisions of these documents will contain current (updated) references.

(9) Content and technical adequacy of the CTP was evaluated and was found to be adequate

after revision.

The CTP is included in the Waste Certificati on Plan (CCP-AK-ORNL-5 02, Revision 2). The

WCPIP states that the CTP must include:16  A description of the waste stream or waste stream lots to which the plan applies

 An explicit description of the waste ch aracterization DQOs and quality assurance objectives (QAOs) that will be satisfie d with the data being qualified

 A description of the DQOs and QAOs that wi ll not be confirmed with the data being qualified and an explanation of how compliance with those DQOs and QAOs will be

demonstrated

 A description of the confirmatory testing proposed, including the percentage of waste containers that will be subj ect to confirmatory testing

 A description of how the tested subpopulation will be represen tative of the waste stream

or waste stream lot

 Quantitative acceptance criteria for determini ng that the AK information in question can be qualified as characterization information

The CTP provides a description of the waste st ream, DQOs/QAOs, and a ge neral description of the characterization program, but did not cl early identify how the various radiological subpopulations are characterized with regard to sampling. ORNL-CCP states that target manufacturing, process development, laboratory work, and maintenance activities constitute a “single process.” However, this “single process” could actually contain different activities (i.e., laboratory support), and the proc ess did not result in wastes with common radiological characteristics. Therefore, the waste stream definition in the CTP Re vision 2 was not supported by the information reviewed during the inspection. EPA examined information presented in other documents and subsequent revisions to th e CTP and determined these documents provided more information substantiating the waste stream determination.

While the Record of Revision for Revision 2 of the CTP indicated that Revision 1 was intended to include the SETF and Pre-SETF time periods, th e discussion therein is not sufficient in that it does not include a clear, understa ndable explanation of the ch aracterization methodologies for each of the radiological populations. EPA disc ussed this with ORNL-CCP personnel and EPA included it in the concern described in (1 ), above, and it is discussed below:

EPA Concern EPA-ORNL-CCP-RH-SETF-T 1-09-01CR, Attachment 1, Item 4 : CCP-AK-ORNL-502 should be updated to include mo re information pertaining to the SETF and Pre-SETF time periods with respect to the ra diological qualification methods. Specifically, Section 2.0 should be revised to clarify the “ove rarching” qualification processes that apply broadly to all REDC wastes, coupled with any sampling/NDA th at was done specifically to qualify certain time periods. Revision of S ections 2 and 3.1 are not necessary, and it is recommended that the discussion clearly addre ss qualification approaches for each time period. It is also possible that Se ction 4.2 (e.g., AK Accuracy, a nd subsequent AK Accuracy memorandum) could require revision.

Concern Resolution : ORNL-CCP provided a freeze file change to CCP-AK-ORNL-502 Revision 3, Draft A in response to EPA’s concer n. The response did not adequately address EPA’s concern, so ORNL-CCP subsequently pr ovided Revision 3, Draft B of CCP-AK-ORNL502. Inclusion of new text and a modified flow diagram adequately addressed EPA’s concern.17 Status of Concern : EPA accepted the revised text and flow chart. Item 4 of the concern is

closed.

(10) Content and technical adequ acy of the WSPF and associat ed CRR were evaluated and were found to be acceptable.

ORNL-CCP provided a WSPF and related CRR fo r waste stream OR-REDC-RH-HET, which was signed by the SPM, Irene Quintana, on Februa ry 18, 2009. The WSPF did not distinguish between the different radiological subsets of the stream, and included the entire anticipated cask population (Mark-42, SETF, and Pre-SETF). The CRR examined during the inspection addressed only casks from the Mark-42 time peri od, as SETF and Pre-SETF wastes have yet to be repackaged. In the baseline approval, EPA st ated: “Revisions to the Waste Stream Profile Form are Tier 1 changes when associated with identification of new s caling factors and waste outside those presented in CCP- AK-ORNL-500 Revision 0; other revisions are Tier 2 changes.” This requirement has not been violated, because the WSPF does not spec ifically identify the SETF/Pre-SETF wastes, but EPA expects to cont inue to be notified of all CRRs (which are completed on a lot basis) under the T2 notificatio n process as establishe d during the baseline approval dated February 3, 2009.

(11) Data limitations, NCRs and Discrepancy Resolution Forms were examined and were found to be adequate.

ORNL-CCP Personnel stated that a detailed exam ination of SETF cask data had not taken place at the time of the inspection and BDRs generate d through repackaging or DTC calculations were not available. Therefore, NCRs for this portion of the waste stream were unavailable. CCP provided DR009, DR003, and DR004 as examples of AK-AK discrepancy resolutions. EPA expects that discrepancy resoluti on reports will be generated as characterization of the SETF
waste progresses.

(12) AK accuracy was assessed and was found to be adequate after revisions were made to

address EPA’s concern.

The WCPIP requires the following with respect to AK accuracy:

The SQAO, consistent with the requireme nts of Section 4.1.1.2 of the WCPIP, will review the AK Summary Report, conf irmatory test data and identified AK discrepancies, and prepare an AK Accuracy Re port. This report will identify the percentage of containers that have been assigned to another SCG. It will also identify the percentage of containers fo r which there are significant discrepancies in radionuclide informati on between the AK record and measured values. What constitutes a significant discrepancy will depend on site- and waste streamspecific considerations. The AK Accura cy Report will be updated annually. If AK accuracy falls below 90%, the site shall document this as a significant condition adverse to quality as defined by the C BFO QAPD. The site s hall notify the CBFO of this condition and implement appropriate corrective actions before proceeding with further characterization activitie s on the affected waste stream(s).18 ORNL-CCP provided an AK Accuracy Report for Lo t 1 of the Mark-42 time period wastes. The REDC waste stream is characterized based pr imarily on AK, so an AK Accuracy Report in which the analytical results are compared with the AK record is not useful from a radiological characterization standpoint. EPA included this in the concern cited in (1) above, and it is

discussed below:

EPA Concern EPA-ORNL-CCP-RH-SETF-T 1-09-01CR, Attachment 1, Item 5 : The AK Accuracy Report deals with the OR-REDC-RH-HET Lot 1, which presumably includes only containers from the Mark-42 time period, since c ontainers from the SETF time period had not undergone DTC. The WCPIP states that the AK Accuracy Report must: “identify the percentage of containers for wh ich there are significant discrepa ncies in radionuclide information

between the AK Record and measured values.” Sites must also determine what constitutes a “significant discrepancy.” The AK Accuracy Report does no t address identification of significant discrepancies, or w hy this identification would not be meaningful for this waste stream with respect to isotopi c contribution. ORNL-CCP indicated that because these wastes have been characterized using AK-based sca ling factors, comparison of the AK and the

measured values based on AK amounts to an AK- AK comparison. It is ag reed that containers within the waste stream that are not TRU waste, or that are greater than 23 curies/liter based on DTC, should be counted against AK Accuracy. In the next AK Accuracy Report revision, identification of a “significant” radiological discrepancy should be addressed. Also the next revision should state why “measurement” and “AK” comparisons are not meaningful with respect to determining the activities/masses of the 10 WIPP- tracked isotopes.

Concern Resolution : No response to this issue is required, as it is anticipated that the concern will be addressed in the next revision of the AK Accuracy Report.

Status of Concern : Item 5 of this concern is closed.

(13) Load Management was assessed and was found to not apply to ORNL-CCP at this time.

During the baseline inspection, ORNL-CCP repr esentatives indicated that any containers generated during repackaging that contained less than 100 nCi/g of TRU radionuclides would be segregated and would not be subject to load management. ORNL-CCP representatives stated that this had not changed. Therefore, EPA understands that load ma nagement will not be performed for the SETF portion of Waste Stream OR-REDC-RH-HET.

Summary of Acceptable Knowledge Findings and Concerns

The EPA evaluation team did not identify any findings related to AK. EPA identified one multicomponent concern during the insp ection related to AK that is discussed above, and a copy of the EPA Evaluation Issue Tracking Form recordi ng it is provided in Attachment 1. All five items of this concern were adequately resolved and this concern is cl osed. There are no open

concerns related to AK result ing from this T1 evaluation.19 Tiering Changes

Based on the results of this T1 evaluation, ther e are no changes to the T1 and T2 designations assigned to AK during th e baseline approval

.

4.2 Radiological Characterization

RH Waste Overview

Waste Stream OR-REDC-RH-HET c ontains mixtures of radionucli des from the commingling of Mark-42, HFIR, and other campaigns conducted from November 1978 until November 1991 within the REDC, referred to as the SETF period. The HFIR cam paigns involved the processing of curium targets that had been irradiated in the HFIR reactor a nd allowed to cool for decay of short-lived fission products before being processed in the REDC. The targets typically contain americium (mostly 243 Am), all of the curium isotopes except 243 Cm, the transcurium elements of californium (Cf), berkelium (B k), einsteinium (Es), mendelevium (Md), fermium (Fm), and a small amount of plutonium impurity cont ributed by the targets and the decay of 242 Cm and

244 Cm. The transcurium elements represent the end products that are produced, removed, and purified in the REDC, and by design, trace amount s remain in the wastes post-processing. Due to the relatively small amounts of 239 Pu in these samples, scaling factors were developed for Am, Pu, Cm, and Europium (Eu) isotopes, which are referred to as actinides in ORNL-CCP documents and in this report. The SETF campai gns also processed: lig ht water reactor (LWR) fuels from two commercial power reactors; fa st reactor mixed oxide fuels that had been

irradiated in the FFTF at Hanfor d; and Am-Cm slugs that had been irradiated at SRS. These materials introduced uranium isotopes and slightly larger concentrations of curium isotopes and plutonium-238 ( 238 Pu) relative to the HFIR campaigns. A total of 81 casks of RH TRU wastes were generated over this time period and these casks are the subject of this T1 evaluation.

Radiological Characterization Overview

The nature of RH TRU wastes presents difficulties with resp ect to obtaining meaningful

measurement data. As has been the case at th e six RH TRU waste characterization sites that EPA has previously approved, RH radiological ch aracterization relies on the development of scaling factors that correlate an easily measur ed parameter like a waste container’s external exposure (dose) rate with isotopic distri butions for specific TRU radionuclides. The development of radionuclide scali ng factors for SETF wastes is essentially the same as what EPA evaluated and approved during the ORNL-CCP baseline inspection. The development of

the 137 Cs scaling factors was supported by the fo llowing three sources of information:

 REDC records of the HFIR processing of rele vant campaigns, including measurement results from the process control samples that were available for each processing campaign. This information was used to develop the inventory ratios for these campaigns.

 Radiochemical sample results from a smear sampling campaign conducted in 1995 and 1996 to support the radiological charact erization of the RH TRU waste generated in the REDC hot cells. This sample information was used in combination with the inventory information to develop the 137 Cs partition factors.20  NDA results from the same CH TRU debris wast e stream generated in the REDC hot cells were used to confirm the model and support th e overall radionuclide uncertainty estimate.

The characterization methods used for the ORNL- CCP SETF RH wastes were evaluated in terms of the technical adequacy of the approach 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 T1 eval uation, EPA examined the following elements of the ONRL-CCP radiological characterization program:

 Development of a DTC correlation as a func tion of waste density using MCNP5 based on each drum’s measured external exposure (dose) rate, assuming the main contributors to the external exposure were 137 Cs and 154 Eu

 Development of partitioning factor s to adjust the ratio of the TR U radionuclides of interest to

137 Cs and 154 Eu, as appropriate

 Derivation of radionuclide scaling factors for quantification of the 10 WIPP-tracked radionuclides as supported by calculation packag es and the destructive assay of swipe samples from 1995–1996

Documents Reviewed

The list provided below includes all document s related to the ORNL-CCP SETF RH TRU radiological characterization pr ogram that were examined to support this T1 evaluation:

 EPA Final Baseline Approval Report, Inspection No. EPA-ORNL-CCP-RH-06.08-8

 Radiological Characterization of REDC RH RTU Waste at OR NL: Status Briefing, June 11-12, 2008, J. Vance

 CCP-AK-ORNL-501, Central Characterization Project Remote-Handled Radiological Characterization Technical Report For Remo te-Handled Transuranic Waste From the Mark-42 Time Period from Oak Ridge Nati onal Laboratory Radioc hemical Engineering Development Center; Waste Stream: OR -REDC-RH-HET; Appendix A, Revision 2, April 27, 2009

 CCP-AK-ORNL-500, Central Characterization Project Acceptable Knowledge Summary Report For Oak Ridge National Laboratory Radi ochemical Engineering Development Center Remote-Handled Transuranic Waste; Wast e Stream: OR-REDC-RH-HET; Revision 0, May 2, 2008

 CCP-AK-ORNL-502, Central Characterization Proj ect RH TRU Waste Cert ification Plan for 40 CFR Part 194 Compliance and Confirmation Test Plan for ORNL RH Waste; Waste Stream: OR-REDC-RH-HET; Revision 0, May 22, 2008

 J. Vance Memorandum, February 2, 2009; Revise d Dose-to-Curie Correlation for ORNL RH

TRU Waste

 CCP-TP-504, Revision 6, CCP Dose-To-Curie Survey Procedure for Remote-Handled Transuranic Waste; February 6, 200821  ORNL-RH-04, Campaigns 69 and M5 Invent ory Information Input Check, May 29, 2009

 ORNL-RH-07, Develop DTC Correlation for Cs-137, Eu-152 and Eu-154, Revision 2, February 13, 2009

 ORNL-RH-11, DTC Spreadsheet for Mark-42 Ti me-Mark/HFIR, Revision 4, February 20,

2009

 ORNL-RH-13, MCNP5 Analysis fo r DTC Uncertainty, April 19, 2008

 ORNL-RH-19, Scaling Factor Development for SETF Time Period, Revision 1, May 29,

2009

 ORNL-RH-23, DTC Spreadsheet for Mark-42 Ti me-HFIR/HFIR, Revision 4, February 20,

2009

 ORNL-RH-25, Uncertainty Calculation fo r the SETF Time Period, June 1, 2009

 ORNL-RH-28, Neutron Dose Rate in DTC Alcove, August 10, 2008

 ORNL-RH-29, Neutron Dose Rate fo r 3 Drums in Cask, August 10, 2008

 ORNL-RH-30, Sr-90 Partition Fa ctor Estimate, April 6, 2009

 ORNL-RH-33, DTC Spreadsheet for SETF Period, Revision 1, June 2, 2009

 ORNL-RH-36, Determination of Reportable Isotopes-SETF Period, Revision 0, March 18,

2009

 ORNL-RH-38, Cs-137 Partition Factor Develo pment for All Campaigns, Revision 1, June 29, 2009

 ORNL-RH-41, Direct Assay Data Anal ysis-SETF, Revision 1, June 2, 2009

 ORNL-RH-45, Typical Cs-137 Activity in HF IR Targets for Missing Inventory Values, April 6, 2009

 ORNL-RH-49, Alternative Scaling Factor Mode ls Using Regression Analysis, April 6, 2009

 ORNL-RH-50, Mark 42 Altern ative Scaling Factor Met hod Using Campaign Partition Factors, April 6, 2009

Technical Evaluation

The EPA inspection team evaluated the following aspects:

(1) The technical adequacy and documentation of the correlation of the SETF radionuclide inventory values to the 137 Cs and 154 Eu concentrations in SETF wastes were evaluated and were found to be adequate.

The basic assumption for the radiological ch aracterization of SETF wastes is that 137 Cs scaling

factors relate to the inve ntory values of the radio nuclides of interest and 137 Cs that are introduced into the hot cells at the start of each processi ng campaign. This had been evaluated and found to be adequate during the baseline inspection and this aspect had not changed for the SETF wastes. There were no concerns regarding the technical adequacy and documentation of the correlation22 of the SETF radionuclide i nventory values to the 137 Cs and 154 Eu concentrations for the SETF period in Waste Stream OR-REDC-RH-HET.

(2) The development of radionuclide scaling fact ors and partition fact ors was evaluated and both were found to be technically ad equate and appropr iately documented.

A radionuclide scaling factor provides a tech nically sound method of deriving a value for

radionuclides that are difficult to measure on the basis of an easily measurable attribute like external dose rate, assuming the measured dose rate can be correlated to a known constituent, i.e., 137 Cs and 154 Eu in the case of SETF wastes. For the HFIR and Mark-42 wastes, there were multiple campaigns involving 244 Cm sources, and three specific isotopic ratios had to be deconstructed for each sample: 134 Cs/ 137 Cs; 242 Cm/ 244 Cm; and 243 Am/ 244 Cm. This resulted in scaling factors in units of curies of each radionucl ide per curie of 137 Cs (Ci/Ci 137 Cs). For SETF wastes, there were campaigns that (Campaigns 57 and 58) did not i nvolve processing HFIR materials, but rather were purification campai gns for Am-Cm slugs that had been produced by SRS. Both campaigns contained re latively large concentrations of 243 Am, and Campaign 58 also contained relatively la rge concentrations of 238 Pu. Accordingly, there ar e three sets of scaling factors: one for campaign 57; one set for Campai gn 58; and one set for all other SETF wastes. These are shown in Table 2, below.

Partition factors were developed based on 244 Cm, which was chosen as representative of the actinides and which was the dominant radionuclide by activity. The partition factor is defined as the ratio of two ratios: the activity inventory ra tio divided by the activity waste ratio, as shown in CCP-AK-ORNL-501, Revision 2, Ta ble A3-1. These activity ratio s were then converted to

mass values and these were used to deri ve an expected ratio of actinide to 137 Cs for all SETF wastes except Campaigns 57 and 58.23 Table 2. ORNL RH TRU Scaling Fact ors for the SETF Time Period in Units of Curies of Specific Radionuclide/Curies 137 Cs (Ci/ 137 Ci)

Radionuclide All Others Campaign 57 Campaign 58

U-233 6.11E-08 7.82E-08 0.00E+00

U-234 1.63E-03 2.16E-03 0.00E+00

U-235 2,48E-05 3.08E-05 0.00E+00

U-238 3.94E-04 4.71E-04 0.00E+00

Pu-238 2.63E+00 2.57E+00 2.43E-01

Pu-239 2.48E+00 4.34E-01 2.76E-02

Pu-240 4.263+00 3.46E+00 1.94E+00

Pu-241 4.19E+01 3.13E+01 5.84E-01

Pu-242 2.683-03 2.64E-03 3.23E-03

Am-241 8.24E+00 4.95E+00 6.14E+00

Am-243 2.82E-01 4.82E+00 7.07E+00

Cm-244 3.45E+02 3.32E+02 2.16E+02

Cm-245 2.39E-02 2.61E-02 1.72E-02

Cm-246 2.75E+00 1.40E+00 1.57E-01

Sr-90 1.73E+01 1.73E+01 1.73E+01

Eu-154 2.02E-02 2.02E-02 2.02E-02

EPA evaluated the following aspects:

 Activity values derived from modeling and sta tistical metrics, namely mean and standard

deviation values for each measured radionuclide

 The appropriateness of the choice of physic al constants and radionuclide-specific attributes (specific activity, phys ical half-life, decay heat, neutron cross-sections, photon transition probabilities, etc.) and the technica l correctness of the values assigned to each

attribute

 Isotopic activity values are co rrelated to the radionuclides whose physical half-lives are such that they could be responsible fo r the measured external dose rate, i.e., 137 Cs and

154 Eu

 Contributions of the short-lived radionuc lides to the total measured dose rate

 Appropriate decay correction according to ORNL-CCP procedure (CCP-TP-504) of all radionuclide values for purposes of model de velopment and routine assays performed via

DTC

 The calculated results are used to develop th e scaling factors and convert the measured

external dose rates obtained via DT C to radionuclide activity levels

 Activity and uncertainty values determin ed for the ten WIPP-Tracked radionuclides ( 233 U, 234 U, 238 U, 238 Pu, 239 Pu, 240 Pu, 242 Pu, 241 Am, 137 Cs and 90 Sr)24  The determination of the contribution of a ll radionuclides to the radiological hazard 3

 Shielding and other calculati ons supporting the scaling fa ctors performed using MCNP5 to derive the appropriate DT C relationships as a function of waste density for the geometry appropriate to the SETF wast e following repackaging (55-gallon drum)

Based on a thorough review of these aspects, it was noted that the source for certain values (e.g., specific activity and decay heat) was the TRAMPAC, as appropriate. However, the source(s) for other values was not documented, specifically the physical half-life of some radionuclides. EPA captured this issue on an EPA Evaluation I ssue Tracking Form, as discussed below (see Attachment 2 of this report for a copy of this form).

EPA Concern No. ORNL-CCP-RH-SETF-T1-09-02C : The sources for the physical half-life

of the radionuclides that are us ed for calculations related to ORNL SETF RH wastes are not documented. The half-life values used were genera lly consistent with values published in typical sources (e.g., Brown & Firestone , Chart of the Nuclides and the DOE TRAMPAC), and this

concern addresses the documentation of the half-life values that we re used. However, there is no concern regarding the accuracy of the values that were used or the data that were generated through their use with respect to supporting the characteriza tion of ORNL SETF RH TRU wastes. This issue was raised at a previous EP A RH inspection (GE Vallecitos Nuclear Center in December 2008) and EPA suggests that CCP address this issue.

Concern Status : This concern did not require a response.

There are no issues rela ted to the technical ad equacy or documentation of radionuclide scaling factors or partition factors for the SETF portion of waste stream OR-REDC-RH-HET.

(3) The technical basis of the DTC correlati on and its documentation were evaluated and found to be unchanged from what EPA had in spected and approved previously, and both aspects were acceptable.

The DTC correlation was based on the following assumptions:

 The waste drum is 100 percent full with waste

 The radionuclides of interest are di spersed uniformly throughout the waste

 The waste matrix’s density is assumed to be unity (one), beca use photon attenuation is more influenced by material density, as opposed to specific composition or atomic

number

 Waste densities range from 0.1 g/cc to 2.1 g/cm 3

3 Although the determination of a waste container’s radiolog ical hazard is not an EPA requirement, this information may be useful in understanding other aspects of a container’s radiological characterization.25 Using MCNP5 4 , ORNL-CCP developed a DTC correlation for an ORNL drum filled with RH

TRU waste in terms of mR/h r for a 1-curie source of 137 Cs and 154 Eu. Figure A6-1 in CCP-AK-ORNL-501, Revision 2 shows a plot of dose rate as a function of waste density at a

distance of 1 meter for 137 Cs and 154 Eu. The DTC spreadsheet that EPA evaluated during the baseline inspection is used for SETF wastes as well, and it had been revised to include the SETF scaling factors from the March 2009 revision (R evision 0 032009). The spreadsheet contained the required information, speci fically: cask identification num ber; container gross weight; estimated fill percentage; and resu lts of the four dose rate measur ements that are obtained via the application of DTC procedure CCP-TP-504. An example Waste Drum DTC Conversion Record (spreadsheet) is included as Table A6-1 in CCP-AK-ORNL-501, Revisi on 2. Since Campaigns 57 and 58 have different scaling factors, the four casks that were generated from these campaigns have been assigned the appropr iate scaling factors in the DTC worksheet based on the cask generation dates. There were no concerns rega rding the technical basis of the DTC correlation

and its documentation for th e ORNL-CCP SETF wastes.

(4) Technical aspects and docu mentation of the radiological characterization process were evaluated and found to be acceptable.

CCP-AK-ORNL-501 is the main document that describes the radiological characterization process that ORNL-CCP used fo r the SEFT wastes. This document is supported by a series of calculation packages, seventeen of which were re viewed in the process of evaluating the SETF wastes. These packages had been prepared and reviewed initially by Jene Vance, Jim Holderness, Dave Moody, and Larry Porter to su pport the ORNL-CCP RH baseline, and many of them had been revised to incorporate the SETF wastes, as listed above. These packages documented the following:

 Application and verifi cation of Microshield ®

 Evaluation of all potential contribut ors to a container’s dose rate

 Decay correction to an assumed reference date of January 1, 2009

 Contributions of short-lived radionuclides to the measured external dose rate

 Potential sources of uncer tainty for SETF wastes

 Information input checks for SETF wastes

 Technical development of scaling factors and 137 Cs partitioning factors

 Technical derivation of the DTC approach and documentation of the DTC spreadsheet

The EPA evaluation team review ed these packages and Revi sion 2 of CCP-AK-ORNL-501 in advance of the formal T1 evaluation meeting at EPA headquarters. Several documents had been revised more recently and these revisions were evaluated during the meeting as they were provided by ORNL-CCP. During these discus sions, the EPA evaluation team had the

4 MCNP5 is Monte Carlo N-Particle Transport Code RSICC, which was developed by ORNL.26 opportunity to discuss all tech nical concerns and apparent discrepancies with ORNL-CCP personnel and to question ORNL-CCP personnel regarding a variety of technical as pects related to the SETF wastes. None of the calculation pa ckages required serious modifications. The EPA

evaluation team found that CCP-AK-ORNL-501 adequately documented the radiological characterization process for SETF wastes, and th e calculation packages cited above adequately supported the activities u pon which the radiological characterizat ion of SETF wastes was based.

There were no issues related to the document ation of technical aspects of the ORNL-CCP radiological characterization approach for SETF wastes.

(5) The technical basis and derivation of To tal Measurement Uncertainty (TMU) were evaluated and were found to be adequate.

The development of TMU for Waste Stream OR -REDC-RH-HET is based on the propagation of uncertainties present in all aspects of the determ ination of the radiologica l constituents of RH TRU waste. These aspects are assumed to be in dependent, which allows them to be added in quadrature. The TMU determination in cluded contributions of the following:

 Drum weight measurement

 Measurement uncertainty

 Scaling factor uncertainty

 MCNP5 code and modeling issues

 Contributions of other gamma emitters

 Drum-to-drum variation within each campaign

 Uncertainty in reported campaign inventories

The treatment of TMU is presented in CCP -AK-ORNL-501 and Calculation Package No. ORNL-RH-25, Revision 1. The principa l sources of uncer tainty in the 137 Cs scaling factors result from: variations in the campaign-to-c ampaign scaling factors; variations in the 137 Cs partition factors; and variati ons in the waste content from drum-to-drum. However, uncertainties for Campaigns 57 and 58 do not incl ude campaign-to-campaign variation, because they are based on a single campaign. The largest single contributor to the overall uncertainty is the scaling factor, as shown in Table 3, below.27 Table 3. Overall Uncertainty Listed by Radionuclide for SETF Wastes Excluding Campaigns 57 and 58, at a Density of 0.3 g/cm 3

Radionuclide 137 Cs Activity Uncertainty Scaling Factor Uncertainty Total Uncertainty

U-233 33.3% 133.6% 137.7%

U-234 33.3% 137.2% 141.2%

U-235 33.3% 132.2% 136.3%

U-238 33.3% 127.6% 131.9%

Pu-238 33.3% 94.0% 114.3%

Pu-239 33.3% 110.4% 140.2%

Pu-240 33.3% 92.8% 104.9%

Pu-241 33.3% 120.0% 109.9%

Pu-242 33.3% 92.6% 115.9%

Am-241 33.3% 106.5% 97.4%

Am-243 33.3% 89.3% 137.8%

Cm-244 33.3% 97.6% 107.4%

Cm-245 33.3% 88.4% 107.6%

Cm-246 33.3% 147.3% 109.4%

Sr-90 33.3% 30.0% 44.8%

Cs-137 33.3% - 33.3%

There were no concerns regarding the technical derivation and documentation of TMU for the

OTNL-CCP SETF RH wastes.

(6) RH and TRU determinations were a ssessed and were found to be adequate.

The determination that the RH containers meet th e definition of TRU wast es and RH waste were examined during the baseline insp ection. Both of these aspects are directly involved with the

DTC measurement at the Transuranic Waste Pro cessing Center (TWPC), as was observed during the baseline inspection. These were not assessed directly during this T1 evaluation but EPA did verify that no aspects of these two determina tions had changed. There were no technical or documentation-related concerns regarding the TRU and RH determinations for ORNL SETF

wastes.

Summary of Radiological Characterization Findings and Concerns

The EPA inspection team did not identify any findi ngs related to radiolog ical characterization. EPA identified one concern during th e inspection related to radiological characterization that is discussed above, and a copy of th e EPA Inspection Issue Tracking Fo rm recording it is provided in Attachment 2. This concern did not require a response and there are no open concerns related to radiological characterization re sulting from this T1 evaluation.28 Tiering Changes

Based on the results of this T1 evaluation, ther e are no changes to the T1 and T2 designations assigned to radiological characteri zation during the ba seline approval

.

5.0 FINDINGS OR CONCERNS

Summary of Findings and Concerns

The EPA inspection team did not identify a ny findings related to AK or radiological

characterization. EPA identified one concern during the inspection related to AK that required a response and one concern in radiological characte rization that did not requi re a response. Both are discussed above, and a copy of both EPA In spection Issue Tracking Forms recording these issues is provided in Attachments 1 and 2, respectively. The AK concern that required a response was adequately addresse d and there are no open concerns related to AK or radiological characterization resulting from this T1 evaluation.

Tiering Changes

Based on the results of this T1 evaluation, ther e are no changes to the T1 and T2 designations that had been assigned to AK or radiological characterization during the baseline approval

.

6.0 CONCLUSIONS

EPA concluded that the waste ch aracterization processes of AK a nd radiological characterization proposed for use to characterize RH TRU wast es from the SETF period are adequate, as evidenced by the records produced in charac terizing ORNL RH TRU Waste Stream OR-REDCRH-HET. There were three c oncerns, two of which require d a response, and ORNL-CCP adequately addressed both concer ns. There are no open issues relative to this T1 evaluation.

Approval

The T1 change that was evaluated consisted of the waste characterizati on techniques of AK and radiological characterization as applied to SETF RH TRU wastes at ORNL-CCP. Based on the results of this evaluation, EPA approves this T1 change. ORNL-CCP is approved to characterize the SETF RH TRU wastes, consistent with the limitations specified in this report.

Tiering Changes

Based on the results of this T1 evaluation, ther e are no changes to the T1 and T2 designations assigned to AK or radiol ogical characterization during the baseline approval

.Attachment 1

EPA Evaluation Issue Tracking Form – Acceptable KnowledgePage 1 of 1

1-1 Inspection No. EPA-ORNL-CCP-RH-SETF

T1-09 Issue Number: EPA- ORNL-CCP-RH-SETF-T1-09-

01CR

Date: July 8, 2009 Inspector: C. Walker

Attachments? YES NO Sample Size: SETF Time Period Waste Population size (if known): Containers in the above time period Description of Issue: Several documents were revi ewed in conjunction with th e Tier 1 evaluation of the SETF-time period waste, including CCP-AK-OR NL-500, CCP-AK-ORNL-502, and the AK Accuracy Memo (dated June 19, 2009). CCP-AK- ORNL-500 should be revised to include additional justification and information pertaining to SNF, waste campaign commi ngling, and SETF-specific radiological information. Additionally, the Certific ation Plan (CCP-AK-ORNL-502) must be updated to include the SETF time period, and the next revision of the AK Accuracy Re port should address WCPIP requirements regarding identification of significant radiol ogical discrepancies. Attachme nt 1 includes specific information.

B. Regulatory Reference: 40 CFR 194.24(c), EPA Docket No:A-98-49, II-A4-111 (see Attachment 1 for specific citations)

C. Site requirement(s): WCPIP, Attachment A

D. Discussed with: Irene Quintana, J.R. Stroble, M. Sensibaugh

E. Additional Comments:

Modifications to CCP-AK-ORNL-500 and CCP-AK- ORNL-502 can be addressed through freeze file changes. Modification of the AK accuracy report can be reflected in the next report version prepared.

F. Site Response Information:

Site Response Required? YES NO

Site Response Due Date: July 24, 20091-2 Attachment 1

1. Examine CCP-AK-ORNL-501 with respect to the discussion of fuel (e.g., Dresden, H.B. Robinson) and modify the SNF discussion w ithin CCP-AK-ORNL-500 to clarify (CCP-AKORNL-501 should also be modified to clarify whether fuel is considered experimental or whatever argument is called upon to ensure that this materi al is not SNF). Freeze File.

2. CCP-AK-ORNL-501 relies heavily on waste commi ngling to justify using a single scaling factor for the SETF time period. However, the AK Summary (CCP- AK-ORNL-500) doesn’t provide much support of this commingling argument. CCP-AK-ORNL-500 should better support 501 in this area. Freeze File.

3. CCP-AK-ORNL-501 includes additional detail pert aining to RH AK in formation that CCP should consider including in CCP-AK-ORNL-5 00. Specifically, t hose data in CCP-AKORNL-501 Appendix A that are AK-based that are not yet include d in the AK Summary (e.g., references P083, U090 and U092—there coul d be more), but which include AK data,

should be evaluated for consideration. For example, Section A.1.1 di scusses the SETF time period and provides a good summary of AK inform ation pertaining to the campaigns specific to this time period. Also, the discussion in A.3. 0 appears to include information/references to information pertaining to AK. It is understa ndable that CCP may be reluctant to include

information from CCP-AK-ORNL-501 into 500 that are calculation-based, and that ultimately define the CCP-derived radiological composition of the wa ste (analogous to NDA procedures/characterization processes). However, if CCP-AL-ORNL-501 contains information useful to defining the radiological properties of a specific time period that has specific radiological characteristics, relevantinformation should be included in CCP-AKORNL-500. Freeze File.

4. CCP-AK-ORNL-502 should be updated to include more information pertaining to the SETF and Pre-SETF time periods with respect to the radiological qua lification methods. Specifically, revision of Section 2.0 to clarify the “overarching” qualific ation processes that apply broadly to all REDC wastes, coupled with any sampling/NDA done to specifically qualify certain time periods is re quired. Revision of Sections 2 and 3.1 appear necessary, and it is recommended that the discussion clearly address qualification appr oaches for each time period. It is also possible that Section 4.2 (e.g., AK Accuracy, and subsequent AK Accuracy memorandum) could require revision. Freeze File.

5. The AK Accuracy Report addresses OR-REDC- RH-HET Lot 1, which presumably includes only Mark-42 time period drums (since no drums from the SETF time period have undergone DTC, to date). The AK Accuracy report, according to the WCPIP must “identify the percentage containers for which there ar e significant discrepa ncies in radionuclide

information between the AK Record and measured values.” Sites must also determine what constitutes a “significant discrepancy.” The AK Accuracy re port does not address identification of significant disc repancies, or why this identifi cation would not be meaningful for this stream (i.e., always 100%) with respect to isotopic contribution. It is understood that because the RH HET is characterized using AK- based scaling factors, comparison of the AK1-3 Record and the measured value would essentiall y be an AK-AK comparison. It is agreed that

containers within the waste stream that ar e not TRU waste or that are greater than 23

curies/liter based on DTC should be counted against AK Accuracy. In the next annual revision, the AK Accuracy Report should addr ess identification of a “significant” radiological discrepancy, and should state why “measurement” and “AK” comparisons are not meaningful with respect to determining the activities/masses of the 10 WIPP- tracked isotopes. Next Revision of AK Accuracy Report.

The questions listed above were posed to addres s questions raised during review of documents listed as part of the T1 process for this SETF change. EPA’s original approval of Oak Ridge RH, Section 8, included but was not limited to the following:

EPA expects that any such T1 change reque st will include the following AK documents, at a minimum, to facilitate EPA’s review of the proposed change: CCP-AK-ORNL-501 (revised) and AK Accuracy Re ports (current revision at the time of the proposed T1 change); Correlation and Surrogate Summary Form (CSSF) pertinent to the population to be added; all revisions to the WSPF that have been amended, to include the subject population; and modifications to the CTP to incorporate the added population.

Revisions to or updates of the CSSF are T1 changes when associated with identification of new radionuclide scaling factors for wast e outside that presented in CCP-AK-ORNL501 other revisions are T2 changes. (See Tabl e 1, where these are included as a T1 and T2 changes, respectively.)

Revisions to the AKSR are T1 changes when th ey are associated with the identification and/or development of new scaling factors and waste outside those presented in CCPAK-ORNL-500; other revisions ar e T2 changes. (See Table 1, where these are included as a T1 and T2 changes, respectively.) EPA expects forthcoming AK Summaries to ensure a thorough link between CCP-AK- ORNL-500 and CCP- AK-ORNL-501. CCPAK-ORNL-500 must include sufficient info rmation to support the waste stream designation and present, at a minimum, summary descriptions of data used in CCP-AKORNL-501 as part of the radiol ogical characterization process

Revisions to the CTP are T1 changes when th ey are associated with new scaling factors

and/or wastes outside those presented in CCP-AK-ORNL-500. (See Table 1, where this is included as a T1 change.) Other revisions to this document are Tier 2 changes. (See Table 1, where this is incl uded as a T2 change.)Attachment A.2

EPA Evaluation Issue Tracking Form – Radiological Characterization2-1 Inspection No. EPA-ORNL-CCP-RH-SETFT1-09 Issue Number: EPA

- ORNL-CCP-RH-SETF-T1-09-

02C

Date: July 8, 2009 Inspector: P. Kelly

Attachments? YES NO Sample Size: All ORNL SETF RH Data Population size (if known): Not applicable

Description of Issue: The source(s) of the values for the physical half-life of radionuclides that are used

for the calculations related to ORNL SETF RH wastes is not documented.

B. Regulatory Reference: 40 CFR 194.24(c)

C. Site requirement(s): Not applicable

D. Discussed with: Jene Vance, Jim Holderness, J.R. Strobl e, Mike Sensibaugh and Irene Quintana

E. Additional Comments: This concern addresses documentation of th e half-life values that were used. There is no concern regarding the accu racy of the half-life values that were used, or the data generated through their application, with resp ect to supporting ORNL SETF RH wast es. This issue was raised at a previous RH inspection at GE VNC (December 2008) a nd EPA suggests that CCP address this issue.

F . Site Response Information:

Site Response Required? YES NO

Site Response Due Date: Not applicable