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

WASTE CHARACTERIZATION REPORT 

EPA TIER 1 EVALUATION 

OF THE CENTRAL CHARACTERIZATION PROJECT (CCP) 

REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION 

PROGRAM FOR OAK RIDGE NATIONAL LABORATORY (ORNL): 

SETF PERIOD WASTES (NOVEMBER 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 2009
 i 

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 Tracking Form – Radiological Characterization 
 1 

1.0 EXECUTIVE SUMMARY 

This report supports the U.S. Environmental 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 [referred to as SETF (Solvent Extraction Test 

Facility)1

 wastes] generated at and packaged by the Oak Ridge National Laboratory (ORNL) for 

disposal at the Waste Isolation Pilot Plant (WIPP). The Central Characterization 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 approved in February 2009 (see EPA 

Docket No. A-98-49, II-A4-111). The baseline approval included retrievably stored RH TRU 

debris wastes that were generated 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 specifically excluded from the baseline approval. 

On May 6, 2009, Carlsbad Field Office (CBFO) requested that EPA review 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 new 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 project personnel. This report presents the 

results of this T1 evaluation. EPA identified two concerns during the evaluation, 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 procedure and processes used by ORNL-CCP for the 

SETF RH TRU wastes were adequate. EPA, therefore, approves this T1 change. 

2.0 PURPOSE OF TIER 1 EVALUATION 

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

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

requirements set forth in 40 CFR 194.8 regulations and incorporated in the 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 baseline inspection of a TRU waste generator site’s waste 

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

of EPA’s baseline inspection is to approve the site’s waste characterization program, based on 

the demonstration that the program’s components, with applicable conditions and limitations, 

can adequately characterize TRU wastes and comply with the regulatory requirements imposed 

on TRU wastes destined for disposal at the WIPP. 

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

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

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

approval prior to implementation (T1), and those requiring post-implementation (T2) 

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

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

 1

 SETF is the radiochemical facility at ORNL where these RH TRU wastes were generated. 
 2 

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

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

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

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

conduct continued compliance inspections to evaluate implemented T2 changes to verify 

adequacy. 

3.0 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 and were identified as needing a T1 change in 

the ORNL-CCP baseline inspection report. A total 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 characterization areas: acceptable knowledge (AK) and 

radiological characterization. Each of these is addressed in a separate 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 Observer
 3 

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 information that distinguishes portions of the waste stream 

based on radiological characteristics of the waste generated during specified time periods. 

Waste Characterization Overview 

As part of the inspection, EPA reviewed the following with respect 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 waste (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 Characterization 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 determining data quality objectives (DQOs) 

 DQOs attained through AK Qualification 

Documents Reviewed 

The following documents were provided for review of relevant information: 

 CCP-AK-ORNL-500, Central Characterization Project Acceptable Knowledge Summary 

Report for Oak Ridge National Laboratory Radiochemical Engineering Development Center, 

Remote-Handled Transuranic Waste, Waste 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 Radiochemical Engineering Development Center, 

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

 CCP-AK-ORNL-502, Central Characterization Project RH TRU Waste Certification Plan for 

40 CFR Part 194 Compliance and Confirmation 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 Project Nondestructive Assay Sampling Plan 

for Oak Ridge National Laboratory Radiochemical Engineering Development Center 

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

 CCP-TP-005, Revision 18: Attachment 1, Acceptable Knowledge Documentation Checklist, 

Oak Ridge National Laboratory REDC RH Debris Waste from Hot Cells, June 23, 2009; and 

Attachment 4, Acceptable Knowledge Source Document 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, original CH assay (2004), Request 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 (examples 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), including 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 Ridge National Laboratory Radiochemical 

Engineering Development Center, Mixed Heterogeneous 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 Energy Carlsbad Field Office, February 5, 2009 

 Remote Handled TRU Waste Characterization Program Implementation Plan, Revision 0d, 

(Subject to Approval), U.S. Department of Energy Carlsbad Field Office, October 30, 2003 
 5 

 C601, Correlation and Surrogate Summary Form (CSSF) for OR-REDC-RH-HET Waste 

Stream, K. Peters, July 1, 2008 

 DR003, Discrepancy Resolution: Generation Location Discrepancies, June 27, 2008 

 DR004, Discrepancy Resolution: Radiological 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 Presence 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 Characterization, ORNL/TM-13292, June 1997 

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

 U011, Safety Analysis: Transuranium Processing Plant, Building 7920, ORNL/TM-7688, 

Chapter 4, December 1984 

 U090, Mark 42 Period-HFIR2 and SETF-ORNL RH TRU Data 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 Characterization 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 Information, 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 Uncertainty, 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 Conduct 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 Period, 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-SETF, ORNL-RH-39, J. Vance, April 6, 2009 

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

 U663, Typical Cs-137 Activity in HFIR Targets 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 adequate upon resolution of EPA’s concern. 

EPA anticipated evaluating the SETF time period wastes during the ORNL-CCP baseline 

inspection of Waste Stream OR-REDC-RH-HET. EPA’s baseline approval cited several 

requirements pertinent to the addition 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 factors for waste outside that presented in CCP-AK-ORNL501. Other revisions are T2 changes. 

 Revisions to the AKSR are T1 changes when they are associated with 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 AK 

Summaries to ensure a thorough link between CCP-AK-ORNL-500 and CCP-AK-ORNL501. CCP-AK-ORNL-500 must include sufficient 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 radiological characterization process. 

 Revisions to the CTP are T1 changes when they 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 Revision 1 of the AKSR, and Revision 2 of the CTP and WSPF. 

ORNL-CCP representatives stated that they had not revised these documents 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 documents raised several 

questions, which were discussed with ORNL-CCP AK personnel during the T1 evaluation in 

Golden, Colorado. These questions were presented as five items under EPA Issue No. EPAORNL-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, including 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 additional justification and information pertaining to SNF, waste 

campaign commingling, and SETF-specific radiological 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 should address waste characterization program 

implementation plan (WCPIP) requirements regarding identification of significant radiological 

discrepancies. Attachment 1 specifies the items 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 approval 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-REDC-RH-HET, stating that this second grouping 

consists of: “LWR and Mixed Oxide fuels [that] were processed in SETF campaigns, which 

were sequenced with the HFIR campaigns...A total of 81 RH TRU casks were generated from 

the HFIR and SETF campaigns over this period. These casks are the subject of this 

characterization report.” 

The AKSR indicates that the waste stream consists of three campaign groupings called the preSETF, SETF, and Mark-42 time periods. The SETF time period includes several SETF 

campaigns that were processed in sequence with HFIR campaigns. The SETF, pre-SETF and 

Mark-42 time periods all contain 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 distributions and quantities of 

the plutonium isotopes, both of which would 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: 

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

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

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

CCP-AK-ORNL-502 Revision 2 states that although 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 generation....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 physical, chemical, or radiological properties as the basis for 

the waste stream. Instead, CCP-AK-ORNL-502, Revision 2 states: “Based on the multiple use 

of process equipment across campaigns, the common 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 argument made by ORNL-CCP regarding a single 

waste stream could be interpreted differently, so EPA examined the physical, chemical, and 

radiological aspects of the waste stream definition to better support the assignment of these 

wastes to a single waste stream. 

The AKSR states that the waste stream is composed of debris generated in chemical processing, 

target fabrication, analytical laboratory and process development, 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 determine whether the physical characteristics of the 

SETF component agreed with the physical description in the AKSR. With regard to waste 

generating processes, ORNL-CCP cites the repackaging process as the methodology for 

homogenizing the waste, but EPA questioned the degree of the waste stream’s homogeneity, 

particularly with respect to repackaging [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-cask partition factors (see Section 4.2) and three 

different scaling factors. 

EPA questioned whether the radiological waste stream description presented in CCP-TP-500 

Revision 2 adequately identified and addressed radiological information presented in CCP-TP501 [see Item (7), below]. ORNL-CCP’s response 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 file 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 physical and radiological similarities of the various campaign 

groupings. EPA recognizes that the radiological compositions based on campaign input 

information imply that there are three distinct populations, which is further supported by the 

choice to use three different scaling factors. In the case of this waste stream, EPA accepts the 

explanation that various scaling 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 generated in the REDC based upon external exposure 
 10 

(surface dose rate) measurements alone. This means that, with the exception of surface dose 

rate, no effort was made to segregate 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 population 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 Tracking Update Forms (various dates, 1981-

1993) 

 Waste Transportation, Storage and Disposal (TSD) Record 

The container data examined by EPA were limited and did not indicate 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 with the overall scaling factors, i.e., the major radionuclide 

contributors (246Cm and 238Pu) identified by radioassay are reflected appropriately in the scaling 

factors. However, no other radiological correlations can be drawn between the surrogate drums 

and the RH waste stream. Based on this information, 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 containers from the SETF time period using DTC 

at the time of the EPA inspection. Additionally, none of the original SETF time period 

containers had undergone repackaging, so batch data reports (BDRs) from visual examination 

(VE) or visual examination technique (VET) were 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, X10SATN02632, 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 Storage or Disposal of Radioactive 

Solid Waste or Special Materials Forms and 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 to 
 11 

contain waste from the HFIR campaigns 57 (campaign date July 25, 1979) and 58 (campaign 

date August 27, 1979). ORNL-CCP representatives also indicated that the content data for the 

casks varies, and more detailed data are sometimes 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 revised CCP-AK-ORNL-500. 

The AK Summary CCP-AK-ORNL-500, Revision 1 states the following with regard to SNF and 

HLW management: 

The WIPP LWA bans the disposal of spent nuclear fuel (SNF) and high-level 

waste (HLW), as defined by the NWPA (Reference 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 waste” 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 contains fission products in sufficient 

concentrations, and other highly radioactive 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 implementing 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 determined 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 understand the pedigree of the waste. This 

reference elaborates on the SNF-HLW management issue, and presents various 

arguments supporting the waste status of fuels managed in REDC saying “Targets 

processed at the REDC are (and were) not irradiated for production of either power or 

weapons grade plutonium, but rather for production of TRU elements for other defense 

related uses and for a wide range of non-defense applications, but particularly for 

research on heavy elements....Irradiated targets processed are not spent nuclear reactor 

fuels under the primary definition adopted in the NWP and DOE Order 435.1”. . 

The AKSR states that the debris created in Building 7920 was generated through: “fabrication of 

target rods containing plutonium, americium, and curium, and to separate and purify heavy 

actinide elements including 249Bk, 252Cf, 253Es, and 257Fm isotopes from the irradiated 
 12 

targets...some uranium fuel cycle development work...[and] research, chemical process 

development, and analytical chemistry” activities that were performed in Building 7920. 

Discussions in the revised AKSR mentioned above and Reference U647 together provide 

sufficient technical basis supporting DOE’s claim that the debris is not SNF or HLW. 

EPA noted that the U647 reference does not address Dresden and H.B. Robinson fuels, which are 

included in the SETF time period wastes. To ensure 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-T1-09-01CR 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 discussion within CCP-AK-ORNL-500 for clarity. 

CCP-AK-ORNL-501 should also be modified 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, ORNL-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. Additionally, the LWR and fast reactor test specimens 

associated with the SETF program involved the processing of these materials for 

development of separation and recovery technologies (References U038 and 

U647). For these reasons, 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 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 evaluated and was found to be adequate. 

The AK Summary Report CCP-AK-ORNL-500 Revision 1 states that a formal defense 

determination was approved by CBFO in April 2006. ORNL-CCP states: 

This determination concluded that the wastes generated by operations in the 

REDC are irretrievably commingled with materials generated, in part, by the 

following atomic energy defense activities (Reference M023): 

• Naval reactors development 

• Defense nuclear materials production 

• Defense nuclear waste and by-products management 

• Defense research and development activities
 13 

ORNL-CCP states that the HFIR target campaigns that produced 252Cf that was fabricated into 

neutron sources and included in the SETF time period waste had defense-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 target campaigns,” thus implying all are defenserelated due to inseparable commingling of waste. 

(7) The AK Summary was evaluated, including physical 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 address the SETF waste stream. However, EPA’s 

review of the document in concert with CCP-AK-ORNL-501, Revision 1 revealed shortcomings 

in CCP-AK-ORNL-500, Revision 1 with respect to specific assumptions and data. EPA 

discussed this issue with ORNL-CCP personnel and included two items relative to 

CCP-AK-ORNL-500, Revision 1 as part of the concern described in (1), above, and they are 

discussed below: 

EPA Concern EPA-ORNL-CCP-RH-SETF-T1-09-01CR, Attachment 1, Item 2: 

CCP-AK-ORNL-501 relies heavily on waste commingling to justify using a single scaling factor 

for the SETF time period. However, the AKSR doesn’t provide much support of this 

commingling argument. CCP-AK-ORNL-500 should better support CCP-AK-ORNL-501 in this 

area. 

EPA Concern EPA-ORNL-CCP-RH-SETF-T1-09-01CR, Attachment 1, Item 3: 

CCP-AK-ORNL-501 includes additional detail pertaining to RH AK information that CCP 

should consider including in CCP-AK-ORNL-500. 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 include 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 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 understandable that CCP may be reluctant to include information from CCP-AK-ORNL-501 

that are calculation-based in CCP-AK-ORNL-500, and that ultimately define the CCP-derived 

radiological composition of the waste (analogous to NDA procedures/characterization 

processes). However, if CCP-AK-ORNL-501 contains information useful to defining the 

radiological properties of a specific time period that has specific radiological characteristics, 

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

Concern Resolution: ORNL-CCP responded by offering several freeze file changes to address 

EPA’s concerns, the most significant of which are excerpted from the text and presented below: 

 Table 4-2 identifies the processing 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 for 
 14 

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 REDC (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. The approach is documented in CCP-AK-ORNL501, CCP Remote-Handled Transuranic Radiological 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 contamination deposition on waste materials are used to derive the 

concentrations of the remainder of the radionuclides 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 already been disposed of. In the time period after 

April 1972, there were a total of 66 processing campaigns: 40 HFIR, 10 SETF, and 

16 Mark-42 (Reference 17). 

In reviewing the radiological information and data collected for these 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 distributions on the waste 

because of the differences in the starting fuel 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 curium 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 campaigns (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, significantly 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 addition, 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 factors from those developed for HFIR campaigns 

only. It is anticipated that waste originating from Campaigns 57 and 58 will have different 
 15 

scaling factors from the rest of the SETF period because these two campaigns were not HFIR 

processing campaigns, but rather purification 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 approach, as containers of 

REDC debris waste are generated during repackaging 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 WCPIP waste stream definitions of waste 

material generated from a single process or from an activity that is similar in material, 

physical form, hazardous constituents, and radiological constituents (References 1, 2, M100, 

and U038). 

Status of Concern: EPA accepted these changes and determined 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 Related Document Tracking were evaluated 

with respect to completeness and found to be adequate. 

ORNL-CCP expends significant effort to identify and acquire AK Support Documents. 

CCP-TP-005, Revision 18, Attachments 1 and 4 present the references for the waste stream and 

overall support documents, respectively, and these forms are typically complete and adequately 

cross-referenced. However, some of the references 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 reference 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 Certification Plan (CCP-AK-ORNL-502, 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 characterization DQOs and quality assurance 

objectives (QAOs) that will be satisfied with the data being qualified 

 A description of the DQOs and QAOs that will 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 subject to confirmatory testing 

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

or waste stream lot 

 Quantitative acceptance criteria for determining that the AK information in question can 

be qualified as characterization information 

The CTP provides a description of the waste stream, DQOs/QAOs, and a general description of 

the characterization program, but did not clearly 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 process did not result in wastes with common radiological 

characteristics. Therefore, the waste stream definition in the CTP Revision 2 was not supported 

by the information reviewed during the inspection. EPA examined information presented in 

other documents and subsequent revisions to the 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, the discussion therein is not sufficient in that it 

does not include a clear, understandable explanation of the characterization methodologies for 

each of the radiological populations. EPA discussed 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-T1-09-01CR, Attachment 1, Item 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 qualification methods. Specifically, 

Section 2.0 should be revised to clarify the “overarching” qualification processes that apply 

broadly to all REDC wastes, coupled with any sampling/NDA that was done specifically to 

qualify certain time periods. Revision of Sections 2 and 3.1 are not necessary, and it is 

recommended that the discussion clearly address qualification approaches for each time period. 

It is also possible that Section 4.2 (e.g., AK Accuracy, and 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 concern. The response did not adequately address 

EPA’s concern, so ORNL-CCP subsequently provided 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 adequacy of the WSPF and associated CRR were evaluated and 

were found to be acceptable. 

ORNL-CCP provided a WSPF and related CRR for waste stream OR-REDC-RH-HET, which 

was signed by the SPM, Irene Quintana, on February 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 period, as SETF and Pre-SETF wastes have yet to 

be repackaged. In the baseline approval, EPA stated: “Revisions to the Waste Stream Profile 

Form are Tier 1 changes when associated with identification of new scaling 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 specifically identify the 

SETF/Pre-SETF wastes, but EPA expects to continue to be notified of all CRRs (which are 

completed on a lot basis) under the T2 notification process as established 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 examination of SETF cask data had not taken place 

at the time of the inspection and BDRs generated 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 resolution 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 requirements of Section 4.1.1.2 of the WCPIP, will 

review the AK Summary Report, confirmatory test data and identified AK 

discrepancies, and prepare an AK Accuracy Report. This report will identify the 

percentage of containers that have been assigned to another SCG. It will also 

identify the percentage of containers for which there are significant discrepancies 

in radionuclide information between the AK record and measured values. What 

constitutes a significant discrepancy will depend on site- and waste streamspecific considerations. The AK Accuracy 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 CBFO QAPD. The site shall notify the CBFO 

of this condition and implement appropriate corrective actions before proceeding 

with further characterization activities on the affected waste stream(s). 
 18 

ORNL-CCP provided an AK Accuracy Report for Lot 1 of the Mark-42 time period wastes. The 

REDC waste stream is characterized based primarily 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-T1-09-01CR, 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 containers from the SETF time period had not 

undergone DTC. The WCPIP states that the AK Accuracy Report must: “identify the 

percentage of containers for which there are significant discrepancies in radionuclide information 

between the AK Record and measured values.” Sites must also determine what constitutes a 

“significant discrepancy.” The AK Accuracy Report does not address identification of 

significant discrepancies, or why this identification would not be meaningful for this waste 

stream with respect to isotopic contribution. ORNL-CCP indicated that because these wastes 

have been characterized using AK-based scaling factors, comparison of the AK and the 

measured values based on AK amounts to an AK-AK comparison. It is agreed 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 representatives 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 management 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 inspection related to AK that is discussed above, and a copy of 

the EPA Evaluation Issue Tracking Form recording it is provided in Attachment 1. All five 

items of this concern were adequately resolved and this concern is closed. There are no open 

concerns related to AK resulting from this T1 evaluation. 
 19 

Tiering Changes 

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

assigned to AK during the baseline approval.

4.2 Radiological Characterization 

RH Waste Overview 

Waste Stream OR-REDC-RH-HET contains mixtures of radionuclides 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 campaigns involved the processing 

of curium targets that had been irradiated in the HFIR reactor and allowed to cool for decay of 

short-lived fission products before being processed in the REDC. The targets typically contain 

americium (mostly 243Am), all of the curium isotopes except 243Cm, the transcurium elements of 

californium (Cf), berkelium (Bk), einsteinium (Es), mendelevium (Md), fermium (Fm), and a 

small amount of plutonium impurity contributed by the targets and the decay of 242Cm and 

244Cm. The transcurium elements represent the end products that are produced, removed, and 

purified in the REDC, and by design, trace amounts remain in the wastes post-processing. Due 

to the relatively small amounts of 239Pu 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 campaigns also processed: light water reactor (LWR) 

fuels from two commercial power reactors; fast reactor mixed oxide fuels that had been 

irradiated in the FFTF at Hanford; 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 (238Pu) 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 respect to obtaining meaningful 

measurement data. As has been the case at the six RH TRU waste characterization sites that 

EPA has previously approved, RH radiological characterization relies on the development of 

scaling factors that correlate an easily measured parameter like a waste container’s external 

exposure (dose) rate with isotopic distributions for specific TRU radionuclides. The 

development of radionuclide scaling factors for SETF wastes is essentially the same as what 

EPA evaluated and approved during the ORNL-CCP baseline inspection. The development of 

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

 REDC records of the HFIR processing of relevant 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 characterization 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 137Cs partition factors. 
 20 

 NDA results from the same CH TRU debris waste stream generated in the REDC hot cells 

were used to confirm the model and support the 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 evaluation, EPA examined the following elements of 

the ONRL-CCP radiological characterization program: 

 Development of a DTC correlation as a function of waste density using MCNP5 based on 

each drum’s measured external exposure (dose) rate, assuming the main contributors to the 

external exposure were 137Cs and 154Eu 

 Development of partitioning factors to adjust the ratio of the TRU radionuclides of interest to 

137Cs and 154Eu, as appropriate 

 Derivation of radionuclide scaling factors for quantification of the 10 WIPP-tracked 

radionuclides as supported by calculation packages and the destructive assay of swipe 

samples from 1995–1996 

Documents Reviewed 

The list provided below includes all documents related to the ORNL-CCP SETF RH TRU 

radiological characterization program 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 ORNL: Status Briefing, June 

11-12, 2008, J. Vance 

 CCP-AK-ORNL-501, Central Characterization Project Remote-Handled Radiological 

Characterization Technical Report For Remote-Handled Transuranic Waste From the 

Mark-42 Time Period from Oak Ridge National Laboratory Radiochemical 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 Radiochemical Engineering Development Center 

Remote-Handled Transuranic Waste; Waste Stream: OR-REDC-RH-HET; Revision 0, 

May 2, 2008 

 CCP-AK-ORNL-502, Central Characterization Project RH TRU Waste Certification 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; Revised 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, 2008 
 21 

 ORNL-RH-04, Campaigns 69 and M5 Inventory 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 Time-Mark/HFIR, Revision 4, February 20, 

2009 

 ORNL-RH-13, MCNP5 Analysis for 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 Time-HFIR/HFIR, Revision 4, February 20, 

2009 

 ORNL-RH-25, Uncertainty Calculation for 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 for 3 Drums in Cask, August 10, 2008 

 ORNL-RH-30, Sr-90 Partition Factor 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 Development for All Campaigns, Revision 1, June 

29, 2009 

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

 ORNL-RH-45, Typical Cs-137 Activity in HFIR Targets for Missing Inventory Values, 

April 6, 2009 

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

 ORNL-RH-50, Mark 42 Alternative Scaling Factor Method 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 137Cs and 154Eu concentrations in SETF wastes were evaluated 

and were found to be adequate.

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

factors relate to the inventory values of the radionuclides of interest and 137Cs that are introduced 

into the hot cells at the start of each processing 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 correlation 
 22 

of the SETF radionuclide inventory values to the 137Cs and 154Eu concentrations for the SETF 

period in Waste Stream OR-REDC-RH-HET. 

(2) The development of radionuclide scaling factors and partition factors was evaluated and 

both were found to be technically adequate and appropriately documented. 

A radionuclide scaling factor provides a technically 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., 137Cs and 154Eu in the case of SETF wastes. For the HFIR and Mark-42 wastes, there were 

multiple campaigns involving 244Cm sources, and three specific isotopic ratios had to be 

deconstructed for each sample: 134Cs/137Cs; 242Cm/244Cm; and 243Am/244Cm. This resulted in 

scaling factors in units of curies of each radionuclide per curie of 137Cs (Ci/Ci 137Cs). For SETF 

wastes, there were campaigns that (Campaigns 57 and 58) did not involve processing HFIR 

materials, but rather were purification campaigns for Am-Cm slugs that had been produced by 

SRS. Both campaigns contained relatively large concentrations of 243Am, and Campaign 58 also 

contained relatively large concentrations of 238Pu. Accordingly, there are three sets of scaling 

factors: one for campaign 57; one set for Campaign 58; and one set for all other SETF wastes. 

These are shown in Table 2, below. 

Partition factors were developed based on 244Cm, 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 ratio divided by the activity waste ratio, as shown 

in CCP-AK-ORNL-501, Revision 2, Table A3-1. These activity ratios were then converted to 

mass values and these were used to derive an expected ratio of actinide to 137Cs for all SETF 

wastes except Campaigns 57 and 58. 
 23 

Table 2. ORNL RH TRU Scaling Factors for the SETF Time Period in 

Units of Curies of Specific Radionuclide/Curies 137Cs (Ci/137Ci) 

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 statistical metrics, namely mean and standard 

deviation values for each measured radionuclide 

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

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

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

attribute 

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

such that they could be responsible for the measured external dose rate, i.e., 137Cs and 

154Eu 

 Contributions of the short-lived radionuclides 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 development and routine assays performed via 

DTC 

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

external dose rates obtained via DTC to radionuclide activity levels 

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

(

233U, 234U, 238U, 238Pu, 239Pu, 240Pu, 242Pu, 241Am, 137Cs and 90Sr) 
 24 

 The determination of the contribution of all radionuclides to the radiological hazard3

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

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

geometry appropriate to the SETF waste 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 Issue 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 used for calculations related to ORNL SETF RH wastes are not 

documented. The half-life values used were generally 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 were 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 characterization of ORNL SETF RH TRU 

wastes. This issue was raised at a previous EPA 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 related to the technical adequacy 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 correlation and its documentation were evaluated and 

found to be unchanged from what EPA had inspected 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 dispersed uniformly throughout the waste 

 The waste matrix’s density is assumed to be unity (one), because 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/cm3

 

3

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

information may be useful in understanding other aspects of a container’s radiological characterization. 
 25 

Using MCNP54, ORNL-CCP developed a DTC correlation for an ORNL drum filled with RH 

TRU waste in terms of mR/hr for a 1-curie source of 137Cs and 154Eu. 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 137Cs and 154Eu. 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 (Revision 0 032009). The spreadsheet contained 

the required information, specifically: cask identification number; container gross weight; 

estimated fill percentage; and results of the four dose rate measurements 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, Revision 2. Since Campaigns 

57 and 58 have different scaling factors, the four casks that were generated from these campaigns 

have been assigned the appropriate scaling factors in the DTC worksheet based on the cask 

generation dates. There were no concerns regarding the technical basis of the DTC correlation 

and its documentation for the ORNL-CCP SETF wastes. 

(4) Technical aspects and documentation 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 for the SEFT wastes. This document is supported by a series of 

calculation packages, seventeen of which were reviewed 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 support 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 verification of Microshield®

 Evaluation of all potential contributors 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 uncertainty for SETF wastes 

 Information input checks for SETF wastes 

 Technical development of scaling factors and 137Cs partitioning factors 

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

The EPA evaluation team reviewed these packages and Revision 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 discussions, 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 technical concerns and apparent discrepancies with ORNL-CCP 

personnel and to question ORNL-CCP personnel regarding a variety of technical aspects related 

to the SETF wastes. None of the calculation packages required serious modifications. The EPA 

evaluation team found that CCP-AK-ORNL-501 adequately documented the radiological 

characterization process for SETF wastes, and the calculation packages cited above adequately 

supported the activities upon which the radiological characterization of SETF wastes was based. 

There were no issues related to the documentation of technical aspects of the ORNL-CCP 

radiological characterization approach for SETF wastes. 

(5) The technical basis and derivation of Total 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 determination of the radiological constituents of RH 

TRU waste. These aspects are assumed to be independent, which allows them to be added in 

quadrature. The TMU determination included contributions of the following: 

 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 principal sources of uncertainty in the 137Cs scaling factors 

result from: variations in the campaign-to-campaign scaling factors; variations in the 137Cs 

partition factors; and variations in the waste content from drum-to-drum. However, 

uncertainties for Campaigns 57 and 58 do not include 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/cm3

Radionuclide 

137Cs 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 assessed and were found to be adequate. 

The determination that the RH containers meet the definition of TRU wastes and RH waste were 

examined during the baseline inspection. Both of these aspects are directly involved with the 

DTC measurement at the Transuranic Waste Processing 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 determinations 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 findings related to radiological characterization. 

EPA identified one concern during the inspection related to radiological characterization that is 

discussed above, and a copy of the EPA Inspection Issue Tracking Form recording it is provided 

in Attachment 2. This concern did not require a response and there are no open concerns related 

to radiological characterization resulting from this T1 evaluation. 
 28 

Tiering Changes 

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

assigned to radiological characterization during the baseline approval.

5.0 FINDINGS OR CONCERNS 

Summary of Findings and Concerns 

The EPA inspection team did not identify any 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 characterization that did not require a response. Both 

are discussed above, and a copy of both EPA Inspection Issue Tracking Forms recording these 

issues is provided in Attachments 1 and 2, respectively. The AK concern that required a 

response was adequately addressed 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, there 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 characterization processes of AK and radiological characterization 

proposed for use to characterize RH TRU wastes from the SETF period are adequate, as 

evidenced by the records produced in characterizing ORNL RH TRU Waste Stream OR-REDCRH-HET. There were three concerns, two of which required a response, and ORNL-CCP 

adequately addressed both concerns. There are no open issues relative to this T1 evaluation. 

Approval 

The T1 change that was evaluated consisted of the waste characterization 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, there are no changes to the T1 and T2 designations 

assigned to AK or radiological characterization during the baseline approval. 
 

 

Attachment 1 

EPA Evaluation Issue Tracking Form – Acceptable Knowledge 
 Page 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 reviewed in conjunction with the Tier 1 evaluation of the 

SETF-time period waste, including 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 additional justification and 

information pertaining to SNF, waste campaign commingling, and SETF-specific radiological 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 should address WCPIP requirements regarding 

identification of significant radiological discrepancies. Attachment 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, 2009
 

1-2 

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 within 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 material is not SNF). Freeze File.

2. CCP-AK-ORNL-501 relies heavily on waste commingling 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 pertaining to RH AK information that CCP 

should consider including in CCP-AK-ORNL-500. Specifically, those data in CCP-AKORNL-501 Appendix A that are AK-based that are not yet included in the AK Summary 

(e.g., references P083, U090 and U092—there could be more), but which include 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 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 understandable 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 waste (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, relevant information 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 qualification methods. 

Specifically, revision of Section 2.0 to clarify the “overarching” qualification processes that 

apply broadly to all REDC wastes, coupled with any sampling/NDA done to specifically 

qualify certain time periods is required. Revision of Sections 2 and 3.1 appear necessary, and 

it is recommended that the discussion clearly address qualification approaches 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 are significant discrepancies in radionuclide 

information between the AK Record and measured values.” Sites must also determine what 

constitutes a “significant discrepancy.” The AK Accuracy report does not address 

identification of significant discrepancies, or why this identification 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 AK 
 

1-3 

Record and the measured value would essentially be an AK-AK comparison. It is agreed 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 annual 

revision, the AK Accuracy Report should address 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 address 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 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 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 waste outside that presented in CCP-AK-ORNL501 other revisions are T2 changes. (See Table 1, where these are included as a T1 and 

T2 changes, respectively.) 

Revisions to the AKSR are T1 changes when they are associated with the identification 

and/or development of new scaling factors and waste outside those presented in CCPAK-ORNL-500; other revisions are 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 information to support the waste stream 

designation and present, at a minimum, summary descriptions of data used in CCP-AKORNL-501 as part of the radiological characterization process 

Revisions to the CTP are T1 changes when they 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 included as a T2 change.) 

 
 

Attachment A.2 

EPA Evaluation Issue Tracking Form – Radiological Characterization 
 

2-1 

Inspection No. EPA-ORNL-CCP-RH-SETFT1-09Issue 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. Stroble, Mike Sensibaugh and Irene Quintana 

E. Additional Comments: This concern addresses documentation of the half-life values that were used. 

There is no concern regarding the accuracy of the half-life values that were used, or the data generated 

through their application, with respect to supporting ORNL SETF RH wastes. This issue was raised at a 

previous RH inspection at GE VNC (December 2008) and EPA suggests that CCP address this issue. 

F. Site Response Information: 

 Site Response Required? YES NO

 Site Response Due Date: Not applicable