DOCKET NO: A-98-49, II-A4-168

WASTE CHARACTERIZATION REPORT

EPA TIER 1 EVALUATION

OF THE CENTRAL CHARACTERIZATION PROJECT

CONTACT-HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM

FOR THE LOS ALAMOS NATIONAL LABORATORY:

APPROVAL OF THE ADDITION OF SUMMARY CATEGORY GROUP S4000 (SOILS)

September–November 2012

U.S. Environmental Protection Agency

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

December 2012ii TABLE OF CONTENTS

Section Page

1.0 Introduction ......................................

................................................... .................................1

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

................................................... ......................4

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

................................................... .........................4

4.0 Scope of the Tier 1 Evaluation.....................

................................................... .....................5

5.0 Evaluation Personnel ..............................

................................................... ..........................5

6.0 Technical Evaluation ..............................

................................................... ..........................5

6.1 Acceptable Knowledge ..............................

................................................... ...........8

6.2 Real-Time Radiography .............................

................................................... .........20

7.0 Conclusions .......................................

................................................... ..............................22

LIST OF TABLES

Table 1. Tiering of Contact-Handled Transuranic Was te Characterization Processes

Implemented by LANL-CCP ...........................

................................................... ........... 2
Table 2. Tier 1 Evaluation Participants ...........

................................................... ............................. 5
Table 3. TA-21 Material Disposal Area Information a nd TRU Waste Soil Generation ................ 7

Table 4. Batch Data Reports Examined, Waste Stream LA-MSG04.001 ...................................... 8
Table 5. Material Types Potentially Present in Wast e Stream LA-MHG04.001 .......................... 10
Table 6. Traceability of Selected Containers in Was te Stream LA-MSG04.001 ......................... 15

ATTACHMENTS

Attachment A: Approval Summary for LANL-CCP CH Was te Characterization Program

Attachment B: List of Documents Reviewed for This Evaluation Attachment C: CCP Standing Order CCP-SO-086, Revis ion 0iii ABBREVIATIONS, ACRONYMS AND INITIALIZATIONS

Ac actinium

AK acceptable knowledge

AKE acceptable knowledge expert

AKIR Acceptable Knowledge Isotopic Ratio (database)

AKSR acceptable knowledge summary report

Am americium

BDR batch data report

CBFO Carlsbad Field Office

CCP Central Characterization Project

CFR Code of Federal Regulations

CH contact-handled

cm centimeter

Cm curium

CONCERT Container Certification (database)

D&D decontamination and decommissioning

DOE U.S. Department of Energy

DP Delta Prime

EA expert analyst

EPA U.S. Environmental Protection Agency

HENC High Efficiency Neutron Counter

HENC No. 1 HENC Unit 1

HENC No. 2 HENC Unit 2

HLW high-level waste

ITR Independent Technical Reviewer

LANL Los Alamos National Laboratory

LLW low-level waste

MDA material disposal area

MT material type

NCR nonconformance report

NDA nondestructive assay

NDE nondestructive examinationiv

NTP National TRU Programs

NWP Nuclear Waste Partnership, LLC

NWPA Nuclear Waste Policy Act

ORNL Oak Ridge National Laboratory

OSRP Offsite Sealed Source Recovery Program

Po polonium

Pu plutonium

QMIS Quality and Management Integrated System

R&D research and development

RTR real-time radiography

SCG summary category group

SNF spent nuclear fuel

SPM site project manager

SuperHENC Super High-Efficiency Neutron Counter

Sr strontium

SSVET Sealed Source VET

T1 Tier 1

T2 Tier 2

Th thorium

TRU transuranic

U uranium

VE visual examination

VET visual examination technique

WAC waste acceptance criteria

WIPP Waste Isolation Pilot Plant

WMP waste material parameter

WSPF waste stream profile form

WWIS WIPP Waste Information System1

1.0 INTRODUCTION

This report supports the U.S. Environmental Protect ion Agency’s (EPA’s) approval of the proposed Tier 1 (T1) change to the EPA-approved tra nsuranic (TRU) waste characterization program at Los Alamos National Laboratory (LANL). T his T1 approval allows the LANL Central Characterization Project (CCP) to dispose o f retrievably-stored, contact-handled (CH) TRU Summary Category Group (SCG) S4000 (Soils) wast e at the Waste Isolation Pilot Plant (WIPP).

In accordance with Title 40 of the Code of Federal Regulations (40 CFR) 194.8(b), EPA conducted Baseline Inspection No. EPA-LANL-CCP-05.0 5-8 of LANL-CCP on May 3–5, 2005. As a result of this baseline inspection, EPA approv ed the LANL-CCP waste characterization program with conditions and limitations as document ed in the LANL baseline final inspection report (see EPA Docket No. A-98-49, II-A4-88).

On July 16, 2012, the Carlsbad Field Office (CBFO) requested EPA approval of the addition of SCG S4000 (Soils) to LANL-CCP’s EPA-approved CH was te characterization program as a T1 change. EPA’s review, conducted in September–Novemb er 2012, covered LANL SCG S4000 Waste Stream LA-MSG04.001. EPA’s desktop evaluation focused on (1) acceptable knowledge (AK) with a supplemental review of relevant compone nts of nondestructive assay (NDA), and (2) nondestructive examination (NDE), specifically, real-time radiography (RTR). During the evaluation, EPA did not identify any findings or co ncerns; however, EPA had questions concerning AK and the required semiannual training of RTR operators and asked that LANLCCP address EPA’s AK questions by revising pertinen t AK documents. Based on this evaluation, EPA approves the addition of SCG S4000 (Soils) to the EPA-approved CH waste characterization program at LANL-CCP. This EPA appr oval required revisions to the Tier 2 (T2) designations, which are indicated in bold in the revised tiering table (see Table 1).

This report serves as EPA’s public notification of the approval of this T1 change. EPA will provide this information through the EPA website an d by sending emails to the WIPPNEWS list, in accordance with 40 CFR 194.8(b)(3).2Table 1. Tiering of Contact-Handled Transuranic Waste Characterization Processes Implemented by LANL-CCP(Based on May 23–25, 2006, Baseline Inspection andSubsequent T1 Evaluations, Updated December 2012)Waste CharacterizationProcess ElementsLANL-CCP Waste Characterization Process – T1 ChangesLANL-CCP Waste Characterization Process – T2 Changes*Acceptable Knowledge (AK) andLoad ManagementAny new waste category, or new Offsite Sealed Source RecoveryProgram (OSRP) wastes addressed in AK summary reports(AKSRs) separate from CCP-AK-008Implementation of load management for waste streamsother thanAK-009Notification to EPA upon completion of, updates toor substantivemodification*** to the following:-AK accuracy reports;-AK reassessment memoranda and combination of wastestreamsthat were distinct at the time of this inspection;-AK-VE memoranda related to VE and/or RTR techniques;-AK-NDA memoranda;-AKSRs (new and updated versions);-Site procedures requiring CBFO approval;-AKSR CCP-AK-008, if changed since the baseline inspectionand/or following the addition of new sealed sources;-Any new or updated waste stream profile forms (WSPFs),including all associated attachments (e.g., characterizationinformation summary and summation of aspects)and anychange notices used to modify and update WSPFs, includingadditions to waste stream(s) within an approved waste categoryNondestructive Assay (NDA) New equipment or physical modifications to approved equipment**Extension or changes to approved calibration rangefor approvedequipmentNotification to EPA upon completion of changes to software forapproved equipment, operating range(s) and site procedures that requireCBFO approvalReal-Time Radiography (RTR) N/A Notification to EPAupon the following:-Implementation of new equipment or substantive modification***to approved equipment;-Completion of changes to site procedures requiringCBFOapprovalsVisual Examination (VE) andVisual Examination Technique(VET), including OSRP Wastes(Sealed Source VET or SSVET)N/A Notification to EPA upon the following:-Completion of changes to site VE and VET proceduresrequiringCBFO approvals, including OSRP VET procedure3WIPP Waste Information System(WWIS)N/A Notification to EPA upon the following:-Completion of changes to WWIS procedure(s) requiring CBFOapprovals;-Changes to the Excel spreadsheet, WWIS data entry summary,characterization and certification*** that requireCBFO approvalNew T1s, T2s and significant modifications to existing T1s or T2s are inboldtext; T1s or T2s that were only revised for styleare not shown in bold.* Upon receiving EPA approval, LANL-CCP will reportall T2 changes to EPA at the end of each fiscal year quarter.** “Modifications to approved equipment” include all changes with the potential to affect NDA data relative to waste isolation and exclude minor changes,such as the addition ofsafety-related equipment.*** “Substantive modification” means changes with the potential to impact the site’s waste characterization activities or documentation thereof, excluding changes that are solelyrelated to environmental safety and health, nuclearsafety, the Resource Conservation and Recovery Act, or are editorial in nature.4

2.0 PURPOSE OF TIER 1 EVALUATION

Certain changes to the waste characterization activ ities since the date of the baseline inspection must be reported to and, if applicable, approved by EPA according to the tiering requirements set forth in 40 CFR 194.8 and incorporated into the LAN L-CCP baseline final report cited in EPA Docket No. A-98-49, II-A4-88.

Under the changes to 40 CFR 194.8 promulgated in th e Federal Register on July 16, 2004 (Vol. 69, No. 136, pages 42571–42583), EPA must per form a single baseline inspection of a TRU waste generator site’s waste characterization p rogram. The purpose of EPA’s baseline inspection is to approve the site’s waste character ization program, based on the demonstration that the program’s components, with applicable cond itions and limitations, can adequately characterize TRU wastes and comply with the regulat ory requirements imposed on TRU wastes destined for disposal at the WIPP.

Following EPA’s baseline approval, EPA is authorize d to evaluate and approve changes, if necessary, to the site’s approved waste characteriz ation program by conducting additional inspections under the authority of 40 CFR 194.24(h) . Changes requiring EPA notification and approval prior to implementation (T1) and those req uiring post-implementation notification (T2) are identified in the site-specific baseline inspec tion reports. When evaluating proposed T1 changes for approval, EPA may conduct a site inspec tion to observe the implementation of the change, or EPA can decide to conduct a desktop revi ew of information provided specific to a change. The U.S. Department of Energy (DOE) may cho ose to characterize and dispose of, at risk of subsequent EPA disapproval, any previously approved TRU waste using processes, procedures or equipment implemented as T2 changes. EPA reviews T2 changes on a quarterly basis and may conduct continued compliance inspecti ons to evaluate implemented T2 changes to verify adequacy.

3.0 PURPOSE OF THIS REPORT

This report presents the results of EPA’s evaluatio n of a T1 change to add SCG S4000 soils to LANL-CCP’s EPA-approved CH waste characterization p rogram. This report presents the technical basis of EPA’s approval decision, which h as been conveyed to DOE separately by

letter. EPA will also announce the decision on its website at www.epa.gov/radiation/wipp , in accordance with 40 CFR 194.8(b)(3).

The DOE documents that EPA reviewed for this evalua tion are cited in different sections throughout the report and are listed in Attachment B. Any of these documents can be requested from the following address:

Carlsbad Field Office Manager, National TRU Program U.S. Department of Energy

PO Box 3090 Carlsbad, NM 88221-30905

4.0 SCOPE OF THE TIER 1 EVALUATION

The scope of this T1 evaluation is the addition of SCG S4000 soils to LANL-CCP’s EPAapproved CH waste characterization program. Section s 6.1 and 6.2 of this report detail the two technical areas assessed during this evaluation:

• Programmatic requirements and AK, including NDA.

• RTR.

5.0 EVALUATION PERSONNEL

EPA and its support personnel conducted a desktop A K review followed by a meeting with LANL-CCP AK experts (AKEs) to resolve outstanding q uestions. Additional EPA questions related to RTR were addressed by email with CBFO an d LANL-CCP personnel. Table 2 lists the EPA evaluation team members and LANL-CCP personnel who participated in this evaluation, with each person’s position during the evaluation a nd affiliation.

Table 2. Tier 1 Evaluation Participants

Inspection Team Member Position Affiliation Ed Feltcorn Lead Inspector U.S. EPA
Rajani Joglekar Inspector U.S. EPA

Connie Walker Technical Inspector, AK S. Cohen & As sociates, Inc.

Dorothy Gill Technical Inspector, NDE S. Cohen & As sociates, Inc.

Patrick Kelly Technical Inspector, NDA S. Cohen & A ssociates, Inc

Rose Gogliotti Technical Inspector, NDA S. Cohen & Associates, Inc.

Randy Fitzgerald Acceptable Knowledge Expert LANL-C CP

Jim Shoen Acceptable Knowledge Expert LANL-CCP

Mike Papp Acceptable Knowledge Expert LANL-CCP

Tom Morgan NTP-CCP Manager CBFO

Ron Reeves Technical Support-Team Lead NWP-CCP

The two waste characterization technical areas of A K and NDE are addressed in section 6.0 of this report. The AK evaluation was comprehensive be cause the documentation for LANL CH soil waste had not been previously reviewed. The ND A and NDE reviews were limited and focused primarily on evaluating NDA and RTR batch d ata reports (BDRs); the NDA review is included in the AK section of this report (section 6.1).

6.0 TECHNICAL EVALUATION

Waste-Generating Activities

Waste Stream LA-MSG04.001 consists of soil generate d during cleanup, retrieval and decontamination and decommissioning (D&D) activitie s at the LANL TA-21 Delta Prime (DP) West Facility. The waste includes minor absorbents that were added during packaging and small amounts of debris, including blacktop, concrete and piping, and contains radionuclides from6

operations at TA-21. Contaminated soil originated f rom the removal of acid wells and lines associated with the liquid waste water treatment sy stems, tunnels below buildings in which “non standard event” spills occurred, material disposal areas (MDAs), and other spill locations. Ongoing cleanup of TA-21 may generate TRU waste soi l that would be included in this waste stream (References C033, D006, D008, D058, D060, D0 69, M003, M004, M020, P036 and P037), a part of SCG S4000.

Soils in Waste Stream LA-MSG04.001 were exclusively generated at TA-21, DP-West (References D008, D010, D016, D035, D058, D059 and D060). DP-West began plutonium (Pu) processing operations in September 1945 (References D059 and U001). Operations included:

• Pu recovery operations (pretreatment, dissolution a nd purification).

• Pyrochemical operations (e.g., metal preparation, e lectrorefining, direct oxide reduction).

• Metal operations (alloy development, assembly, cast ing and inspection).

• 239 Pu fuels programs (e.g., advanced fuels fabrication and analysis).

• Americium (Am) processing operations (oxide product ion and hydroxide precipitation).

• 238 Pu heat source fabrication.

• Miscellaneous and special processing.

• Waste management and D&D operations.

LANL used five onsite MDA (MDAs A, B, T, U and V) t renches at TA-21 for solid and liquid waste disposal between 1945 and 1984 (Reference D06 9). Pu-bearing waste generated at TA-21 between 1945 and 1978 was primarily disposed of in these trenches. The TA-21 DP-West Pu operations were transferred to TA-55 in 1978. Waste from Pu processing generated after 1978 was shipped to TA-54 Area G, but LLW disposal in th e TA-21 MDAs continued through 1984 (Reference D059). Table 3 summarizes information ab out each MDA, including remediation status and anticipated generation of TRU soil (Refe rences D059, D069 and P036).

As shown in Table 3, LANL used the TA-21 MDAs for d isposal of TRU waste (References D010 and D059). Soil waste from MDA B is currently in the waste stream. TRU waste may be retrieved from MDA A and MDA T, which could be adde d to this waste stream if physical and radiological characteristics are similar. Remediati on of TA-21 MDAs is ongoing under LANL’s Environmental Restoration Project.

Following the movement of Pu production to TA-55, s ome TA-21 buildings were

decontaminated to a level that allowed “continued o ccupancy of non-plutonium research operations” between 1978 and 1981 (Reference D035). Decontamination included walls and floors and removal of process service systems and g loveboxes; soil was also generated during D&D of Building 257 and all of these wastes were se nt to TA-54 Area G for management (References C033, D006, D008, D035, D058, D060, D06 9, M003, M004, M008, M020, P036 and P037). See section 6.1, Item (7), for more info rmation about TA-54 Area G waste

management.7Table 3. TA-21 Material Disposal Area Information and TRU Waste Soil GenerationMDAPeriod of UseDisposal Featuresand ActivitiesRadiologicalMaterialOtherInformationRemediation StatusSource of TRUSoil Waste?MDA A 1945–1946;Reactivated1969–1977 forLLW disposalThree disposal pitsand two 50,000-gallon tanksPo, Pu, U and Thbearing solid andliquid wastesTanks used for Pu-bearingprecipitation wastes. In 1975,10,600 gallons transferred toTA-21-257, leaving precipitatein tank.Backfilled in 1978.Remediation ongoingunder LANLEnvironmental RestorationProgram.Potential sourceof TRU soilwasteMDA B 1946–1948 One large pit Pu, Po, U, Am,Cm and Ac, solidwastesWestern 2/3 asphalted in 1966,eastern 1/3 used for “in-situexperimental trench cap studies”as of 1986.Remediation ongoingunder LANLEnvironmental RestorationProgram.Source of TRUsoil wasteMDA T 1945–1984 Four absorption bedsused for disposal ofPu process waste(1945–1952). Also62 asphalt-linedvertical shafts usedfor LLW disposaland retrievable wastepit used to 1984.Pu process wastes Liquid waste diverted to TA-21-35 after 1952 for treatment, butfew hundred gallons/year wereplaced in beds up to 1967, afterwhich liquid wastes werediverted to TA-21-257. 1968–1983: liquid LLW solidified andemplaced in asphalt-lined shafts.TRU liquid wastes werecemented and pumped intovertical shafts lined withcorrugated metal pipes.Corrugated metal pipeswere removed in 1986 andtransferred to TA-54 AreaG. Surface area stabilizedin 1984. Remediationongoing under LANLEnvironmental RestorationProgram.Potential sourceof TRU soilwasteMDA U 1945–1968Two absorption beds227Ac and210Powaste waterDisposal of non-TRU waste,based on available records.Soil removed in 1985 andtransferred to Area G.Excavated area was filledand is now monitored.Remediation is ongoingunder LANLEnvironmental RestorationProgram.No TRU wasteexpectedMDA V 1945–1961 Three interconnectedpits used laundryoperation liquidwaste disposal.“Small quantities”of90Sr and239PuArea was isolated in 1984 withchain link fence and surfacewaste stabilized.Remediation ongoingunder LANLEnvironmental RestorationProgram.No TRU wasteexpected8

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

EPA evaluated the documentation that LANL-CCP prepa red to support the addition of the S4000 SCG to the LANL-CCP baseline approval. Attachment B presents the full list of all documents

reviewed.

EPA examined the following RTR and NDA BDRs:

Table 4. Batch Data Reports Examined, Waste Stream LA-MSG04.001

Example Drum Number RTR BDR No. NDA BDR No.

89987 LA-RTR2-11-0116 1LANDA1470

89983 LA-RTR2-11-0116 1LANDA1470

89982 LA-RTR2-11-0116 2LANDA0878

6.1 Acceptable Knowledge

EPA examined the AK process and associated informat ion specific to the radiological and physical contents of the waste stream to determine whether LANL-CCP’s proposed addition of CH retrievably-stored and newly-generated SCG S4000 waste complies with 40 CFR 194.24 and

194.8. EPA also reviewed RTR BDRs for technical ade quacy. The results of this evaluation are presented below.

Technical Evaluation

EPA performed a T1 evaluation of Waste Stream LA-MS G04.001 to determine whether SCG

S4000 waste should be included in EPA’s LANL-CCP CH baseline approval. EPA evaluated the adequacy of AK information in the following areas.

(1) The definition of the waste stream was evaluated an d found to be adequate.

CCP-TP-005, Revision 24, page 22, defines a waste s tream as “waste materials that have common physical form, that contain similar hazardou s constituents (similar radiological properties for WCPIP compliance) and that are gener ated from a single process or activity.”

Waste Stream LA-MSG04.001 was evaluated to determin e whether the waste stream was adequately defined by its physical and radiological contents. As described in section 6.0 above, Waste Stream LA-MSG04.001 consists of soil generate d during various activities at the TA-21 DP-West Facility. LANL-CCP historically assigned nu mber MSG01-DD to contaminated soil from the TA-21 DP-West Facility (References C033, D 006, D008, D058, D060, D069, M003, M004, M020, P036 and P037).

The TA-21 DP-West plutonium operations were transfe rred to TA-55 in 1978. The AK available for TA-21 operations is minimal; however, operation al activities at TA-55 mirrored those performed at TA-21. Table 3 in the acceptable knowl edge summary report (AKSR) compares these activities. Therefore, the TA-55 process info rmation as detailed in the AKSR is an adequate substitute for the TA-21 process informati on.9

Based on the above information, the processes gener ating Waste Stream LA-MSG04.001 are adequately defined.

LANL-CCP described the physical composition of the waste stream in the AKSR and in CCPTP-005, Attachment 6. LANL-CCP based this descripti on on an Oak Ridge National Laboratory (ORNL) soil because stream-specific NDE was not ava ilable. However, the soil characteristics of

Waste Stream LA-MSG04.001 and the ORNL soil waste s tream are very different. The ORNL soil waste stream underwent homogenization and was mixed with various sorbents (e.g., RADSORB), so ORNL soil does not contains debris lik e what is expected in Waste Stream LAMSG04.001, which will not be sorted or homogenized to remove debris. LANL-CCP will reevaluate the physical characteristics of the wast e stream as CCP NDE data become available and will revise the AKSR appropriately. See Item (4 ) for additional information. When this evaluation is complete, the physical characteristic s of Waste Stream LA-MSG04.001 will be adequately defined. Notification to EPA upon comple tion of new or revised AKSRs is a new T2 change (see Table 1).

The AKSR states that the two predominant radionucli des by mass are plutonium-239 ( 239 Pu) and uranium-238 ( 238 U), as represented by Material Type (MT) 52. 1 Generator-reported radionuclide composition data are available for many containers in the waste stream, but the nature of this information ranges from detailed isotopic distribut ions to only 239 Pu values or identification of MTs (References C033, C037, M004, M009 and M020). T he radiological composition of Waste Stream LA-MSG04.001 is adequately defined and will be verified through actual assay; the AKSR will be updated as necessary to reflect this i nformation. See Item (2) for additional

information.

(2) Acceptable knowledge information pertaining to the radiological characteristics of

transuranic wastes was examined and found to be ade quate.

Table 14 in the AKSR presents the overall radiologi cal composition based on generator TRU waste storage and solid waste disposal records, inf ormation from the LANL Acceptable Knowledge Isotopic Ratio (AKIR) and Container Certi fication (CONCERT) databases, augmented by LANL-CCP NDA data. Historical measurem ent data were not reported on reviewed documentation, but the MT was sometimes re ported. LANL-CCP included this information in the AK tracking spreadsheet. AKSR Ta ble 14 indicates that 239 Pu and 238 Pu are the predominant radionuclides by weight and that 239 Pu and 241 Am are the predominant radionuclides by activity.

EPA determined that radiological information for ea ch container generated between 1978 and

1981 included 239 Pu mass information, and nearly two-thirds of the d rums with data also reported

masses for 235 U, 238 Pu and 241 Am. Recently generated MDA B soil data results also reported

mass data for 234 U, 238 U, strontium-90 ( 90 Sr), cesium-137 and tritium (Reference M020). EPA examined representative solid waste disposal and TR U waste storage records as well as data from the AKIR and CONCERT databases and AK tracking spreadsheet to verify radiological information about each container (References C033, C037, M004, M009 and M020).

1 MTs represent a range of specific isotopic composi tions focusing on accountable (nuclear) material, i.e., Pu, U, 241 Am and other radionuclides, as appropriate.10

As mentioned in Item (1), the Pu processing operati ons that took place at TA-55 directly correlate to processing that took place at TA-21; t herefore, the radiological characteristics of material managed at the two facilities should be co mparable. LANL-CCP assigned common MTs to the TA-21 activities that directly correlate to TA-55 activities. Table 5 presents radiological MTs managed at TA-21.

Table 5. Material Types Potentially Present in Wast e Stream LA-MHG04.001

Material Type (MT) Plutonium Isotope (Weight %) Estimated Weight %

Relative to Total

Plutonium a

238 Pu 23 9 Pu 240 Pu 241 Pu 242 Pu 244 Pu 234 U 235 U 241 Am

MT 51 0.006 96.77 3.13 0.076 0.018 — 0.001 0.1 0.06

MT 52 0.01 93.78 6.0 0.2 0.02 — 0.002 0.1 0.2

MT 53 0.03 91.08 8.45 0.366 0.071 — 0.007 0.09 0.3

MT 54 0.046 87.42 11.5 0.81 0.22 — 0.01 0.09 0.7

MT 55 0.06 83.88 14.73 1.03 0.304 — 0.02 0.09 0.9

MT 56 0.061 81.99 16.51 1.18 0.355 — 0.02 0.09 1.0

MT 57 0.433 74.63 20.7 2.55 1.69 — 0.1 0.08 2.0

MT 42 0.73 1.06 6.4 1.97 89.83 — 0.3 0.0009 3.0

MT 83 78.9 18.4 2.5 0.055 0.15 — 33.1 0.02 0.42

Uranium Isotope (Weight %)

234 U 235 U 236 U 238 U

MT 12 0.0015 0.23 0.008 99.77

MT 35 0.36 37.6 0.14 61.9

MT 36 0.63 62.44 0.18 36.75

MT 38 1.03 93.04 0.41 5.53

MT 39 1.32 97.52 0.17 0.99
Source: CCP-AK-LANL-010, Central Characterization P roject Acceptable Knowledge Summary Report for Los Alamos National Laboratory, TA-21 DP West Facility, Waste Streams: LA-MHD04.001, LA-MSG04.001, Revision 5, May 1, 2012, Table 7 and Table 8.

a Assumes no chemical fractionation (References C021 and D034).

Soil generated during site cleanup may contain seve ral different MTs because multiple releases occurred from different origins. Individual contain er data may not correlate to a specific MT and may be better represented by a combination of MTs, as implied by the overall composition presented in AKSR Table 14. The AK-NDA memorandum p resented with CCP-TP-005, Attachment 7 (September 23, 2012), states, “The pri mary MT fed into the processes producing this waste stream is weapons grade Pu (MT 52), howe ver, other material types were also

introduced as feed material.” Distributions presented in AKSR Table 14 show that 239 Pu is the predominant plutonium isotope, but the distribution s do not match the MT 52 distribution exactly, supporting LANL-CCP’s determination that s oil contains mixtures of various MTs.

Based on current information, the radiological comp osition of the waste is adequately defined and will be modified as necessary to reflect ongoin g LANL-CCP NDA data. EPA expects LANL-CCP to modify AKSR Table 14, as necessary. EPA will evaluate revisions of this table when the AKSR is submitted as a T2 change.11

(3) Radioassay batch data reports were evaluated an d were found to be adequate.

EPA reviewed NDA BDR Nos. 1LANDA1470 and 2LANDA0878 for the High Efficiency Neutron Counter Unit 1 (HENC No. 1) and HENC No. 2, respectively, which contained assays

of S4000 and S5000 wastes. The two BDRs contained a total of 14 drums, seven of which were S4000 waste: Drum Nos. 89987, 89985 and 89984 from HENC No. 1 BDR 1LANDA1470; and Drum Nos. 89982, 89988, 89891 and 89986 from HENC N o. 2 BDR 2LANDA0878. EPA verified that each BDR included the following:

• Site project manager (SPM) checklist, Attachment 3.

• BDR cover sheet, Attachment 1.

• Discrepancy resolution table of contents, Attachmen t 2.

• BDR narrative summary, Attachment 3.

• Independent technical reviewer (ITR) review checkli st, Attachment 4.

• Measurement control report.

• Container data sheets.

• Evidence of signatures by the ITR and an SPM.

• Type of waste in each container, SCG S4000 or S5000

.

Both of the BDRs were technically adequate.

(4) Identification of physical form, including waste ma terial parameters and prohibited items, was assessed and found to be adequate.

Waste Stream LA-MSG04.001 is soil, sand and gravel and has been assigned Waste Matrix Code

S4200. The waste stream has total volume of 168.4 c ubic meters. Additional waste volume is anticipated through repackaging and radiological ch aracterization of the containers, and it is also possible that additional TRU soil could be generate d during remediation of MDAs A and T (References C033, C037, D058, D059, D060, M004, M00 9 and M020). The waste stream may

also contain absorbent material such as vermiculite , as well as debris such as plastic packaging, blacktop, concrete, insulation and piping. LANL-CCP estimated the soil percentages presented in

the AKSR based on an ORNL soil waste stream that is composed of 97% soil and 3% inorganic matrix and plastic. However, as discussed in Item ( 1) above, this approach does not accurately represent Waste Stream LA-MSG04.001 because the ORN L soil does not include debris anticipated in the LANL soil waste. LANL soil may c ontain more debris than that represented in the AKSR, as evidenced by Reference DR007, which do cuments reassignment of a soil container

to the debris waste stream.

LANL-CCP will perform NDE on each container to dete rmine its physical composition and will also identify the presence of prohibited items. Bec ause LANL-CCP revised the AKSR to commit to re-evaluating the physical composition of the wa ste stream based on actual NDE data and

because it is unclear whether this information will be available in the near future, EPA is not requiring LANL-CCP to provide the revised waste mat erial parameter (WMP) estimates prior to approving this T1 change. EPA will evaluate future versions of the AKSR as part of ongoing T2 review of AKSRs. When LANL-CCP completes its review based on actual NDE information, the physical characteristics of Waste Stream LA-MSG 04.001 will be adequately defined.12

(5) Acceptable knowledge procedural adequacy and implem entation were assessed and found to be adequate (e.g., assembly compilation, i nterpretation, confirmation, discrepancy resolution).

CCP-TP-005, Revision 24, was effective as of Novemb er 28, 2011, and was in place when the latest version of the AKSR was prepared. It include s the following attachments:

• “Attachment 1 – Acceptable Knowledge Documentation Checklists.”

• “Attachment 2 – Record of Communication.”

• “Attachment 3 – Acceptable Knowledge Source Documen t Summary.”

• “Attachment 4 – Acceptable Knowledge Source Documen t Reference List.”

• “Attachment 5 – Hazardous Constituents.”

• “Attachment 6 – Waste Form, WMPs, Prohibited Items, and Packaging.”

• “Attachment 7 – Radionuclides.”

• “Attachment 8 – Waste Containers List.”

• “Attachment 9 – Waste Characterization Data Cross-R eference.”

• “Attachment 10 – Acceptable Knowledge Re-evaluation Checklist.”

• “Attachment 11 – Acceptable Knowledge Source Docume nt Discrepancy Resolution

Form.”

• “Attachment 12 – Form and Content Guide for AKSRs.”

• “Attachment 13 – CCP Waste Stream Characterization Checklist.”

• “Attachment 14 – CCP Acceptable Knowledge Accuracy Report.”

• “Attachment 15 – CCP TRU Waste Correlation and Surr ogate Summary Form.”

LANL-CCP provided Attachments 1, 2, 3, 4, 5, 6, 7, 8, 10 and 11. Attachments 1 and 4 are adequate. Attachment 2s are listed in Attachment B to this evaluation as “C” source documents

and Attachment 3s are source document summaries and quality assurance records that are retained separately. Attachment 5 is not applicable to EPA’s review. Attachments 6 and 7 are addressed under Items (2), (4) and (15). Attachment 8 presents the number of containers in the waste stream at the time the attachment was generat ed and will be augmented when the wastes are repackaged. The AK tracking spreadsheet is upda ted in real time when repackaging occurs and presents ongoing waste stream contents and cont ainer status. The generation dates were in error on the original Attachment 8, dated August 7, 2012, so LANL-CCP revised Attachment 8 and provided the revision to EPA on September 23, 2 012. LANL-CCP provided an example

Attachment 10 that addressed misidentification of a drum and also provided the related Attachment 11 discrepancy resolution (Reference DR0 07).

Attachments 9, 12 and 15 are not required. Attachme nts 13 and 14 have not yet been prepared due to the early characterization status of the was te stream; therefore, LANL-CCP did not provide them.

EPA examined the attachments and the source documen ts and interviewed the AKEs. EPA verified that all AK source documents are provided to CCP document control as electronic records, but only CCP-generated documents (e.g., CC P-TP-005 attachments and AKSRs) are retained as quality assurance records. EPA found th at some of the attachments were prepared13

using CCP-TP-005, Revision 18, not Revision 24. The general content of the forms applicable to CH waste did not change substantially between Revis ions 18 and 24. In the future, EPA expects

CCP-TP-005 attachments to reflect the version of th is procedure in place at the time that the final AKSR is prepared. EPA determined that LANL-CCP demo nstrated the ability to follow the AK procedure for the elements examined.

(6) The acceptable knowledge summary report was assesse d and found to be adequate.

EPA examined the AKSR, Revision 5, for Waste Stream LA-MSG04.001 to determine whether major technical components were present and to ensu re that the document adequately justified

and described the waste stream. EPA found that the AKSR did not adequately address the following:

• Process information pertaining to soil waste genera tion at MDAs.

• Radiological characterization of the waste stream a nd consistency between the AK-NDA

memorandum and AKSR.

• Physical characterization of the waste stream.

LANL-CCP representatives provided a freeze-file 2 modification of the AKSR representing the changes in progress. These changes include addition al process information concerning soil generation from MDA cleanup, modification of the AK -NDA memorandum [see Item (15) below] and modification of the AKSR to indicate tha t evaluation of physical WMPs will be based on LANL-CCP NDE data. LANL-CCP will provide arevised AKSR incorporating freezefile changes to EPA. Notification of the availabili ty of an updated AKSR is a new T2 change (see Table 1). EPA expects that the freeze file cha nges will be incorporated in the next revision

of the AKSR.

(7) Drum traceability and the ability to follow the acc eptable knowledge process for containers was assessed and found to be adequate.

Waste Stream LA-MSG04.001 soil generated during the 1978–1981 TA-21 D&D effort was placed in TA-54 Area G Pits 1, 2 and 9, or Domes 33 , 153, 232 or 283. Waste Stream LAMSG04.001 soils generated during remediation of MDA B were shipped directly to Area G, Pad 1. The AKSR states that, “Of the current popula tion of 82 soil containers, 45 are currently stored below-grade at Area G.” Specifically, crates previously placed in domes or generated through remediation of MDA B are currently stored o n Pad 1, while 55-gallon drums and a few crates remain in burial Pit 9 (Reference M003). Was te on the pads is subsequently repackaged as necessary and characterized before WIPP shipment. T RU waste management at Area G currently includes below-grade retrieval operations from pits and other areas, as well as container storage, container venting, decontamination and volume reduc tion at Building 412, Dome 231 Permacon

2 “Freeze file”: As a result of an inspection-relate d EPA issue, LANL-CCP may have to revise a document

. LANL-CCP makes the change(s) and provides the revis ed document to EPA as a freeze file to serve as obj ective evidence for the inspection. CCP’s document control process in Carlsbad, NM, then generates an officia l version of

the revised document.14

and Dome 375 Box Line Process (References D010, D03 0, D032, D036, D058, D059 and D060).

From 1971 to 1992, container data were documented o n radioactive solid waste disposal records that included container origin, radionuclides, wast e description and disposal location. LANL requires a waste profile form for each waste stream (and sometimes each container) generated since 1991, and this form documents the waste’s ori gin and chemical content. Also, TRU waste storage records documenting the waste’s origin and radioassay were required after 1992.

LANL-CCP obtained information about the waste strea m from various databases, including: AKIR database, listing available isotopic informati on by container; CONCERT, a historical LANL database that was not used after the early 200 0s and also includes radiological information; and TA-54’s own database documenting i ts waste management practices. All of these were examined by LANL-CCP and are included in EPA’s traceability analysis.

EPA selected seven containers for traceability anal ysis: Container Nos. 89987, 89983, 89982, 66122, S780204, S794044 and S813323. Table 6 presen ts available traceability information for

these selected drums. EPA obtained much of the info rmation presented in this table through interviewing the LANL-CCP AKEs.

As shown in Table 6, documentation available for ea ch container varied based on the generation date and management practices. LANL-CCP representat ives track the radiological

characterization status of each container on the AK tracking spreadsheet. However, it was impossible to determine the traceability presented in Table 6 based solely on records review, as some source documents (such as M009) did not includ e the soil waste stream (LANL-CCP revised M009 to include this information). EPA inte rviewed LANL-CCP representatives to obtain a better understanding of drum traceability. EPA ascertained that containers are generally traceable from the point of origin to their current location, although this process required

examination of several different source documents a nd databases. Table 6 verifies the drum

contents and transfer information for the seven con tainers chosen and demonstrates that container information is traceable from waste gener ation through the characterization process.15Table 6. Traceability of Selected Containers in Waste Stream LA-MSG04.001CCPDrumNumberOriginalLANLDrum orContainerNumberOriginalContainerTypeaDate of DrumGenerationaDrum Receipt atArea G andSubsurfaceStorageLocationaTransferfrom Area GSubsurfaceLocation toPadRepackagingInformationand DateCCP-TP-005Attachment8 GenerationDate (dateaccepted atArea G forstorage)Final WasteContainerCCP NDE NDABDRs66122 66122StandardWaste Box4/14/11Not applicable,sent directly fromMDA B toPad 1b,cNotapplicable,sent directlyfrom MDA Bto Pad 1a,b,cNot applicable,sent directlyfrom MDA Bto Pad 1a,b,c4/14/11StandardWaste BoxNot Available89982 S813240 CrateOriginal CrateS8132403/10/80, closuredate 1/27/811/29/81 Pit 1 1998dRepackaged9/13/11 atBuilding 412e1/29/8155-GallonDrumLARTR2-11-0116,2LANDA087889983 S813240 CrateOriginal CrateS8132403/10/80, closuredate 1/27/811/29/81 Pit 1 1998dRepackaged9/13/11 atBuilding 412e1/29/8155-GallonDrumLARTR2-11-0116,1LANDA147089987 S813240 CrateOriginal CrateS8132403/10/80, closuredate 1/27/811/29/81 Pit 1 1998dRepackaged9/13/11 atBuilding 412e1/29/8155-GallonDrumLARTR2-11-0116,1LANDA1470S780204 S78020455-GallonDrum2/6/78 2/15/78 Pit 9N/A,still in Pit 9N/A,still in Pit 92/15/78TBD, basedon condition atretrievalNot AvailableS794044 S794044 Crate 7/5/79 7/19/79 Pit 1 1998dDuringrepackaging,determined tobe LLW7/23/12f7/19/79Unknown – inLLW streamReassigned toLLW population,based on LANLCCP surveyinformationS813323 Crate 4/29/80 12/8/81 Pit 2 1998dDuringrepackaging,determined tobe LLW7/23/12f12/8/81Unknown – inLLW streamReassigned toLLW populationbased on LANLCCP surveyinformationaReference M020, radioactive solid waste disposal orTRU waste storage records.bTA-54 database (as presented in the AK tracking spreadsheet).cReferences P035 and P036 applicable to 18 StandardWaste Boxes.dReference M008, CONCERT database.eReference M009, AKIR database.fCCP Waste Data System.16

(8) The defense origin of transuranic wastes was examin ed and found to be adequate.

The TRU waste streams to be emplaced in the WIPP mu st be “defense” waste. LANL-CCP states that, based on DOE guidance, a waste is defe nse in origin if it was generated “in whole or part by one of the atomic energy defense activities listed in section 10101(3) of the Nuclear Waste Policy Act of 1982 (NWPA).” The AKSR states that, while both defense a nd nondefense activities were performed at TA-21, the waste conta ins radionuclides that originated from atomic energy defense activities, including defense nuclea r materials production, byproducts management and research and development (Reference D059). Defense-related activities included the Hanford Ash Program, the objective of which was to produce driver fuel for the liquid metal fast breeder reactor program at Hanfor d (References C002 and C022). Also, research and development operations were conducted at TA-21 that were ultimately used in national defense applications. For example, the AKS R states, “the LANL Space Heat Source Program not only provided R&D [research and develop ment] results that were directly applied to military applications at both LANL and other Atomic Energy Commission sites, but also used Pu-238 derived from a defense reactor to produce he at source materials that were incorporated into those applications. There were no possible dis tinctions between operations and materials that supported the non-defense space program and th e similar requirements of some defense programs that benefited simultaneously” (References C001, C002, C003, C022, D014, D032, D049 and D050).

Pu production focused on extraction and recovery of Pu from materials that originated from both defense and nondefense activities, but individual c ontainers cannot be traced to a solely nondefense origin due to waste commingling (Referen ces D059 and M020). The isotopic

distribution of radionuclides in soil cannot be use d to support a defense origin for those radionuclides (References C009, C021, D020, D025, D 026, D027 and D029). Based on the AKSR, the supporting references and DOE’s guidance regarding defense waste, this waste stream is defense in origin.

(9) The presence of spent nuclear fuel and high-level w aste status was evaluated, and this waste stream was found to be in compliance with the Waste Isolation Pilot Plant Land

Withdrawal Act.

The WIPP Land Withdrawal Act prohibits the disposal of spent nuclear fuel (SNF) and highlevel waste (HLW) as defined by the NWPA at the WIP P. The NWPA states that SNF is “fuel

that has been withdrawn from a nuclear reactor foll owing irradiation, the constituent elements of which have not been separated by reprocessing. SNF may not include test specimens irradiated for research and development only (i.e., these may be classified as waste when it is technically infeasible, cost prohibitive, or would increase wor ker exposure).” HLW is defined by the NWPA as “the highly radioactive material resulting from the reprocessing of spent nuclear fuel, including liquid waste produced directly in reproce ssing and any solid material derived from such liquid waste that contains fission products in sufficient concentrations, and other highly radioactive material that the Commission, consisten t with existing law, determines by rule requires permanent isolation.” Waste Stream LA-MSG0 4.001 contains radioactive material derived from Pu processing and related operations t hat did not involve the use of SNF or reprocessing of constituent elements from reactor f uel. Therefore, the soils are neither SNF nor17

HLW, have not been historically managed as HLW and, therefore, are eligible for disposal at the WIPP (References D058, D059 and D060).

(10) Waste stream profile form preparation and completen ess were evaluated and found to be adequate.

LANL-CCP provided a draft waste stream profile form (WSPF) to demonstrate its ability to prepare this required document. The WSPF did not in clude the characterization information summary or summation of aspects typically attached to the profiles, presumably because neither were yet prepared. EPA expects that both items will be included with the final WSPF. EPA

assumed that the references cited in section 27 of the WSPF are the same as those cited in the AKSR, and EPA found the following issues related to the draft WSPF:

• References cited in Item 27D were not waste packagi ng logs.

• References M004, M008 and M009 in Item 27F did not address TA-21 soils. References D017 and P035 in Item 27H were not representative o f industry standard documents, as D017 was an historical Rocky Flats document pertain ing to pyrochemical salts and P035 contained MDA B-specific packaging requirements.

• Reference D017 in Item 27K did not contain sampling and analysis data from a surrogate waste form, as this reference addresses pyrochemica l salts and reactivity, not soils.

LANL-CCP revised the draft WSPF to reference the co rrect source documents. Notification of availability of a final approved WSPF, including th e characterization information summary and summation of aspects, continues to be a T2 change. The applicable T2 designation in Table 1 was modified to specify that completion of or revis ion to the WSPF attachments (e.g., characterization information summary and summation of aspects) is a notification requirement.

(11) Training for acceptable knowledge personnel was exa mined and found to be adequate.

CCP-TP-005, Revision 24, references CCP-QP-002, Rev ision 31, for AK training. This requires that personnel assigned to compile, evaluate and re solve AK discrepancies have training in the following areas:

• WIPP Waste Analysis Plan briefing.

• WAC knowledge.

• Federal and state Resource Conservation and Recover y Act regulations associated with

solid and hazardous waste determinations.

• Knowledge of CCP procedures associated with:

o Waste characterization using AK.

o CCP AK records development, including AK discrepanc y resolution.

o Nonconformance report (NCR)/corrective action repor t process.

o Knowledge of resolving and managing prohibited item s as noted in nonconformance reporting.18

The LANL-CCP lead SPM is responsible for ensuring t hat LANL-CCP personnel are qualified and trained to perform their assigned job functions . Ms. Veronica Waldram is the SPM; because EPA recently reviewed her qualifications during a s eparate inspection, EPA did not re-examine them as part of this T1 review.

LANL-CCP provided qualification cards for AKEs Jim Shoen, Randy Fitzgerald and Michael Papp indicating that their training with respect to the WIPP permit, WAC, CCP Procedures CCPTP-001 through 005, CCP Procedures CCP-PO-001 throu gh 003, CCP Procedure CCP-PO-505, CCP Procedures CCP-QP-004 through 008, and CCP Proc edure CCP-QP-036 is current as of June 2011. The qualification cards did not specify any procedural revision dates and clearly could not apply to CCP-TP-005, Revision 24, which w as approved in November 2011. Quality and Management Integrated System (QMIS) screen shot s verified that Randy Fitzgerald had read the most recent version of CCP-AK-LANL-10, Revision 5; EPA determined that Mr. Papp and

Mr. Shoen were authors of the document and therefor e did not require QMIS verification. EPA

determined that these individuals were familiar wit h the updated waste characterization procedures and that LANL-CCP demonstrated adequate training for AK personnel.

(12) Preparation of nonconformance reports was evaluated and found to be adequate.

LANL-CCP provided two NCRs for this waste stream as sociated with NDA BDRs. Each addressed “insufficient AK or isotopic information for analysis.” LANL-CCP AKEs clarified

that the NCRs were issued because 241 Am was detected on assay but was not addressed in t he

AKSR. The NCRs and affected drums in this waste str eam are as follows:

• NCR-LANL-3636-11 for soil Drum Nos. 89987, 89985, 8 9984 and 89983.

• NCR-LANL-3637-11 for soil Drum Nos. RL-6043-11, 899 88, 89986, 89892 and 89891.

The NCRs were dispositioned by the AK-NDA memorandu m and a revised AKSR, as stated in

NCR-LANL-3636-11 and NCR-LANL-3637-11: “CCP-AK-LANL -010 Rev. 5 and the corresponding LA-MSG04.001 NDA memo have been issue d, so the analysis and S4000 drums in BDRs 1LANDA1470 and 2LANDA0878 are now compliant with AK. NCR-LANL-3636 and NCR-LANL-3637 can now have a final disposition of ‘ use-as-is.’” A LANL-CCP AKE stated that an AK re-evaluation and discrepancy resolution report are typically issued when AK-NDA discrepancies are found. However, the AKSR was in t he process of being revised when NCRLANL-3636-11 and NCR-LANL-3637-11 were issued, so t he AKSR was updated to comply with radioassay data and no discrepancy resolution was issued. LANL-CCP also provided NCRLANL-3697-11 and discrepancy resolution DR007, whic h were prepared when Container No.

S843289 was found to contain more than 50% debris. Preparation of NCRs was adequately

demonstrated.

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

LANL-CCP AKEs confirmed that an AK accuracy report has not yet been prepared, even though radiological characterization has been completed fo r two NDA BDRs. EPA has examined the19

AK accuracy process for several waste streams and f ound it to be adequate. Notification of the availability of a completed AK accuracy report for this waste stream remains a T2 change.

(14) Load management was found to be not applicable.

LANL-CCP personnel indicated that load management w ould not be performed by LANL-CCP.

(15) Nondestructive assay–acceptable knowledge communica tion was assessed and found to be adequate.

CCP-TP-005, Revision 24, requires preparation of an AK-NDA memorandum that presents how AK will be applied during assay, including a discus sion of its limitations. LANL-CCP provided the AK-NDA memorandum, but the radionuclide distrib ution it presented differed from the AKSR, as did the predominant radionuclides by weigh t. LANL-CCP revised the AK-NDA

memorandum to be consistent with the AKSR.

The AK-NDA memorandum states that limitations assoc iated with AK data include “zero assay”

values for some containers that are inconsistent wi th MTs associated with TA-21 soil. The AK-NDA memorandum reported a large-gram value of 244 Pu in one container (the origin of which is unknown and may be an error). Radioassay o f the waste stream will be performed using HENC Nos. 1 and 2 and the SuperHENC. LANL-CCP propo sed to use AK in the radiological characterization process as follows:

• When gamma isotopic measurements fail or are suspec t, AK will be used to determine the plutonium isotopic distribution.

• The radiological expert analyst (EA) will determine when AK is used and will also determine the “representativeness of the AK isotopi cs for each particular measurement.” The EA will determine the appropriate AK-based isot opics for the measurement.

• The final determination of whether measurement resu lts confirm AK will be made by the SPM during lot evaluation and preparation of AK con firmation checklists.

• The AKE will provide container-specific information to the EA, and all AK used by the

EA will be included in the BDRs.

LANL-CCP did not provide an AK re-evaluation checkl ist specific to radioassay, and the AKEs confirmed that, to date, EAs have not used AK to de termine isotopic distributions. The LANLCCP AK tracking spreadsheet includes radiological i nformation for the EAs’ use.

Notification of availability of AK-NDA memoranda an d updates of those memoranda for all LANL CH waste streams continues to be a T2 change.

Summary of Acceptable Knowledge Findings and Concer ns

EPA did not identify any findings or concerns durin g this T1 evaluation and there are no open

issues relative to this T1 evaluation.20

Changes to Tiering

Based on the results of this T1 evaluation, EPA has revised the AK T2 designations to add notification of availability of all new and revised AKSRs as a T2 change and to specify that completion of or revision to the WSPF attachments ( e.g., characterization information summary and summation of aspects) is a notification require ment. For consistency, all of the T2 elements listed under AK in Table 1 apply to all approved LA NL CH TRU waste streams.

Acceptable Knowledge Approval

Based on this evaluation, EPA approves this T1 chan ge. LANL-CCP is approved to characterize SCG S4000 CH TRU waste, consistent with the limitat ions specified in this report.

6.2 Real-Time Radiography

Waste Characterization Element Description

EPA reviewed RTR BDRs to support DOE’s Tier 1 reque st for Waste Stream LA-MSG04.001,

SCG S4000. This is a CH waste stream. EPA reviewed the containers that were subject to RTR examination in September 2011. EPA’s review include d the RTR written procedure, audiovisual and written records, and operator training.

Documents Reviewed

EPA reviewed the following documents and records:

• BDR LA-RTR2-11-0116, both written and audiovisual r ecords.

• List of qualified individuals (LOQI) for the time p eriods covered by the BDRs.

• CCP-TP-053, “CCP Standard Real-Time Radiography (RT R) Inspection Procedure,”

Revision 11.

• Demonstration-of-capability audiovisual recordings for two of the operators responsible
for RTR of the subject containers.

• Remote-handled radiography test drum inventory shee t for containers NDE-TEST-14 and

INL-RH-NDE-TEST-14.

• Remote-handled radiography training drum inventory sheet for containers NDE-Training09, NDE-Training-14 and NDE-Training-19.

• CCCP Standing Order CCP-SO-LANL-50, Revision 0.

Technical Evaluation

EPA randomly selected containers from the BDR and r eviewed them to ensure that RTR data were generated in accordance with CCP’s procedure.21

Before starting RTR operations, LANL-CCP verified t hat the resolution of the x-ray system met requirements by performing an image test pattern te st. The number of line pairs per centimeter (lines-pair/cm) recorded for each day of operations met the minimum requirement of five linespair/cm. EPA verified, through review of the BDR, t hat data sheets were completed and signed as required. LANL-CCP performed the quality control examinations for the BDR; specifically, the replicate and independent observations. No NCRs were generated for this BDR.

EPA reviewed demonstration-of-capability audiovisua l recordings for two operators. EPA identified an issue in the training of one RTR oper ator (Dillard). The EPA Lead Inspector informed CBFO and LANL-CCP managers of the particul ars of the issue in an email, dated October 22, 2012. EPA was concerned that the operat or was not current in his training when he performed RTR on S4000 containers. Specifically, th e training requirement was for operators to complete training containers semiannually or every six months, but the operator of concern performed training containers over eight months apa rt. The following excerpt from the EPA Lead Inspector’s email of October 22, 2012, provide d the details supporting EPA’s issue:

• CCP-QP-002, R. 33, section 4.3.2[D] states that tra ining containers are completed semiannually

• Dillard performed training container on 1/25/11 (re cord completed 2/1/11)

• Dillard completed training container 9/29/11 (recor d completed 10/5/11)

• RTR (S4000) examinations took place 9/26/11, with c orrections on 9/28/11

• LOQI for 9/26 &9/27 (the only ones provided for rev iew) had Dillard as qualified with a note in red “Training cont. 09/201 1”

On December 4, 2012, EPA received LANL-CCP’s final response in the form of Standing Order CCP-SO-086, Revision 0, “Clarification of the Time Period for Performance of the RTR Semiannual Training Container Required by CCP-QP-00 2,” which stated that a two-month grace period would be applied to the RTR biannual trainin g period if needed but would be structured to ensure that training took place every 6 months. EPA ’s response was to require the grace period to be reduced to one month. LANL-CCP agreed to this change and subsequently provided the revised standing order to EPA (see Attachment C).

Summary of Real-Time Radiography Findings and Conce rns

RTR characterization activities for these drums wer e performed in accordance with required procedures by trained and qualified operators.

Changes to Tiering

Based on the results of this T1 evaluation, there a re no revisions to the RTR T2 designations.22

Real-Time Radiography Approval

Based on this evaluation, EPA approves this T1 chan ge. LANL-CCP is approved to characterize SCG S4000 CH TRU waste using RTR, consistent with t he limitations specified in this report.

7.0 CONCLUSIONS

Summary of Findings and Concerns

EPA concluded that the waste characterization proce sses of AK, NDA and RTR that LANL-CCP used to characterize retrievably stored and newly g enerated SCG S4000 CH TRU waste are adequate. There were no findings or concerns, and t here are no open issues relative to this T1

evaluation.

Tiering Changes

Based on the results of this T1 evaluation, EPA has revised the AK T2 designations to add notification of availability of all new and revised AKSRs as a T2 change and to specify that completion of or revision to the WSPF attachments ( e.g., characterization information summary and summation of aspects) is a notification require ment. For consistency, all of the T2 elements listed under AK in Table 1 apply to all approved LA NL CH TRU waste streams. No revision of T1 requirements was warranted. Consistent with EPA’ s authority under 40 CFR 194.24(h), EPA may request any information relative to these activ ities if EPA deems it necessary to ensure continued compliance with EPA regulations.

Approval

This T1 change consisted of the waste characterizat ion processes of AK, NDA and RTR as evidenced by the records LANL-CCP generated in char acterizing SCG S4000 CH TRU waste. Based on this evaluation, EPA approves LANL-CCP to characterize SCG S4000 waste, consistent with the limitations specified in this r eport.A-1 ATTACHMENT A

APPROVAL SUMMARY FOR LANL-CCP

CONTACT-HANDLED WASTE CHARACTERIZATION PROGRAM

Approved Activity EPA Inspection Number, Approval Dates Docket Number

LANL-CCP CH Baseline Approval LANL-CCP-05.06-8 — Ju ne 21, 2007 A-98-49, II-A4-88

T1 Change – Extension of range for the High Efficiency Neutron Counter No. 2 October 28, 2007 A-98-49; II-A4-91

T1 Change – Extension of range for the High Efficiency Neutron Counter No. 1 December 7, 2007 A-98-49, II-A4-95

T1 Change – Assay of lead-lined drums on the High Efficiency Neutron Counter

No. 2 November 10, 2010 A-98-49, II-A4-139

T1 Change – Addition of the SuperHENC October 28, 2 011 A-98-49, II-A4-153

T1 Change – Calibration extension of High Efficiency Neutron Counter No.1 and SuperHENC August 14, 2012 A-98-49; II-A4-164B-1 ATTACHMENT B

LIST OF DOCUMENTS REVIEWED FOR THIS EVALUATION

Acceptable Knowledge Expert (AKE) Qualification Car ds, Randy Fitzgerald, Michael Pap and Jim Shoen, June 9, 2011

Acceptable Knowledge Isotopic Ratio (AKSR) database printouts, provided September 23, 2012

Area TA-55 412 Box Line Production Report, Drum Nos . 89993–89987, provided September 23,

2012

CCP-AK-LANL-006, Central Characterization Project A cceptable Knowledge Summary Report for Los Alamos National Laboratory TA-55 Mixed Tran suranic Waste Streams: LA-MHD01.001, LA-CIN01.001, LA-MIN02-V.001, LA-MIN0 4-S.001, Revision 11, September 23, 2011

CCP-AK-LANL-010, Central Characterization Project A cceptable Knowledge Summary Report for Los Alamos National Laboratory, TA-21 DP West F acility, Waste Streams: LA-MHD04.001, LA-MSG04.001, Revision 5, May 1, 2012

CCP-SO-LANL-50, Revision 0

CCP-SO-086, Revision 0, Clarification of the Time P eriod for Performance of the RTR Semiannual Training Container Required by CCP-QP-00 2, June 14, 2011

CCP-TP-005, Revision 24, CCP Acceptable Knowledge D ocumentation, effective date November 28, 2011

CCP-TP-005, Revision 24, AK Tracking Spreadsheet, J uly 7, 2012, and September 6, 2012

CCP-TP-005, Attachment 1, Revision 24, Acceptable K nowledge Documentation Checklists, July 3, 2012

CCP-TP-005, Attachment 4, Revision 24, Acceptable K nowledge Source Document Reference List, July 18, 2012

CCP-TP-005, Attachment 6, Revision 24, Waste Form, WMPs, Prohibited Items, and Packaging, April 12, 2012

CCP-TP-005, Attachment 7, Revision 24, Radionuclide s (including AK-NDA memorandum), July 24, 2012, revised September 23, 2012

CCP- TP-005, Attachment 8, Revision 24, Waste Conta iners List, August 7, 2012, revised September 23, 2012B-2

CCP-TP-005, Attachment 10, Revision 24, Acceptable Knowledge Re-evaluation Checklist, November 3, 2009, and June 7, 2012

CCP-TP-005, Attachment 11, Revision 18, Acceptable Knowledge Source Document Discrepancy Resolution Form (see DR007), provided S eptember 23, 2012

CCP-TP-053, CCP Standard Real-Time Radiography (RTR ) Inspection Procedure, Revision 11

CCP Waste Stream Profile Form, Waste Stream Profile Number: LA-MSG04.001, Draft September 6, 2012, revised September 23, 2012

Container Certification (CONCERT) database printout s, provided September 23, 2012

Correspondence from Los Alamos Site Office to James Bearzi, Bureau Chief, Hazardous Waste Bureau, New Mexico Environment Department, Request for Extension of Date for Submittal of Material Disposal Area T Remedy Completion Report, April 27, 2010

Correspondence from Los Alamos Site Office to James Bearzi, Bureau Chief, Hazardous Waste Bureau, New Mexico Environment Department, RE: Requ est for Extension of Date for Submittal of Material Disposal Area A Investigation/Remediati on Report, January 12, 2011

C001, Correspondence from T. Keenan and J. Foxx, Pl utonium-238 Heat Source Fabrication for Space and Artificial Heart R&D Activities at TA-21 West and CMR Building from 1970 to 1978, TWCP-19811/P2010-0778, January 1, 2004

C002, Correspondence from J. Foxx and C. Smith, TA- 21 Operations at Buildings 2, 3, 4, 5 and 150 and Pu-238 questions, TWCP-19433/P2010-0695, Ja nuary 8, 2004

C003, Correspondence from J. Foxx and C. Smith, Pu- 238 Information at TA-21 West, TWCP19812/P2010-0777, January 8, 2004

C009, Correspondence from J. Foxx and C. Smith, TA- 21 DP West Plutonium-238 Operations, 1970–1977, Purity of Pu-238 Feed Material, Commingl ing of Pu-238 with Other Material Types, TWCP-19900/P2010-0561, February 17, 2004

C021, Correspondence from W. Schueler, Material Typ e Isotopic Compositions and Am-241

Content in Solid Transuranic Waste Benchmark Enviro nmental Corporation, AL-7193/LA-UR01- 6170, TWCP-0698, May 2, 1997

C022, Correspondence from J. Foxx, Commingling of D efense and Nondefense TRU Waste, Memo to TWCP Records Center, LA-UR-02-6087, TWCP-08 87, August 21, 1997

C033, Correspondence from J. Schoen, Evaluation of Volume, Period Generation, and

Calculation of Individual and Total Radionuclide Ma sses and Activities for Waste Stream LA-MSG04.001, September 30, 2009B-3

C037, Correspondence from J. Schoen, Evaluation of Volume, Period of Generation and

Calculation of Individual and Total Radionuclide Ma sses and Activities for Waste Streams LA-MHD04.001, LA-MSG04.001, April 4, 2012

D006, Demolition of Building 12, An Old Plutonium F ilter Facility, R. Garde, A. Valentine and E. Christensen, LA-5755, TWCP-18949, January 1975

D008, Historic Building Assessment for the DOE Conv eyance and Transfer Project, E. McGehee and K. Garcia, LA-UR-00-1003, TWCP-18951, Volume 1, Report No. 178, December 23, 1999

D010, TA-21 Operable Unit RFI Work Plan for Environ mental Restoration Los Alamos National Laboratory, LA-UR-91-0962, TWCP-19101, May 1991

D014, Final Safety Analysis Report for TRANSIT RTG Volume 1, Reference Design Document—Introduction and Table 1-1, TRW Systems Gr oup, TRW(A)-11464-0491, TWCP19438, March 1, 1971

D016, Plutonium Research: Historical Role of DP-Wes t in the Atom, V. Lees, TWCP-19768, Volume 4, Number 12, pp.1–8, December 1967

D017, Backlog Waste Reassessment Baseline Book, Roc ky Mountain Remediation Services, TWCP-02501, P2010-0670, January 4, 1995

D020, K. Johnson, The Atom, Nuclear Power for an Ar tificial Heart, TWCP-19770, Volume 7, No. 6, June 1970

D025, Fused Salt Processing of Impure Plutonium Dio xide to High-Purity Plutonium Metal, L. Mullins, D. Christensen and B. Babcock, TWCP-225 80, LA- 9154-MS, January 1982

D026, Los Alamos TRU Waste Certification Plan for N ewly Generated TRU Waste, Los Alamos National Laboratory, LA-UR-02-6085/TWCP-00697, WCP- HSE7-CPL-01, November 1984

D027, Direct Reduction of 238-PuO2 and 239-PuO2 to Metal, C. Foxx and L. Mullins, TWCP22581, LA-9073, February 1982

D029, Six-Kilogram Scale Electrorefining of Plutoni um Metal, A. Morgan, S. Apgar and D. Christensen, TWCP-22582, LA-9469-MS, September 1 982

D030, Plutonium Scrap Processing at the Los Alamos Scientific Laboratory, A Nixon, B. McKerley and E. Christensen, LA-UR-80-835, CONF- 800303—12, Revision 0, March 24, 1980

D032, Bi-Monthly Progress Report – Multi-Hundred Wa tt Radioisotope Thermoelectric Generator Program, C. Whitmore, TWCP-22029, June 30 , 1975B-4

D034, Final Documentation for RadWaste ORACLE Datab ase’s List of Acceptable Radioisotopes, Specific Activities, Categories, and Regulatory Limits, D.Taggart, TWCP-8003, January 31, 1992

D035, Los Alamos DP West Plutonium Facility Deconta mination Project 1978–1981, R. Garde, E. Cox and A. Valentine, LA-9513-MS, TWCP-14396, Se ptember 1982

D036, Process AK Report for Chloride Operations at TA-55, J. Musgrave, TWCP-15411, TWCP-AK-2.1-002, LA-UR-02-1710, LAUR-01-2557, Revis ions 2 and 2/IC1, May 17, 2001, and March 31, 2002

D049, Initial Development and Characterization of P lutonia-Iridium Cermets, M. Tokar, TWCP21979, LA- 5255-MS, undated

D050, Data Sheets for PPO Radioisotopic Fuel, T. Ke enan, R. Kent, R. Mulford and M. Shupe, TWCP-21978, LA-5160-MS, February 1973

D058, Los Alamos National Laboratory Transuranic Wa ste Characterization Acceptable Knowledge Information Summary (AKIS), TWCP-PLAN-0.2 .7-001, February 28, 2003

D059, Acceptable Knowledge Operations Report for Pl utonium Processing at the TA-21 DP West Facility (Draft Report), C. Smith, P2010-0608, TWCP 23596; AK-00-23, Revision 0, July 8, 2004

D060, Acceptable Knowledge Information Summary for LANL Transuranic Waste Streams, AK-00-019, Revision 1, C. Smith, September 22, 2003

D069, A History of Waste Disposal at Technical Area 21 1943–1978, E. Merrill, March 1990

DR007, Removal of One (1) Debris Container from Soi l Waste Stream LA-MSG04.001, R. Fitzgerald, June 7, 2012

Freeze File Changes, CCP-AK-LANL-010, Revision 5, S eptember 6, 2012, and September 23, 2012

Los Alamos National Laboratory Waste Profile 23358: Soil from MDA-B Enclosure Number 2, printed July 26, 2012

Los Alamos National Laboratory, Information Sheet: Technical Area 21 Material Disposal Areas, ER2002-0466, printed September 17, 2012

Los Alamos National Laboratory, Corrective Measures Evaluation Report for Material Disposal Area A, Solid Waste Management Unit 21-014, at Tech nical Area TA-21, LA-UR-08-5520, EP2008-0448, September 2008B-5

M003, Waste Streams from Buildings TA-21, TA-55, TA -50, and TA-00 at LANL, Appendices B, C, D, E and F (Changes to Sampling Plan), TWCP-0 4138, TWCP Plan-0.2.7-001, Revision 2, June 4, 1999

M004, TA-55 NMT Waste Management System (CONCERT Da tabase) LANL, NMT division,

undated

M008, Excerpt from CONCERT Database, LANL, August 1 7, 2006

M009, AKIR Database Extracted DP West (TA-21) Radio nuclides in Grams, LANL AK-00-020, Revision 0, August 22, 2006

M020, Radioactive Solid Waste Disposal/TRU Waste St orage Records for LA-MSG04.001,

undated

NCR No. NCR-LANL-3537-11, Revision 0, May 21, 2012

NCR No. NCR-LANL-3636-11, Revision 0, May 21, 2012

NCR No. NCR-LANL-3637-11, Revision 0, December 20, 2011

NDA BDR Nos. 1LANDA1470, 1LANDA1470 and 2LANDA0878

P030, Sort, Segregate, Size Reduction, and Repackag ing Activity, S. Miller, EP-AREAGWODOP-0216, Revision 15, May 23, 2011

P031, TA-54 Area G Sludge Remediation Activities, S . Miller, EP-AREAG-WODOP-0219, Revision 8, May 23, 2011

P032, TA-54 Area G TRU Crate SSSR Activities, EP-AR EAG-WODOP-0227, Revision 11, P. Newberry, February 13, 2012

P035, MDA-B TRU Waste Container Packaging in SWBs, TA21-MDAB-00017, Revision 0, D. Allen, April 21, 2011

P036, Waste Management Plan for Material Disposal A rea (MDA) B, TA21-MDAB-PLAN00014, Revision 1, D. Allen, December 15, 2010

P037, Waste Management Procedure for Environmental Program TA-21 Closure Project Activities (U), TA21-AP-00002, Revision 0, D. Allen , March 16, 2012

Quality Management Integrated System (QMIS) Screen Shot for CCP-AK-LANL-010, Revision 5, electronic signature, Randy Fitzgerald, provided September 23, 2012

RTR BDR No. LA-RTR2-11-0116B-6

U001, A Brief History of C-AAC, no author cited, TW CP-19898, January 20, 2004C-1 ATTACHMENT C

CCP STANDING ORDER CCP-SO-086, REVISION 0C-2